Superfund Record of Decision Savannah River Site (USDOE) Operable Unit 5 Aiken SC 3/27/1997


                                    EPA/ROD/R04-97/023
                                    1997
EPA Superfund
     Record of Decision:
     SAVANNAH RIVER SITE (USDOE)
     EPA ID: SC1890008989
     OU05
     AIKEN, SC
     03/27/1997

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United States Department of Energy
Savannah River Site
Record of Decision
Remedial Alternative Selection for the
Gunsite 113 Access Road  (631-24G) Operable Unit: Final
Action (U)
WSRC-RP-96-00833
Revision 1
January 1997
Prepared by:
Westinghouse Savannah River Company
Savannah River Site
Aiken, South Carolina 29808

Prepared for the U.S. Department of Energy Under Contract No. DE-AC09-96SR18500

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CERTIFIED MAIL
RETURN RECEIPT-REQUESTED

4WD-FFB

Mr. Keith Collinsworth, FFA Project Manger
Federal Facility Agreement Section
Division of Site Engineering and Screening
Bureau of Solid & Hazardous Waste Management
South Carolina Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201

SUBJ:  Transmittal of Signed Records of Decision for Gunsite 720, Gunsite 113, Grace Road,
       D-Area Burning/Rubble Pits, F-Area Burning/Rubble Pits, and Silverton Road Waste Unit

Dear Mr. Collinsworth:
       Enclosed you will find six  (6) Records of decision for the above referenced sites.  The
Environmental Protection Agency  (EPA) has signed these documents.  We are transmitting them
to you for signature by the State of South Carolina.  After signature, please forward the signed
documents to the Department of Energy so that they may be included in the administrative record.

       If you have any guestions, please contact me at (404)562-8551 or Jeffery L. Crane, FFA
Project Manger at  (404) 562-8546.

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                   RECORD OF DECISION
           REMEDIAL ALTERNATIVE SELECTION (U)

          The Gunsite 113 Access Road (631-24G)
              Operable Unit:  Final Action

                     WSRC-RP-96-00833
                        Revision 1
                       January 1997

                   Savannah River Site
                  Aiken,  South Carolina

                       Prepared by:

           Westinghouse Savannah River Company
                          for the
U.S. Department of Energy under Contract DE-AC09-96SR18500
             Savannah River Operations Office
                   Aiken, South Carolina

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DECLARATION FOR THE RECORD OF DECISION

Unit Name and Location

Gunsite 113 Access Road Unit
(SRS Building 631-24G)
Savannah River Site
Aiken, South Carolina

The Gunsite 113 Access Road Unit (631-24G) 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 (SRS).

Statement of Basis and Purpose

This decision document presents the selected remedial action for the Gunsite 113 Access Road
Unit located at the Savannah River Site near Aiken, South Carolina. The selected action was
developed in accordance with CERCLA, as amended, and to the extent practicable, the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP). The selected remedy satisfies both
CERCLA and RCRA 3004(u) reguirements. This decision is based on the Administrative Record File
for this specific RCRA/CERCLA Unit.

Description of the Selected Remedy

The results of the Resource Conservation and Recovery Act Facility Investigation/Comprehensive
Environmental Response, Compensation, and Liability Act Remedial Investigation, indicate that
the Gunsite 113 Access Road Unit poses no risk to human health or the environment. Therefore,
no action is needed at the Gunsite 113 Access Road Unit. This is the final RCRA/CERCLA action
for the Gunsite 113 Access Road Unit. The South Carolina Department of Health and Environmental
Control has modified the SRS RCRA permit to incorporate the selected remedy.

Declaration Statement

Based on the results of the remedial investigation, no action is necessary at the Gunsite 113
Access Road Unit to ensure the protection of human health and the environment. Since the
Gunsite 113 Access Road Unit poses no threat to human health or the environment, and no action
is needed, the CERCLA Section 121 reguirements are not applicable. This action is protective of
human health and the environment and is meant to be a permanent solution, final action, for the
Gunsite 113 Access Road Unit. No five-year remedy review is needed or will be performed.

Date R. Lewis Shaw
Deputy Commissioner
Environmental Quality Control
South Carolina Department of Health and Environmental
Control

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                    DECISION SUMMARY
           REMEDIAL ALTERNATIVE SELECTION (U)

          The Gunsite 113 Access Road  (631-24G)
              Operable Unit:  Final Action

                     WSRC-RP-96-00833
                        Revision 1
                       January 1997

                    Savannah River Site
                   Aiken, South Carolina

                       Prepared by:

           Westinghouse Savannah River Company
                          for the
U.S. Department of Energy under Contract DE-AC09-96SR18500
             Savannah River Operations Office
                    Aiken, South Carolina

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                             Table of Contents

SECTION
I.    Site and Operable Unit Names, Locations, and Descriptions	 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 No Action Alternative	9
VIII.  References	10

List of Figures

1.  Location of the Gunsite 113 Access Road Unit in Relation to Major SRS
    Facilities 	2
2.  Layout of the Gunsite 113 Access Road Unit Showing Sample Locations	3

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Section I. Site and Operable Unit Name, Location, and Description

Introduction

The Savannah River Site (SRS) occupies approximately 803 square kilometers (310 square miles) of
land adjacent to the Savannah River, principally in Aiken and Barnwell Counties of South
Carolina. SRS is a secured U.S. qovernment facility with no permanent residents. SRS is
located approximately 40 kilometers (25 miles) southeast of Auqusta, GA and 32 kilometers (20
miles) south of Aiken, SC. Fiqure 1 shows the location of the Gunsite 113 Access Road Unit in
relation to other facilities at SRS.

SRS is owned by the Department of Enerqy (DOE). Manaqement and operatinq services are provided
by Westinqhouse Savannah River Company (WSRC. SRS has historically produced tritium, plutonium,
and other special nuclear materials for national defense. SRS has also provided nuclear
materials for space proqram and for medical, industrial, and research efforts. Chemical and
radioactive wastes are byproducts of nuclear material production processes.

The Federal Facility Aqreement (FFA, 1993) for SRS lists the Gunsite 113 Access Road Unit
(631-24G) as a RCRA/CERCLA Unit that required further evaluation. An investiqation/assessment
process that inteqrates and combines the RCRA Facility Investiqation(RFI) with the CERCLA
Remedial Investiqation (RI) to determine the actual or potential impact to human health and the
environment was performed.

The Gunsite 113 Access Road Unit is located in the northeast comer of SRS, adjacent to the
access road leadinq to Gunsite 113, and is approximately 91.5 meters (300 feet) east of where
SRS Road 8 crosses the SRS facility boundary (see Fiqure 1).

The Gunsite 113 Access Road Unit covers an area of approximately 370 square meters (4,000 square
feet) and is a qrassy area of weeds and small trees within a mature pine forest. It consists of
several small mounds of dirt and asphalt adjacent to die qrassy area and several downed pine
trees. The mounds of dirt/debris are covered with a thick layer of pine straw, brush, and younq
trees. The qrassy open area, east of the mounds, was identified as the area most likely
impacted by possible waste disposal activities. The area contains several dead trees that have
fallen down.

The terrain of the Gunsite 113 Access Road Unit is flat with an elevation of about 97.5 meters
(320 feet) above mean sea level. There are no major drainaqe features nearby. The nearest
surface water body is a small unnamed creek located approximately 1.3 kilometers (0.8 miles)
southeast which feeds into Rosemary Creek, a tributary of Salkehatchie River. The water table
is approximately 60 feet below qround surface.

Section II. Operable Unit History and Compliance History

Operable Unit History

Durinq the period from 1955 to 1960, to defend SRS in the event of an air attack, the U.S. Army
established onsite anti-aircraft artillery qun emplacements at several locations near the
perimeter of SRS. In the mid 1980s, sparse veqetation, dead trees, and small mounds of soil
were discovered on a portion of the road leadinq to Gunsite 113. This arm encompassinq a
portion of the road, became the Gunsite 113 Access Road Unit.

The area appears to have been used as a surface disposal area for spoil dirt and/or road
construction debris. There is no documentation or record of any hazardous substance manaqement,
disposal, or any other type of waste disposal at this unit. There is no evidence that any recent
disposal activities have occurred in this area or that disposal activities were more widespread.
Also, there is no evidence of any burninq or excavation at this waste unit.

There are no structures of any type located at or near the Gunsite 113 Access Road Unit. The
only nearby man-made features are SRS Road 8, which passes within 91.5 meters (300 feet) east of
the unit and the unpaved access road to Gunsite 113, which passes by the unit.

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Compliance History

At SRS, certain waste materials are managed in accordance with the requirements of the Resource
Conservation and Recovery Act  (RCRA).   To comply with the requirements of RCRA, certain SRS
activities have required treatment, storage, or disposal, closure, or post-closure RCRA permits.

Non-regulated units, called solid waste management units  (SWMU),  include any activity where
hazardous constituents may remain uncontrolled and may potentially release to the environment.
Investigation and potential corrective action for these SWMU(s) are mandated under RCRA 3004(u).

In 1995, SRS received a hazardous waste permit from the South Carolina Department of Health and
Environmental Control (SCDHEC), which includes corrective action requirements.  Specifically,
Part V of the permit mandates  that SRS establish and implement a RCRA Facility Investigation
(RFI) program to fulfill the requirements specified in Section 3004(u) of RCRA.

Hazardous substances, as defined by CERCLA, are also present in the environment at SRS.  On
December 21, 1989, SRS was placed on the National Priorities List  (NPL).   A site placed on the
NPL comes under the requirements of CERCLA.  In accordance with Section 120 of CERCLA, DOE has
entered into an FFA with EPA and SCDHEC to coordinate cleanup activities at SRS into one
comprehensive strategy that fulfills RCRA Section 3004(u) and CERCLA assessment, investigation,
and response action requirements.

The remedial investigation for the Gunsite 113 Access Road Unit was conducted from March 1988 to
early 1993.  The results of the RFI/RI Report completed in 1996 (WSRC, 1996a)  indicate that the
Gunsite 113 Access Road Unit poses no current or future risk to human health or the environment.
Therefore, no action is warranted.

According to EPA guidance, if  there is no current or potential threat to human health and the
environment and no action is warranted, the CERCLA 121 requirements am not triggered.  This
means that there is no need to evaluate other alternatives.

To fulfill the public participation requirements of CERCLA, RCRA,  and the South Carolina
Hazardous Waste Management Regulations (SCHWMR), a Statement of Basis/Proposed Plan  (WSRC,
1996b) presenting the no action alternative and the rational for selecting the alternative was
prepared and submitted for public comments.  The public was provided an opportunity to
participate in the remedy selection process and was strongly encouraged to submit comments  (see
Section III).  Following the public comment period, all the comments submitted were reviewed and
considered.  DOE, in consultation with EPA-Region IV and SCDHEC,  selected the final action for
the Gunsite 113 Access Road Unit.  Final selection of the remedial alternative satisfies
FFA requirements.  SCDHEC has modified the SRS RCRA permit to incorporate the selected remedy.

Section III.  Highlights of Community Participation

Public participation requirements are listed in CERCLA Sections 113 and 117.  These requirements
include the establishment of an Administrative Record File that documents the selection of
remedial alternatives and allows for review and comments by the public regarding those
alternatives.  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.  Section 117(a) of CERCLA requires publication of a notice of any
proposed remedial action and provides the public an opportunity to participate in the selection
of a remedial action.  The Statement of Basis/Proposed Plan for the Gunsite 113 Access Road
Unit, which is part of the Administrative Record File, highlights the aspects of the
investigation and identifies the preferred action for addressing the Gunsite 113 Access Road
Unit.

RCRA provides opportunities for the public to comment on draft permit modifications. Public
participation requirements are also listed in SCHWMR R.61-79.124 and require publication of the
draft permit modifications.  SCHWMR R.61-79.124 requires a brief description and response to all
significant comments be made available to the public as a part of the Administrative Record.
The preferred alternative proposed in the Statement of Basis/Proposed Plan was also proposed as
a draft permit modification under RCRA.  Therefore, any comments received on the Statement of
Basis/Proposed Plan was also applicable to the draft RCRA permit modification, proposing the

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same remedy for the Gunsite 113 Access Road Unit.

The Administrative Record File, which contains the Statement of Basis/Proposed Plan and all the
documents  (unabridged) listed in the reference section of this document, 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, SC 29801
(803) 641-3465

Thomas Cooper Library
Government Documents Department
University of South Carolina
Columbia, SC 29208
(803) 777-4866

Similar information is available through the repositories listed below:

Reese Library
Augusta State University
2500 Walton Way
Augusta, GA 309 10
(706) 737-1744

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

The public was notified of a public comment period by mailing the SRS Environmental Bulletin, a
newsletter sent to approximately 3500 citizens in South Carolina and Georgia, and through the
Aiken Standard, the Allendale Citizen Leader, the Barnwell People-Sentinel, the State, and the
Augusta Chronicle 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.  No public comments were received.

Section IV.  Scope and Role of Operable Unit within the Site Strategy

The overall strategy for addressing the Gunsite 113 Access Road Operable Unit was to: (1)
determine if there had been a release of hazardous substances; (2)  determine the nature and
extent of any contamination;  (3) perform a baseline risk assessment; and (4) evaluate the need
for remedial action to address any potential risks to human health and the environment.

The investigation and risk assessment have been completed for the Gunsite 113 Access Road Unit.
Since the results of the investigation indicate that the unit poses no risk to human health or
the environment, no action was recommended.

The field investigations and soil sampling conducted during 1990 and 1993 also indicate that
there are no hazardous substances at the Gunsite 113 Access Road Unit that would impact the
groundwater.

The Gunsite 113 Access Road Unit is an operable unit located within the Upper Three Runs Creek
watershed.  All source control and groundwater operable units located within this watershed will
be evaluated to determine their impacts, if any, to the associated streams and wetlands.

SRS will manage all source control units to prevent impact to the watershed.  Upon disposition
of all source control and groundwater operable units within this watershed, a final
comprehensive ROD for the Upper Three Runs Creek watershed will be pursued.

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Section V. Summary of Operable Unit Characteristics

Gunsite 113 was one of the anti-aircraft artillery gun emplacements the U.S. Army established at
several locations near the perimeter of SRS. The Gunsite 113 Access Road Unit forms a portion
of the access road leading to the Gunsite 113. There is no documentation or record of any
hazardous substance management or disposal at this unit. There is no evidence that any recent
disposal activity has occurred. Also, there is no evidence of any burning or excavation at this
waste unit.

Media Assessment

The RFI/RI Work Plan (WSRC, 1990) and RFI/RI Report (WSRC, 1996a) contain detailed information
and analytical data for all the investigations conducted and samples taken in the media
assessment of the Gunsite 113 Access Road Unit. These documents are part of the Administrative
Record File. The results of the RFI/RI Report are summarized below.

Preliminary investigations pertaining to the Gunsite 113 Access Road Unit were conducted in
March and April 1988. The investigations consisted of ten soil samples and ten soil gas
samples. The soil samples showed trace levels of 1, 2 -dichloroethylene (<11 mg/kg but >3
mg/kg). The soil gas samples contained only low levels of light hydrocarbons (<2500 parts per
billion by volume (ppbv) methane). However, these levels were within the range of natural
background levels.

In March 1989, a ground penetrating radar survey was conducted. The survey indicated that there
was no evidence of any buried or underground objects in the area.

Soils

During 1990, 13 soil samples were collected from four borehole locations. Three boreholes were
drilled within the Gunsite 113 Access Road Unit and one outside the unit for background
sampling. The soil samples were taken at different depth ranges: 0.9-1.5 meters (3-5 feet);
2.4-3.05 meters (8-10 feet); 3.9-4.6 meters (13-15 feet); and 5.5-6.1 meters (18-20 feet) below
the ground surface. The only hazardous substances which were detected and exceeded their
respective unit-specific background levels were three metals (arsenic, chromium, and lead).
Total cyanide and trace levels of tin, vanadium, and zinc were also detected but, their
concentrations were below EPA risk-based concentration (RBC) levels.

In 1993, SRS performed an additional ground penetrating radar survey for the purpose of making a
final determination of any buried waste or any other debris at the Gunsite 113 Access Road Unit.
Eleven lines totaling about 305 meters (1,000 feet) were acguired. An additional soil gas
survey was also completed in 1993. A total of 30 sample locations were established and samples
were collected at each location (see Figure 2).

The ground penetrating radar survey confirmed that no buried objects, trenches, or burial pits
exist at the Gunsite 113 Access Road Unit.

The levels of volatile and diesel-range organics observed in the soil gas survey were consistent
with the normal background levels associated with the natural decay of plant and animal matter.

In summary, data collected during the field investigations conducted in 1990 and 1993 revealed
that only three metals (arsenic, chromium, and lead), exceeded their respective unit-specific
background levels.

Groundwater

Since the ground penetrating radar surveys and field investigations conducted in 1988 and 1989
and soil sampling conducted in 1990 showed no sign of any hazardous waste disposal at this unit,
groundwater investigations were not conducted.

Surface Water/Sediment

No surface water or sediment sampling was conducted because the nearest surface water feature (a
small unnamed creek which feeds into Rosemary Creek) is located approximately 1.3 kilometer (0.8

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miles) from the Gunsite 113 Access Road Unit.

Section VI. Summary of Operable Unit Risks

Human Health Risks

As part of the RCRA/CERCLA process for the Gunsite 113 Access Road Unit, a risk assessment was
performed using data generated during the assessment phase. Detailed information regarding the
development of constituents of potential concern, fate and transport of contaminants and risk
assessment can be found in the RF/RI Report for the Gunsite 113 Access Road Unit (631-24G)(U),
WSRC-RP-95-359, Rev. 1 (WSRC, 1996) .

After combining analytical data and eliminating those analytes not detected in any samples, the
data were evaluated on the basis of quality with respect to sample guantitation limits,
frequency of detection, relative toxic potential of the constituent, laboratory qualifiers and
codes, and blanks. The remaining data (constituents detected) were compared to two times the
unit-specific background and EPA developed Risk-Based Concentrations (RBCs).

RBCs developed by EPA Region III (EPA, 1995) were used to screen the constituents of potential
concern for the Gunsite 113 Access Road Unit. This guidance provides reference doses and
carcinogenic potency data for nearly 600 chemicals. These toxicity constants have been combined
with "standard" exposure scenarios to calculate RBCs (i.e., chemical concentrations
corresponding to fixed levels of risk; a hazard quotient of 1, or a lifetime cancer risk of one
in one million). The RBCs are very similar to preliminary remediation goals which are
concentration goals for individual chemicals for a specific medium and land use combinations at
CERCLA Units.

Following the comparison to unit-specific background levels, it was concluded that three
hazardous materials (arsenic, chromium, lead) exceeded their unit-specific background levels.
Hence, the maximum concentrations of these three hazardous materials were compared to their
respective EPA risk-based concentration action levels to determine if there is any risk to human
health and the environment.

The maximum concentration of arsenic detected was 1.8 m/kg which exceeds EPA risk-based
concentration level of 0.43 mg/kg for soil ingestion, residential scenario. However, the
concentration of the arsenic detected is consistent with the concentration levels found
throughout SRS. Arsenic may be naturally occurring or added to the soils as a pesticide prior
to SRS activities. The source of the arsenic will be evaluated on a sitewide basis during the
implementation of the sitewide Soil Background Study.

The maximum concentration of chromium detected was 24.3 mg/kg. Compared to the EPA risk-based
concentration (RBC) level (390 mg/kg, residential), the concentration of chromium is low.
However, the concentration of chromium (24.3 mg/kg) was detected in the soil sample collected
from the 2.4-3.05 meters (8-10 feet) depth interval. This concentration exceeds EPAs generic
soil screening level (SSL) for migration from soil to groundwater which is 19 mg/kg. Also the
EPA site specific SSL for transfer of chromium from soil to groundwater for the 2.4-3.05 meters
(8-10 feet) depth interval is 13.5 mg/kg. Hence, the maximum concentration of chromium detected
exceeds the EPA's SSLs.

Because the chromium concentration detected exceeded both SSLs, it was decided to evaluate
further for any potential unacceptable risk to a future resident that may be associated with
chromium's migration from soil to groundwater. To determine the potential risk, a chromium
leachability model was studied using site specific standard groundwater model equations. The
model estimated that the chromium concentration in the groundwater would peak at a concentration
of 0.18 mg/L in approximately 1,707 years. The calculated concentration is approximately 0.08
mg/L higher than the 0.10 mg/L accepted maximum contaminant level goal (MCLG) for chromium VI,
but is equivalent to the chromium VI risk-based concentration (RBC) for tap water (0.18 mg/L)
resulting in a hazard index (HI) equal to 1. For chromium III which has an RBC value of 37.0
mg/L, the HI calculated was 4.9 x 10 -3.

These results for chromium are considered to be conservative since chromium was detected in only
one sample at the 2.4- 3.05 meters (8-10 feet) depth interval and peak concentration in the
groundwater would be achieved in nearly 2,000 years. Additionally, soil samples collected in the

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source borehole at the 0.9-1.5 meters (3-5 feet), 3.9-4.6 meters (13-15 feet), and 5.5- 6.1
meters (18-20 feet) depth intervals did not detect chromium.

The maximum concentration of lead was 4.8 mg/kg. The concentration is significantly lower than
the EPA risk-based concentration level (400 mg/kg, residential).

The results of the risk analyses indicated that the concentrations of all hazardous substances
analyzed, with the exception of arsenic, were near or below naturally occurring background
levels and/or below EPA risk-based concentrations. While the concentration of arsenic detected
(1.8 mg/kg) exceeded the EPA risk-based concentration (RBC) level of 0.43 mg/kg for soil
ingestion, the level detected is consistent with the levels found throughout SRS and the source
of arsenic will be evaluated on a sitewide basis during the implementation of the sitewide Soil
Background Study. Hence, there are no constituents of concern (COCs) and there is no impact to
human health or the environment from the Gunsite 113 Access Road Unit.

Current Land Use

Since there is no current activity at the Gunsite 113 Access Road Unit, the current land use
scenario is not applicable.

Future Land Use

Since there are no contaminants of concern and no determinable risk associated with the Gunsite
113 Access Road Unit, the future land use scenario is not applicable.

Ecological Risks

Based on the physical and analytical data pertaining to this unit, there is no evidence that
waste materials were managed or disposed of at the Gunsite 113 Access Road Unit. Therefore, it
is reasonable to conclude that this unit presents no significant ecological risk.

Section VII. Description of the No Action Alternative

Based on the unit characterization and risk assessment, the Gunsite 113 Access Road Unit poses
no risk to human health and the environment. Therefore, the unit requires no cleanup activities
and the no action alternative is recommended for this unit. No additional alternatives were
considered for evaluation. However, arsenic will be evaluated on a sitewide basis during the
sitewide Soil Background Study.

The no action alternative means that no remedial action will be performed at the Gunsite 113
Access Road Unit. There is no waste to treat, no institutional or engineering controls are
required, and there are no applicable or relevant and appropriate requirements (ARARs). Because
no further action would be taken, the Gunsite 113 Access Road Unit would remain in its present
condition. No costs will be involved for this action.

Since the Gunsite 113 Access Road Unit poses no risk to human health or the environment and no
action is warranted at this unit, the CERCLA Section 121 requirements are not applicable. The
no action alternative will be the final action for the Gunsite 113 Access Road Unit and there
will be no five-year (ROD) review.

This solution is meant to be permanent and effective in both the long and short term, and
protective of human health and the environment.

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Section VIII.  References

DOE  (U.S. Department of Energy), 1994,
Public Involvement, A plan for the
Savannah River Site, Savannah River
Operations Office, Aiken, SC.

EPA  (U.S. Environmental Protection
Agency),  1995, Risk-Based Concentration
Table, EPA-III, January-June 1995, dated
March 7,  1995.

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

WSRC, 1990, RCRA Facility
Investigational Remedial Investigation Plan
for the Gunsite 113 Access Road Unit,
WSRC-RP-90-996, Westinghouse
Savannah River Company, Aiken, SC.

WSRC, 1996a, RCRA Facility
Investigational Remedial Investigation Report
for the Gunsite 113 Access Road Unit
(631-24G)(U) WSRC-RP-95-359, Rev. 1,
Westinghouse Savannah River Company,
Aiken, SC.

WSRC, 1996b, Statement of Basis/
Proposed Plan for the Gunsite 113 Access
Road Unit  (631-24G) (U) , WSRC-RP-96-
218, Rev. 1, Westinghouse Savannah
River Company, Aiken, SC.
                                APPENDIX A

                          RESPONSIVENESS SUMMARY

                           No comments received

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