Superfund Record of Decision Savannah River Site USDOE Burma Road Rubble Pit OU32 SC


                                    EPA/ROD/R04-96/268
                                    1996
EPA Superfund
     Record of Decision:
     SAVANNAH RIVER SITE (USDOE)
     EPA ID: SC1890008989
     OU32
     AIKEN, SC
     06/18/1996

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United States Department of Energy

Savannah River Site

Record of Decision
Remedial Alternative Selection
for the
Burma Road Rubble Pit  (231-4F)  (U)

WSRC-RP-96-101
Revision 1
April 1996

Westinghouse Savannall River Company
Savannah River Site                                         
Aiken, South Carolina 29808

PREPARED FOR THE U.S. DEPARTMENT OF ENERGY UNDER CONTRACT DE-AC09SR18035

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                    DECISION SUMMARY
           REMEDIAL ALTERNATIVE SELECTION  (U)

           BURMA ROAD RUBBLE PIT UNIT  (231-4F)

                     WSRC-RP-96-101
                       Revision 1
                       April 1996

                   Savannah River Site
                  Aiken, South Carolina

                      Prepared by:

           Westinghouse Savannah River Company
                        for the
U.S. Department of Energy Under Contract DE-AC09-89SR18035
            Savannah River Operations Office
                  Aiken, South Carolina

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                                    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	8
VI.         Summary of Operable Unit Risks	9
VII.       Description of the No Action Alternative	14
VIII.      Explanation of Significant Changes	14
IX.         References	15
List of Figures

Figure 1:  Location of the Burma Road Rubble Pit at the Savannah River Site....2
Figure 2:  Location of the Burma Road Rubble Pit Waste Unit	3
Figure 3:  General Configuration of the Burma Road Rubble Pit	4
Figure 4:  Burma Road Rubble Pit Regional Groundwater Flow Map
           (Second Quarter 1994)	7
List of Tables

Table 1:    Current Land Use - Noncarcinogenic Hazard Indices	12
Table 2 :    Current Land Use Carcinogenic Risks	12
Table 3:    Future Land Use - Noncarcinogenic Hazard Indices	12
Table 4 :    Future Land Use - Carcinogenic Risks	13
Appendix

A.         Responsiveness Summary	16

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DECLARATION FOR THE RECORD OF DECISION

Unit Name and Location

Burma Road Rubble Pit unit (SRS Building Number 231-4F)
Savannah River Site
Aiken, South Carolina

The Burma Road Rubble Pit (BRRP) unit (231-4F) is listed as a Resource Conservation and Recovery
Act (RCRA) 3004(u) solid waste management unit/Comprehensive Environmental Response,
Compensation and Liability Act (CERLCA) 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 action for the BRRP unit soils located at
the SRS in 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). This decision is based on the Administrative Record File for this
specific RCRA/CERCLA unit.

Description of the Selected Remedy

The results of the RCRA Facility Investigation/Remedial Investigation indicate that the BRRP
unit soils pose minimal risk to human health and the environment. Therefore, no action is
needed for the BRRP unit soils. Only non-hazardous, inert material (e.g., wood, trash, wire,
bottles, plastic, rubble, foam, concrete, etc.) was placed at the BRRP source unit. A notation,
identifying the presence of buried, inert debris, on the deed to the facility property will be
placed in the Aiken County Records. This notation will include a survey plat, prepared and
certified by a professional land surveyor, of the area. This is a final RCRA/CERCLA action for
the BRRP unit soils.

Groundwater contamination beneath the BRRP is due to migration from upgradient sources and thus
will not be addressed in this remedial action. Following an investigation on upgradient
groundwater contaminant sources, a determination will be made as to what corrective action might
be appropriate for the groundwater beneath the BRRP.

Declaration Statement

Based on the results of the remedial investigation, no action is necessary at the BRRP unit
soils to ensure the protection of human health and the environment. Since the BRRP unit soils
pose minimal risk to human health and the environment, and no action is needed, the CERCLA
Section 121 reguirements are not applicable. This action protective of human health and the
environment and is meant to be a permanent solution final action, for the BRRP unit soils.
Section 300.430(f)(4)(ii) of the NCP reguires that a Five-Year Review of the Record of Decision
be performed if hazardous substances, pollutants, or contaminants remain at the unit. The three
Parties have determined that a Five-Year Review of the ROD for the BRRP unit soils will not be
performed. The remedial action selected for this unit (No Action) results in no hazardous
substances, pollutants, or contaminants remaining in the soils of the BRRP source unit.

Date T.F. Heenan
Assistant Manager for Environmental Restoration and Solid Waste
U.S. Dept. of Energy, Savannah River Operations Office

Date John H. Hankinson, Jr.
Regional Administrator
U.S. Environmental Protection Agency

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

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

The Savannah River Site  (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. Department of
Energy (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.   SRS has also provided nuclear
materials for the space program and for
medical,  industrial,  and research efforts.
Chemical and radioactive wastes are by-
products of nuclear material production
processes.

The Federal Facility Agreement (FFA) lists
the Burma Road Rubble Pit  (BRRP)  source
unit (231-4F;  Figure 2) as a Resource
Conservation and Recovery Act  (RCRA)/
Comprehensive Environmental Response,
Compensation,  and Liability Act (CERCLA)
unit that required further evaluation.  An
investigation/assessment process that
integratesand combines the RCRA Facility
Investigation (RFI)  process with the
CERCLA Remedial Investigation  (RI)to
determine the actual or potential impact to
human health and the environment was
performed.

The BRRP, 231-4F, is located
approximately one-half mile southwest of F-
Area Separations Facility and one-tenth mile
southwest of C Road.   The BRRP is between
Upper Three Runs Creek  (approximately
4000 feet to the northwest) and Four Mile
Creek (approxitnately one mile to the
southwest).  A westward trending tributary to
the Upper Three Runs Creek is located
approximately 2,000 feet to the north.  The
BRRP ground surface elevation is
 
 
approximately 290 feet mean sea level.
Surface runoff is northwestward toward the
tributary.  The soil type that exists at the
BRRP consists of Udorthents.

The BRRP consists of two unlined earthen
pits dug into surficial soil and filled with
various waste materials.  The BRRP was
originally reported to be 485 feet long, 125
to 150 feet wide, and at least 10 feet deep.
A GPR survey, conducted in September
1988, indicates that the BRRP area consists
of two generally rectangular pits (GPR Zone
1 and GPR Zone 2, Figure 3), each about
400 feet long, up to 50 feet wide, and 10
feet deep.  A small circular area (GPR Zone
3, Figure 3) of disturbed soil was detected
adjacent to these pits and is considered to
have been used as a source of backfill for the
pits.

II.   Operable Unit History and
      Compliance History

Operable Unit History

The BRRP was used from 1973 to 1983 for
the disposal of dry inert rubble such as wood,
trash, wire, bottles, plastic, rubble, foam,
concrete, etc.  No record' of hazardous
substance disposal at the BRRP has been
found.  In 1983, disposal at the BRRP ceased
and it was backfilled with soil.  The area is
currently delineated by orange marker balls
at the perimeter of the waste unit.

Compliance History

At SRS, waste materials are managed which
are regulated under the RCRA.  Certain SRS
activities have required Federal operating or
post-closure permits under RCRA.  SRS
received a RCRA hazardous waste permit
from the South Carolina Department of
Health and Environmental Control
(SCDHEC) on Septrmber 30, 1987.  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.

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Hazardous substances, as defined by
CERCLA, are also present in the
environment at SRS.   On December 21,
1989, the SRS was placed on the National
Priorities List  (NPL).   A site placed on the
NPL comes under the jurisdiction of
CERCLA.  In accordance with Section 120
of CERCLA, DOE has negotiated an FFA
(FFA, 1993)  with the U.S. Environmental
Protection Agency (EPA)  and SCDHEC to
coordinate remedial activities at SRS into
one comprehensive strategy which fulfills
these dual regulatory reguirements.

The BRRP RFI/RI investigation was
conducted from November 1993 to February
1994.  The results of the RFI/RI indicate
that the BRRP source unit soils pose
minimal risk to human health or the
environment.  The only soil contamination
found at the BRRP source unit was arsenic at
a concentration of 1.74 mg/kg.  This soil
concentration led to a risk value of 1.9 x
10-6 for the future residential adult (i.e.,
there is a 1.9 in one million chance of
developing cancer from the ingestion of
arsenic) and a risk value of 2.8 x 10-6 for
the future residential child  (i.e.,  there is a
in one million chance of developing cancer
from the ingestion of arsenic).  Based on
these risk values, no action is warranted at
the BRRP source unit soils.  No other
alternatives were considered.  This is a
proposed final CERCLA action for the
BRRP source unit soils only.

Since the arsenic concentration does not
appear to be from the BRRP Operable Unit,
the source of the arsenic will be evaluated on
a site-wide scale during the implementation
of the Soil Background Study  (or potentially
the Site-wide Soil Integrator Operable Unit
Workplan).

Groundwater contamination found beneath
the BRRP is due to migration from
upgradient sources such as the F-Area
Inactive Process Sewer Lines and thus will
not be addressed in this remedial action.
Following all investigation on upgradient
groundwater contaminant sources, a
determination will be made as to what
  corrective action migat be appropriate for
  the groundwater beneath the BRRP.

  Public participation reguirements  are listed
  in Sections 113 and 117 of CERCLA.  These
  reguirements include establishment of an
  Administrative Record File that documents
  the selection of remedial alternatives and
  allows for review and comment 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 (PIP)
  (DOE,  1994) is designed to facilitate public
  involvement in the decision-making process
  for permitting, closure,  and the selection of
  remedial alternatives.

  A Proposed Plan (PP) was submitted that
  fulfills the reguirements of CERCLA Section
  117 (a) by providing the public an
  opportunity to participate in the  selection
  of a remedial action.  The PP presented the
  preferred alternative and the rationale for
  selecting the alternative.  DOE, in
  consultation with EPA and SCDHEC
  selected the final action for the  BRRP
2.8  source unit soils following the public
   comment period.

      III.   Highlights of Community
             Participation

  Public participation reguirements  are listed
  in Sections 113 and 117 of CERCLA.  These
  reguirements include the establishment of an
  Administrative Record File that documents
  the investigation nd selection of  the
  remedy for addressing the BRRP.  The SRS
  PIP (DOE, 1994) is designed to facilitate
  public involvement n the decision-making
  processes for permitting, closure, and the
  selection of remedial alternatives.  The SRS
  PIP addresses the reguirements of  RCRA,
  CERCLA, and the National Environmental
  Policy Act (NEPA.   Section 117(a)of
  CERCLA, as amended, reguires the
  preparation of a proposed plan as  part of
  the site remedial process.  The Proposed
  Plan for the Burma Road Rubble Pit (231-
  4F) (WSRC, 1995b), which is part of the
  Administrative Reccrd File, highlights key

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aspects of the investigation and identifies
the preferred action for addressing the BRRP
soils only.

The Administrative Record File, which
contains the information pertaining to the
selection of the response action, was made
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
received are addressed in the Responsiveness
Summary  (Appendix A) .

    IV.   Scope and Role of Operable Unit
          Within the Site Strategy
The  overall strategy for addressing the
BRRP source unit was to:  (1) characterize
the waste 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, chemicals of
concern, exposure pathways, and
characterize potential risks; and  (3) evaluate
and perform a final action to remediate, as
needed, the identified media(s)  of concern.
Thomas Cooper Library
Government Documents Library
University of South Carolina
Columbia, South Carolina 29208
(803) 777-4866

Similar information is available through the
repositories listed below:

Reese Library
Augusta College
2500 Walton Way
Augusta, Georgia 30910
(706) 737-1744
Asa H. Gordon Library
Savannah State College
Tompkins Road
Savannah, Georgia 31404
(912) 356-2183

The public was notified of the comment
period for the proposed plan through
mailings of the SRS Environmental Bulletin,
a newsletter sent to approximately 1400
citizens in South Carolina and Georgia, and
through notices in local newspapers
including the Aiken Standard, the Augusta
Chronicle, the Allendale Citizen Leader, and
the Barnwell People-Sentinel.

The public comment period for the
Proposed Plan began on January 10, 1996
and ended on February 8, 1996.  Comments
The investigation and risk assessment have
been completed for the BRRP source unit.
Since the results of the investigation indicate
that the BRRP source unit soils pose
minimal risk to human health or the
environment, no action was recommended
by the Proposed Plan for the Burma Road
Rubble Pit  (231-4F) (WSRC, 1995b).   Only
non-hazardous, inert material  (e.g., wood,
trash, wire, bottles,  plastic, rubble, foam,
concrete, etc.)  was placed at the BRRP
source unit.  A notification, identifying the
presence of buried, inert debris, will be
placed in the Aiken County Records which will
include a survey plat, prepared and certified
by a professional land surveyor, of the area.

Although there is groundwater
contamination benetth the BRRP, the
groundwater contamination is due to
migration from upgradient sources such as
the F-Area Inactive Process Sewer Lines
(Figure 2) and thus will not be addressed by
this remedial action.   The depth to the water
table beneath the BRRP is 61 to 83 feet.

Figure 4 illustrates the regional groundwater
flow direction in the vicinity of the BRRP,
The map indicates west-northwestward flow
of the shallow aguifer system groundwater in
the BRRP area.  Groundwater data from two
nearby areas, the F-Area Seepage Basins and
the F-Area Separations Facility which

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includes the Inactive Process Sewer Lines,
suggest that these areas may have impacted
the BRRP.  The F-Area Separations Facility
is located approximately 2,000 feet
northeast of the BRRP.  The F-Area
Seepage Basins are located approximately
1,100 feet to the southeast of the BRRP.

Following an investigation on upgradient
groundwater contaminant sources, a
determination will be made as to what
corrective action might be appropriate.

The BRRP is a source control operable unit
(OU) located within the Upper Three Runs
Watershed.  Several source control and
groundwater OUs, including the F- and H-
Area Groundwater OU, within this watershed
will be evaluated to determine impacts, if
any, to associated streams and wetlands.  It
has been determined that the BRRP source
control OU does not contribute
contamination to the area groundwater or
surrounding soils.  The proposed action for
the BRRP source unit soils is a final action.

V.   Summary of Operable Unit
     Characteristics

The BRRP was used from 1973 to 1983 for
the disposal of dry inert rubble such as metal,
concrete, lumber, poles, light fixtures, and
glass.  No record of hazardous substances
disposal at the BRRP has been found.  In
1983, disposal at the BRRP ceased and it was
backfilled with soil.  The area is currently
delineated by orange marker balls at the
perimeter of the waste unit.

RFI/RI Characterization
Burma Road Rubble Pit (231-4F),  (WSRC,
1995a).

 Surface and subsurface soil samples were
 collected from seventeen locations within
 the BRRP in areas of suspected
 contamination (e.g., the soil borings were
 located in areas when a soil gas anomaly was
 detected or adj  Lcent to potential
 underground object,  and/or areas of high
 metal concentrations as indicated by
 anomalies in the GPR, electromagnetic
 (EM),  or magnetometer surveys).   These
 sampling depths  provide a representation of
 soil conditions  above the fill material and at
 the bottom layer below the fill material.

 During the sampling, none of the soil
 borings encountered any containers (e.g.,
 drums), liquid,  sludge, or experienced a rod-
 drop that would indicate a drubs or container
 had been punctured.   Only inert materials
 (e.g.,  wood,  trash,  wire, bottles, plastic,
 rubble, foam,  concrete, etc.)  were
 encountered during the soil sampling.

 Four background subsurface soil samples and
 two background surface soil samples were
 collected to gather data for statistical and
 comparative analysis against samples
 collected in the areas suspected of
 containing hazardous material.   The
 background soil  samples were located in
 areas that were  away from GPR Zones 1, 2,
 3 (Figure 3)  and were outside of the soil gas
 anomalies.  The  background surface soil
 samples were located upgradient and at a
 sufficient distance from the BRRP source
 unit so as to preclude any impact from the
 unit.
The BRRP RFI/RI investigation was
conducted from November 1993 to February
1994.  Samples were collected to
characterize the chemical concentrations in
soil, groundwater, sediments, and surface
water at the BRRP.
Sampling and investigation activities are
summarized below.  Detailed information
regarding sampling/investigation activities
can be found in the Final RFI/RI Report for
 Background surface water samples were
 unavailable because there is no upgradient
 body of surface water within a reasonable
 distance of the waste unit from which to
 obtain unit-specific background samples.

 All samples were analyzed in accordance
 with EPA-approved protocols.  The detailed
 analytical results are contained in the
 Quality Control Summary Report for the
 Burma Read Rubble Pit RFI/RI Unit

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Assessment  (WSRC, 1994).   Validation and
verification of the analytical data were
performed as part of the RFI/RI data review
process; therefore, the data were considered
acceptable for this evaluation.

Nine new groundwater monitoring wells were
installed at varying depths in 3 three-well
clusters.  Of the 14 wells that exist at BRRP
(new and existing), sixwells are considered
to be upgradient wells.  However, the entire
BRRP is downgradient of the SRS F-Area
Separations Facility and the entire BRRP
well network may be impacted by
groundwater migration from F-Area.

The BRRP RFI/RI investigation process
concluded that source characterization has
shown that historical documents are correct
in stating that only inert material was
disposed of at the BRRP;  therefore, the
BRRP is not expected to be a future source
of contamination.

VI.    Summary of Operable Unit
      Risks

The BRRP operable unit investigation
addressed the rubble (potential source term),
surrounding soils, and the groundwater under
the facility.  This section summarizes the
baseline risk assessment information
associated with the BRRP operable unit.  It
should be noted, however, that the remedial
action proposed by this plan is for the BRRP
soils only.  The groundwater contamination
will be addressed following an investigation
on upgradient contaminant sources.

Human Health Risk Assessment

As part of the investigation/assessment
process for the BRRP source unit, a risk
assessment was performed using the data
generated during the assessment phase.

Detailed information regarding the
development of contaminants of potential
concern, the fate and transport of
contaminants, and the risk assessment can
be found in the Final RFI/RI Report for
Burma Road Rubble Pit  (231-4F),  (WSRC,
1995a).
The process of designating the constituents
of potential concern  (COPCs) was based on
consideration of backgoround concentrations,
freguency of detection, the relative toxic
potential of the chemicals, and chemical
nutrient status.  COPCs are the constituents
that are potentially site-related and whose
data are of sufficient guality for use in the
risk assessment.  COPCs included volatile
organic compounds, semi-volatile organic
compounds, metals and other inorganic
analytes, and radionuclides identified through
approved site characterization activities.

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 existing
(current) exposure scenario identified for the
BRRP was for environmental researchers
who may work or traverse the BRRP on an
intermittent/limited basis.  Future exposure
scenarios identified for the BRRP included
future environmental researchers as well as
conservative future esidential adult and
child and an occupational worker.

Per EPA guidance, the carcinogenic  (cancer)
risks and non-carcinogenic hazards should be
calculated to determine the appropriate
remedial action for a waste unit.

Cancer risks are estimated as the
incremental probability of an individual
developing cancer over a lifetime as a result
of pathway-specific exposure to
carcinogenic 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
EPA target range of one in ten thousand

(1.0x10-4) to one in one million (1.0x10-6)
for incremental cancer risk at NPL sites.
This means that one in ten thousand to one
in one million people may develop cancer
over a lifetime as result of exposure to
cancer-causing contaminants.  Risk levels at
or above 1.0 x 0-4 are considered

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significant.  In order to account for
simultaneous exposure to multiple
carcinogens through a given pathway, the
risk calculated for each individual
carcinogen in that medium were summed to
obtain an estimate of the total cancer risk
for the pathway.

Non-carcinogenic effects are evaluated by
comparing an exposure level over a specified
time period (e.g., lifetime) with a reference
dose (RID) derived for a similar exposure
period.  To evaluate the non-carcinogenic
effects of exposure to soil contaminants, the
hazard guotient (HQ),  which is the ratio of
the exposure dose to the RfD, is calculated
for each contaminant.   The non-
carcinogenic HQ assumes that below a given
level of exposure (e.g., the RfD), even
sensitive populations are unlikely to
experience adverse health effects.  If the
exposure level exceeds the threshold there
may be concern for potential non-
carcinogenic health effects.

HQs are summed for each exposure pathway
to create a pathway specific hazard index
(HI) for eachexposure scenario.  The more
the HI exceeds unity (1.0), the greater the
concern that adverse health effects will
occur.

The reasonable maximum exposure
concentration value was used as the exposure
point concentration.

In order to determine the carcinogenic
(cancer) and non-carcinogenic hazards the
following general exposure assumptions were
used in the baseline risk assessment:

Current Land Use Scenario
Environmental Researcher
The adult environmental researcher receptor
was assumed to enter onto the BRRP unit on
an intermittent basis.   The adult was assumed
to work in the BRRP area for 72 days per
year (approximately one guarter of the
year).   Exposures were evaluated for a short-
term and long-term scenario  (over a half-
year and a 25 year interval, respectively).  It
was also assumed that the person would
remain at the BRRP unit or in the BRRP
vicinity for a four hear work period.  The
person would wear clothing which covers all
bodily areas with the exception of the face,
hands, and forearms.

Future Land Use Scenarios
Residential Scenario
The future residential adult receptor was
assumed to reside on he BRRP for a long-
term duration of 30 years and/or a short-
term duration of 5 years.  It was anticipated
that the adult residential person would
engage in gardening/yard maintenance
activities for a total of eight hours per week
year-round (four two- our periods per week,
350 days/year, assuming approximately two
weeks spent away from the residence per
year).  During such activities, the person
would wear clothing which covers all bodily
areas with the exception of the face, arms,
hands, and lower legs.

The future residential child receptor was
assumed to reside on the BRRP between the
ages of two through even years.  The child
was assumed to live in a house constructed in
close proximity to the BRRP.  The child
would engage in outdoor activities 350
days/year (assuming approximately two
weeks spent away from the residence per
year).  The average rate for time spent
outdoors would encompass periods when
exposures may be more or less freguent, as
well as times when adverse weather would
prohibit outdoor activity.  It was assumed
that the young child would remain outdoors
for a four hour period.

Occupational Worker
The primary receptor examined under the
future commercial use scenario was an on-
site adult worker aged 18 years or older.  Soil
exposure could occur during normal day-to-
day activities for an on-site worker.

Environmental Researcher
The adult environmental researcher receptor
was assumed to enter onto the BRRP unit on
an intermittent basis.  The adult was assumed
to work in the BRRP area for 72 days per
year  (approximately one guarter of the
year).  Exposures were evaluated for a short-
term and long-term scenario (over a half-
year and a 25 year interval, respectively). It

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was also assumed that the person would
remain at the BRRP unit or in the BRRP
vicinity for a four hour work period.  The
person would wear clothing which covers all
bodily areas with the exception of the face,
hands, and forearms.
          dermal contact with  soil  (based on
          exposure to the face, arms, hands,
          and lower legs),
          inhalation of chemicals in ambient
          air, and
          ingestion of homegrown produce.
Current Land Use - Noncarcinogenic
Hazard Indices

Table 1 provides a summary of the
noncarcinogenic hazard indices and
applicable constituents of concern (COCs)
associated with the current land use scenario
for the BRRP unit soils.

The total noncarcinogenic  (noncancer)
hazard index did not exceed unity for the
environmental researcher receptor evaluated
in the current land use scenario.  This
indicates that potential adverse health
effects are not likely to occur for the
current environmental researcher.

Current Land Use - Carcinogenic Risks

Table 2 provides a summary of the
carcinogenic risks and applicable COCs
associated with the current land use scenario
for the BRRP unit soils.

Under the current land use scenario,  the
total carcinogenic (cancer) risk (for
chemicals and radionuclides)  did not exceed a
level of 1.0 x 10-6 for the environmental
researcher which indicates that carcinogenic
risk from the unit soils is not significant.

Future Land Use - Noncarcinogenic Hazard
Indices

Table 3 provides a summary of the
noncarcinogenic hazard indices and
applicable COCs associated with the future
land use scenario for the BRRP unit soils.

The His were all less than one, indicating
that adverse noncarcinogenic effects are
unlikely for the following pathways:
Future Land Use - Caarcinogenic Risks

For the future residential adult, the only
estimated risk from the unit soils was the
ingestion of arsenic with a risk value of 1.9
x 10-6, (i.e., there is a 1.9 in one million
chance of developing cancer from the
ingestion of arsenic).   And, for the future
residential child, the only estimated risk
from the unit soils was the ingestion of
arsenic with a risk value of 2.8 x 10-6  (i.e.,
there is a 2.8 in one million chance of
developing cancer from the ingestion of
arsenic).   The arsenic level associated with
both risks was 1.74 mg/kg.

Table 4 provides a summary of the
carcinogenic risks and applicable COCs
associated with the future land use scenario
for the BRRP unit sois.

Ecological Risk Assessment

An ecological risk assessment was conducted
to assess the potential impacts to biota
caused by exposure to chemicals and
radionuclides at the BRRP.

A site ecological reconnaissance was
conducted in August 1994.   No wetlands or
threatened and endangered (T&E) species
were observed in the vicinity of the BRRP,
and use of the site by T&E species was not
expected.   The potential media of
contaminant exposure were surface soil,
sediment,  and surface water at or near the
BRRP.

Based on the ecological risk assessment,
ecological impacts from the BRRP source
unit are unlikely.
    !  incidental ingestion of soil,

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  Table 1 - Current Land Use - Noncarcinogenic Hazard Index

RECEPTOR                          EXPOSURE TO CHEMICALS  (HAZARD INDEX)


Environmental
Researcher - ST & LT
Table 2 - Current Land
RECEPTOR


Environmental
Researcher- ST
Environmental
Researcher- LT
RECEPTOR


Environmental
Soil -
Ingestion
0.041

Soil -
Dermal
0.024

Soil -
Inhalation
0.0000034

Total (Soils
Only)
0.065

COCs

NA

Use - Carcinogenic Risks

Soil -
Ingestion
3.2 x 10-9

1.6 x 10-7

EXPOSURE TO
Soil -
Dermal
3.4 x 10-10

1.7 x 10-8

CHEMICALS
Soil -
Inhalation
2.6 x 10-11

1.3 x 10-9


Total (Soils
Only)
3.6 x 10-9

1.8 x 10-7


COCs

NA

NA

EXPOSURE TO RADIONUCLIDES
Soil -
Ingestion
5.3 x 10-12
Soil -
Dermal
1.9 x 10-8
Soil -
Inhalation
1.6 x 10-15
Total (Soils
Only)
1.9 x 10-8
COCs

NA
Researcher- ST
Environmental
Researcher- LT
1.5 x 10-10   7.1 x 10-E
                            1.2 x 10-14
                                           7.1 x 10-7
                                                           NA

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Table 3 - Future Land Use - Noncarcinogenic Hazard Index

 RECEPTOR
                                       EXPOSURE TO CHEMICALS  (HAZARD INDEX)
 Environmental
 Researcher - ST &
 LT
 Residential
 Adult- ST & LT
 Residential
 Child - ST
 Occupational
 Worker- ST & LT
 COCs - Constituents of Concern
 LT - Long Term
Soil -
Ingestion
0.041
0.026
0.23
0.14
Soil -
Dermal
0.024
0.029
0.11
0.083
Soil -
Inhalation
0.0000034
0.0000027
0.000013
0.000024
Produce -
Ingestion
NA
0.00013
0.00030
NA
ST - Short Term
NA - Not Applicable
                             Total  (Soils   COCs
                             Only)
                             0.065          NA
                             0.055          NA

                             0.34           NA
                             0.22
                                            NA

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Table 4 - Future Land Use -Carcinogenic Risks

  RECEPTOR
                                                EXPOSURE TO CHEMICALS

Soil -

Ingestion
Environmental
Researcher - ST
Environmental
Researcher - LT
Residential
Adult - ST
Residential
Adult - LT
Residential
Child - ST
Occupational
Worker - ST
Occupational
Worker - LT
RECEPTOR

3.2 x

1.6 x

3.1 x

1.9 x

2.8 x

1.1 x

5.6 x

10-9

10-7

10-7

10-6

10-6

10-7

10-7

Soil -
Dermal
3.4 x

1.7 x

1.6 x

9.8 x

6.4 x

1.2 x

5.8 x


Soil
-
Inhalation
10-10

10-8

10-8

10-8

10-8

10-8

10-8

2.6

1.3

7.5

4.5

3.6x

1.8

9.0

EXPOSURE
Soil -

Ingestion
Environmental
Researcher - ST
Environmental
Researcher - LT
Residential
Adult - ST
Residential
Adult - LT
Residential
Child - ST
Occupational
Worker - ST
Occupational
Worker - LT
5.3 x

1.5 x

4.0 x

1.6 x

8.3 x

1.4 x

9.0 x

10-12

10-10

10-10

10-9

10-10

10-10

10-10

Soil -
Dermal
1.9 x

7.1 x

2.6 x

3.6 x

2.6 x

7.8 x

1.1 x


Soil
x 10-11

x 10-9

x 10-9

x 10-8

10-8

x 10-9

x 10-9

Produce -
Ingestion
NA

NA

2.0 x 10-8

1.2 x 10-7

4.4 x 10-8

NA

NA

Total (Soils
Only)
3.6 x 10-9

1.8 x 10-7

3.5 x 10-7

2.2 x 10-6

2.9 x 10-6

2 x 10-7

1.2 x 10-7

COCs

NA

NA

NA

Arsenic

Arsenic

NA

NA

TO RADIONUCIDES
-
Inhalation
10-8

10-8

10-7

10-7

10-7

10-8

10-7

1.6

1.2

2.1

3.7

2.4

5.0

8.5

x 10-15

x 10-14

x 10-13

x 10-13

x 10-13

x 10-14

x 10-14

Produce -
Ingestion
NA

NA

2.8 x 10-14

1.1 x 10-13

1.5 x 10-14

NA

NA

Total (Soils
Only)
1.9 x 10-8

7.1 x 10-8

2.6 x 10-7

3.6 x 10-7

2.6 x 10-7

7.8 x 10-8

1.1 x 10-7

COCs

NA

NA

NA

NA

NA

NA

NA

  Shaded items represent exceedances.        COCs - Constituents of Concern
  ST - Short Term             LT - Long Term       NA - Not Applicable

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VII.   Description of the No Action
       Alternative

According to the EPA guidance document
Guidance on Preparing Superfund Decision
Documents (EPA, 1989),  if there is no
current or potential threat to human health
or the environment and no action is
warranted, the CERCLA 121 requirements
are not triggered.  This means that there is
no need to evaluate other alternatives or the
no action alternative against the nine
criteria specified under CERCLA.
VIII.   Explanation of Significant
        Changes

 No significant changes were made to the
 Record of Decision based on the, public
 comment period for the proposed plan.
 Two public comments were received.
 However, they did not have an impact on
 the no action preferred alternative decision.
 One of the comments required clarification
 information to be added to Section VI,
 Summary of Operable Unit Risks  (see
 Appendix A).
Under the No Action alternative, no
treatment will be performed, no new
institutional controls or engineering controls
will be implemented, and no cost is
associated  with implementing the
alternative.  According to CERLCA
regulations, Section 121, if no action is the
preferred action, then no applicable or
relevant and appropriate requirements are
associated with the alternative.

Since the BRRP source unit poses minimal
known risk to human health or the
environment and the no action alternative is
warranted, it does satisfy the CERCLA
criteria.  The no action alternative is
intended to be the final action for the BRRP
source unit soils only.  This solution is
meant to be permanent and effective in both
the long and short term.  The no action
decision is the least cost option with no
capital, operating, or monitoring costs, and
is protective of human health and the environment.
The groundwater contamination beneath the
BRRP is due to migration from upgradient
sources such as the F-Area Inactive Process
Sewer Lines and thus will not be addressed by
this re,nedial alternative.  Following an
investigation on upgradient groundwater
contaminant sources, a determination will be
made as to what corrective action might be
appropriate for the groundwater beneath the BRRP.

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

EPA  (U.S. Environmental Protection
  Agency), 1989.  Guidance on Preparing
  Superfund Decision Documents.  Office
  of Solid Waste and Emergency Response -
  OSWER Directive 9355.3-02.
WSRC  (Westinghouse  Savannah  River
Company),  1995b.  Proposed Plan  for
the Burma  Road Rubble  Pit  (231-4F)
(U), WSRC-RP-95-1531, Rev 1,
Westinghouse  Savannah  River  Company,
Aiken,  South  Carolina.
EPA  (U.S. Environmental Protection
  Agency), 1991.  Guide to Develop
  Superfund No Action, Interim Action, and
  Contingency RODs.  Office of Solid
  Waste and Emergency Response
  OSWER Directive 9355.3-02FS-3.

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), 1993.  Phase II RFI/RI Work
   Plan for the Burma Road Rubble Pit
    (231-4F) (u), WSRC-RP-90-1104, Rev.
   2, Westinghouse Savannah River
   Company, Aiken, South Carolina.

WSRC (Westinghouse Savannah River
  Company), 1994 .   Quality Control
  Summary Report for the Burma Road
  Rubble Pit RFI/RI Unit Assessment  (U) ,
  ESH-EMS-94-0425, Westinghouse
  Savannah River Company, Aiken, South
  Carolina.
WSRC  (Westinghouse Savannah River
  Company), 1995a.  Final RFI/RI Report
  for Burma Road Rubble Pit  (231-4F)
  (U), WSRC-RP-94-1217, Rev. 1,
  Westinghouse Savannah River Company,
  Aiken, South Carolina (includes the
  Baseline Risk Assessment).

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APPENDIX A

RESPONSIVENESS SUMMARY

The public comment period for the Burma Road Rubble Pit Proposed Plan began on January 10, 1996
and ended on February 8, 1996. There were no requests for public meeting about the proposed
action. Two comments were received. Specific comments and responses are found below.

Public Comment #1

Phone Call

January 11, 1996

Burma Road Comment (U)

On January 11, 1996, Lee Poe, citizen, offered the following comment, for consideration and
response, regarding the Proposed Plan for the Burma Road Rubble Pit 231-4F).

"How much money has SRS spent, to date, on the characterization and remedial process for the
Burma Road Rubble Pits?"

Response to Public Comment #1

The costs for the BRRP characterization/assessment are estimated to be $1,780,791. A breakdown
of the costs by the investigation and assessment phases follow.

The associated cost for the investigation phase are estimated to be $1,576,325. The activities
associated with this phase consist of the following:
(1) Work Plan development and regulatory approval,
(2) Field characterization including data validation,
(3) RFI/RI/BRA Report development and regulatory approval, and
(4) Program management associated with these tasks,

The cost for the assessment phase is estimated to be $204,466. The activities associated with
this phase consist of the following:
(1) Initiation of a feasibility study,
(2) Proposed Plan development and approval,
(3) Record of Decision development and approval and,
(4) Program management associated with these tasks.

It should be noted that the feasibility study was initiated before SRS had received approval
from the regulators to proceed with the no action proposed plan.

Although these costs may seem high for a no action unit, it should be noted that the BRRP was
not initially a candidate for no action. SRS had to provide sufficient data in the RFI/RI
Report and the Baseline Risk Assessment (BRA) in order to show the regulators that this should
be a no action waste unit. Information regarding the types of waste that were encountered
during characterization had to be placed in the RFI/RI Report. Based on the RFI/RI Report, the
BRA determined that the only contamination in the waste unit soils was arsenic which was used
before the SRS existed. The groundwater contamination that exists beneath the BRRP is the
result of upgradient migration and a corrective action for the groundwater will be determined
after an investigation on the upgradient migration sources. After all the information was
presented to the regulators, a decision was made to proceed with the no action for the BRRP
surface unit only.

Public Comment #2

Phone Call

January 29, 1996

Public Comment on Burma Road Proposed Plan (U)

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The following comment was offered by Lee Poe, citizen, on the Burma Road Proposed Plan.

"The risk discussion portion of this Proposed Plan is unclear and written in a manner that
assumes the reader has a thorough understanding of the CERCLA process and risk methodology.
Future Proposed Plans should more clearly explain the assumptions used in the risk assessment,
as well as the real risk associated with the waste unit in terms that are easily understood by
the reader. Risk numbers should be accompanied with units and an explanation of what these
numbers mean, to make the documents less confusing and complex."

Response to Public Comment #2

Section VI, Summary of Operable Unit Risks has been revised to list the assumptions used for
the Current Land Use and Future Land Use Baseline Risk Assessment. This section has also
been revised to more clearly state what the risk numbers mean. The revisions to the text are
shown below:

p. 10 - 1st column
"... This means that one in ten thousand to one in one million people may develop cancer over
a lifetime as a result of exposure to cancer-causing contaminants . . . . "

p. 10 - 2nd column through p. 11 - top of 2nd column
"In order to determine the carcinogenic (cancer) and non-carcinogenic hazards the following
general exposure assumptions were used in the baseline risk assessment:

Current Land Use Scenario
Environmental Researcher
The adult environmental researcher receptor was assumed to enter onto the BRRP unit on an
intermittent basis. The adult was assumed to work in the BRRP area for 72 days per year
(approximately one guarter of the year). Exposures were evaluated for a short-term and long-
term scenario (over a half-year and a 25 year interval, respectively). It was also assumed that
the person would remain at the BRRP unit or in the BRRP vicinity for a four hour work period.

The person would wear clothing which covers all bodily areas with the exception of the face,
hands, and forearms.

Future Land Use Scenarios
Residential Scenario
The future residential adult receptor was assumed to reside on the BRRP for a long-term
duration of 30 years and/or a short-term duration of 5 years. It was anticipated that the adult
residential person would engage in gardening/yard maintenance activities for a total of eight
hours per week year-round (four two-hour periods per week, 350 days/year, assuming
approximately two weeks spent away from the residence per year). During such activities, the
person would wear clothing which covers all bodily areas with the exception of the face, arms,
hands, and lower legs.

The future residential child receptor was assumed to reside on the BRRP between the ages of
two through seven years. The child was assumed to live in a house constructed in close
proximity to the BRRP. The child would engage in outdoor activities 350 days/year (assuming
approximately two weeks spent away from the residence per year). Thel average rate for time
spent outdoors would encompass periods when exposures may be more or less freguent, as well
as times when adverse weather would prohibit outdoor activity. It was assumed that the young
child would remain outdoors for a four hour period.

Occupational Worker
The primary receptor examined under the future commercial use scenario, was an on-site adult
worker aged 18 years or older. Soil exposure could occur during normal day-to-day activities
for an on-site worker.

Environmental Researcher
The adult environmental researcher receptor was assumed to enter onto the BRRP unit on an
intermittent basis. The adult was assumed to work in the BRRP area for 72 days per year
(approximately one guarter of the year). Exposures were evaluated for a short-term and long-
term scenario (over a half-year and a 25 year interval, respectively). It was also assumed that

-------
 the person would remain at the BRRP unit or inthe BRRP vicinity for a for hour work period.
The person would wear clothing which covers all bodily areas with the exception of the face,
 hands,  and forearms."

 p. 13 - 1st column
 For the future residential adult,  the only estimated risk from the unit soils was the ingestion
 of arsenic with a risk value of 1.9 x 10-6 (i.e., there is a 1.9 in one million chance of
 developing cancer from the ingestion of arsenic).  And, for the future residential child, the
 only estimated risk from the unit soils was the ingestion of arsenic with a risk value of 2.8 x
 10-6 (i.e., there is a 2.8 in one million chance of developing cancer from the ingestion of
 arsenic).

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