Superfund Record of Decision Savannah River Site (USDOE) Operable Unit 14 Aiken SC


                                    EPA/ROD/R04-97/022
                                    1997
EPA Superfund
     Record of Decision:
     SAVANNAH RIVER SITE (USDOE)
     EPA ID: SC1890008989
     OU14
     AIKEN, SC
     03/27/1997

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DECLARATION FOR THE RECORD OF DECISION

Unit Name and Location

F-Area Burning/Rubble Pits (231-F, 231-1F, and 231-2F)
Savannah River Site
Aiken, South Carolina

The F-Area Burning/Rubble Pits (FBRP)(231-F, 231-1F, and 231-2F) source unit is listed as a
Resource Conservation and Recovery Act (RCRA) 3004(u) Solid Waste Management Unit/Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) unit in Appendix C of the
Federal Facility Agreement (FFA) for the Savannah River Site.

Statement of Basis and Purpose

This decision document presents the selected remedial alternative for the FBRP located at the
SRS in Aiken, South Carolina. The selected alternative was developed in accordance with CERCLA,
as amended, and to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the Administrative Record File for this
specific RCRA/CERCLA unit.

Description of the Selected Remedy

The preferred alternative for the FBRP source operable unit is Institutional Controls which will
preclude residential use of this land. Implementation of the Institutional Controls alternative
reguires both near-term and long-term actions which will be protective of human health and the
environment. For the near-term, signs will be posted at the source unit which indicate that
this area was used for the disposal of waste material and contains buried waste. In addition,
existing SRS access controls will be used to maintain the use of this site for industrial use
only. Groundwater contamination at the FBRP will be addressed within the Technical Memorandum
and Summary for the FBRP. Based upon the conclusions of this document, one of three options
described below will be selected and implemented. If options 1 or 2 are selected, the new
groundwater operable unit will be placed into Appendix C of the Federal Facility Agreement. The
Technical Memorandum and Summary for the FBRP will contain the proposed implementation schedule
for this groundwater operable unit.

1) If no upgradient source is indicated, the contribution of the FBRP source unit is confirmed
and a ROD for the FBRP groundwater will be pursued.

2) If a previously unrecognized upgradient source is identified, a new groundwater operable
unit will be created which will undergo Remedial Investigation/Feasibility Study
assessment.

3) If an existing upgradient groundwater operable unit is determined to be the source of the
contamination, the boundaries of the existing operable unit will be modified to include the
groundwater contamination in the FBRP area.

In the long-term, if the property is ever transferred to non-federal ownership, the U.S.
Government would create a deed for the new property owner which would include information in
compliance with Section 120(h) of CERCLA. The deed shall include notification disclosing former
waste management and disposal activities taken on the site. The deed notification shall, in
perpetuity, notify any potential purchaser that the property has been used for the management
and disposal of construction debris and other materials, including hazardous substances.

The deed shall also include deed restrictions precluding residential use of the property,
However, the need for these restrictions could be reevaluated at the time of ownership transfer
in the event that contamination no longer poses an unacceptable risk under residential use.

In addition, if the site is ever transferred to non-federal ownership, a survey plat of the area
would be prepared, certified by a professional land surveyor, and recorded with the appropriate
county recording agency.

The FBRP Corrective Measures Implementation/Remedial Action Report (CMI/RAR) post-ROD document
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will identify the actions to be taken for the institutional control remedy. The CMI/RAR will be
submitted to the regulatory agencies four months after issuance of the ROD. The regulatory
review period, SRS revision period, and final regulatory review and approval period for the
CMI/RAR will be 90 days, 60 days, and 30 days respectively.

The SCDHEC has modified the SRS RCRA permit to incorporate the selected remedy.

Statutory Determinations

Based on the FBRP RCRA Facility Investigation/Remedial Investigation (RFI/RI) Report and the
Baseline Risk Assessment (BRA), the FBRP poses no significant risk to the environment and
minimal risk to human health. Because risk levels exceed 1 x 10 -6, a decision was made to
implement the Institutional Controls alternative in an effort to be fully protective of human
health and the environment.

Section 300,430 (f)(4)(ii) of the NCP reguires that a Five Year Review of the ROD be performed
if hazardous substances, pollutants, or contaminants remain in the source unit. The three
Parties have determined that a Five Year Review of the ROD for the FBRP would be performed to
ensure continued protection of human health and the environment.

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DECISION SUMMARY
TABIiE OF CONTENTS

Section Page

I. Site And Operable Unit Name, Location, And Description 1
II. Operable Unit History And Compliance History 1
III. Highlights Of Community Participation 5
IV. Scope And Role Of Operable Unit Within the Site Strategy 6
V. Summary Of Operable Unit Characteristics 6
VI. Summary Of Operable Unit Risks 7
VII. Description Of The Considered Alternatives 12
VIII. Summary Of Comparative Analysis Of The Alternatives 16
IX. The Selected Remedy 18
X. Statutory Determinations 24
XI. Explanation Of Significant Changes 24
XII. Responsiveness Summary 24
XIII. Post-Rod Document Schedule 24
XIV. References 26

Appendix A - Responsiveness Summary 27
List of Figures

Figure 1 Location Of The F-Area Burning/Rubble Pits (231-F And 231-1F) And Rubble Pit
(231-2F) In Relation To Major Savannah River Site Facilities 2

Figure 2 F-Area Burning/Rubble Pits (FBRP) In Relation To The F-Area 3

Figure 3 Topographic And Water Table Potentiometric Map Of The F-Area Burning/Rubble
Pits (231-F And 231-1F) And Rubble Pit (231-2F) 4

Figure 4 Conceptual Site Risk Model For Soil For The F-Area Burning/Rubble Pits 14

Figure 5 Post-ROD Document Schedule 25

List of Tables

Table 1 Summary of Carcinogenic Risk and Noncarcinogenic HI Values or Soil, Current
Visitors; Hypothetical Future Residents and Workers, Burning Rubble Pits 231-F
and 231-1F 9

Table 2 Summary of Carcinogenic Risk and Noncarcinogenic HI Values for Soil, Current
Visitors; Hypothetical Future Residents and Workers, Rubble Pit 231-2F 10

Table 3 Remedial Goal Options for Intermediate Risk Contaminants of Concern for Soil by
Receptor for the F-Area Burning/Rubble Pits (231-F/1F) and Rubble Pit (231-2F) . . . .13

Table 4 Evaluation of Alternative 1 - No Remedial Action Under the Nine CERCLA
Criteria 19

Table 5 Evaluation of Alternative 2 - Institutional Controls Under the Nine CERCLA
Criteria 20

Table 6 Evaluation of Alternative 3 - Soil Cover (41) Under the Nine CERCLA Criteria 21

Table 7 Evaluation of Alternative 4 - Thermal Desorption/Incineration Under the Nine
CERCLA Criteria 22

Table 8 Evaluation of Alternative 5 - Offsite Soil Disposal Under the Nine CERCLA
Criteria 23
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I. SITE AND OPERABIiE UNIT NAME, LOCATION, AND DESCRIPTION

SRS occupies approximately 310 square miles of land adjacent to the Savannah River, principally
in Aiken and Barnwell counties of South Carolina (Figure 1). SRS is a secured U.S. Government
facility with no permanent residents. SRS is located approximately 25 miles southeast of
Augusta, Georgia and 20 miles south of Aiken, South Carolina.

SRS is owned by the U.S. DOE. Management and operating services are provided by Westinghouse
Savannah River Company (WSRC). SRS has historically produced tritium, plutonium, and other
special nuclear materials for national defense. Chemical and radioactive wastes are by-products
of nuclear material production processes. Hazardous substances, as defined by CERCLA, are
currently present in the environment at SRS.

The Federal Facility Agreement lists the FBRP, as a RCRA/CERCLA unit requiring further
evaluation using an investigation/assessment process that integrates and combines the RFI
process with the CERCLA RI to determine the actual or potential impact to human health and the
environment.

Figure 1 shows the location of the FBRP in relation to other facilities at SRS, Figure 2 shows
the location of the FBRP within the F-Area, and Figure 3 shows the layout of the FBRP with
sample locations and monitoring wells.

The FBRP comprise a RCRA/CERCLA source unit located within the SRS, approximately 3000 feet west
of F-Ares, and 1100 feet north of SRS Road C. Upper Three Runs is located approximately 2,300
feet northwest of the pits. The local topography of the area is flat upland and the pits are at
an elevation of 290 feet above mean sea level and 170 feet above Upper Three Runs. The water
table is 70 to 100 feet below ground surface in the area of the FBRP. Surface drainage is to
the northwest toward an ephemeral tributary of Upper Three Runs about 7.5 miles upstream of its
confluence with the Savannah River.

The two contiguous burning/rubble pits, which cover a total area of 1.05 acre, are designated as
231-F and 231-1F; a twenty foot wide berm of undisturbed soil separates these two pits. The
rubble pit (231-2F) covers about 0.13 acre. Approximate dimensions of the pits are:

231-F: 275 feet x 62 feet x 10 feet
231-1F: 325 feet x 89 feet x 10 feet
231-2F: 165 feet x 33 feet x 4-9 feet.

The pits have been backfilled with soil; the pit cover is mounded above the surrounding terrain,
which is essentially level, to enhance drainage. Vegetation has been established on the pits to
reduce erosion.

II. OPERABIiE UNIT HISTORY AND COMPLIANCE HISTORY

Operable Unit History

Between 1951 and 1973, SRS used Pits 231-F and 231-1F to burn a variety of wastes which were
considered non-hazardous at that time. Some of these waste materials (degreasers and solvents)
are now considered to be hazardous based on ingestion or possible dermal contact. Waste was
usually burned on a monthly basis. The chemical composition and volumes of the disposed waste
are unknown, but waste materials burned included paper, plastics, wood, rubber, rags, cardboard,
oil, degreasers, and spent organic solvents. No known or suspected radioactive materials were
allowed in the burning pits. These radioactive wastes were managed in the Radioactive Waste
Burial Ground about 1.5 miles east. Pit 231-2F was used exclusively as a rubble pit. Large
volumes of uncontaminated construction debris disposed in the pits may have included relatively
small, nonhomogeneously distributed amounts of low level contamination by cesium-137,
strontium-90, and iodine- 129. Traces of these radionuclides may also have entered the
burning/rubble pits as fallout. Uranium-238, radium-226, and potassium-40 are all naturally
occurring radionuclides; radium is always associated with uranium. The typical soils in this
region contain about twice as much uranium and potassium as the average soil in the United
States.
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Burning of waste in the SRS pits was discontinued by October 1973. A layer of soil was then
placed over the residue in the pits and they were subsequently used as rubble pits. Materials
allowed in the rubble pits included concrete, bricks, tile, asphalt, plastic, metal, empty
drums, wood products, and rubber. When the pits were filled to capacity in 1978, a layer of
clayey soil was placed over the contents and the surface was compacted and mounded. Vegetation
has been established to reduce erosion.

Compliance History

At SRS, waste materials are managed which are regulated under RCRA, a comprehensive law
requiring responsible management of hazardous waste. Certain SRS activities have required
Federal operating or post-closure permits under RCRA. SRS received a hazardous waste permit
from the South Carolina Department of Health and Environmental Control on September 5, 1995.
Part V of the permit mandates that SRS establish and implement an RFI Program to fulfill the
requirements specified in Section 3004(u) of the Federal permit.

Hazardous substances, as defined by CERCLA, are also present in the environment at the SRS. On
December 21, 1989, SRS was included on the National Priorities List. This inclusion created a
need to integrate the established RFI Program with CERCLA requirements to provide for a focused
environmental program. In accordance with Section 120 of CERCLA, DOE has negotiated a Federal
Facility Agreement (FFA, 1993) with U. S. Environmental Protection Agency (EPA) and SCDHEC to
coordinate remedial activities at SRS into one comprehensive strategy which fulfills these dual
regulatory requirements.

III. HIGHLIGHTS OF COMMUNITY PARTICIPATION

Both RCRA and CERCLA require that the public be given an opportunity to review and comment on
the draft permit modification and proposed remedial alternative. Public participation
requirements are listed in South Carolina Hazardous Waste Management Regulation (SCHWMR)
R.61-79.124 and Sections 113 and 117 of CERCLA. These requirements include establishment of an
Administrative Record File that documents the investigation and selection of the remedial
alternatives for addressing the FBRP soils and groundwater. The Administrative Record File must
be established at or near the facility at issue. The SRS Public Involvement Plan (DOE, 1994) is
designed to facilitate public involvement in the decision-making process for permitting,
closure, and the selection of remedial alternatives. The SRS Public Involvement Plan addresses
the requirements of RCRA, CERCLA, and the National Environmental Policy Act. SCHWMR R.61-79.124
and Section 117(a) of CERCLA, as amended, require the advertisement of the draft permit
modification and notice of any proposed remedial action and provide the public an opportunity to
participate in the selection of the remedial action. The Statement of Basis/Proposed Plan for
the F-Area Burning/Rubble Pits (231 -F, 231-1F, and 231-2F) (WSRC, 1996e), which is part of the
Administrative Record File, highlights key aspects of the investigation and identifies the
preferred action for addressing the FBRP.

The FFA Administrative Record File, which contains the information pertaining to the selection
of the response action, is available at the EPA office and at the following locations:

U. S. Department of Energy
Public Reading Room
Gregg-Graniteville Library
University of South Carolina-Aiken
171 University Parkway
Aiken, South Carolina 29801
(803) 641-3465

Thomas Cooper Library
Government Documents Department
University of South Carolina
Columbia, South Carolina 29208
(803) 777-4866
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Reese Library
Augusta State University
2500 Walton Way
Augusta, Georgia 30910
(706) 737-1744

Asa H. Gordon Library
Savannah State University
Tompkins Road
Savannah, Georgia 31404
(912) 356-2183

The public was notified of the public comment period through mailings of the SRS Environmental
Bulletin, a newsletter sent to approximately 3500 citizens in South Carolina and Georgia,
through notices in the Aiken Standard, the Allendale Citizen Leader, the Augusta Chronicle, the
Barnwell People-Sentinel, and the State newspapers. The public comment period was also
announced on local radio stations.

The 45-day public comment period began on September 17, 1996 and ended on October 31, 1996. A
public comment meeting was held on October 15, 1996. A Responsiveness Summary was prepared to
address comments received during the public comment period. The Responsiveness Summary is
provided in Appendix A of this Record of Decision.

IV. SCOPE AND ROIiE OF OPERAKLE UNIT WITHIN THE SITE STRATEGY

The overall strategy for addressing the FRBP was to: (1) characterize the source unit
delineating the nature and extent of contamination and identifying the media of concern (perform
the RFI/RI); (2) perform a baseline risk assessment to evaluate media of concern, constituents
of concern (COCs), exposure pathways, and characterize potential risks; and (3) evaluate and
perform a final action to remediate, as needed, the identified media of concern.

The FBRP operable unit consists of source materials, soils, and groundwater. It is located
within the Upper Three Runs Watershed. Source control and groundwater operable units within
this watershed will be evaluated to determine impacts, if any, to associated streams and
wetlands. SRS will manage all source control units to prevent impact to the Upper Three Runs
Watershed. Groundwater contamination has been documented during the FBRP groundwater monitoring
program in both upgradient and downgradient wells. The Technical Memorandum and Summary
for the FBRP is being finalized and will determine how groundwater contamination in this area
will be addressed. This contamination will, therefore, not be dealt with concurrently with the
FBRP source operable unit. The proposed action for the FBRP source unit is intended as a final
action. Upon disposition of all source control and groundwater operable units within this
watershed, a final, comprehensive ROD for the watershed will be pursued.

V. SUMMARY OF OPERAKLE UNIT CHARACTERISTICS

The Data Summary Report (WSRC, 1994), RFI/RI Report (WSRC, 1996a), BRA (WSRC, 1996b), and
Corrective Measures Study/Feasibility Study (WSRC, 1996c) contain detailed analytical data
for all of the environmental media samples taken in the characterization of the FBRP. These
documents are available in the Administrative Record (See Section III).

Soils

Analytical data indicate that little or no significant contamination of the soil outside of the
FBRP has occurred. During the preparation of the RFI/RI Report, it was noted that constituents
of potential concern (including arsenic, benzo(a)pyrene, cadmium, cesium-137, chromium,
heptachlorodibenzo-p-dioxin, lead, manganese, PCB-1254, and radium) were confined to the debris
interval of the soil within the pits. This distribution and the contaminant transport modeling
results indicate limited mobility of these contaminants in the soil. Despite being a
groundwater risk driver, carbon tetrachloride was not detected in the soil of the FBRP source
unit.

The approximate pit boundaries and sample locations are shown on Figure 3.
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Arsenic was found in most of the samples from the debris interval in Pits 231-F and 231-1F, but
was only found in one sample in Pit 231-2F. The highest value reported was 15.2 mg/kg (parts
per million) in the 2-4 foot interval of boring 16 in Pit 231-F. Cadmium was only found in nine
samples from Pits 213-F and 231-1F, with a maximum value of 22.2 mg/kg in the 6-8 foot sample
from boring 13 in Pit 231-1F. This sample also yielded the highest reported values for chromium
(16,000 mg/kg), copper (917 mg/kg), manganese (1030 mg/kg), and nickel (7140 mg/kg), suggesting
a concentration of metals from a single source.

The maximum value for benzo(a)pyrene was 2.37 mg/kg, found in the 4-6 foot interval of boring 14
in Pit 231-1F. Benzo(a)pyrene was only identified in a single sample from Pit 231-2F.
Heptachlorodibenzo-p-dioxin was found in two samples in Pit 231-2F and 16 samples in Pits 231-
F and 231-1F. The maximum value, 0.009 mg/kg, was reported from the 6-8 foot interval in boring
13, Pit 231-1F. PCB-1254 was found in four samples in Pit 231-2F, including the highest value,
9.14 mg/kg, an estimated value, in the 6-8 foot interval in boring 17. This value is less than
the industrial cleanup goal of 10 mg/g. The 18 detects in Pits 231-F and 231-1F were all less
than the residential cleanup goal of 1 mg/kg PCB-1254.

Cesium-137 was found in 11 samples in Pit 231-2F and 27 samples from Pits 231-F and 231-1F. The
highest value was 32.4 pCi/g in the 8-10 foot sample from boring 12, Pit 231-1F. The maximum
value for total alpha emitting radium was 4 pCi/g in the 6-8 foot interval in boring 13, Pit
231-1F.

VI. SUMMARY OF OPERABIiE UNIT RISKS

Human Health Risk Assessment

As part of the investigation/assessment process for the FBRP, a BRA was performed using data
generated during the assessment phase. Detailed information regarding the development of
constituents of potential concern, the fate and transport of contaminants, and the risk
assessment can be found in the RFI/RI and BRA reports. The process of designating the
constituents of concern was based on consideration of background concentrations, frequency of
detection, the relative toxic potential of the constituents, and human nutrient requirements.
Constituents of potential concern are the constituents that are potentially site-related and are
reported at a sufficient data quality level for use in the risk assessment.

An exposure assessment was performed to provide an indication of the potential exposures which
could occur based on the chemical concentrations detected during sampling activities. The only
current exposure scenario identified for the FBRP was for on-site visitors. Conservative future
exposure scenarios identified for the FBRP included future industrial workers and future
resident adults and children. The reasonable maximum exposure concentration value was used
as the exposure point concentration.

Carcinogenic risks are estimated as the incremental probability of an individual developing
cancer over a lifetime as a result of pathway-specific exposure to cancer-causing contaminants.
The risk to an individual resulting from exposure to non-radioactive chemical carcinogens is
expressed as the increased probability of cancer occurring over the course of a 70 year
lifetime. Cancer risks are related to the target risk range of one excess human cancer in a
population of ten thousand (1 x 10 -4) to one in one million (1 x 10 -6) for incremental cancer
risk at National Priorities List sites

Non-carcinogenic effects are also evaluated to identify a level at which there may be concern
for potential health effects other than cancer-causing. The hazard quotient, which is the ratio
of the exposure dose to the reference dose, is calculated for each contaminant. Hazard
quotients are summed for each exposure pathway to determine the specific hazard index for each
exposure scenario. If the hazard index exceeds unity (1.0), there is concern that adverse
health effects might occur.

The following sections discuss the carcinogenic risks and noncarcinogenic hazards for current
visitors, hypothetical future workers, and hypothetical future residents. These risks are
summarized in Table 1 (Burning Rubble Pits 231-F and 231-1F) and Table 2 (Rubble Pit 231-2F).

Current Land Use - Noncarcinogenic Hazards
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The BRA shows that potential adverse noncarcinogenic health effects are not likely to occur,
because none of the hazard indices exceeds a value of one.

Current Land Use - Carcinogenic Risks

Under the current land use scenario, human health risks were characterized for the current
on-unit visitor. The highest estimated nonradiological cancer risk was 2 x 10 -7 for dust
inhalation from pit 231-2F. Media evaluated include soil inside the FBRP source unit, soil
outside the FBRP source unit, associated airborne soil particulates, and surface water and
sediment in an adjacent seasonal wetland.

The highest estimated radiological risk for each pathway was: 3 x 10 -7 for direct radiation in
all of the pits; 2 x 10 -10 for ingestion of soil in the 231-2F pit; and 3 x 10 -12 for
inhalation of particulates from soil inside the FBRP.

Future Industrial Land Use - Noncarcinogenic Hazards

The hazard indices were less than one for all constituents by all exposure pathways.

Future Industrial Land Use - Carcinogenic Risks

The risks for chemical carcinogens were all within or below the target risk range. The maximum
risk from soil ingestion was 5 x 10 -6 driven by arsenic, heptachlorodibenzo-p-dioxin, and
benzo(a)pyrene in Pits 231-F and 231-1F and 4 x 10 -6 driven by PCB-1254 in Pit 231-2F.

Carcinogenic risk for radiological exposure was within the target risk range for all pathways.
The highest risk under this pathway was 3 x 10 -6 for exposure to soil from the 231-F and 231-1F
pits. This risk was driven by cesium-137 and potassium-40. Potassium-40 is a naturally
occurring radionuclide.

Future Residential Land Use - Noncarcinogenic Hazards

The hazard indices for noncarcinogenic hazards under a future resident scenario were less than
one for all pathways except ingestion of soil from Pit 231-2F. The hazard index for ingestion
of soil was 2.0, predominantly driven by PCB-1254 in Pit 231-2F.

Future Residential Land Use - Carcinogenic Risks

The nonradiological ingestion and dermal exposure pathways for the future on-unit resident
had estimated carcinogenic risks within the target risk range. The highest risks were 2 x 10 -5
for the soil ingestion pathway in Pits 231-F and 231-1F, driven by arsenic, benzo(a)pyrene, and
heptachlorodibenzo-p-dioxin; 2 x 10 -5 for the soil ingestion pathway in Pit 231-2F, driven by
PCB-1254.

Carcinogenic risk for radiological exposure was within or below the target risk range for all
pathways. The highest risk under the direct radiation pathway was 3 x 10 -5 for ingestion of
fruit grown in pits 231-F/1F. This risk was driven by cesium-137 and potassium-40.

Ecological Risk Assessment

Based on characterization of the environmental setting and identification of potential receptor
organisms, a conceptual site model was developed to determine the complete exposure pathways
through which receptors could be exposed to constituents of potential concern.

Interpretation of the ecological significance of the unit-related contamination at the FBRP
source unit concluded that there was no likelihood of unit related constituents causing
significant impacts to the community of species in the vicinity of the unit.

Site-Specific Considerations
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Site-specific considerations, based on the conclusions of the BRA and RFI/RI, which suggest
limited or no potential for significant risk include:

1) The FBRP contain a large volume of buried nonhazardous waste material and cover soil.

2) The levels of contamination recognized during Phase II characterization are generally very
low; there is a preponderance of "non-detects". The contaminants are very stable chemically
and exhibit limited mobility in the soil.

3) The groundwater monitoring program indicates that there has not been significant impact from
the waste materials in the pits.

4) The FBRP are in a remote area which has been recommended as an industrial zone by the
Citizens Advisory Board and the Savannah River Site Future Use Project Report (DOE, 1996),
precluding future residential use.

Remedial Action Objectives

Remedial action objectives specify unit-specific contaminants, media of concern, potential
exposure pathways, and remediation goals. The remedial action objectives are based on the
nature and extent of contamination, threatened resources, and the potential for human and
environmental exposure. Initially, preliminary remediation goals are developed based upon
ARARs, or other information from the RFI/RI Report and the BRA. These goals should be modified,
as necessary, as more information concerning the unit and potential remedial technologies
becomes available. Final remediation goals will be determined when the remedy is selected and
shall establish acceptable exposure levels that are protective of human health and the
environment.

Constituents of potential concern are site- and media-specific, man-made and naturally occurring
inorganic and organic chemicals, pesticides, and radionuclides detected at a unit under
investigation. Constituents of concern are isolated from the list of constituents of potential
concern by calculating carcinogenic risks and noncarcinogenic hazard indices. A constituent of
concern contributes significantly to a pathway having a carcinogenic risk greater than 1 x 10 -4
and a hazard index greater than 1.0. Risk levels at or above the upper-bound of the target risk
range 1 x 10 -4 are considered significant and these sites are expected to undergo remediation.
Risk levels between 1 x 10 -6 and 1 x 10 -4 reguire consideration for remediation.

ARARs are those cleanup standards, standards of control, and other substantive reguirements,
criteria, or limitations promulgated under federal, state, or local environmental law that
specifically address a hazardous substance, pollutant, contaminant, remedial action, location,
or other circumstance at a CERCLA site. Three types of ARARs; action-, chemical-, and
location-specific; have been developed to simplify identification and compliance with
environmental reguirements. Action-specific reguirements set controls on the design, performance
and other aspects of implementation of specific remedial activities. Chemical-specific
reguirements are media specific, health-based concentration limits developed for site-specific
levels of contaminants in specific media. Location-specific ARARs must consider federal, state,
and local reguirements that reflect the physiographical and environmental characteristics of the
unit or the immediate area.

There were no action-specific or location-specific ARARs relevant to establishing remedial
action objectives for the FBRP source unit. There also were no chemical-specific ARARs
identified, however a to-be-considered guidance level for PCBs was identified. The Toxic
Substances Control Act establishes an action level of 10 mg/kg for PCBs in soil. The maximum
level of PCBs found in the 0 to 2 foot interval in any of the pits was 2.87 mg/kg in 231-2F.
This value is below the to-be-considered guidance.

None of the risks associated with the soil in the FBRP source unit has been found to be greater
than 1 x 10 -4. The only hazard index that exceeded 1.0 was for PCB-1254 from the 0-2 foot
soil interval in Pit 231-2F for future residents. The hazard index for this exposure scenario
was 2.0. The only guidance that was exceeded for soil concentrations was for PCB-1254 which had
a maximum value of 2.87 mg/kg in the 0 to 2 foot interval. The to-be-considered guidance for
PCBs specifies recommended soil action levels of 1.0 mg/kg for residential use and 10-25 mg/kg
for industrial use (EPA, 1990). The maximum PCB-1254 concentration in Pit 231-2F is well below
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the range for industrial land use.

Table 3 lists the Remedial Goal Options for intermediate risk contaminants (1 x 10 -4 to 1 x 10
-6) for soil by receptor for all of the pits. Figure 4 is a graphical summary of the conceptual
site risk model for soil for all of the pits for both future residents and future on-site
workers.

VII. DESCRIPTION OF THE CONSIDERED ALTERNATIVES

Description of the Considered Alternatives for the FBRP Source Control Operable Unit

The RFI/RI and BRA indicate that the FBRP source unit poses minimal risk to the environment
and minimal risk to human health when industrial exposure scenarios are assumed. Although the
risks are generally within the target risk range, this Corrective Measures Study/Feasibility
Study was conducted to consider possible actions which could reduce the risks to 1 x 10 -6 or
less.

The Corrective Measures Study/Feasibility Study included detailed analyses for five alternatives
which are described below.

Alternative 1. No Remedial Action

Under this alternative, no remedial action would be taken at the FBRP. EPA policy and
regulations reguire consideration of a no remedial action alternative to serve as a basis
against which other alternatives can be compared. Because no remedial action would be taken and
the FBRP would remain in their present condition, there are no costs associated with this
alternative and there would be no reduction or mitigation of risk.

Alternative 2. Institutional Control

Under this alternative, institutional controls would be implemented at the FBRP. Implementation
of this alternative will reguire both near- and long-term actions. For the near-term, signs
will be posted indicating that this area was used to manage hazardous materials. In addition,
existing SRS access controls will be used to maintain the use of this site for industrial use
only.

In the long-term, if the property is ever transferred to non-federal ownership, the U.S.
Government would, in compliance with Section 120(h) of CERCLA, create a deed for the new
property owner. The deed would include notification disclosing former waste management and
disposal activities as well as remedial actions taken on the site. The deed notification would,
in perpetuity, notify any potential purchaser that the property has been used for the management
and disposal of non-hazardous, inert construction debris, and that wastes containing hazardous
substances, such as degreasers and solvents, were also managed and burned on the site.

The deed would also include deed restrictions precluding residential use of the property.
However, the need for these deed restrictions could be reevaluated at the time of transfer in
the event that contamination no longer poses an unacceptable risk under residential use.
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Table 3 Remedial Goal Options for Intermediate Risk Contaminants of Concern for Soil by
Receptor for the F-Area Burning/Rubble Pits (231-F/1F) and Rubble Pit (231-2F)
Target Cancer Risk
Target Hazard Quotient
Reasonable
Maximum
Medium Chemical
BRPs 231-F/1F, Future Resident
1 x 10 -4
1 x 10 -5
1 x 10 -6
0.1
Soil (mg/kg)

Soil (PCi/g)
(Radionuclides)
BRPs 231-F/1F,
Soil (mg/kg)

Soil (pCi/g)
(Radionuclides)
Arsenic
HpCDD
B[a]P
Cs-137
K-40
Future Worker
Arsenic
HpCDD
Cs-137
K-40
80.152
0.079
16.225
27.918
103.390

370.769
0.374
104.118
384.685
8.015
0.0079
1.623
2.792
10.339

37.077
0.0374
10.412
38.469
0.8015
0.00079
0.162
0.279
1.034

3.708
0.00374
1.041
3.847
EPC

5.29
0.00411
0.649

1.77
4.27
5.29
0.00411

1.77
4.27
RP 231-2F, Future Resident
Soil (mg/kg) PCB-1254
Soil (pCi/g)
(Radionuclides)
Cs-137
K-40
Sr-90
1.44E+01

27.998
103.268
51.282
1.44E+00

2.790
10.327
5.128
1.44E-01

0.279
1.033
0.513
4.72
1.57
0.157
0.178

1.77
4.27
2.96
RP 231-2F, Future Worker
Soil (mg/kg) PCB-1254

Soil (pCi/g) Cs-137
(Radionuclides) K-40
6.51E+01

104.118
384.685
6.51E+00

10.412
38.469
6.51E-01

1.041
3.947
123
40.9
4.09
0.178

1.77
4.27
Note:
HpCDD is Heptachlorodibenzo-p-dioxin
B[a]P is Benzo[a]pyrene
PCB-1254 is a contaminant of concern for 231-2F soil only.
Potential future resident/worker exposure to soil contaminants includes ingestion, dermal contact, and inhalation of
particulates.
EPC is Exposure Point Concentration. Reasonable maximum EPC is the lower of the 95% UCL of the transformed data
or the maximum.

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In addition, if the site is ever transferred to non federal ownership, a survey plat of the area
would be prepared, certified by a professional land surveyor, and recorded with the appropriate
county recording agency.

There are no construction costs associated with this alternative. The cost for surveying the
land, installing signs, and filing with the Aiken County Records is estimated to be $2,000. Five
year reviews of remedy would be reguired; the estimated present value for these reviews over the
next 30 years is $8,000. The total present value cost for Alternative 2 would be $10,000.

The remaining risk via soil ingestion to future on site workers would be 5 x 10 -6 and the
hazard index would be 0.02 for Pits 231-F and -IF. The risk and hazard index from Pit 231-2F
would be 4 x 10 -6 and 0.09 respectively.

Alternative 3. Native Soil Cover (4')

Under this alternative, a four foot thick cover of native soil would be installed over the
present surface of each of the pits to reduce the likelihood that future excavation for
construction of a typical basement would expose waste or contaminated soil. If the property is
ever transferred to private ownership, in compliance with CERCLA 120(h), the U.S. Government
would create a deed with notifications and restrictions similar to those identified in
Alternative 2. A deed restriction prohibiting excavation below four feet would also be filed in
Aiken County Records. The deed restrictions on excavation below four feet would be necessary to
prevent potential exposure of future workers or residents to buried waste which may contain low
concentrations of hazardous constituents.

The cost for developing a, CERCLA Remedial Design/Remedial Action Work Plan would be
$50,000. The construction costs associated with this alternative are estimated at $347,000 for
the installation of a four foot thick native soil cover. The cost for surveying the land,
installing signs, and filing with the Aiken County Records is estimated to be $2,000. Present
value costs of maintenance over 30 years is $8000. Five year reviews of remedy could be
reguired; the estimated present value for these reviews over the next 30 years is $8,000. Total
present value costs for this alternative are estimated at $415,000.

Remaining risks from the pits would be insignificant. The hazard indices from all pits would be
less than 1.0.

Alternative 4. Thermal Desorption/Incineration

Under this alternative, the upper four feet of contaminated soil and waste in the pits would be
excavated for treatment to eliminate the PCB-1254 and other organic contaminants by thermal
desorption/incineration. The soil would be fed through a high temperature rotary kiln to
extract the volatile organic contaminants from the soil. The extracted gases would then be
destroyed in the incinerator. The treated soil would be returned to the site and vegetation
would be established to prevent erosion. If the property is ever transferred to private
ownership, in compliance with CERCLA 120(h), the U.S. Government would create a deed with
notifications and restrictions similar to those identified in Alternative 2. Deed restrictions
on excavation below four feet would be necessary to prevent potential exposure of future workers
or residents to buried waste which may contain low levels of hazardous constituents.

A National Emission Standards for Hazardous Air Pollutants permit would be reguired because of
the potential for atmospheric releases during remediation; the cost of obtaining this permit
would be $150,000. The estimated cost for developing a CERCLA Remedial Design/Remedial Action
Work Plan would be $150,000. The cost for excavation and backfilling would be $412,000. The
cost for thermal desorption/incineration is $6,166,000. The deed notifications and restrictions
would cost $2,000. The total cost for this alternative would be $6,880,000.

This alternative is protective of human health and would permanently reduce risk to less than 1
x 10 -6 for ingestion of soil in Pit 231-2F. The remaining risk to future residents would be 6
x 10 -6 (from arsenic) for nonradiological exposure and 1 x 10 -5 for radiological exposure for
direct radiation in Pits 231-F and 231-1F and 8 x 10 -6 for pit 231-2F. The risk for ingestion
of fruit is 3 x 10 -6 for BRPs 231-F and -IF and 2 x 10 -6 for RP 231-2F. The risks from
ingestion of leafy vegetables is 6 x 10 -6 for the BRPs and 5 x 10 -6 for the RP. The risk
from ingestion of tuberous vegetables is 4 x 10 -6 for the BRPs and 3 x 10 -6 for the RP.
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Alternative 5. Offsite Soil Disposal

Under this alternative, the upper four feet of soil in the pits would be excavated and
transported to a licensed offsite disposal facility. The excavation would be filled to grade
with clean native soil and cover vegetation would be established. If the property is ever
transferred to private ownership, in compliance with CERCLA 120(h), the U.S. Government would
create a deed with notifications and restrictions similar to those identified in Alternative 2.
Deed restrictions on excavation below four feet would also be necessary to prevent potential
exposure of future workers or residents to buried waste which may contain low levels of
hazardous constituents.

The cost for developing a CERCLA Remedial Design/Remedial Action Work Plan would be
$150,000. The cost for excavation and backfilling would be $411,000. The cost for
transportation is estimated to be $761,000. The cost for disposal is $3,350,000. The deed
notifications and restrictions would cost $2,000. The total cost for this alternative would be
$4,674,000.

This alternative is protective of human health and would permanently reduce risk to less than 1
x 10 -6 for soil related risks in all of the pits.

VIII. SUMMARY OF COMPARATIVE ANALYSIS OF THE ALTERNATIVES

Description of Nine Evaluation Criteria

Each of the remedial alternatives was evaluated using the nine criteria established by the
National Oil and Hazardous Substances Contingency Plan (NCP). The criteria were derived from
the statutory reguirements of CERCLA Section 121. The NCP [40 CFR ° 300.430 (e) (9)] sets forth
nine evaluation criteria that provide the basis for evaluating alternatives and selecting a
remedy. The criteria are:

• overall protection of human health and the environment,
• compliance with ARARs,
• long-term effectiveness and permanence,
• reduction of toxicity, mobility, or volume through treatment,
• short-term effectiveness,
• implementability,
• cost,
• state acceptance, and
• community acceptance.

In selecting the preferred alternative, the above mentioned criteria were used to evaluate the
alternatives developed in the F-Area Burning/Rubble Pits (231-F, 231-1F, and 231-2F) Corrective
Measures Study/Feasibility Study (U) (WSRC, 1996e). The nine criteria are used to evaluate all
the alternatives, based on human health and environmental protection, cost, and feasibility
issues. Brief descriptions of a nine criteria are given in the following section.

Overall Protection of Human Health and the Environment - The remedial alternatives are assessed
to determine the degree to which each alternative eliminates, reduces, or controls threats to
human health and the environment through treatment, engineering methods, or institutional
controls.

Compliance with Applicable or Relevant and Appropriate Reguirements (ARARs) - ARARs are
Federal and state environmental regulations that establish standards which remedial actions must
meet. There are three types of ARARs: (1) chemical-specific, (2) location-specific, and (3)
action-specific.

Chemical-specific ARARs are usually health- or risk-based levels or methodologies which, when
applied to unit-specific conditions, result in the establishment of numerical values. Often
these numerical values are promulgated in Federal or state regulations.

Location-specific ARARs are restrictions placed on the concentration of hazardous substances or
the conduct of activities solely because they are in specific locations. Some examples of
specific locations include floodplains, wetlands, historic places, and sensitive ecosystems or
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habitats.

Action-specific ARARs are usually technology- or remedial activity-based requirements or
limitations on actions taken with respect to hazardous substances or unit-specific conditions.
These requirements are triqqered by the particular remedial activities that are selected to
accomplish a remedy.

The remedial activities are assessed to determine whether they attain ARARs or provide grounds
for invoking one of the five waivers for ARARs. These waivers are:

• the remedial action is an interim measure and will become a part of a total remedial
action that will attain the ARAR,

• compliance will result in greater risk to human health and the environment than
other alternatives,
• compliance is technically impracticable from an engineering perspective,

• the alternative remedial action will attain an equivalent standard of performance
through use of another method or approach,
• the state has not consistently applied the

• promulgated requirement in similar circumstances or at other remedial action
sites in the state.

In addition to ARARs, compliance with other criteria, guidance, and proposed standards that are
not legally binding, but may provide useful information or recommended procedures should be
reviewed as To-Be-Considered when setting remedial objectives.

Long-Term Effectiveness and Permanence - The remedial alternatives are assessed based on their
ability to maintain reliable protection of human health and the environment after
implementation.

Reduction of Toxicity, Mobility, or Volume Through Treatment - The remedial alternatives are
assessed based on the degree to which they employ treatment that reduces toxicity (the harmful
nature of the contaminants), mobility (ability of the contaminants to move through the
environment), or volume of contaminants associated with the unit.

Short-Term Effectiveness - The remedial alternatives are assessed considering factors relevant
to implementation of the remedial action, including risks to the community during
implementation, impacts on workers, potential environmental impacts (e.g., air emissions), and
the time until protection is achieved.

Implementability - The remedial alternatives are assessed by considering the difficulty of
implementing the alternative including technical feasibility, constructability, reliability of
technology, ease of undertaking additional remedial actions (if required), monitoring
considerations, administrative feasibility (regulatory requirements), and availability of
services and materials.

Cost - The evaluation of remedial alternatives must include capital and operational and
maintenance costs. Present value costs are estimated within +50/-30 percent, per EPA guidance.
The cost estimates given with each alternative are prepared from information available at the
time of the estimate. The final costs of the project will depend on actual labor and material
costs, actual site conditions, productivity, competitive market conditions, final project scope,
final project schedule, and other variable factors, As a result, the final project costs may
vary from the estimates presented herein.

State Acceptance - In accordance with the Federal Facility Agreement (FFA) , the State is
required to comment/approve the RFI/RI Report, the Baseline Risk Assessment, the Corrective
Measures Study/Feasibility Study, and the Statement of Basis/Proposed Plan

Community Acceptance - The community acceptance of the preferred alternative is assessed by
giving the public an opportunity to comment on the remedy selection process. A public comment
period was held and public comments concerning the proposed remedy are addressed in the
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Responsiveness Summary of this Record of Decision.

Detailed Evaluation

The remedial action alternatives discussed in Section VII have been evaluated using the nine
criteria just described. Tables 4 through 8 present the evaluation of the remedial alternatives.

IX. THE SEIiECTED REMEDY

The preferred action at the FBRP is institutional controls (Alternative 2).

Implementation of this alternative will reguire both near- and long-term actions. For the near-
term, signs will be posted indicating that this area was used to manage hazardous materials. In
addition, existing SRS access controls will be used to maintain use of this site for industrial
use only.

In the long-term, if the property is ever transferred to non-federal ownership, the U.S.
Government will create a deed for the new property owner which will include information in
compliance with Section 120(h) of CERCLA. The deed will include notification disclosing former
waste management and disposal activities on the site. The deed notification will, in perpetuity,
notify any potential purchaser that the property has been used for the management and disposal
of non-hazardous, inert construction debris, and that wastes containing hazardous substances,
such as degreasers and solvents, were also managed and burned on the site.

The deed will also include restrictions precluding residential use of the property. However, the
need for these deed restrictions could be reevaluated at the time of transfer in the event that
contamination no longer poses an unacceptable risk under residential use.

The Institutional Controls Alternative is intended to be the final action for the FBRP source
unit. The solution is intended to be permanent and effective in both the long and near terms.
Alternative 2 is considered to be the least cost option that is still protective of human health
and the environment. Alternatives 3, 4, and 5 offer only an incremental reduction in risk and
hazard for a substantial increase in cost (up to 688 times).

This proposal is consistent with EPA guidance and the National Contingency Plan for sites that
have relatively large volumes of waste with low levels of contamination and is an effective use
of risk management principles.

Since the initial groundwater assessment did not conclusively determine where the groundwater
contamination was coming from, further assessment of the groundwater contamination was conducted
under the groundwater assessment program addendum to the Work Plan (WSRC, 1996d) to determine
whether the FBRP source unit is the source of the contamination. Depending on the results of
the groundwater assessment three possible options were recognized for addressing the groundwater
contamination:

1) If no upgradient source is indicated, the contribution of the FBRP source unit is confirmed
and a ROD for the FBRP groundwater will be pursued.

2) If a previously unrecognized upgradient source is identified, a new groundwater operable
unit will be created which will undergo Remedial Investigation/Feasibility Study
assessment.

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3) If an existing upgradient groundwater operable unit is determined to be the source of the
contamination, the boundaries of the existing operable unit will be modified to include the
groundwater contamination in the FBRP area.

The Technical Memorandum and Summary for the FBRP is being finalized. Based upon the conclusions
of this document, one of the three options described above will be selected and implemented. If
options 1 or 2 are selected, the new groundwater operable unit will be placed into Appendix C of
the Federal Facility Agreement. The Technical Memorandum and Summary for the FBRP will contain
the proposed implementation schedule for this groundwater operable unit.

The SCDHEC has modified the SRS RCRA permit to incorporate the selected remedy.

This proposal is consistent with EPA guidance and is an effective use of risk management
principles.

X. STATUTORY DETERMINATIONS

Based on the FBRP RCRA Facility Investigation/Remedial Investigation (RFI/RI) Report and the
Baseline Risk Assessment (BRA) , the FBRP poses no significant risk to the environment and
minimal risk to human health. Because risk levels exceed 1 x 10 -6, a decision was made to
implement the Institutional Controls alternative in order to be fully protective of human health
and the environment.

The selected remedy is protective of human health and the environment, complies with federal and
state reguirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. The random distribution and low levels of contaminants in the
soils make treatment impractical. Institutional controls will result in hazardous substances,
pollutants, or contaminants remaining in the source unit. Because treatment of the principal
threats of the site was found to be impracticable, this remedy does not satisfy the statutory
preference for treatment as a principal element. Section 300.430 (f)(4)(ii) of the NCP reguires
that a Five Year Review of the ROD be performed if hazardous substances, pollutants, or
contaminants remain in the source unit. The three Parties have determined that a Five Year
Review of the ROD for the FBRP would be performed to ensure continued protection of human health
and the environment.

XI. EXPLANATION OF SIGNIFICANT CHANGES

There are no significant changes from the preferred alternative stated in the Statement of
Basis/Proposed Plan.

The 45-day public comment period began on September 17, 1996 and ended on October 31, 1996. A
public comment meeting was held on October 15, 1996. Comments that were received during the
45-day public comment period are addressed in Appendix A of the Record Of Decision and are
available with the final RCRA permit.

XII. RESPONSIVENESS SUMMARY

A Responsiveness Summary of the comments received during the public comment period is included
in Appendix A.

XIII. POST-ROD DOCUMENT SCHEDULE

The post-ROD document schedule is listed below and is illustrated in Figure 5:

1) Corrective Measures Implementation/Remedial Action Report (CMI/RAR) (rev. 0) for
Institutional Controls will be submitted 4 months after issuance of the ROD.

2) EPA and SCDHEC review of the CMI/RAR (rev. 0), (90 days).

3) SRS revision of CMI/RAR (rev. 0) after receipt of regulatory comments, (60 days).

4) EPA and SCDHEC final review of CMI/RAR (rev. 1), (30 days).
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XIV. REFERENCES

DOE (U.S. Department of Energy), 1994. Public involvement, A Plan for the Savannah River
Site. Savannah River Operations Office, Aiken, South Carolina.

DOE (U.S. Department of Energy), 1996. Savannah River Site Future Use Project
Report. Savannah River Operations Office, Aiken, South Carolina.

EPA (Environmental Protection Agency), 1990. A Guide on Remedial Actions at Superfund Sites
With PCB Contamination. Office of Solid Waste and Emergency Response Directive
9355.4-01 FS, August 1990.

FFA, 1993. Federal Facility Agreement for the Savannah River Site. Administrative Docket
No. 89-05-FF, (Effective Date: August 16, 1993) .

WSRC (Westinghouse Savannah River Company), 1994. Data Summary Report for the F-Area
Burning/Rubble Pits. WSRC-TR-94-0293, Rev. 0, Westinghouse Savannah River Company, Aiken,
South Carolina (1994) .

WSRC, 1996a. RFI/RI Report for F-Area Burning/Rubble Pits (231-F, 231-1F and 231-2F)(U).
WSRC-RP-94-938, Rev. 1.1. Westinghouse Savannah River Company, Aiken, South Carolina
(March 1996).

WSRC, 1996b. Baseline Risk Assessment for the F-Area Burning/Rubble Pits (U). WSRC-TR
94-108, Rev. 1.2, Westinghouse Savannah River Company, Aiken, South Carolina (March 1996).

WSRC, 1996c. F-Area Burning/Rubble Pits (231-F, 231-1F, and 231-2F) Corrective Measures
Study/Feasibility Study (U). WSRC-RP-95-660, Rev. 1.1, Westinghouse Savannah River
Company, Aiken, South Carolina (June 1996).

WSRC, 1996d. Phase II, RCRA Facility Investigation/Remedial Investigation Plan for the F-Area
Burning/Rubble Pits (231-F and 231-1F) and Rubble Pit (231-2F) (U). WSRC-RP-90486, Rev. 2.1,
Westinghouse Savannah River Company, Aiken, South Carolina (May 1996) .

WSRC, 1996e. Statement of Basis/Proposed Plan for the F-Area Burning/Rubble Pits (231-F,
231-1F, and 231-2F)(U). WSRC-RP-95-831, Rev. 1.2, Westinghouse Savannah River
Company, Aiken, South Carolina (August 1966).
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APPENDIX A - RESPONSIVENESS SUMMARY

The 45-day public comment period for the Statement of Basis/Proposed Plan for the F-Area
Burning/Rubble Pits (231-F, 231-1F, and 231-2F) began on September 17, 1996 and ended on
October 31, 1996. A public meeting was held on October 15. 1996. During the public meeting,
there were two guestions received during the Public Meeting and Comment Session on the Limited
Action Proposed Plans/Permit Modifications presentations; and there was one public comment
received during the Formal Public Comment Session. All of the comments are listed as recorded
in the Savannah River Site Information Exchange transcript based on the October 15, 1996 Public
Meeting.

Specific comments and responses are found below.

Public Comments

The following two comments were received during the Limited Action Proposed Plans/Permit
Modifications presentations.

1) PUBLIC CITIZEN: What risk is there for animals or I guess future environmental, like if
you were going to turn this into a park?

Response to Comment 1):

The Baseline Risk Assessment investigated the ecological affects that any contaminants at the
FBRP could have. This document determined that there is "essentially no likelihood that
ecologically significant impacts to the community of species in the vicinity of the unit will
occur". Therefore, the animal and plant species found in this area should not be affected by
any contaminants found at the F-Area Burning/Rubble Pits. The Savannah River Site is currently
considered to be a national environmental research park and as such, the site is/will be used
for environmental research.

This site is located in dose proximity to the F-Area which has a number of facilities which
contain high levels of radioactive waste. It is unlikely that this particular area would be
made available to the public as a recreational park in the near future. For this reason, it is
recommended that the FBRP be retained as part of an industrial area.

2) PUBLIC CITIZEN: Are you using like private landfills and private -- or I guess other
communities that have developed? I mean it looks like a landfill to me. And it looks like
there are landfills all over the country and there's a whole lot of landfills that have turned
into like parks and stuff. Is that an opportunity here to turn it into a park or to use private
models and maybe who have done this a lot? I guess the EPA guy was talking about streamlining.
Are you guys using private streamlining ideas?

Response to Comment 2):

The FBRP was operated very much like a small-scale landfill. Waste was deposited on a regular
basis and, initially, was burned monthly. After burning ceased, the waste was deposited and
finally covered by a layer of soil when the site was closed.

The Savannah River Site is currently considered to be a national environmental research park and
as such, the site is/will be used for environmental research. The F-Area Burning/Rubble Pits
have been shown to pose an insignificant threat to any plants or animals in the area.

This site is located in close proximity to the F-Area which has a number of facilities which
contain high levels of radioactive waste. It is unlikely that this particular area would be
made available to the public as a recreational park in the near future. For this reason, it is
recommended that the FBRP be retained as part of an industrial area.

The following comment was received during the Formal Public Comment Session.

3) Mike Rourak: My name is Mike Rourak and my guestion is directed directly to Mr. Brian
Hennessey's earlier discussion [unintelligible] Silverton Road property, for example. In the
Future Use Manual that was sent out to some of us about the disposal of close to a million acres
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of property for DOE, in your deed restrictions there're things that we cannot do. And we're
going to need a little bit before we can respond back to Washington. Those of us who received
the manual, we almost are going to need to know what those deed restrictions are because if we
cannot have a subdivision then there's no need to bid the price accordingly or say that's what
we want to use it for. If we cannot graze cattle there like we do in Tennessee at
[unintelligible] or something or grow crops because we cannot put a well in for contamination,
then we are left with only looking at it for the pine trees.

So being federal, you own this property. Even with deed restrictions you've got to give us
either a Phase I, II, or III audit. In this case, it's the seller who has to provide this
liability, not necessarily the buyer's neglect of liability to due diligence. So it would
really help if we knew what deed restrictions would be there to a more extent and also what we
can use the land for. If I want to use it for applying 50 - -- under the Code of Federal
Regulations 503, if I want to use it for bio solid disposal, can I do so? Because it's adjacent
to your other property. So the deed restrictions that you brought up were of immense concern
about responding back to the future use and the disposal of roughly 849, 000 acres nationwide
for - to be put back into - I understand from Washington, they would like to put it back mainly
into public use to get the taxes off of it. Maybe not so much for the government, but for the
local entities who lose the tax base. Thank you.

Response to Comment 3):

The SRS Future Use Project Report was distributed to inform citizens of the planned future uses
of SRS. The recommendations that were presented in the report may change over time and will be
discussed with the stakeholders. Deed restrictions for federal property are not determined
until the land is transferred to non-federal control. At the time of property transfer, the
need for deed restrictions will be evaluated. Due to natural attentuation, decay, etc., the
conditions at specific areas may not warrant any deed restrictions. All legal reguirements will
be met at the time of property transfer.
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