Superfund Record of Decision Feed Materials Production Center USDOE Operable Unit 4 Fernald, Ohio


                                    EPA/ROD/R05-95/287
                                    1995
EPA Superfund
     Record of Decision:
     FEED MATERIALS PRODUCTION CENTER (USDOE)
     EPA ID: OH6890008976
     OU04
     FERNALD, OH
     12/07/1994

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FINAL
RECORD OF DECISION
FOR REMEDIAL ACTIONS AT
OPERABLE UNIT 4


FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
FERNALD, OHIO



DECEMBER 1994

U.S. DEPARTMENT OF ENERGY
FERNALD FIELD OFFICE

DECLARATION STATEMENT

SITE NAME AND LOCATION

Fernald Environmental Management Project  (FEMP) Site - Operable Unit 4, Fernald, Hamilton County, Ohio

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for Operable Unit 4 of the Fernald Site in
Fernald, Ohio.  This remedial action was selected in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act  (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986  (SARA), and to the extent practicable 40 Code of Federal Regulations  (CFR) Part
300, the National Oil and Hazardous Substances Pollution Contingency Plan  (NCP).

For Operable Unit 4 at the FEMP, DOE has chosen to complete an integrated CERCLA/NEPA process.  This decision
was based on the longstanding interest on the part of local stakeholders to prepare an Environmental Impact
Statement (EIS) on the restoration activities at the FEMP and on the recognition that the draft document was
issued and public comments received.  Therefore, this single document is intended to serve as DOE's Record of
Decision (ROD) for Operable Unit 4 under both CERCLA and NEPA; however, it is not the intent of the DOE to
make a statement on the legal applicability of NEPA to CERCLA actions.

The decision presented herein is based on the information available in the administrative record for Operable
Unit 4 and maintained in accordance with CERCLA.  The major documents prepared through the CERCLA process
include the Remedial Investigation  (RI), the Feasibility Study (FS), and the Proposed Plan  (PP) for Operable
Unit 4.  The FS and the PP also comprised DOE's draft EIS and were made available for public review and
comment.  This decision is also based on the public hearing held on March 21, 1994, in Harrison, Ohio, and
the public meeting held on May 11, 1994, in Las Vegas, Nevada following the issuance of the Feasibility
Study/Proposed Plan-Draft Environmental Impact Statement (FS/PP-DEIS).  DOE has considered all comments
received during the public comment period on the FS/PP-DEIS and following issuance of the final EIS in the
preparation of this ROD.

The State of Ohio concurs with the remedy and the applicable or relevant and appropriate reguirements  (ARARs)
put forth in this ROD for Operable Unit 4.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from Operable Unit 4, if not addressed by implementing
the response action selected in this ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment.

DESCRIPTION OF THE REMEDY

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This is the selected remedial action for Operable Unit 4, one of five operable units at the FEMP. The
materials within Operable Unit 4 exhibit a wide range of properties. Most notable would be the elevated
direct radiation associated with the K-65 residues versus the much lower direct radiation associated with
cold metal oxides in Silo 3. Even more significant would be the much lower levels of contamination
associated with the soils and building materials, like concrete, within the Operable Unit 4 Study Area. To
account for these differences and for the varied cleanup alternatives applying to each waste type, Operable
Unit 4 was segmented into three subunits. These subunits are described as follows:

Subunit A: Silos 1 and 2 contents (K-65 residues and bentonite clay) and the sludge in the decant sump
tank

Subunit B: Silo 3 contents (cold metal oxides)

Subunit C: Silos 1, 2, 3, and 4 structures, contaminated soils within the Operable Unit 4 boundary,
including surface and subsurface soils and the earthen berm around Silos 1 and 2; the decant sump tank; the
radon treatment system; the concrete pipe trench and the miscellaneous concrete structures within Operable
Unit 4, any debris (i.e., concrete, piping, etc.) generated through implementing cleanup for Subunits A and
B, and any perched groundwater encountered during remedial activities.

On the basis of the evaluation of final alternatives, the selected remedy addressing Operable Unit 4 at the
FEMP is a combination of Alternatives 3A.l/Vit - Removal, Vitrification, and Off-site Disposal - Nevada Test
Site (NTS); 3B.l/Vit - Removal, Vitrification, and Off-site Disposal - NTS; and 2C - Demolition, Removal and
On-Property Disposal. These alternatives apply to Subunits A, B, and C respectively. The major components
of the selected remedy include:

! Removal of the contents of Silos 1, 2, and 3 (K-65 residues and cold metal oxides) and
the decant sump tank sludge.

! Vitrification (glassification) to stabilize the residues and sludges removed from the
silos and decant sump tank.

! Off-site shipment for disposal at the NTS of the vitrified contents of Silos 1, 2, 3,
and the decant sump tank.

! Demolition of Silos 1, 2, 3, and 4 and decontamination, to the extent practicable, of
the concrete rubble, piping, and other generated construction debris.

! Removal of the earthen berms and excavation of contaminated soils within the boundary of
Operable Unit 4, to achieve remediation levels. Placement of clean backfill to original
grade following excavation.

! Demolition of the vitrification treatment unit and associated facilities after use.
Decontamination or recycling of debris prior to disposition.

! On-property interim storage of excavated contaminated soils and contaminated debris in a
manner consistent with the approved Work Plan for Removal Action 17 (improved storage of
soil and debris) pending final disposition in accordance with the Records of Decision
for Operable Units 5 and 3, respectively.

! Continued access controls and maintenance and monitoring of the stored wastes
inventories.

! Institutional controls of the Operable Unit 4 area such as deed and land use
restrictions

! Potential additional treatment of stored Operable Unit 4 soil and debris using Operable
Unit 3 and 5 waste treatment systems.

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! Pumping and treatment as required of any contaminated perched groundwater encountered
during remedial activities.

! Disposal of Operable Unit 4 contaminated debris and soils consistent with the Records of
Decision for Operable Units 3 and 5, respectively.

The remedy specifies off-site disposal of vitrified contents of Silos 1, 2 and 3 at the NTS. At the time of
the signing of this ROD, The Department of Energy - Nevada Operations Office (DOE-NV) is in the process of
preparing a site-wide environmental impact statement (EIS) under NEPA for the NTS. Shipments of Operable
Unit 4 vitrified waste are not proposed to begin until after the planned completion of the EIS for the NTS.

The planned date of completion of the EIS for the NTS is December 1995, at which time a Record of Decision is
expected to be issued. Shipments of low-level waste generated from the remediation of Operable Unit 4 are
not proposed to begin until mid-1997, which should be after the planned completion of the NTS site-wide EIS.
Given these timeframes, DOE does not anticipate the NTS EIS schedule will negatively impact the Operable Unit
4 remediation schedule discussed in the ROD.

The containerized vitrified product will require interim storage at the FEMP prior to its transportation to
the NTS for disposal. The purpose of this interim storage is two-fold; first, the vitrified product will
require verification sampling in order to certify that each production lot has met specific performance and
waste disposal criteria; and second, to provide the Fernald waste shipping program a buffer staging area
where the material can be safely managed prior to its shipment to NTS in accordance with DOE as low as
reasonably achievable (ALARA) principles, ARARs identified and included in the Operable Unit 4 ROD, as well
as in a manner protective of human health and the environment. It has been anticipated that the interim
storage area will be needed to accommodate the interim handling of approximately 90 days of vitrification
production.

The decision regarding the final disposition of the remaining Operable Unit 4 contaminated soil and debris
will be placed in abeyance, until completion of the Records of Decision for Operable Units 3 and 5 remedial
actions, in order to take full advantage of planned and in progress waste minimization treatment processes by
these operable units. Further, this strategy enables the integration of disposal decisions for contaminated
soils and debris on a site-wide basis.

In the unlikely event unforeseen circumstances preclude the integration of Operable Unit 4 soil and debris
into the Operable Unit 3 and/or Operable Unit 5 treatment and disposal decisions, the disposal decision for
Operable Unit 4 contaminated soils and debris will be documented in a ROD amendment for Operable Unit 4 in
accordance with Section 117(c) of CERCLA and United States Environmental Protection Agency (EPA) guidance.
The ROD amendment will provide the public and the EPA further opportunity to review and comment on the final
disposal option for Operable Unit 4 soils and debris. A ROD amendment to the Operable Unit 4 ROD will not be
necessary in the event the Operable Unit 3 remedy for debris and the Operable Unit 5 remedy for contaminated
soils can be feasibly implemented for Operable Unit 4.

In reaching the decision to implement this remedial alternative, DOE evaluated other alternatives for each
subunit, in addition to no action. The other alternatives are: (a) Subunit A - Silos 1 and 2 Contents: (1)
Removal, Cement Stabilization, Off-Site Disposal at Nevada Test Site; (b) Subunit B - Silo 3 Contents: (1)
Removal, Vitrification, On-Property Disposal; (2) Removal, Cement Stabilization, On-Property Disposal; (3)
Removal, Cement Stabilization, Off-Site Disposal at Nevada Test Site; (c) Subunit C - Silos 1, 2, 3, and 4
Structures. Soils, and Debris: (1) Demolition, Removal, Off-Site Disposal at Nevada Test Site; (2)
Demolition, Removal, Off-Site Disposal at Permitted Commercial Facility.

A description of the alternatives is provided in the Decision Summary of the ROD, hereby incorporated by
reference for DOE's NEPA ROD, and is available in the Administrative Record. CERCLA's nine criteria set
forth in 40 CFR Part 300, the National Oil and Hazardous Substances Pollution Contingency Plan were used to
evaluate the alternatives. The selected remedy represents the best balance among the alternatives with
respect to these criteria and is the environmentally preferable alternative.

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The preferred alternative for Operable Unit 4 provides the best performance when compared with the other
alternatives, with respect to the evaluation criteria.  This remedy will achieve substantial risk reduction
by removing the sources of contamination, treating the material which poses the highest risk, shipping the
treated residues off-site for disposal, managing the remaining contaminated soils and debris consistent with
the site-wide strategy.  The selected treatment alternative both reduces the mobility of the hazardous
constituents and results in significant reduction in the volume of materials reguiring disposal.  The
selected remedy also provides the highest degree of long-term protectiveness for human health and the
environment.

STATUTORY DETERMINATIONS

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.  This remedy utilizes permanent solutions and alternative treatment  (or resource recovery)
technologies to the maximum extent practicable, and satisfies the statutory preference for remedies that
employ treatment, and also reduce toxicity, mobility, or volume as a principal element.  This remedy will
result in contaminated debris and soil being dispositioned bv Operable Units 3 and 5, respectively.  Because
this remedy will result in hazardous substances (i.e.,  contaminated soil and debris) remaining on site,
above health-based levels, a review will be conducted every five years after commencement of remedial action
to ensure that the remedy continues to provide adeguate protection of human health and the environment.

All practical means to avoid or minimize environmental harm from implementation of the selected remedy have
been adopted.  During excavation activities.  sediment controls will be implemented to eliminate potential
surface water runoff and sediment deposition to Paddys Run.  Final site layout and design will include all
practicable means (e.g., sound engineering practices and proper construction practices) to minimize
environmental impacts.
Regional Administrator,
U.S. Environmental Protection Agency Region V

Assistant Secretary for Environmental Management
U.S. Department of Energy
Date
Date
TABLE OF CONTENTS                                Page

         List of Tables	v

         List of Figures	v

         Acronym List	vi

         List of Weights and Measures	viii

         1.0  Site Location and Description	1-1

              1.1  Location	1-1

              1.2  Demographics and Land Use	1-6

              1.3  Topography and Surface Water Hydrology  	 1-7

              1.4  Geology and Hydrogeology	1-9

              1.5  Ecology	1-11

         2.0  Site and Operable Unit 4 History and Enforcement Activities	2-1

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     2.1  Site History	2-1

     2.2  Operable Unit 4 History	2-2

3.0  Community Participation  	  3-1

     3.1  Operable Unit 4 Public Involvement Activities 	  3-1

4.0  Scope and Role of Remedial Action	4-1

     4.1  Integration of NEPA into CERCLA	4-2

5.0  Summary of Operable Unit 4 Characteristics	5-1

     5.1  Investigative Studies 	  5-1

     5.2  Summary Description of Contamination Sources  	  5-1

          5.2.1  Classification of Contamination Sources  	  5-1

          5.2.2  Source Characteristics 	  5-2

     5.3  Nature and Extent of Contamination	5-4

          5.3.1  Surface Soils	5-4

          5.3.2  Subsurface Soils 	  5-6

          5.3.3  Surface Water and Sediment	5-6

          5.3.4  Groundwater	5-6

     5.4  Potential Exposure Pathways for Contaminant Migration 	  5-8

          5.4.1  Direct Radiation 	  5-9

          5.4.2  Air Emissions	5-9

          5.4.3  Surface Water Runoff	5-10

          5.4.4  Groundwater Transport  	   5-10

6.0  Baseline Risk Assessment	6-1

     6.1  Summary of the Baseline Assessment of Risks to Human Health	6-2

          6.1.1  Constituents of Concern	6-2

          6.1.2  Exposure Assessment	6-2

          6.1.3  Toxicity Assessment	6-7

          6.1.4  Risk Characterization Results  	   6-21

                 6.1.4.1  Current Land Use Without Access Control/Current
                          Source-Term Scenario  	   6-21

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                 6.1.4.2  Current Land Use Without Access Control/Future
                          Source-Term Scenario  	  6-24

                 6.1.4.3  Current Land Use With Access Control/Current
                          Source-Term Scenario  	  6-24

                 6.1.4.4  Future Land Use/Current Source-Term Scenario  	  6-24

                 6.1.4.5  Future Land Use/Future Source-Term Scenario   	  6-25

          6.1.5  Risk Assessment Uncertainties	6-25

                 6.1.5.1  Sources of Uncertainty  	  6-26

                 6.1.5.2  Toxicity Assessment 	  6-26

     6.2  Overview of the Baseline Ecological Risk Assessment	6-27

7.0  Description of Remedial Alternatives   	 7-1

     7.1  No-Action Alternative For All Subunits	7-3

     7.2  Subunit A - Contents of Silos 1 and 2 and the Decant Sump Tank	7-4

          7.2.1  Alternative 3A.l/Vit - Removal, Vitrification,  and
                 Off-Site Dispsal - Nevada Test Site	7-4

          7.2.2  Alternative 3A.l/Cem - Removal, Cement Stabilization, and
                 Off-Site Disposal - NTS	7-7

     7.3  Subunit B - Contents of Silo 3	7-8

          7.3.1  Alternative 2B/Vit - Removal, Vitrification, and
                 On-Property Disposal 	 7-9

          7.3.2  Alternative 2B/Cem - Removal, Cement Stabilization, and
                 On-Property Disposal 	  7-11

          7.3.3  Alternative 3B.l/Vit - Removal, Vitrification,  and
                 Off-Site Disposal - NTS	7-12

          7.3.4  Alternative 3B.l/Cem - Removal, Cement Stabilization, and
                 Off-Site Disposal - NTS	7-13

          7.3.5  Alternative 4B -Removal and On-Property Disposal 	  7-14

     7.4  Subunit C - Silos 1, 2, 3, and 4 Structures, Soils, and Debris  	  7-14

          7.4.1  Alternative 2C - Demolition,  Removal, and On-Property Disposal .  .  .  7-16

          7.4.2  Alternative 3C.1 - Demolition,  Removal, and Off-Site
                 Disposal - NTS	7-19

          7.4.3  Alternative 3 C.2 - Demolition, Removal, and Off-Site
                 Disposal (Permitted Commercial Disposal Site)  	  7-19

8.0  Summary of the Comparative Analysis of Alternatives	8-1

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     8.1  Evaluation Criteria 	  8-1





     8.2  Comparative Analysis of Alternatives	8-2





          8.2.1  Analysis for Subunit A	8-2





                 8.2.1.1  Threshold Criteria  	  8-2




                 8.2.1.2  Primary Balancing Criteria  	  8-7





                 8.2.1.3  Modifying Criteria  	   8-10





                 8.2.1.4  Subunit A Comparative Analysis Summary  	   8-10





          8.2.2  Subunit B	8-10




                 8.2.2.1  Threshold Criteria  	   8-10





                 8.2.2.2  Primary Balancing Criteria  	   8-13





                 8.2.2.3  Modifying Criteria  	   8-15





                 8.2.2.4  Subunit B Comparative Analysis Summary  	   8-15




          8.2.3  Subunit C	8-16





                 8.2.3.1  Threshold Criteria  	   8-16





                 8.2.3.2  Primary Balancing Criteria  	   8-17





                 8.2.3.3  Modifying Criteria  	   8-20





                 8.2.3.4  Subunit C Comparative Analysis Summery  	   8-20




9.0  Selected Remedy	9-1





     9.1 Key Components	9-1





         9.1.1  Removal of Silo 1,  2 and 3,  and Decant Sump Tank Contents	9-2





         9.1.2  Vitrification of Silo 1,  2 and 3,  and Decant Sump Tank Contents    .  .  .  9-2




         9.1.3  Off-Site Shipment and Disposal of Treated Material  	  9-3





         9.1.4  Demolition and Decontamination of Structures  	  9-3





         9.1.5  Demolition and Decontamination of Other Operable Unit 4 Structures   .  .  9-4





         9.1.6  Disposition of Demolished Structures and Debris 	  9-4





         9.1.7  Soil Removal	9-5





         9.1.8  Soil Disposition	9-6





         9.1.9  Cost	9-7





     9.2  Soil Cleanup Criteria	9-7

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                   9.2.1  Land Use and Receptor Description	9-7

                   9.2.2  Preliminary Remediation Levels 	  9-9

              9.3  Measures to Control Environmental Impacts 	   9-13

        10.0  Statutory Determinations 	   10-1

              10.1  Protection of Human Health and the Environment 	   10-1

              10.2  Compliance With Legally Applicable or Relevant and Appropriate
                    Requirements 	   10-2

              10.3  Cost Effectiveness	10-3

              10.4  Utilization of Permanent Solutions and Alternative Treatment
                    Technologies or Resource Recovery Technologies to the Maximum
                    Extent Practicable 	   10-3

              10.5  Preference for Treatment as a Principal Element  	   10-4

              10.6  Unavoidable Adverse Impacts  	   10-4

              10.7  Irreversible and Irretrievable Commitment of Resources 	   10-7

        11.0  Documentation of Significant Changes 	   11-1

              11.1  Repromulgation of 40 CFR § 191	11-1

                    11.1.1  Background 	   11-1

                    11.1.2  Impacts of Repromulgation  	   11-2

        References	R-l

        Appendix A          Summary of Major ARARs for Operable Unit 4 Remedial Action
                            Alternatives   	  A-l

        Appendix B          Summary of ARARs for the Operable Unit 4 Remedial Action	B-l

        Appendix C          Responsiveness Summuary  	  C-l

        Appendix D          Administrative Record File Index 	  D-l

        Appendix E          State of Ohio Concurrence	E-l

LIST OF TABLES
                                                                                                 Page

         6-1  Constituents of Concern for Operable Unit 4	6-3

         6-2  Summary of Land-Use/Receptor/Source-Term Scenarios 	  6-8

         6-3  Cancer Slope Factors for Carcinogenic Effects of Constituents of
              Concern for Operable Unit 4	   6-12

         6-4  Cancer Slope Factors for Operable Unit 4 Radionuclides of

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              Concern	  6-16

         6-5  Reference Doses for Noncarcinogenic Effects of Constituents of
              Concern for Operable Unit 4	  6-17

         6-6  Incremental Lifetime Cancer Risk Summary All Sources/All
              Pathways	  6-22

         6-7  Hazard Index Summary All Sources/All Pathways  	  6-23

         8-1  Comparison of Remedial Alternatives  	 8-3

         8-2  Operable Unit 4 Remedial Alternative Cost Summary (Million $)   	8-11

         9-1  Combined Cost Estimate for Selected Remedy 	 9-8

         9-2  Preliminary Remediation Levels in Soils - Radionuclides  	  9-10

         9-3  Preliminary Remediation Levels in Soils - Chemicals  	  9-11

         10-1 Unavoidable Adverse Impacts on Resources 	  10-5

LIST OF FIGURES

                                                                                                Page

         1-1     FEMP Facility Location Map	1-2

         1-2     Waste Storage Area	1-3

         1-3     Operable Unit 4	1-5

         1 4     Surface Water Hydrology 	 1-8

         1-5     Approximate Boundaries of Jurisdictional Wetlands at FEMP 	  1-13

         1-6     Great Miami River and Paddys Run 100-Year and 500-Year Floodplain 	  1-14

         6-1     OU4 Conceptual Model - Silo Contents	6-9

         6-2     OU4 Conceptual Model - Soil and Berm Fill Material	6-10

ACRONYM LIST

AEA          Atomic Energy Act

AEC          Atomic Energy Commission

ARAR         applicable or relevant and appropriate reguirements

CERCLA       Comprehensive Environmental Response, Compensation, and Liability Act

CIS          Characterization Investigation Study

CFR          Code of Federal Regulations

CMSA         Consolidated Metropolitan Statistical Area

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COG          Constituents of Concern





COE          United States Army Corps of Engineers





CT           central tendency





DOE          United States Department of Energy




DOE-FN       United States Department of Energy - Fernald Field Office





DOE-NV       United States Department of Energy - Nevada Operations Office





DOT          U.S. Department of Transportation





EIS          Environmental Impact Statement




EP           Extraction Procedure





EPA          United States Environmental Protection Agency





FEMP         Fernald Environmental Management Project





FERMCO       Fernald Environmental Restoration Management Corporation




FFCA         Federal Facility Compliance Agreement





FMPC         Feed Materials Production Center





FRESH        Fernald Residents for Environment, Safety,  and Health





FS           Feasibility Study





FS/PP-DEIS   Feasibility Study/Proposed Plan - Draft Environmental Impact Statement




FSIPP-FEIS   Feasibility Study/Proposed Plan - Final Environmemtal Impact Statement





HEAST        Health Effects Assessment Summary Table





HEPA         High-Efficiency Particulate Air (filter)





HI           Hazard Index




HQ           Hazard Quotient





IARC         International Agency for Research on Cancer





ILCR         incremental lifetime cancer risk





IRIS         Integrated Risk Information System





ISA          Initial Screening of Alternatives







LRA          leading remedial alternative





MCL          maximum containment level

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MCLG         maximum containment level goal





MCW          Mallinckrodt Chemical Works





MSL          mean sea level





NCP          National Oil and Hazardous Substances Pollution Contingency Plan





NEPA         National Environmental Policy Act





NOEL         No Observed Effect Level





NOI          Notice of Intent





NOV          Notice of Violation





NPDES        National Pollutant Discharge Elimination System





NPL          National Priorities List





NRHP         National Register of Historic Places





NTS          Nevada Test Site





O&M          operation and maintenance





OAC          Ohio Administrative Code





OEPA         Ohio Environmental Protection Agency





ORC          Office of Regional Council





PAH          polyaromatic hydrocarbons





Pb           lead





PCB          polychlorinated biphenyls





PEIC         Public Environmental Information Center





Po           polonium





PP           Proposed Plan





PRG          proposed remediation goals





PRL          proposed remediation level





Ra           radium





RCRA         Resource Conservation and Recovery Act





RfD          reference dose





RI           Remedial Investigation





RI/FS        Remedial Investigation/Feasibility Study

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RME          reasonable maximum exposure





Rn           radon





ROD          Record of Decision





RTS          radon treatment system





SARA         Superfund Amendment and Reauthorization Act





SDWA         Safe Drinking Water Act





TBC          to be considered





TCLP         Toxicity Characteristic Leaching Procedure





Th           thorium





U            uranium





USDA         United States Department of Agriculture





VOC          volatile organic compounds





LIST OF WEIGHTS AND MEASURES





cm           centimeter





ft           feet





ha           hectare





in           inch





kg           kilogram





km           kilometer





km2          sguare kilometers





L            liters





m            meter





m3           cubic meters





y.g/1         micrograms per liter





M            million





mi           miles





mi2          sguare miles





mg           milligram





mg/kg        milligrams per kilogram

-------
mg/kg-day milligrams per kilogram day

mg/1 milligrams per liter

pCi/1 picoCuries per liter

pCi/g picoCuries per gram

ppb parts per billion

yd3 cubic yards

1.0 SITE LOCATION AND DESCRIPTION

1.1 LOCATION

The Fernald Environmental Management Project (FEMP) site is a 425 hectare (ha) (1050 acres), government-owned
facility located in southwestern Ohio, approximately 29 kilometers (km) (18 miles) northwest of downtown
Cincinnati. The facility is located just north of Fernald, Ohio, a small farming community, and lies on the
boundary between Hamilton and Butler counties (Figure 1-1).

In accordance with the reguirements of the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), the FEMP was placed on the National Priorities List (NPL) in November 1989 as a result of
environmental impacts caused by facility operations.

From 1952 until 1989, the FEMP site provided high-purity uranium metal products to support United States
defense programs. Uranium production was halted in 1989 due to declining demand and a recognized need to
commit available resources to environmental remediation. Former uranium operations at the FEMP site were
limited to a fenced 55 ha (136 acres) tract of land known as the former Production Area located near the
center of the site. The former Production Area consists of plant buildings, scrap metals, eguipment, and
drummed inventories all of which are components of Operable Unit 3. Large guantities of liguid and solid
wastes were generated by the various production operations at the FEMP site. Prior to 1984, solid and
slurried wastes received from off site sources and generated from FEMP processes were stored or disposed in
the Waste Storage Area. This area, located west of the production facilities, includes: six low-level
radioactive waste storage pits, two earthen-bermed concrete silos containing K-65 residues, one concrete silo
containing metal oxides, one unused concrete silo, two lime sludge ponds, a burn pit, a clearwell, and a
solid waste landfill. The Waste Storage Area, shown graphically in Figure 1-2, is addressed under FEMP
Operable Units 1, 2, and 4. The former Production Area and Waste Storage Area are fenced and closed to the
general public. Operable Unit 5 consists of all environmental media not associated with the preceding
operable units. The remaining FEMP site areas consist of forest and pasture lands, a portion on which a
nearby dairy farmer is authorized to graze livestock.

A sixth operable unit, known as the Comprehensive Site-Wide Operable Unit, was added as a provision of the
Amended Consent Agreement (signed in 1991). This is not a specific site area; rather, it was created to
enable DOE, the EPA, and the public to make a final assessment from a site wide perspective that ongoing
planned remedial actions identified in the Records of Decision for the five operable units will provide a
comprehensive remedy which is protective of human health and the environment.

This remedial action addresses Operable Unit 4 at the FEMP. Operable Unit 4 (Figure 1-3) is a 2.3 ha (5.8
acres) area located on the western side of the facility and is comprised of the following facilities and
associated environmental media:

! Silos 1 and 2 and their contents (also termed K-65 silos);

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! Silo 3 and its contents (termed cold metal oxide silo);

! Silo 4 (empty);

! The decant sump (an underground tank and its contents);

! A radon treatment system;

! A portion of a concrete pipe trench and other concrete structures;

! An earthen berm surrounding Silos 1 and 2;

! Soils beneath and immediately surrounding Silos 1, 2, 3, and 4;

! Perched groundwater in the vicinity of the silos that are encountered during the
implementation of remedial actions;

Silos 1 and 2, the K-65 silos, contain 6,120 cubic meters (m3) [8,005 cubic yards (yd3)] of K-65 residues
generated from the processing of high-grade uranium ore. The silos are large, cylindrical, above-grade,
concrete vessels with post-tensioned steel reinforcing. Each of the domed silos is 24.4 meter (m) [80 feet
(ft)] in diameter and 11 m (36 ft) high to the center of the dome.

The K-65 residues contain large activity concentrations of radionuclides, including radium and thorium.
These radionuclides contribute to an elevated direct penetrating radiation field in the vicinity of the silos
and to the chronic emission of significant guantities of the radioactive gas, radon, to the atmosphere from
the silos. The K-65 residues are classified as by-product materials, consistent with Section 11 (e)2 of the
Atomic Energy Act (AEA), generated conseguential to the processing of natural uranium ores.

Silo 3 contains 3,890 m3 (5,088 yd3) of residues, known as cold metal oxides, which were generated at the
FEMP site during uranium extraction operations in the 1950s involving the previously mentioned uranium ores
and ore concentrates received from a variety of uranium mills in the United States and abroad. Silos 3 and 4
are identical in design and construction to Silos 1 and 2. The residues within Silo 3 are similarly
classified as by-product materials pursuant to Section 11 (e)2 of the AEA. Silo 4 was never used for waste
storage; however, rainwater has infiltrated the silo and has been removed in 1989 and again in 1991.

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Paddys Run Road approximately 2.4 km (1.5 mi) south of the FEMP property. These residences are in the
vicinity of the South Plume, a portion of the Great Miami Aquifer that contains a plume of uranium
contamination originating from the FEMP extending south of the property boundary for approximately
three-guarters of a mile.

More than 160 ha (395 acres) of the open land on the FEMP property are leased to a nearby dairy farmer who
grazes livestock on the property. Pine plantations are located to the northeast and southwest of the former
Production Area. A considerable amount of the soils within the boundaries of the FEMP site are designated by
the United States Department of Agriculture (USDA) as prime agricultural soil (USDA 1980, 1982). However,
none of the land on the FEMP site is designated prime farmland under the Farm and Policy Protection Act
regulations (7 CFR §658) of 1981. Because the area had been intensively used for agricultural purposes prior
to the establishment of the FEMP facility, there is no land on or in the vicinity of the FEMP site where a
pre-developed natural environment remains intact. The land closest to this description would be recreated
prairie lands on the Miami Whitewater Forest Park, several miles south of the FEMP site.

The area surrounding the FEMP site has a large and diverse archaeological and historical resource base.
According to records kept by the Miami Purchase Association for Historic Preservation, an unusually high
percentage of the existing 19th century buildings in the area are historically important. Within the
vicinity of the FEMP site [a 3.2 km (2 mi) radius from the boundary], there are properties listed on the
National Register of Historic Places (NRHP) and a number of additional structures that have been judged
eligible for inclusion in the listing. Six major archaeological sites lie within five miles of the FEMP site
and five of these are included in the NRMP. No archaeological sites or properties on the NRHP are located in
or adjacent to Operable Unit 4.

1.3 TOPOGRAPHY AND SURFACE WATER HYDROLOGY

The maximum elevation along the northern boundary of the FEMP property is a little more than 213 m (700 ft)
above mean sea level (MSL). The former Production Area and Waste Storage Area rest on a relatively level
plain at about 174 m (580 ft) above MSL. The plain slopes from 183 m (600 ft) above MSL along the eastern
boundary of the FEMP to 174 m (570 ft) above MSL at the K-65 silos, and then drops off toward Paddys Run
stream at an elevation of 168 m (550 ft) above MSL.

All drainage, including surface water on the FEMP site is generally from east to west towards Paddys Run,
with the exception of the extreme northeast corner which drains east toward the Great Miami River. Major
surface water bodies on and adjacent to the FEMP site include the Storm Sewer Outfall Ditch, Paddys Run, end
the Great Miami River (see Figure 1-4). The Storm Sewer Outfall Ditch originates within the FEMP site and
flows toward the southwest where it enters Paddys Run, which flows southward along the western boundary of
the facility. Paddys Run is a tributary of the Great Miami River. The Great Miami River flows generally
toward the southwest; however, locally it flows to the east and south of the FEMP site.

Paddys Run originates north of the FEMP site, flows southward along the western boundary of the facility, and
enters the Great Miami River approximately 2.4 km (1.4 mi) south of the southwest corner of the FEMP
property. The stream is approximately 14 km (8.8 mi) long and drains an area of approximately 40.9 sguare
kilometers (km2) [15.8 sguare miles (mi2)]. Due to the highly permeable channel bottom, the stream loses
water to the underlying Great Miami Aguifer in some locations. In addition, the stream is ephemeral and is
generally dry during the summer months.

The Great Miami River is the main surface water feature in the vicinity of the FEMP site, which receives
effluent water from a National Pollutant Discharge Elimination System (NPDES) permitted discharge from the
FEMP site. The river flows generally to the southwest and has a drainage area of approximately 8702 km2
(3360 mi2) at the Hamilton gauge, which is located about 16.1 km (10 mi) upstream from the FEMP site NPDES
discharge outfall.

The river exhibits meandering patterns that result in sharp directional changes over distances of less than
900 m (2,953 ft). Directly east of the FEMP site and within the site-wide Remedial Investigation/Feasibility
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Study (RI/FS) Area, the river passes through a 180-degree curve known as the Big Bend. A 90-degree bend in
the river also occurs near New Baltimore, approximately 3.2 km (2 mi) downstream from the FEMP site discharge
outfall.

Surface water flow within Operable Unit 4 is directed through a series of trench drains, concrete curbs, and
gutters to an inground concrete sump located in waste storage area. Water from these storm water control
facilities are directed through existing site treatment systems prior to discharge through the FEMP effluent
line to the Great Miami River.

1.4 GEOLOGY AND HYDROGEOLOGY

The FEMP overlies a 3.2 to 4.8 km (2 to 3 mi) wide buried Pleistocene valley known as the New Haven Trough.
This valley was formed (eroded) by the ancestral Ohio River during the Pleistocene period and was
subseguently filled with glacial outwash materials that were in turn covered by glacial overburden as
glaciers advanced across the area. The outwash deposits under the FEMP are a part of the Great Miami
Aguifer, which is a widely distributed buried valley aguifer. In addition to surface water, the valley fill
aguifer system is the major source of drinking water in the southwestern Ohio area.

Since the last retreat of continental glaciers, the streams in the area have removed much of the glacial
overburden and lacustrine strata left by the ice sheets. The Great Miami River has eroded through the
glacial overburden and is now in direct contact with the outwash deposits that comprise the Great Miami
Aguifer. Paddys Run is also in contact with these deposits in its lower reaches.

The Great Miami Aguifer is the principal aguifer within the FEMP Study Area and has been designated a
sole-source aguifer under the provisions of the Safe Drinking Water Act (SDWA) . The buried valley in which
it occurs varies in width from about 0.8 km (0.5 mi) to more than 3.2 km (2 mi), having a U-shaped cross
section with a broad, relatively flat bottom and steep valley walls. This valley is filled with extensive
deposits of sand and gravel that range in thickness from 36 to 60 m (120 to 200 ft) in the valley to only
several feet along the valley walls, along with scattered silt and clay deposits.

Contained within the sand and gravel that underlies much of the FEMP property is a relatively continuous,
low-permeability clay interbed ranging from about 1.5 to 4.5 m (5 to 15 ft) in thickness. The clay interbed
which exists below the Operable Unit 4, occurs at an approximate elevation of 140 m (460 ft) above MSL. This
clay interbed divides the aguifer into upper and lower sand and gravel units, referred to as the Upper Great
Miami Aguifer and the Lower Great Miami Aguifer.

Overlying the Great Miami Aguifer throughout most of the FEMP property, including Operable Unit 4, are a
series of glacial overburden deposits. The glacial overburden is composed primarily of till, a dense, silty
clay that contains discontinuous and isolated lenses of poorly sorted fine- to medium-grained sand and
gravel, silty sand, and silt. The glacial overburden exposed at the surface has relatively low permeability,
so most of the precipitation that falls on it is lost to evaporation and surface water runoff. Within
Operable Unit 4, sand and gravel outwash deposits of the buried valley are overlain by 1.5 to 3 m (5 to 10
ft) of till that is in turn overlain by 4.5 to 6m (15 to 20 ft) of lacustrine sediments. The till is an
unsorted mixture of clay, silt, sand, and pebble to cobble size material with 70 to 80 percent of the
material filling in the clay and silt size range.

Erratically distributed pockets of silty sand and gravel within the glacial overburden contain zones of
perched groundwater. Perched groundwater is separated from the underlying aguifer by the surrounding
relatively impermeable clay and silt components of the overburden. These low-permeability units behave as an
aguitard that can store groundwater, then transmit it slowly downward from one more porous saturated zone to
another.

The conceptual model for groundwater flow in the glacial overburden in Operable Unit 4 indicates that the
lacustrine strata have good, but slow, hydraulic communication and that the till that underlies the
lacustrine strata acts as an aguitard. Groundwater within the approximately 6 m (20 ft) of lacustrine strata
is predicted to flow at a lateral rate that is significantly greater than its downward rate. Therefore,
groundwater is likely discharging westward to the bank of Paddys Run and southward in the east-west
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drainageway immediately south of Silo 1.

1.5 ECOLOGY

The FEMP site and surrounding areas lie in a transition zone between two distinct sections of the Eastern
Deciduous Forest Province; the Oak-Hickory and the Beech-Maple. The dominant species are oaks, with an
abundance of hickeries. The fauna vary little between the two forest sections and include white-tailed deer,
gray fox, gray sguirrel, white-footed mouse, and short-tailed shrew; the cardinal, woodthrush, summer
tanager, red-eyed vireo, and the hooded warbler; the box turtle, common garter snake, and timber rattlesnake.

The Indiana bat is listed as both a federally and state endangered species and occurs in Butler and Hamilton
Counties. Surveys were conducted at the FEMP to determine the distribution and presence of the Indiana bat
and to identify potential habitat on the FEMP and in the immediate vicinity. The Indiana bat has not been
identified at the FEMP. Potential habitat for the Indiana bat occurs in portions of the riparian woodland
associated with Paddys Run.

The Sloan's crayfish, a state listed threatened species, has been identified in Paddys Run in northern
sections on property and southern sections off property in preliminary surveys in September 1993. Potential
harm may occur as a result of siltation and runoff into Paddys Run.

The cave salamander, a state listed endangered species, has not been identified at the FEMP site. Moderate
habitat has been identified in a well in the northeastern section of the FEMP and a ravine in the north
woodlot.

A site-wide wetland delineation was conducted in February 1993, in accordance with the 1997 United States
Army Corps of Engineers (COE) Wetlands Delineation Manual. A jurisdictional determination was approved in
August 1993 by the COE that verified wetland boundaries and waters of the United States. Results from the
site-wide delineation, subject to COE approval, indicate a total of 14.4 ha (35.9 acres) of wetlands that
include 10.6 ha (26.6 acres) of palustrine forested wetlands, 2.8 ha (7 acres) of drainage ditches/swales,
and 0.95 ha (2.37 acres) of isolated emergent and emergent-scrub/shrub wetlands (see Figure 1-5).

Floodplains within the FEMP property are confined to the north-south corridor containing Paddys Run. Outside
the boundaries of the FEMP site, the 100 year floodplain of the Great Miami River extends west nearly to the
eastern boundary of the facility (see Figure 1 6). The 100 year floodplain of the river also extends
northward along Paddys Run from the confluence of the two streams to a point about 180 m (600 ft) from the
southern boundary of the FEMP site.

2.0 SITE AND OPERABLE UNIT 4 HISTORY
AND ENFORCEMENT ACTIVITIES

2.1 SITE HISTORY

In January 1951, the New York Operations Office of the Atomic Energy Commission (AEC) proceeded on an
expedited basis with the selection of a suitable site for the construction of a new feed material production
center to supply high purity uranium products. Sixty-three sites were considered with a site near Fernald,
Ohio being selected as best meeting established criteria. Construction operations were initiated in May
1951, on the 1050 acre site. The facility was designated the Feed Material Production Center (FMPC) prior to
initiation of on-property pilot operations in October 1951. Production operations were initiated in 1952 and
continued until July 1989, at which time operations were placed on standby to focus on environmental
compliance and waste management initiatives. Following appropriate congressional authorizations, the
ficility was formally closed in June 1991. To reflect a new site mission focused on environmental
restoration, the name of the facility was changed to the Fernald Environmental Management Project (FEMP) in
August 1991.
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On March 9, 1985, the EPA issued a Notice of Noncompliance to the DOE identifying EPA's concerns over
potential environmental impacts associated with the FEMP's past and ongoing operations. On July 18, 1986, a
Federal Facility Compliance Agreement (FFCA) detailing actions to be taken by DOE to assess environmental
impacts associated with the FEMP was signed by DOE and EPA. The FFCA was entered into pursuant to Executive
Order 12088 (43 FR 47707) . The purpose of the FFCA was to ensure compliance with existing environmental
statutes and implementing regulations. Also, environmental impacts associated with past and present
activities at the FEMP site would be thoroughly and adeguately investigated so that appropriate response
actions could be implemented. As required by the FFCA, a RI/FS was initiated in July 1986, pursuant to 42
U.S.C. 9601 et seg, CERCLA.

In November 1989, the FEMP was placed on the NPL for investigation and remediation under CERCLA. This
placement, in addition to progressive findings in the RI/FS progrmn, necessitated the amendment of the FFCA.
The 1986 FFCA was superseded by a Consent Agreement under Sections 120 and 106(a) of CERCLA (Consent
Agreement) providing for the implementation of operable units for the FEMP RI/FS and revising the milestone
commitments for the RI/FS program without modifying the underlying objectives of the FFCA. The Consent
Agreement also provided for the implementation of removal actions to address site conditions which pose an
immediate threat to human health and the environment, including removal actions for Operable Unit 4, such as
the K-65 Silos Removal Action. The Consent Agreement was signed on April 9, 1990, and became effective on
June 29, 1990, following a period of public comment.

In October 1990, the first version of the RI Report for Operable Unit 4 was submitted to the EPA for review
and comment. The EPA determined that the FMPC had not adeguately characterized Operable Unit 4, and
subsequently, issued a Notice of Violation (NOV) against the site. The EPA issued two other NOVs at
approximately the same time regarding other components of the ongoing RI/FS. Following negotiations between
the EPA and DOE, a resolution agreement was jointly signed by the EPA and DOE. Pursuant to the terms of this
resolution agreement, DOE paid a financial penalty to EPA, agreed to perform a supplemental project
beneficial to the environment surrounding the site, and also agreed to enter into negotiations with EPA to
define new schedules for re submittal of the RI/FS documents.

The Consent Agreement was amended in 1991 to revise the schedules for completing the RI/FS for the five
identified operable units. This Amended Consent Agreement was signed on September 20, 1991, and became
effective on December 19, 1991, following a period of public comment.

2.2 OPERABLE UNIT 4 HISTORY

Originally constructed in 1951 and 1952, three of the four reinforced concrete storage silos within Operable
Unit 4 received by-product materials until 1960. Silos 1 and 2 received K-65 residues generated from the
processing of high assay uranium ores, termed pitchblende ores, at the FEMP and the Mallinckrodt Chemical
Works (MCW) in St. Louis, Missouri. The pitchblende ores processed at MCW and the vast majority of
pitchblende ores processed at the FEMP came primardy from one mine, the Shinkolobwe Mine in the Belgian Congo
(now Zaire).

The Shinkolobwe Mine was owned and operated by the African Metals Corporation. These ores contained
relatively high concentrations of uranium oxides (U308) in the range of 40 to 50 percent as well as high
concentrations of radium. Based on the high value of radium at the time, the agreement reached between the
AEC and the African Metals Corporation stipulated that the African Metals Corporation would retain ownership
of the radium within any processing residues; after the United States had processed the pitchblende ore to
extract uranium, the residue would be returned to the African Metals Corporation.

The K-65 silos were constructed at the FEMP site to provide interim storage of the residues, pending the
return of the materials to the country of origin. For more than 30 years, these material remained in storage
at the FEMP site, under the terms of the original agreement, awaiting transfer. In 1984, ownership of the
K-65 residues was transferred to DOE.

As the drums were received by railroad car at the FEMP, from MCW, the drums were temporarily staged in an
area to the east of Silos 3 and 4 (Figure 1-3). The drummed material was slurried in the Drum Handling
Building, formerly located between Silos 2 and 3, and then pumped to Silos 1 and 2 for storage.
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Approximately 31,000 drums of residues generated through MCW processing operations were received at the FEMP.
Approximately 24,000 of these drums were transferred to Silo 1, completely filling the structure in November
1953. The remaining 7,000 drums were transferred to Silo 2 for storage.

Additionally, Silo 2 received residues generated at the FEMP from the processing of pitchblende ores from the
Shinkolobwe Mine and a small guantity of Australian ores from two mines, the Rum Jungle Mine and the Radium
Hill Mine. The last residues were placed in Silo 2 in January 1959. Following the end of K-65 processing
operations at the FEMP, approximately 150 drums of radium contaminated material, consisting of soils from
drum staging areas, clean-up materials, and excess K-65 samples were placed into Silo 2 in June 1960.

Silos 3 and 4 were constructed in 1952 for storing metal oxides generated by the FEMP refinery. Unlike Silos
1 and 2, which received residues from the processing of ores from mainly one mine, Silo 3 received metal
oxides generated from FEMP refinery operations from May 1954, until late 1957. During this period, the FEMP
refinery processed the previously mentioned pitchblende ores and uranium ore concentrates received from a
number of foreign and domestic uranium mills. Select refinery waste streams were first filtered to remove
radium and subseguently directed to an evaporator and calciner. These finely powdered, dried refinery
residues (termed cold metal oxides) were transferred to a surge hopper from where the materials were
pneumatically conveyed through a pipeline to Silo 3.

Following a programmatic decision in early 1957 to utilize raffinate surface impoundments, the calcining
systems were eventually abandoned. As a result of this decision, Silo 4 was never employed for the storage
of cold metal oxides or other site materials and remains empty. Inspections completed on Silo 4 during the
Rl-related site investigations confirmed that no waste materials are present within the silo.

In 1963, it became visually obvious that Silos 1 and 2 were deteriorating. In 1964, site workers repaired
the concrete coating around each silo and constructed an earthen berm around them to counterbalance the
outward load from the silos contents. The berm also protected the silos walls from weathering and served as
a radiation shield. This berm was expanded in 1983 to reduce soil erosion.

Other improvements to Silos 1 and 2 included: sealing the vents in the domes in 1979; installing plywood
covers on the domes in 1986; and adding a polyurethane coating in 1987 to reduce weathering and to help lower
radon emissions. This coincided with the installation of the radon treatment system (RTS), which was
designed to draw air from the silos, remove moisture and radon through a charcoal-adsorption process, and
recirculate clean air back into the silos. The RTS, which was upgraded in 1991, helped to lower radon
emissions to allow workers to apply a layer of bentonite clay (November 1991) over the K-65 residues within
the silos (K-65 Silo Removal Action No. 4).

The bentonite clay layer has reduced the amount of radon escaping from the silos into the environment and
would help prevent the release of contaminants into the air if a natural disaster (e.g., a tornado) should
occur or if the silo dome should collapse. An expedited removal action was conducted in December 1991 to
remove the Silo 3 dust collector after an inspection had revealed significant deterioration of the dust
collector (Removal Action No. 21). Also, in April 1991, a time-critical removal action was performed to
remove approximately 30,300 liters (8000 gallons) of liguid from the decant sump (Removal Action No. 5).

3.0 COMMUNITY PARTICIPATION

Various forums has been used to provide information to the community, including a periodic newsletter,
regular community meetings, and other availability sessions. Other activities included site tours, open
houses, a speakers bureau, and fact sheets about the Fernald site. Several readings rooms, which later were
consolidated into one facility near the Fernald site, were opened. This reading room contains information
about all aspects of the RI/FS at Fernald. In 1990, DOE established an "Administrative Record" for the site;
a copy of the Administrative Record also is maintained at the U.S. EPA's Region 5 offices in Chicago.

In November 1993, DOE implemented a public participation program at Fernald, in an attempt to involve
community members and other interested parties in the Fernald decision-making process. The public
involvement program at Fernald Consists of three elements:
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1. Public information
2. Management involvement
3. Person-to-person communication

These efforts, in concert with other community relations activities, such as publication of notices of
availability, which are required by law, reflect DOE's new initiative to offer opportunities for interested
parties to take part in the decision-making process at Fernald.

3.1 OPERABLE UNIT 4 PUBLIC INVOLVEMENT ACTIVITIES

To encourage stakeholders to review drafts of the Operable Unit 4 RI/FS documents, Notices of Availability
for public inspection were published in April 1993 for the Operable Unit 4 RI Report and in September 1993
for the FS/PP-DEIS in three local newspapers: the Cincinnati Enguirer, the Journal-News and The Harrison
Press. No public comments were received on the RI Report for Operable Unit 4.

On September 9, 1993, the FS/PP-DEIS were made available at the Public Environmental Information Center, and
stakeholders were encouraged to provide informal comments on the preliminary documents. Encouraging public
inspection and informal comment on these preliminary documents, prior to EPA approval, provided a genuine
opportunity for stakeholders to identify issues, voice their concerns and learn about proposed cleanup plans
for Operable Unit 4. The informal opportunity for the public to provide input enabled DOE to address some
stakeholder questions and concerns in advance of the formal public comment period.

On October 14, 1993, approximately 29 stakeholders attended a public roundtable on "Proposed Plans and
Technology for Operable Unit 4 Remediation." At the roundtable, attendees were invited to offer opinions on
the draft final Proposed Plan and the preferred alternative for Operable Unit 4 remediation. These
stakeholder comments were documented and evaluated during preparation of the final document.

In addition, a two-way information exchange on the Operable Unit 4 Risk Assessment occurred at the October
19, 1993, Science, Technology, the Environment and the Public (STEP) session on "Risk. Again, Fernald
personnel addressed the stakeholders' questions and concerns presented at the meeting. Information about the
Operable Unit 4 Remedial Investigation Report was also provided at DOE's October 21, 1993, RI/FS public
meeting and at local township trustee meetings.

In response to stakeholder requests at the January 5, 1994, formal public hearing on the Operable Unit 3
(Production Area) Interim Record of Decision, a public roundtable to discuss integration of CERCLA and NEPA
was held January 24, 1994. The roundtable included discussions on differences between environmental
assessments and environmental impact statements approximately 45 stakeholders attended.

On February 21, 1994, invitations to attend the March 21, 1994, formal public hearing on the FS/PP-DEIS were
mailed to 2,000 plus Fernald stakeholders. The Proposed Plan for Remedial Actions at Operable Unit 4 fact
sheet was enclosed with each invitation.

On February 24, 1994, advance copies of the Proposed Plan for Remedial Actions at Operable Unit 4 were mailed
to several key stakeholders. Also on February 24, copies of the final FS/PP-DEIS and Proposed Plan fact
sheets were mailed to the Nevada Operations Office and to Nevada environmental protection organizations. The
DOE Operable Unit 4 Branch Chief personally distributed several advance copies of the Proposed Plan to
attendees at the February 24, 1994, Fernald Residents for Environmental, Safety, and Health (FRESH) meeting.
In addition, she provided an update on Operable Unit 4 activities, plans and progress, and was available for
an informal question-and-answer session.

To encourage stakeholders to review and offer input on the final FS/PP-DEIS, a Notice of Availability for
formal public comment was published in March 1994 in the Federal Register and three local newspapers: the
Cincinnati Enquirer, the Journal-News and The Harrison Press. On March 1, 1994, the Proposed Plan,
FS/PP-DEIS became available at the Public Environmental Information Center.

On March 2, 1994, Ohio EPA representatives discussed the FS/PP-DEIS with members of the Fernald Citizens Task
Force and FRESH.
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On March 4, 1994, a Fernald site news release titled "Key Fernald Cleanup Plan Receives Conditional U.S. EPA
Approval" was sent to local electronic and print media, as well as local elected officials, FRESH and the
Fernald Citizens Task Force. Articles were published in local newspapers.

On March 7, 1994, the formal 45-day public comment period on the final FS/PP-DEIS officially began.

On March 8, 1994, Fernald representatives met formally with officials of the DOE Nevada Operation Office and
Nevada protection agencies.

On March 15, 1994, postcard reminders about the March 21, 1994, formal public hearing were mailed to Fernald
stakeholders. In addition, courtesy phone calls were made to key stakeholders, inviting them to the formal
public hearing.

Display advertisements announcing the March 21, 1994, formal public hearing were published in three local
newspapers: The Cincinnati Enguirer, March 18 and March 20; The Cincinnati Post, March 18; and the
Journal-News, March 18.

On March 21, 1994, approximately 80 people attended the formal public hearing on the Operable Unit 4
FS/PP-DEIS. Formal oral public comments were documented by a court reporter and are available in a
transcript at the Public Environmental Information Center. In addition, several stakeholders submitted
formal written comments. All formal written and oral stakeholder comments and guestions asked informally
during the March 21 public hearing, as well as DOE's responses, are documented in the Operable Unit 4
Responsiveness Summary.

The formal public comment period for the Operable Unit 4 FS/PP-DEIS was originally scheduled to conclude
April 20, 1994. However, the public comment period was extended 30 days, until May 20, 1994, in response to
a reguest for a 60 day extension by a Nevada State Clearinghouse representative.

The extension reguest was made on behalf of a group of concerned Nevadans, affected indian tribes and local
government officials, who, along with officials from the State of Nevada and DOE, jointly participated in the
establishment of a site-specific advisory board for the U.S. Department of Energy- Nevada Operations Office
(DOE-NV) Environmental Restoration and Waste Management Program at the Nevada Test Site (NTS). "The Citizens
Advisory Board for NTS Programs (CAB)" will play a key role in advising DOE-NV about stakeholder concerns
involving major program decisions at NTS, such as those proposed for Fernald's Operable Unit 4 waste. CAB's
first meeting was held March 8, 1994.

The National Contingency Plan, section 300.430(f) (3)(i) (C) states," ... Upon timely reguest, the lead
agency will extend the public comment period by a minimum of 30 additional days...." In accordance with the
Amended Consent Agreement (1991), DOE and U.S. EPA concurred with a 30-day extension of the formal public
comment period to minimize impact to the Operable Unit 4 schedule, yet still provide what DOE and EPA
considered adeguate time for stakeholder review. A Notice of Availability was published May 4 in The
Cincinnati Enguirer, the Journal-News and The Harrison Press.

On May 11, 1994, the DOE-NV conducted a public meeting in Las Vegas, Nevada. In attendance were members from
the DOE, EPA (Region V) , Ohio EPA, CAB and the public. This meeting was the first meeting of the
newly-organized CAB. As part of the meeting's agenda, the DOE conducted two presentations. One of the
presentations, furnished by the DOE-FN, discussed the Operable Unit 4 FS/PP-DEIS and summarized the proposal
to transport and dispose of low-level radioactive waste, which would be generated by the cleanup and
environmental restoration of the FEMP site as a whole (including Operable Unit 4), at the NTS. The other
presentation was furnished by the DOE-NV which summarized the current low-level radioactive waste management
program at the NTS. During the discussions following the presentation of the Operable Unit 4 FS/PP-DEIS, the
CAB reguested a second 3-day extension of the Operable Unit 4 formal public comment period. DOE and EPA
concurred with the second extension of the formal public comment period, which finally concluded June 19,
1994. A Notice of Availability regarding the second 3-day extension was published May 25, 1994, in The
Cincinnati Enguirer, the Journal-News and the Harrison Press.
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During the Operable Unit 4 formal public comment period, stakeholders expressed concern regarding public
participation opportunities and activities after the conclusion of the RI/FS Study process. In 1994, Records
of Decision will be completed for Operable Unit 4 and Operable Unit 1 (Waste Pits), and an Interim Record of
Decision will be completed for Operable Unit 3 (Production Area).

In 1994, Fernald's Commnnity Relations Plan, which guides public involvement activities, was revised with
input from stakeholders who participated in formal in-person and telephone "community assessment" interviews.
Fernald's Community Relations Plan is located in the RI/FS Work Plan, Volume III, which is available at the
Public Environmental Information Center, 10845 Hamilton-Cleves Highway, Harrison, Ohio (phone:
513-738-0164).

The community assessment interviews were conducted to ensure stakeholder participation in determining public
involvement activities and programs during Remedial Design and Remedial Action at Fernald. Fernald's first
community assessment was done in 1986, when Fernald's original Community Relations Plan was developed. In
1988, minor revisions were made to the Community Relations Plan and were reflected in the RI/FS Work Plan,
Volume III. In 1989, a second community assessment was conducted, and the Community Relations Plan was again
revised and approved in August 1990. In 1992, Fernald's Community Relations Plan was revised a fourth time;
however, no community assessment was conducted in 1992.

4.0 SCOPE AND ROLE OF REMEDIAL ACTION

The FEMP site and associated environmental issues have been segmented into five operable units. The operable
unit concept at the FEMP site involves grouping waste areas or related environmental concerns in a manner so
as to permit the more expedient completion of the RI/FS process. The five FEMP operable units are broadly
defined as:

! Operable Unit 1 - Waste Pit Area

! Operable Unit 2 - Other Waste Units

! Operable Unit 3 - Former Production Area

! Operable Unit 4 - Silos 1 through 4

! Operable Unit 5 - Environmental Media

Separate RI/FS documentation and RODs are being issued for Operable Units 1 through 5. A sixth operable unit
known as the Comprehensive Site-Wide Operable Unit was added as a provision of the Amended Consent Agreement.
Operable Unit 6 is not a specified area; however, it was created to perform a final assessment from a
site-wide perspective that ongoing or planned remedial actions identified in the RODs for the five operable
units will provide a comprehensive remedy for the FEMP site which is protective of human health and the
environment.

The primary focus of this remedial action is the permanent disposition of inventoried processing residues
contained in three concrete silos and an underground sump at the FEMP. The scope also includes the
disposition of contaminated building materials associated with the concrete silos and ancillary support
facilities. The action further involves the disposition of contaminated soils, process wastewater perched
water encountered within the Operable Unit 4 Study Area. The nature of the residues, coupled with their
potential threat of release from their present storage configuration and the potential threat of contaminant
migration from the affected soils into the atmosphere and the underlying aguifer system, represent a
potential threat to human health and the environment. The purpose of the remedial action is to prevent
current and future exposure to the inventoried residues, contaminated soil and debris within Operable Unit 4,
and remove the threat of release of hazardous substances into the environment.

Several removal actions are ongoing or have been completed within the Operable Unit 4 study area. These
removal actions are summarized as follows:
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! Installation of a bentonite clay layer over the K-65 residues in Silos 1 and 2.

! Removal and treatment of water from the K-65 decant sump tank at the FEMP advanced
wastewater treatment plant. Water within the tank is removed whenever the liquid level
in the sump reaches 80 percent of the tanks capacity.

! Removal of a deteriorated dust collector on the dome of Silo 3.

! Installation of a series of drainage control structures, swales, and culverts to direct
surface runoff to the existing in-ground sump.

In addition to the removal actions listed above, polyurethane foam insulation was applied to the exterior of
the dome surfaces of Silos 1 and 2 to inhibit wide temperature swings within the silos. These removal
actions have been conducted to respond to contaminant releases and to mitigate health and safety threats in
accordance with CERCLA. These actions have also been conducted in accordance with Council on Environmental
Quality regulations for implementing the provisions of NEPA.

Cleanup decisions for groundwater beneath the Operable Unit 4 Study Area, sediment in Paddys Run, and soil
and waste source areas outside the Operable Unit 4 Study Area are not included in the scope of this remedial
action. Separate RI/FS and other remediation documentation will be prepared for these facilities and media
by other FEMP operable units. These documents will be issued consistent with the terms of the Amended
Consent Agreement.

4.1 INTEGRATION OF NEPA INTO CERCLA

For Operable Unit 4 at the FEMP, DOE has chosen to complete an integrated CERCLA/NEPA process. This decision
was based on the longstanding interest on the part of local stakeholders to prepare an EIS on the restoration
activities at the FEMP and on the recognition that the draft document was issued and public comments
received. Therefore, an integrated Feasibility Study/Proposed Plan - Final Environmental Impact Statement
(FS/PP-FEIS) has been completed which evaluates alternatives for the treatment and disposal of radioactive
residues contained in storage silos at FEMP.

In accordance wth both CERCLA and NEPA processes, this documentation was made available to the public for
comment. The contents of the documents prepared for the remedial actions at the FEMP are not intended to
represent a statement on the legal applicability of NEPA to remedial actions conducted under CERCLA.

SUMMARY OF OPERABLE UNIT 4 CHARACTERISTICS

Several investigative studies were conducted to determine the characteristics of the contamination sources
and the nature and extent of contamination within Operable Unit 4. These investigative activities focused on
the following facilities and associated environmental media:

! Silos 1 and 2 and their contents (also termed the K-65 silos)

! Silo 3 and its contents (also termed the cold metal oxide silo)

! Silo 4

! K-65 decant sump tank, its contents, and associated piping

! A radon treatment system (RTS)

! A portion of a concrete pipe trench and other concrete structures

! An earthen berm surrounding Silos 1 and 2

! Soils beneath and immediately surrounding Silos 1, 2, 3, and 4
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groundwater encountered in the vicinity of the silos during implementation of
Operable Unit 4 cleanup activities. Note that groundwater within the Great Miami
Aguifer underlying the silo area is not within the scope of Operable Unit 4, but
it is within the scope of Operable Unit 5.
5.1 INVESTIGATIVE STUDIES
The Operable Unit 4 RI/FS sampling program was the primary source of the information utilized to characterize
contamination sources and to evaluate the nature and extent of contamination associated with Operable Unit 4.
Other investigative studies which provided characterization data for Operable Unit 4 include the Waste Pit
Area Runoff Control Removal Action, the FEMP Environmental Monitoring Program, and the Characterization
Investigation Study (CIS). Section 6 provides a list of the contaminants of concern which were identified
and used to determine baseline risks attributable to Operable Unit 4.

5.2 SUMMARY DESCRIPTION OF CONTAMINATION SOURCES

5.2.1 Classification of Contamination Sources

The residues in Silos 1, 2, and 3 are classified as by-product material as defined under the AEA of 1954, and
are therefore excluded from regulation as solid or hazardous waste under the Resource Conservation and
Recovery Act (RCRA), 40 CFR § 261.4(a)(4). By-product material, as defined by the AEA, includes tailings or
wastes produced as a result of the extraction or concentration of uranium (U) and thorium (Th) from any ore
processed primarily for its source material content (42 United States Code 2014).

Since the residues contained in the silos are excluded from regulation as solid or hazardous waste, the
reguirements under RCRA are not applicable to Operable Unit 4 remedial actions. However, analytical data for
the silo residues indicate that these materials exceed Toxicity Characteristic Leaching Procedure (TCLP)
limits for various metals, as defined under RCRA. The silo residues are therefore sufficiently similar to
hazardous waste regulated under RCRA resulting in some RCRA reguirements being appropriate for the conditions
of release or potential release of hazardous constituents during disposal. As a result of this, the relevant
and appropriate substantive reguirements of RCRA are being applied as part of the Operable Unit 4 remedy for
the silo residues.

5.2.2 Source Characteristics

Silos 1 and 2, known as the K-65 silos, contain approximately 6,796 m3 (8,890 yd3) of waste residues
generated from processing high-grade uranium ores. As part of the remedial investigation, samples were
collected from the contents of the silos. The waste materials within the silos are primarily a silty clay
with an average moisture content of approximately 40 percent. Analytical results from these samples
confirmed prior process knowledge and identified significant activity concentrations of radionuclides within
the uranium decay series.

The average Silo 1 concentration of radium (Ra)-226 is 391,000 pCi/g, thorium (Th)-230 is 60,000 pCi/g, lead
(Pb)-210 is 165,000 pCi/g and polonium (Po)-210 is 242,000 pCi/g. The average Silo 2 concentration of Ra-226
is 195,000 pCi/g, Th-230 is 48,300 pCi/g, Pb-210 is 145,000 pCi/g and Po-210 is 139,000 pCi/g. The two silos
contain in excess of 3,700 Curies of Ra-226, 600 Curies of Th-230, and 1,800 Curies of Pb-210. It is also
estimated that Silos 1 and 2 contain more than 28 metric tons of uranium.

Other significant metals include more than 118 metric tons of barium, 830 metric tons of lead, and 2.6 metric
tons of arsenic. TCLP tests indicate that the lead is leachable with leach test concentrations from Silo 1
averaging 614 milligrams per liter (mg/1) and leach test concentrations from Silo 2 averaging 516 mg/1. The
silos also contain elevated concentrations of the polychlorinated biphenyls (PCBs) Aroclor-1248 [1.2
milligrams per kilogram (mg/kg)], Aroclor-1257 (7.4 mg/kg), Aroclor-1260 (2.6 mg/kg), and tributylphosphate
(15 mg/kg).

Silos 1 and 2 are eguipped with a decant sump tank, which was first used to decant liguids from waste
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slurried into the silos. The system also served to collect silo leachate that entered the Silos 1 and 2
underdrain system. The tank is located beneath the silo berm, between Silos 1 and 2, at a depth
approximately 0.6 m (2 ft) below the base of the silos. The decant sump tank is connected to the berm
surface via a standpipe. In 1990, personnel noted 1.2 m (4 ft) of liquid in the standpipe. In 1991, and
again in February 1993, the desant sump tank was emptied and sampled. Analytical results of the decant sump
tank liquids are, in general, consistent with the contents of Silos 1 and 2.

The presence of significant quantities of liquid in the decant sump tank indicates that the system is
collecting leachate from the silo underdrain system, as it was designed to do. Excess quantities of liquid
in the decant sump tank, causing liquid to overflow into the standpipe, appear to provide a mechanism for
leachate from the silos to enter perched groundwater.

Structural evaluations completed in 1986 on Silos 1 and 2 identified a significant loss of the load- carrying
capability at the center portion of the domes on both structures. A protective barrier was placed over the
deteriorated central portions of the silo domes in 1986 to minimize potential environmental impacts in the
event of a catastrophic dome collapse. The remaining structures, Silos 3 and 4, like Silos 1 and 2, are
beyond their onginal design life and show visible signs of deterioration due to the effects of weathering.
However, based on the more recent February 1994 Silo Structural Integrity Report, the silos are considered to
be more structurally sound than previously reported in the 1986 study by Camargo. The extensive
non-destructive testing and computer analysis indicated that the silos are not in immediate danger of
collapse.

As a natural consequence of the decay of the Ra-226 present in the Silo 1 and 2 waste materials, a
radioactive gas, Rn-222, is generated. Samples collected in 1987 from the unfilled, upper portions of Silos
1 and 2 showed a maximum concentration of 30 million picocuries per liter (pCi/1). Average background
concentrations of Rn-222 in ambient air are approximately 0.5 pCi/1. In 1991, a layer of bentonite clay was
placed over the residues in Silos 1 and 2. This clay layer was insalled to reduce the release of ration gas
to the atmosphere. Samples collected following emplacement of the bentonite clay show a significant
reduction in the Rn-222 present in the headspace of the silos.

The inventory of radionuclides present in the K-65 residues significantly elevates the direct penetrating
radiation field in the vicinity of the silos. Measurements collected from the dome surfaces prior to the
installation of the bentonite clay layer showed exposure rates in excess of 200 millirem per hour, or
approximately 20,000 times natural background radiation levels. Measurements collected from the surfaces of
the domes following bentonite installation showed a greater than 95 percent decrease in the direct radiation
fields on the dome surfaces.

Silo 3 contains waste residues, known as cold metal oxides, which were generated at the FEMP site during
uranium extraction operations in the 1950s. The residues in Silo 3 are substantially different than those in
Silos 1 and 2. First, Silo 3 residues are dry, while the residues in Silos 1 and 2 are moist. Second, while
the radiological constituents are similar to those in Silos 1 and 2, certain radionuclides, such as radium,
are present in Silo 3 in much lower concentrations. Thus, Silo 3 exhibits a significantly lower direct
radiation field and radon emanation rate than Silos 1 and 2.

Samples collected from the contents of Silo 3 confirmed process knowledge and indicated the presence of
significant activity concentrations of the radionuclides within the uranium decay series. The predominant
constituent identified within Silo 3 was Th-230, a radionuclide produced from the natural radioactive decay
of U-238. Distributed within the 3,890 m3 (5,088 yd3) of waste residues inside Silo 3 is approximately 450
Curies of Th-230. Extraction Procedure (EP) Toxicity tests performed on samples of the Silo 3 residues to
determine the leachability of inorganic substances present detected eight metals, with the highest mean
concentrations being attributed to arsenic (9.48 mg/1), cadmium (0.85 mg/1), chromium (5.05 mg/1), and
selenium (2.65 mg/1).

5.3 NATURE AND EXTENT OF CONTAMINATION

Investigations were performed as part of the RI and other site programs to examine the nature and extent of
contamination present in environmental media associated with Operable Unit 4. These investigations included
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the collection and laboratory analysis of samples and the collection of direct field measurements. The
investigations included examination of surface and subsurface soil, surface water and sediment, and
groundwater.

5.3.1 Surface Soils

Sampling performed as part of the RI/FS and other site programs in the vicinity of Operable Unit 4 indicates
the occurrence of above background concentrations of uranium, and to a lesser degree other radionuclides, in
the surface soils within and adjacent to the Operable Unit 4 Study Area. Activity concentrations observed
during the RI for the surface soils in the vicinity of Operable Unit 4 were as much as 20.8 picocuries per
gram (pCi/g) for U-238, or 16 times natural background, and 4.8 pCi/g for Th-230, or two times background.
These above background concentrations appear to be generally limited to the upper six inches of soil.

Of the inorganic constituents detected in the Operable Unit 4 surface soils, antimony, beryllium, chromium,
copper, magnesium, nickel, silver, and sodium were consistently above background. The only volatile organic
compounds detected consisted of common laboratory contaminants. With the exception of one sample collected
at a depth of 0.5 to 0.6 m (1.5 to 2.0 ft), which contained elevated concentrations of a number of
semivolatile organic compounds including benzo(a)pyrene, semivolatile organic compounds were at or only
slightly above the contract reguired guantitation limit for the laboratory. Available sample data and
process knowledge indicate no direct relationship between the surface soil contamination in the Operable Unit
4 Study Area and the silo contents. Further, more than 70 percent of the surface soil samples indicate that
the uranium contamination in surface soils is depleted uranium (i.e., the urmium contains depleted
percentages of U-235). The silo residues consist of natural uranium. Thus, the existence of these activity
concentrations in the surface soils is attributed to air deposition resulting from the form Production Area
and past plant production operations and/or waste handling practices in the waste pit area.

Soil samples were collected from the soils contained in the earthen embankment (berm) surrounding Silos 1 and
2. The highest concentrations of radionuclide constituents were detected in a sample taken at a location 9 m
(30 ft) below the berm surface, near the base of Silo 1. This sample indicates the occcurrence of either
some spillage of silo residues during filling operations or seepage from the silo onto the original surface
soils adjacent to the silo at that location. Analytical results from other berm samples showed the presence
of radionuclides at relatively lower concentrations, with the majority of samples showing concentrations near
background.

The concentration ranges for those constituents in relatively higher concentrations are 0.62 to 417 pCi/g for
Pb-210; 1.03 to 943 for polonium (Po)-210; 0.62 to 876 pCi/g for Ra-226; 0.74 to 51.2 pCi/g for Th-230; and
0.75 to 24.7 pCi/g for U-238. Inorganic constituents detected consisted mostly of metals in concentrations
close to background concentrations. There were also some organic constituents reported. Most of these
constituents are common laboratory contaminants and do not demonstrate any direct linkage to the silo
contents.

5.3.2 Subsurface Soils

As part of the RI for Operable Unit 4, samples were collected from the subsurface soils located under and
adjacent to the K-65 silos. Analytical results reveal elevated concentrations of radionuclides from the
uranium decay series in the soils at the interface between the berm and the original ground level. Elevated
concentrations (up to 53 pCi/g for U-238, about 40 times background) were also noted in slant boreholes,
which passed in close proximity to the silo underdrains. The occurrence of these above background
concentrations in soils near the silo underdrains are attributed to vertical migration of leakage from the
silo underdrains or decanting system. Elevated readings at the interface between the silo berms and the
native soils may be attributed to historical air deposition or past spillage from the silos during filling
operations in the 1950s, prior to installation of the berms.

5.3.3 Surface Water and Sediment

Extensive sampling was conducted on the sediment and surface water present in Paddys Run and on key drainage
swales leading to Paddys Run, as part of the RI for Operable Unit 4 and other site programs. Results of the
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surface water sampling indicate the occurrence of above background concentrations of U-238, up to 1500 times
background, in the drainage swales in the vicinity of the Silos 1 through 4. The highest readings were
recorded in a drainage ditch, which flows from east to west, located approximately 76 m (250 ft) south of
Silo 1. The most probable source of the contamination in Paddys Run and the drainage swales is the
resuspension of contaminated particles from surface soils within the Operable Unit 4 and Operable Unit 1
Study Areas into stone water.

5.3.4 Groundwater

Groundwater samples were collected from wells within the Operable Unit 4 Study Area during the RI for
Operable Unit 4. Groundwater occurs not only in the Great Miami Aguifer underlying the FEMP site, but also
in discrete zones of fine-grained sands located in the glacial overburden. The water contained in these sand
packets in the clay-rich glacial soils are termed perched water zones. Samples were collected from slant
borings placed adjacent to and under Silos 1 and 2; 1000-series wells screened in the glacial overburden;
2000 series wells screened at the water table in the Great Miami Aguifer; and 3000-series wells screened at
approximately the central part of the Great Miami Aguifer, just above the clay interbed.

Background concentrations of naturally occurring inorganics and radionuclides in groundwater in the vicinity
of FEMP site were being established under the site-wide RI/FS during the completion of the RI for Operable
Unit 4. In accordance with background data available at the time, background concentration of total uranium
in groundwater of less than 3 micrograms per liter (yg/1) or 3 parts per billion (ppb) was utilized.

Perched Water
Uranium was the major radionuclide contaminant found in the perched water. Elevated concentrations of total
uranium were detected in the slant boreholes under and around Silos 1 and 2. Slant Boring 1617, immediately
southwest of Silo 1, contained the highest concentration of total uranium (9,240 yg/1). Uranium
concentrations were also elevated in samples collected from the 1000-series wells. The highest observed
total uranium concentrations obtained from 1000-series wells were in samples collected from Well No. 1032,
located 46 m (150 ft) due west of Silo 2. The range of the concentrations was 196 to 276 yg/1. Considering
both the slant borings and 1000-series wells, U-238 was found in the range of 1.1 to 1313 pCi/1.

The major inorganic constituents found in the perched water samples taken from 1000-series wells and the
slant borings, included elevated concentrations for major cations (iron, magnesium, manganese, and sodium)
and major anions (chloride, nitrate, and sulfate). In particular, the concentrations of sodium, sulfate, and
nitrate were significantly above background in slant boring samples. Boring 1615, northwest of Silo 2, had
the highest sodium concentration(1,040 mg/1), boring 1618, southeast of Silo 1, had the highest sulfate
concentration 2,200 mg/1), and boring 1617 had the highest nitrate concentration (554 mg/1). Low levels of
organic constituents, determined to be contaminants, were detected in some samples. Overall, well
measurements and analytical results confirmed that the perched groundwater in the vicinity of Operable Unit 4
flows from west to east. Further, contaminants within Operable Unit 4 are contributing to contamination of
perched groundwater in this region of the site.

Great Miami Aguifer
The concentration of total uranium in the upper portion of the Great Miami Aguifer, based on analysis of
samples from the 2000-series wells, ranged from less than 1 yg/1 to 40.3 yg/1. These data do not
necessarily suggest that the silos are the source of the observed contamination because both upgradient and
downgradient wells contain above background concentrations of total uranium. Well No. 2032, located 46 m
(150 ft) west of Silos 1 and 2, exhibited a concentration of total uranium at 39.0 y.g/1. Well No. 2033,
located 46 m (150 ft) east of Silos 1 and 2, exhibited a concentration of total uranium at 40.3 yg/1.
Because groundwater flow in this region of the Great Miami Aguifer is from west to east, these two wells are
located upgradient and downgradient of Operable Unit 4, respectively.

The isotopic ratio of U-234 and U-238 would suggest a natural uranium ratio in these samples. Such a ratio
may be expected from Operable Unit 4, but is not a "fingerprint" for this source. The presence of uranium
upgradient in the aguifer from an Operable Unit 4 source could be explained by leachate travel in the perched
groundwater zone of the glacial overburden with emergence to Paddys Run. Here the diluted leachate could
enter the aguifer via stream bed infiltration or flow at the perched zone/stream channel interface. No
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evidence is available to support or preclude this potential route.

The concentration of total uranium measured at deeper levels in the Great Miami Aquifer (3000-series wells)
ranged from less than 1 to 4 jlg/1, with the exception of 1 sample out of 16, which contained 15 jlg/1. Like
the 2000-series wells, no conclusion could be drawn that linked this contamination to the silos.

5.4 POTENTIAL EXPOSURE PATHWAYS FOR CONTAMINANT MIGRATION

Contaminant transport from Operable Unit 4 may occur via the following pathways:

! Direct radiation

• Direct exposure to gamma radiation from radioactive constituents within the
silos.

• Direct exposure to Silo 3 residues under the future source term scenario assuming
structural collapse of the silo.

• Direct exposure to gamma radiation from radioactive constituents in surface soil.

! Air emissions

• Dispersion of radon that escapes from the silos into the atmosphere.

• Dispersion of volatile organic compounds (VOC) or fugitive dust emissions
generated from soil erosion.

• Dispersion of Silo 3 contents under the future source term scenario assuming
structural collapse of the silo.

! Surface water runoff

• Erosion of contaminated soils into Paddys Run from the vicinity of the silos.

• Erosion of released Silo 3 contents under the future source term scenario
assuming structural collapse of the silo.

! Groundwater transport

• Leaching of contaminants from the silo contents via soils to underlying
groundwater.

Each of these potential contaminant transport pathways is discussed below. The summary of the baseline risk
assessment presented in Section 6 provides additional information about the impacts on environmental media or
human receptors.

5.4.1 Direct Radiation

Gamma radiation from the K-65 residues and surface soils are transported as electromagnetic radiation, thus
requiring no transport mechanism. As the distance from the K-65 silos and the surface soil source;
increases, the magnitude of the radiation's intensity decreases. The soil berms around Silos 1 and 2 provide
shielding to potential receptors from the direct gamma radiation associated with the K-65 residues. The
bentonite clay layer covering the silo residues decreases the diffusion of radon into the silo headspace.
Radon progeny are gamma-emitters that contribute significantly to direct radiation exposure. Therefore, as
long as the integrity of the berms, the bentonite clay liner, and silos is maintained, there should be no
change or increase in direct radiation exposure due to this pathway.
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5.4.2 Air Emissions

Rn-222 generated by the radioactive decay of Ra-226 in the K-65 and metal oxide residues accumulates in the
void headspace inside the silos. At the time of their design, the four silos were not reguired to be
airtight; therefore, air exchanges with the outside environment occur. The air exchange is a result of
changes in ambient temperatures that cause expansion and contraction of the air mass inside the silos. The
foam installed on top of Silos 1 and 2 in 1987 has reduced the K-65 silo breathing losses by limiting daily
temperature variations inside the silo dome. In addition to direct release to the atmosphere, radon gas can
also diffuse through the K-65 silo walls into the surrounding soil berms. Radon has a short half-life (3.82
days) and is expected to decay into its progeny, Pb-210 and Po-210, in the silo walls and in the soil berms
surrounding Silos 1 and 2. These are nonvolatile constituents that accumulate in the soil berms. These
progeny could be transported via resuspension if the berms are eroded to a point where this area is exposed.

Contaminated soil particulates can also be resuspended into the air from the surface of the K-65 berms and
the surrounding Operable Unit 4 soils and transported by winds to other locations.

5.4.3 Surface Water Runoff

Contaminants in the surface soils can be transported away from Operable Unit 4 through surface soil erosion
caused by surface water runoff. If the existing runoff control structures (i.e., trench drains and curb and
gutters) at the perimeter of Operable Unit 4 were to fail, this would permit storm water runoff to directly
enter Paddys Run. Contaminants contained in near surface soils which are subject to erosion can be
transported to Paddys Run by either dissolving in the runoff surface water or attaching to entrained sediment
carried by the water. A portion of these contaminants will partition (i.e., separate) into stream sediment
and will not be available for immediate transport to the aguifer. Contaminants in the dissolved phase could
be transported to the Great Miami Aguifer by recharge from Paddys Run throughout the length of Paddys Run
from Operable Unit 4 to the Great Miami River.

5.4.4 Groundwater Transport

The final potential transport route is via groundwater. Contamination may be transported through the vadose
zone into the Great Miami Aguifer in the vicinity of Operable Unit 4 by traveling through the glacial
overburden present beneath the silos. A conceptual model of potential contaminant transport from the bottom
of the silos to the Great Miami Aguifer has been developed. This model is based on the current understanding
of the Operable Unit 4 Study Area and data from past investigations and is listed below:

! Leachate derived from Silos 1 and 2 is formed under the current storage
configuration of the silos from liguids used to slurry waste materials into the
silos. Additional leachate may be formed based on the assumption that
precipitation infiltrates the silos through the silo top and sidewalls and
interacts with the wastes within. This leachate may pass through the wastes, out
the bottom of the silo, and enter the glacial overburden.

! Perched groundwater in the vicinity of Operable Unit 4 flows to the west, toward
Paddys Run. Thus, once out of the silo, leachate may migrate through the glacial
overburden toward the west, until it reaches Paddys Run, or in a vertical
direction until it reaches the Great Miami Aguifer.

! Once in Paddys Run or the Great Miami Aguifer, the contamination can be
transported rough surface water or groundwater to either on-property or off-site
receptors.

6.0 BASELINE RISK ASSESSMENT

Baseline risk assessments were performed to determine the potential human health effects and ecological risks
which could result from exposure to contaminants currently present in Operable Unit 4.
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The baseline assessment of human health risks quantified the health risks to hypothetical human receptors due
to exposure from chemical sources in Operable Unit 4 under the no-action alternative. The process analyzed
the human health consequences that could occur under different scenarios if no remedial actions were taken to
address identified environmental concerns. This process utilized a structured, sequential analytical process
that:

! Identified the specific Constituents of Concern (COCs) for Operable Unit 4.

! Assessed contaminant transport from the sources to potential exposure points.

! Quantified potential exposures to receptors under current and future land use
scenarios.

! Characterized the potential baseline risks associated with Operable Unit 4 under
current and potential future land use scenarios.

Appendix D and Section 6.0 of the RI Report for Operable Unit 4 provide detailed information on the baseline
assessment of human health risks.

Site-wide baseline ecoloqical risks were evaluated and included in the Site-Wide Characterization Report (DOE
1993b). An overview of that discussion is included in Section 6.2 of this ROD. The purpose was to conduct a
qualitative assessment of the potential current and future risks posed by FEMP site contaminants to
ecoloqical receptors (e.g., plants and animals) if no remediation is implemented, thus, serving as a baseline
for all future assessments. The Amended Consent Aqreement between EPA and DOE stipulates that Operable Unit
5 is responsible for the preparation of the Site-Wide Ecoloqical Risk Assessment as part of the RI and FS
Reports for Operable Unit 5.

6.1 SUMMARY OF THE BASELINE ASSESSMENT OF RISKS TO HUMAN HEALTH

6.1.1 Constituents of Concern

The COCs for human health and their ranqes of concentration in effected Operable Unit 4 media are provided in
Table 6-1. COCs were detected in Silos 1, 2, and 3, the surroundinq surface soil and subsurface soil, and
the silo berm soils. Baseline risk assessment source term concentrations were determined for the COCs in
these media. Fate and transport modelinq was then conducted to estimate the exposure point concentrations of
contaminants in environmental media (e.g., groundwater, air, and surface water). Contaminants with the
potential of posinq risk to human health include radionuclides, metals, inorqanic anions, polyaromatic
hydrocarbons (PAHs), and pesticides/polychlorinated biphenyls (PCBs). The selection of COCs was based on the
evaluation of characterization data with respect to the distribution on contaminants in various media and the
potential contribution of these contaminants to the overall human health effects. Appendix E of the RI
Report for Operable Unit 4 provides full details of the process for selectinq COCs.

6.1.2 Exposure Assessment

The exposure assessment and baseline risk assessment follow the methodoloqy described in the Risk Assessment
Work Plan Addendum (DOE 1992), with the exception of those items identified in Section D.1.0 of Appendix D of
the RI Report for Operable Unit 4 (DOE 1993a). Baseline risks were calculated under a number of contaminant
release mechanisms providinq exposure to hypothetical receptors under three separate land use scenarios.
Baseline risks under these land use scenarios were calculated for a current source term and a future source
term. The concentrations of contaminants found in the contents of Silos 1, 2, and 3, the surroundinq surface
soil, the silo berm soil, and subsurface soil within the Operable Unit 4 Study Area were used to determine
the source term concentrations used in each exposure scenario.

Land use scenarios include: (1) current land use without access controls, (2) current land use with access
controls, and (3) future land use without access controls. Under the first scenario, the FEMP site is
assumed to be manaqed by an industrial concern other than DOE. Access restrictions currency provided by DOE
are assumed to be discontinued. In addition, no remedial actions are assumed to have been taken, and no
-------
members of the public establish residence within the boundaries of Operable Unit 4. Thus, potential
receptors include an off-property resident farmer, a trespassing child, an on-property worker
(groundskeeper), and an off-property user of surface water from the Great Miami River.
-------
TABLE 6-1 CONSTITUENTS OF CONCERN FOR OPERABLE UNIT 4

Range of Detection for Chemicals (mg/kg)

2-Butanone
2-Hexanone
2-Nitrophenol
4,4'-DDE
4,4'-DDT
4-Methyl-2-pentanone
4-Nitrophenol
Acenaphthylene
Acetone
Aldrin
Ammonia
Anthracene
Antimony
Aroclor-1248
Aroclor-1254
Aroclor-1260
Arsenic
Barium
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzoic Acid
Beryllium
Bis(2-ethylhexyl)phthalate
Boron
Cadmium
Carbon tetrachloride
Chromium
Chrysene
Cobalt
Copper
Cyanide
Di-n-butyl phthalate
Di-n-octyl phthalate
Dieldrin
Diethyl phthalate
Dimethyl phthalate
Endosulfan-II
Endosulfan-I
Silo 1 & 2
0.002-0.022
0.002-0.017

0.029-0.120
0.014-0.068
0.002-0.003
0.033-0.150
0.056a
1.100-8.90

13.300-77.4
1.700-10.0
0.420-20.0
0.340-3.50
3.100-1960
89.20-22100
0.075-0.390
0.590-6.00
0.070-6.00
18.400-81.20
0.560-19-1
0.170a
0.207-165

6.20-2430
122-1790
0.520-7.10
0.046-0.057
0.045-0.970
0.093a
0.410a
0.068-0.160
0.082-0.260
0.011-0.092
Silo 3
.052a
.045a
Surface Soil
0.002-0.008
Berm Soil
O.Olla
532-6380
118.000-332.000
10.000-39.900

21.500-204.000

139-560

1100-3520
1610-7060
1.30a
0.004-0.079
0.780a
22.60-32.30
2.70-9.50
44.7-113.0
0.062-4.70
5.20a
0.150-9.70
5.30a
0.059a
0.670-1.00
0.075-1.60

4.70-6.20

10.20-22.60
0.062-3.50

16.200-23.50
0.120a
0.190a
0.064a
19.100-24.900
5.000-8.000
47.100-89.400
0.670-0.850

2.600-4.200

16.400-28.400
19.300-23.800
0.120a
0.048a
-------
Table 6-1
(continued)
Range of Detection for Chemicals (mg/kg)

Endrin
Fluoranthene
Fluoride
Heptachlor epoxide
Indeno(1,2,3-cd)pyrene
Lead
Manganese
Mercury
Methylene chloride
Molybdenum
N-nitroso-di-n-propylamine
Nickel
Nitrate
Phenanthrene
Phenol
Phosphorus
Pyrene
Selenium
Silver
Tetrachlorethene
Thallium
Toluene
Total xylenes
Tributyl Phorphate
Uranium
Vanadium
Zinc
Silo 1 & 2
0.089a
0.064a
15.0-394
0.022-0.20

153-299000

0.150-2.80
0.015-0.190
148-8600
0.059-0.260
14.60-3380
2216-8900

0.40a
0.40-3290
0.047a
49.60-2810
5.0-34.9
0.140a
0.090-5.700
0.002-0.190
0.003a
0.200-73.00
137.0-8394.0
21.90-535.00
7.70-212.00
Silo 3
646-4430
2420-6500
0.300-0.690
1760-6170
101.000-349.000
9.200-23.800

4.000-73.900
738.0-4554.0
418-4550
301-672
Surface Soil
0.040-6.70
4.20a
0.025a
3.60-4.90

22.8-38.9

2.60a
0.230a

0.045-8.20

6.60-9.70

O.SlOa
O.OOla
4.0-64.0
15.9-27.7
32.9-65.2
Berm Soil
2.400-13.300

21.700-32.400

O.llOa

5.880-14.400

0.710a
0.002-0.200
0.069a

10.50-12.40
24.600-28.400
44.200-59.600
-------
Table 6-1
(continued)
Range of Detection for Radionuclides (pCi/g)

Actinium-227
Cesium-137
Lead-210
Polonium-210
Protactinium-231
Radium-224
Radium-226
Radium-228
Strontium-90
Technetium-99
Thorium-228
Thorium-230
Thorium-232
Uranium-234
Uranium-235/236
Uranium-238
Silo 1 & 2
2905.0-17390

48980.0-399200
55300-43400
4041a

657.0-890700
411.0-7360
8365.0-132800
661.0-1106
89.0-1548
19.1-172
46.0-1925
Silo 3

234.0-1363

454.0-6427

266.0-931
64.00-453.00
467.0-6435
82.0-559
459.0-966
21010.0-71650
411.0-1451
348.0-1935
42.0-158
320.0-2043
Surface Soil
0.6-2.3
0.5-1.7
0.8-1.8
1.2-3.6
0.9-1.4
1.4-4.8
0.9-1.7
2.4-6.9

2.4-20.£
Bern Soil
0.23a
0.98-4.45
1.68-4.70

1.020a
1.04-6.6E
0.8-0.9E
1.12-1.52
1.69-4.78
0.86-1.45
1.26-3.62

1.13-4.19
a -only one sample was found to be above the detection limit.
-------
Under the second scenario, the site access restrictions historically provided by DOE are assumed to be
maintained, and no remedial actions are assumed to have been taken. The scenario further assumes that no
members of the public have established residence in the Operable Unit 4 Study Area, and that DOE maintains a
site-specific health and safety program to ensure that non-remediation workers and visitors are properly
protected. Therefore, the risk assessment addresses workers subjected to short exposure durations under
controlled conditions. These controls include engineered emission control equipment, personnel protective
equipment, and administrative health and safety practices. Potential receptors under this scenario include
an off-property resident farmer, a trespassing child, and an off-property user of surface water from the
Great Miami River.

The third land-use scenario, future land use without access controls, includes exposure routes that require
development time, such as establishing a home and farm within Operable Unit 4. Access controls are assumed
to be absent and no remedial actions are assumed to have been taken. In addition, members of the public are
assumed to have established a residence within the Operable Unit 4 boundaries. Hypothetical receptors under
this scenario are a reasonable maximum exposure (RME) on-property resident farmer, a central tendency (CI)
on-property resident farmer, an go-property resident child, an off-property resident farmer, and an
off-property user of surface water from the Great Miami River.

In addition to the three land use scenarios, there are two source term scenarios: the current source- term
scenario and the future source term scenario. The current source term scenario considers the silos as they
exist today. The future source term scenario considers complete structural failure of Silo 3, resulting in
the spread of its contents to Operable Unit 4 surface soil, and dome collapse for Silos 1 and 2, consequently
exposing their contents to the elements and increasing leaching of the contents through the interception of
rainwater.

Under the current land use scenario without access control and the future land use scenario, risks are
calculated using both the current source term and the future source term. Under the current land use with
access control scenario, the future source term does not apply; if the site remains under the institutional
control of DOE, the assumption is made that measures would be undertaken to maintain the current
configuration of the silos and implement mitigative action in the event of silo failure. Thus, under the
current land use with access control scenario, risk was calculated only for the current source term.

The on-property resident farmer receptor was also evaluated using exposure and intake parameters such as
exposure duration, which represents the CT of risk. This was performed in response to new guidance from EPA,
which suggests that all risk assessments provide an evaluation of the CT of the risk range, using the best
information available to describe the average situation (EPA 1992a). This scenario is used to provide an
estimate of risk closer to average for the resident adult scenario. This receptor scenario is currently
being developed by EPA and will require additional review as guidance becomes available. The CT receptor for
this scenario is located at the same location as the RME on-property resident farmer receptor. Table 6-2
provides a summary of the land use/source term/receptor scenarios used for the Baseline Risk Assessment.

Exposure pathways quantified in the risk assessment for each scenario are shown in Figures 6-1 and 6-2 and
are discussed in greater detail in Appendix D of the RI Report for Operable Unit 4. A summary of exposure
pathways that have the most impact to site risks is presented in Section 6.1.4. The conceptual model
depicted in Figures 6-1 and 6-2 indicates which exposure routes are quantitatively evaluated in the risk
assessment for each receptor and land use scenario, and the basis for excluding other exposure routes.
Exposures to the RME resident farmer due to the ingestion of groundwater consider two scenarios, which
include water obtained from the Great Miami Aquifer and water obtained from perches water beneath and west of
Silos 1 and 2.

Section 5.0 and Appentix E of the RI Report for Operable Unit 4 address in detail all fate and transport
modeling efforts employed in the determination of exposure point concentrations of the COCs. Appendix D of
the RI Report for Operable Unit 4 discusses the assumptions regarding source term and potential release
mechanisms upon which the fate and transport modeling is based.

6.1.3 Toxicity Assessment
-------
The human health hazards identified in the toxicity assessment are cancer induction and chemical toxicity.
Chemical toxicity includes numerous health effects such as kidney damage, liver disease, or eye irritation.
For both types of health hazards, dose-response data from human and animal studies are used to determine the
potency of the individual radionuclides and chemicals.

Intakes calculated in the exposure assessment are used in conjunction with the cancer slope factor from the
dose-response data to determine the incremental lifetime cancer risk (ILCR). Toxicity data for the Operable
Unit 4 risk assessment were taken from the Integrated Risk Information System
-------
TABLE 6-2

SUMMARY OF LAND-USE/RECEPTOR/SOURCE TERM SCENARIOS
RECEPTORS
LAND USE
CURRENT SOURCE TERM
FUTURE SOURCE
Current Land Use Without Access Control
Current Land Use With Access Control
Future Land Use
Off-Property Farmer, Trespassing Child,
Groundskeeper Worker, Off-Property User
of Surface Water from the Great Miami
River

Off-Property Farmer, Trespassing Child,
Off-Property User of Surface Water

RME On-Property Resident Farmer, CT
On-Property Resident Farmer, On Property
Resident Child, Off-Property Farmer, Off-
Property User of Surface Water from the
Great Miami River
Notes: N/A
RME
CT

Not Applicable
Reasonable Maximum Exposure
Central Tendency
Off-Property Farmer, Trespassing Child,
Groundskeeper Worker, Off-Property User
of Surface Water from the Great Miami
River

N/A
RME On-Property Resident Farmer, CT
On-Property Resident Farmer, On Property
Resident Child, Off-Property Farmer, Off-
Property User of Surface Water from the
Great Miami River
-------
(IRIS, EPA 1992a) and the updated Health Effects Assessment Summary Table (HEAST, EPA 1992b). Cancer slope
factors have been developed by the EPA for estimating ILCRs associated with exposure to carcinogenic
chemicals. The slope factors, which are expressed in units of milligrams per kilograms-day (mg/kg-day)-1,
are multiplied by the estimated intake of a carcinogen, in mg/kg-day, to provide an upper bound estimate of
the ILCR associated with exposure at that intake level. The term "upper-bound" reflects the conservative
estimate of the risks calculated from the slope factor. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. Cancer slope factors are derived from the results of human
epidemiological studies, or chronic animal bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied. Tables 6-3 and 6-4 provide the cancer slope factors for Operable Unit 4 chemical
COCs and radiological COCs respectively.

For cancer induction, it is assumed that no dose threshold exists. Therefore, for any dose of a carcinogen,
there exists a possibility, however small, of contracting cancer. Incremental lifetime cancer risks are
expressed in terms of the probability that a given receptor (person) will contract cancer due to the
calculated exposures. For example, if the receptor has an additional 1 chance in 10,000 of contracting
cancer due to the calculated exposures, the probability of developing cancer is expressed as a 10-4 (1 in
10,000) risk. However, these risk factors should only be used to make a gualitative estimate of individual
receptor impact, because the risk coefficients are intended for predicting cancer in a large population.

For chemical toxicants, the data suggests a dose threshold or reference dose (RfD) exists below which no
toxic effect is observed. RfDs have been developed by the EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting non-carcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels for humans, including sensitive
individuals. Estimated intakes of chemicals from environmental media (e.g., the amount of a chemical
ingested from contaminated drinking water) can be compared to the RfD). RfDs are derived from human
epidemiological studies or animal studies to which uncertainty factors have been applied (e.g., to account
for the use of animal data to predict effects on humans). These uncertainty factors help ensure that the
RfDs will not underestimate the potential for adverse non-carcinogenic effects to occur. Table 6-5 provides
the RfDs for Operable Unit 4 COCs.

To determine if the exposure levels of Operable Unit 4 constituents may cause adverse health effects, the
estimated intake of a particular constituent (calculated from the exposure assessment) is compared to the
RfD, which, defines the acceptable intake. If the ratio of estimated intake to the acceptable intake is
greater than one, the site-related intake may cause toxic effects. This ratio is called the Hazard Quotient
(HQ). When HQs for multiple COCs are summed, the resultant value is the Hazard Index (HI).
-------
TABLE 6-3

CANCER SLOPE FACTORS FOR CARCINOGENIC EFFECTS OF CONSTITUENTS OF CONCERN
FOR OPERABLE UNIT 4
Tumor Site
Chemical

Inorganics

Ammonia
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium (food)
Cadmium (water)
Chromium (VI)
Cobalt
Copper
Cyanide
Fluoride
Lead
Manganese
Mercury
Molybdenum

Nickel

Nitrate
Phosphorus

Selenium
Silver
Thallium compounds
Oral Cancer Slope Facter
(mg/kg/day)-1
NDc
ND
1.75
ND
4.3
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND
Inhalation Cancer Slope
Factor (mg/kg/day) -la
ND
ND
15
ND
8.4
ND
6.3
6.3
42
ND
ND
ND
ND
ND
ND
ND
ND

0.84

ND
ND

ND
ND
ND
Oral
Inhalation
Cancer
Classification ab
ND
ND
skin
ND
gross tumors
ND
ND
ND
ND
ND
ND
ND
ND
kidney
ND
ND
ND
ND
ND
respiretory tract
ND
lung
ND
respiratory tract
respiratory tract
lung
ND
ND
ND
ND
ND
ND
ND
ND
ND
D
A
D
B2
ND
Bl
Bl
A
ND
D
D
ND
B2
D
D
D
ND

ND
ND

ND
ND
ND
respiratory tract

ND
ND

ND
ND
ND
A

ND
D

D
D
ND
Reference
ND
d
e
d
e
ND
e
e
e
ND
e
e
ND
e
e
e
d
ND
e

e
e
e
-------
TABLE 6-3
(Continued)

Tumor Site
Chemical

Uranium
Vanadium
Zinc
Oral Cancer Slope Facter
(mg/kg/day) -1

ND
ND
ND
Inhalation Cancer Slope
Factor (mg/kg/day) -la

ND
ND
ND
Oral

ND
ND
ND
Inhalation

ND
ND
ND
Cancer
Classification ab

ND
ND
D
Reference

f
d
e
Volatiles

2-Butanone
2-Hexanone
4-Metyl-2-pentanone
Acetone
Carbon tetrachloride
Methylene chloride
Tetrachloroethene
Toluene
Total xylenes

Semivolatiles
ND
ND
ND
ND
0.13
0.0075
0.052
ND
ND
ND
ND
ND
ND
0.053
0.0016
0.002
ND
ND
ND
ND
ND
ND
liver
liver
lung
ND
ND
ND
ND
ND
ND
ND
lung, liver
lung
ND
ND
D
ND
ND
D
B2
B2
B2-C
D
D
e
ND
ND
e
e
e
g
e
e
Acenaphthylene ND
Aldrin 17
Anthracene ND
Benzo(a)anthracene 7.3
Benzo(a)pyrene 7.3
Benzo(b)fluoranthene 7.3
Benzo(g,h,i)perylene ND
Benzoic acid ND
bis(2-Ethylhexyl)phthalate 0.014
Chrysene 7.3
Di-n-butylphthalate ND
ND
17
ND
6.1
6.1
6.1
ND
ND
ND
6.1
ND
ND
liver
ND
ND
stomach
ND
ND
ND
liver
lymphoma, skin
ND
ND
ND
ND
ND
respiratory tract
ND
ND
ND
ND
ND
ND
D
B2
D
B2
B2
B2
D
D
B2
B2
D
e
e
e
h
e,g
h
e
e
e
h
e
-------
TABLE 6-3
(Continued)
Tumor Site
Chemical
Oral Cancer Slope Facter
(mg/kg/day) -1
Di-n-octylphthalate ND
Dibenzo(a,h)anthracene 7.3
Diethyl phthalate ND
Dimethyl phthalate ND
Fluoranthene ND
Indeno(1,2,3-cd)pyrene 7.3
2-Nitrophenol ND
4-Nitrophenol ND
N-Nitroso-di-n-propylamine 7
Phenanthrene ND
Phenol ND
Pyrene ND
Tributyl phosphate ND

Pesticides/PCBs

Aroclor-1248 7.7
Aroclor-1254 7.7
Aroclor-1260 7.7
4,4'-DDE 0.34
4,4'-DDT 0.34
Dieldrin 16
Endosulfan I ND
Inhalation Cancer Slope
Factor (mg/kg/day)-la

ND
6.1
ND
ND
ND
6.1
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.34
16
ND
Oral

ND
ND
ND
ND
ND
ND
ND
ND
multiple
ND
ND
ND
ND
liver
liver
liver
liver
liver
liver
ND
Inhalation

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Cancer
Classification ab

ND
B2
D
D
D
B2
ND
ND
B2
D
D
D
D
B2
B2
B2
B2
B2
B2
ND
Reference

ND
h
e
e
e
h
ND
ND
e
e
e
e
i
i
i
e
e
e
e
ND
Endosulfan II
Endrin
Heptachlor epoxide
ND
ND
9.1
ND
ND
9.1
ND
ND
liver
ND
ND
ND
ND
D
B2
ND
d
e
-------
TABLE 6-3
(Continued)
Tumor Site
Oral Cancer Slope Facter Inhalation Cancer Slope Cancer
Chemical (mg/kg/day) -1 Factor (mg/kg/day) -la Oral Inhalation Classification ab Reference
a Derived from inhalations unit risk.
b Cancer weight-of-evidence Group A = human carcinogen; Group Bl and B2 = probable human carcinogen;
Group C = possible human carcinogen; Group D - not classifiable as to carcinogenicity to humans; Group E = evidence of noncarcinogenicity to humans
c ND - no data
d EPA - 1993b, "Drinking Water Regulations and Health Advisories"
e Integrated Risk Information System (IRIS), 1993 (EPA 1993a) current as of April 1993
f The carcinogenicity of uranium is attributed to its radioactivity; see Appendix D of the Operable Unit 4 Remedial Investigation.
g EPA, Health Effects Assessment Summary Table (HEAST) (EPA 1992a).
h The oral and inhalation cancer slope factors for benzo(a)pyrene are used for the other polyaromatic hydrocarbons assigned to cancer classification B2 (see the toxicological profile
for polyaromatic hydrocarbons of Appendix D from the Operable Unit 4 Remedial Investigsation for additional information).
i EPA, 1993d, Memorandum from J. Dollarhide ECAO to P. V, 7/21/93, including Attachments 1-6.
-------
TABLE 6-4

CANCER SLOPE FACTORS FOR OPERABLE UNIT 4 RADIONUCLIDES OF CONCERN
ICRP
Lung Classb
Y
Y
Y
W
Gas
D
Y
Y
Y
Y
W
Y
W
D
Inhalation
(pCi)
5,
2,
2,
3,
7,
4,
2,
3,
8,
2,
6,
7,
8,
6,
.2
.6
.9
.0
.7
.0
.5
.6
.8
.8
.9
.8
.3
.2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-1
10-8
10-8
10-8
10-9
10-12
10-9
10-8
10-8
10-8
10-8
10-10
10-8
10-12
10-11
GI Absorption
Factor
(fl)
5.
5.
2.
2.
1.
2.
5.
1.
1.
2.
2
2.
8.
3.
0
0
0
0
0
0
0
0
0
0
.
0
0
0
X
X
X
X
X
X
X
X
X
X
0 x
X
X
X
10-2
10-2
10-4
10-1
100
10-1
10-2
10-3
10-3
10-4
10-1
10-4
10-1
10-1
Penetrating External
Ingestion Exposure
(pCi)-l
2
1
1
1
1
6
1
9
3
1

5
1
3
.8 x
.6 x
.3 x
.2 x
.7 x
.6 x
.6 x
.2 x
.5 x
.2 x
1.0 x
.5 x
.3 x
.6 x
10-11
10-11
10-11
10-10
10-12
10-10
10-11
10-11
10-10
10-11
10-10
10-11
10-12
10-11
(pCi
3.
3.
5.
6.
5.
1.
2.
2.
8.
2.
2
5.
6.
0.
.yr/g)-l
6
0
4
0
9
6
4
6
5
6

6
0
0
x
x
X
X
X
X
X
X
X
X
9 x
X
X
X
10-8
10-11
10-11
10-6
10-6
10-10
10-7
10-8
10-7
10-11
10-6
10-6
10-13
100
Radionuclide

Uranium - 238 Series
U-238 + 2 dtrs
U-234
Th-230
Ra-226 + 5 dtrs
Rn-222 + 4 dtrs
Pb-210 + 2 dtrs
Uranium - 235 Series
U-235 + 1 dtr
Pa-231
Ac-227 + 7 dtrs
Thorium - 232 Series
Th-232
Ra-228 + 1 dtr
Th-228 + 7 dtrs
Fission Products
Tc-99
Sr-90 + 1 dtr

a EPA, Health Effects Assessment Summary Tables, Annual FY 1992 including the July 1992 and November 1992 supplements (EPA
b Classification recommended by the ICRP for half-time for clearance from the lung. "Y" = years, "W" = weeks, "D" = days.
-------
TABLE 6-5

REFERENCE DOSES FOR NONCARCINOGENIC EFFECTS OF CONSTITUENTS OF CONCERN
FOR OPERABLE UNIT 4
Factor
Target Organ
Uncertainty
Chemical

Inorganics

Ammonia
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium (food)
Cadmium (water)
Chromium (VI)
Cobalt
Copper
Cyanide
Fluoride
Lead
Manganese
Manganese
Mercury
Molybdenum
Nickel
Nitrate
Oral Reference Dose
(mg/kg/day)
ND
0.0004b
O.OOOSb
0.07b
O.OOSb
0.09b
O.OOlb
O.OOOSb
O.OOSb
0.06a
ND
0.02b
0.06b
ND
0.14 (food)b
0.005 (water)b
0.0003d
O.OOSb
0.02b
1.6b
Inhalation Reference Dose
(mg/kg/day)a
Oral
0.029b
NDc
ND
0.00014d
ND
0.0057d
ND
ND
ND
0.0000003f
ND
ND
ND
ND
O.OOOllb
O.OOOllb
0.000086d
ND
ND
ND
ND
Liver
skin
Cardiovascular
ND
Testis
kidney
Kidney
ND
Cardiovascular
ND
Central nervous
Teeth
Central nervous
Central nervous
Central nervous
Kidney
Liver
ND
Blood

system

system
system
system

Inhalation
Respiratory system
ND
ND
Fetus
ND
Respiratory system
Cancer (see Table 6-3)
Cancer (see Table 6-3)
ND
Respiratory system
ND
ND
ND
Central nervous system
Respiratory system
Respiratory system
Central (see Table 6-3)
ND
Cancer (see Table 6-3)
ND
Oral
Inhalation
ND
1000
3
3
100
100
10
10
500
ND
ND
500
1
ND
1
1
1000
30
300
1
30
ND
ND
1000
ND
100
ND
ND
ND
1000
ND
ND
ND
ND
300
300
30
ND
ND
ND
-------
TABLE 6-5
(Continued)
Oral Reference Dose
Chemical (mg/kg/day)
Inhalation

Inorganics

Phosphorus 0.00002b
Selenium O.OOSb
Silver O.OOSb
Thallium 0.00006b,g
Uranium O.OOSb
Vanadium 0.007d
Zinc 0.3b
Volatiles
2-Butanone O.OSd
2-Hexanone 0.04b
4-Metyl-2-pentanone O.OSd
Acetone 0. Ib
Carbon tetrachloride 0.0007b
Methylene chloride 0.06b
Tetrachloroethene O.Olb
Toluene 0.2b
Total xylenes 2b
Semivolatiles
Acenaphthylene ND
Aldrin O.OOOOSb
Anthracene 0.3b
Inhalation Reference Dose
(mg/kg/day) a
ND
ND
ND
ND
ND
ND
ND

0.3b
ND
0.023d
ND
0.00057h
0.86d
ND
O.lld
ND

ND
ND
ND
Target Organ
Oral
Inhalation
Uncertainty Factor
Oral
Reproductive systm
Skin
ND
Central nervous system
kidney
ND
Blood
ND
ND
Liver
Liver
Liver
Liver
Liver
Liver
Central nervous systme
ND
Liver
ND
ND
ND
ND
ND
ND
ND
ND
Fetus
ND
Liver
ND
ND
Liver
ND
Central nervous
ND
ND
ND
ND
1000
3
3
3000
1000
100
3
1000
ND
1000
1000
1000
100
1000
system 1000
100
ND
1000
3000
ND
ND
ND
ND
ND
ND
ND
1000
ND
1000
ND
ND
100
ND
300
ND
ND
ND
ND
-------
TABLE 6-5
(Continued)
Chemical

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Oral Reference Dose
(ing/kg/day)

ND
ND
ND
ND
Benzoic acid 4b
bis(2-Ethylhexyl)phthalate 0.02b
Chrysene ND
Di-n-butylphthalate 0.Ib
Di-n-octylphthalate 0.2d
Dibenzo(a,h)anthracene ND
Diethyl phthalate 0.8b
Dimethyl phthalate lOd
Fluoranthene 0.04b
Indeno(1,2,3-cd)pyrene ND
2-Nitrophenol ND
4-Nitrophenol 0.008b
N-Nitroso-di-n-propylamine ND
Phenanthrene ND
Phenol 0.6b
Pyrene O.OSb
Tributyl phosphate O.OOSb
Inhalation Reference Dose
(mg/kg/day) a

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Target Organ
Oral

ND
ND
ND
ND

ND
Liver
ND
ND
Liver
ND
ND
Kidney
Kidney
ND
ND
ND
ND
ND
Fetus
Kidney
ND
Uncertainty Factor
Inhalation

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Oral

ND
ND
ND
ND

1
1000
ND
1000
1000
ND
1000
10
3000
ND
ND
ND
ND
ND
100
3000
ND
Inhalation

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
-------
TABLE 6-5
(Continued)
Chemical

Pesticides/PCBs

Aroclor-1248

Aroclor-1254
Aroclor-1260
4,4'-DDE
4,4'-DDT
Dieldrin

Endosulfan I

Endosulfan II
Endrin
Heptachlor epoxide
Oral Reference Dose
(mg/kg/day)
0.00007b,i

0.00007b,i
0.00007b,i
ND
O.OOOSb
O.OOOOSb

0.000051

0.000051
O.OOOSb
O.OOOOlSb
Inhalation Reference Dose
(mg/kg/day)a
ND

ND
ND
ND
ND
ND

ND
ND
ND
Target Organ
Oral
Fetus

Fetus
Fetus
ND
Liver
Liver

Kidney

Kidney
Liver
Liver
Uncertainty Factor
Inhalation Oral
ND 100

ND 100
ND 100
ND ND
ND 100
ND 100

ND 3000

ND 3000
ND 100
ND 1000
a Derived from inhalation RfC.
b Integrated Risk Information Syetem (IRIS) (EPA 1993') current as of April 1993.
c ND - no data.
d EPA, Health Effects Assessment Summary Tables, (HEAST) Annuel FY 92 including July and November Supplements (EPA 1992a).
e EPA 1992e Memorandum from D. L. Forman, U.S. EPA Region VII, Philadelphia, Pennsylvania, "Subject: Cobalt Toxicity," dated March 12, 1992.
f EPA 1990c, Memorandum from Pei-Fung Hurst, ECAO, Cincinnati, Ohio, to R. Riccio, U.S. EPA Region III, Philadelphia, Pennsylvania, "Subject:
Chemical/Wilmington, Delaware)," dated October 9, 1990.
g Derived by analogy to thallium sulfate, adjusting for differences in molecular weight.
h EPA 1993c
i Based on anology to Aroclor - 1016.
j EPA, 1993e, Health Effects Assessment Summary Tables, (HEAST), March, 1993.
k EPA, 1993d, Memorandum from J. Dollarhide, ECAO to P. VanLeeuwen, Region V, 7/21/93.
Inhalation
ND

ND
ND
ND
ND
ND

ND
ND
ND
Toxicity of Cobalt (Halby
-------
6.1.4 Risk Characterization Results

Excess lifetime cancer risks are determined by multiplying the intake level with the cancer potency factor.
These risks are probabilities that are generally expressed in scientific notation (e.g. 1 x 10-6 or 1E-6).
An excess lifetime cancer risk of 1 x 10-6 indicates that, as a plausible upper bound, an individual had a
one in one million chance of developing cancer as result of site-related exposure to a carcinogen over a
70-year lifetime under the specific exposure conditions at a site.

Potential concern for noncarcinogenic effects of a single contaminant in a single medium is expressed as the
HQ (or the ratio of the estimated intake derived from the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all contaminants within a medium or across all media to
which a given population may reasonably be exposed, the HI can be generated. The HI provides a useful
reference point for gauging the potential significance of multiple contaminant exposures within a single
medium or across media.

Tables 6-6 and 6-7 shows the baseline risks and His for each hypothetical receptor by land use and source
term scenario. Risk values in Table 6-6 are reported in units of ILCR for radiological, chemical, and total
risk. The chemical HI, which has no units, is presented in Table 6-7.

6.1.4.1 Current Land Use Without Access Control/Current Source-Term Scenario

The receptor with the greatest total radiological risk is the trespassing child (Table 6-6). The greatest
contributor under this scenario is from exposure to external radiation while the receptor is on top of the
Silo 1 or 2 dome (5 x 10-3) . In addition, the receptor is exposed to air, soil, and surface water pathways
resulting in radiological risk of 3 x 10-5. The total radiological risk to the trespassing child is 5 x 10-3
(external radiation) plus 3 x 10-5 (nuclide-specific radiation) totalling 5 x 10-3. The receptor with the
greatest total chemical risks (1 x 10-4) is the off-property resident farmer (Table 6-6). The greatest
contribution under this scenario is from exposure to air pathways (1 x 10-4) . The receptor with the greatest
total radiological plus chemical risk under this scenario (5 x 10-3, Table 6-6) is the trespassing child.
The greatest HI is 0.3 to the trespassing child (Table 6-7). The greatest contribution, under this scenario
is from soil exposure pathways (0.2) .
-------
TABLE 6-6
INCREMENTAL LIFETIME CANCER RISK SUMMARY ALL SOURCES/ALL PATHWAYS
Land Use/
Source Term
Scenario Type of Risk

Radiological-Nuclide Specificb
Current Land Use
without Access Radiological-Externala
Control/Current
Source Term Chemical Risk
Scenario
Total Risk

Radiological-Nuclide Specific

Chemical Risk

Total Risk

Radiological-Nuclide Specific
Current Land Use
with Access Radiological-External
Control/Current
Source Term Chemical Risk
Scenario
Total Risk

Radiological-Nuclide Specific
Future Land
Use/Current Source Radiological-External
Current Land Use
without Access
Control/Future
Scenario
Term Scenario
Chemical Risk

Total Risk

Radiological-Nuclide Specific NA
Future Land Use
Future Source Term Chemical Risk
Scenario
Grounds
Off-Property
Off-Property User of Surface CT On-Property RME On-Property On-Property
:SJ
3,

1.
5,
1.
4,
1.
3,
5,
1.
5,

Dassing Child
. 0 x 10-5
5 x 10-3
. 0 x 10-5
. 0 x 10-3
. 0 x 10-2
.0 x 10-4
. 0 x 10-2
. 0 x 10-5
. 0 x 10-3
. 0 x 10-5
. 0 x 10-3
NA
NA
NA
NA
NA
NA
Keeper
8.0 x 10-5
1 x 10-4
2.0 x 10-5
2.0 x 10-4
3.0 x 10-2
6.0 x 10-4
3.0 x 10-2
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Resident Farmer Water
1.

1.
1.
2.
2.
2.
1.

1.
1.
1.

1.
1.
2.
2.
,0

,0
,0
,0
,0
,0
,0

,0
,0
,0

,0
,0
,0
,0
x
NA
x
X
X
X
X
X
NA
X
X
X
NA
x
X
X
X
10-5

10-4
10-4
10-3
10-4
10-3
10-5

10-4
10-4
10-5

10-4
10-4
10-3
10-4
1.

1.
2.
1.
7.
2.
1.

1.
2.
1.

1.
2.
1.
7.
,0

,0
,0
,0
,0
,0
,0

,0
,0
,0

,0
,0
,0
,0
x
NA
x
X
X
X
X
X
NA
X
X
X
NA
x
X
X
X
10-7

10-7
10-7
10-6
10-7
10-7
10-7

10-7
10-7
10-7

10-7
10-7
10-6
10-7
Resident Farmer Resident Farmera Resident C.
NAc
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2.0 xlO-4
2.0 xlO-4
5.0 x 10-3
5.0 x 10-3
1.0 xlO-1
l.Ox 10-2
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3.0 x 10-3
2.0 x 10-3
8.0 x 10-2
9.0 x 10-2
1.0 x 100
2.0 x 10-1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3.0
9.
5.
6.
1.
9.

x 104
0 xlO-3
0 xlO-2
0 xlO-2
0 xlO-1
0 xlO-2
Total Risk
NA
NA
2.0 x 10-3
2.0 x 10-4
1.0 x 10-1
2.0 x 10-1
-------
a The ILCR values were identical for the future land use/future source term scenario evaluated for either the Great Miami Aquifer or for perched water.

b The ILCR result from exposure to radionuclides from air, water, (ground and surface), soil and sediment as detailed in Attachment II of Appendix D and summarized in tables within
Section D.5.

c NA signifies not applicable.

d This risk results from exposure to direct external radiation from large sources (Silos 1, 2, and 3) and are presented in Table D 5-2. It does not include exposure to external
radiation emanating from radionuclides in surface soils. These later risk are accounted for in the nuclide-specific ILCR.
-------
TABLE 6-7
HAZARD INDEX SUMMARY ALL SOURCES/ALL PATHWAYS
Land Use/
Source Term Scenario
Off-Property Off-Property
Trespassing Grounds Resident
Type of Risk
Current Land Use Chemical Hazard Index
without Access Control/Current
Source Term Scenario
Child

0.3
Keeper Farmer

0.1 0.05 0.0004
User of Surface CT On-Property
Water
Resident Farmer

NAb
RME On-Property ON-Property
Resident Farmera Resident Child
NA
NA
Current Land Use Chemical Hazard Index
without Access Control/Current
Source Term Scenario
20
20
0.002
NA
NA
NA
Current Land Use
with Access Control/Current
Source Term Scenario
Chemical Hazard Index
0.3
NA
0.05
0.0004
NA
NA
NA
Future Land
Use/Current
Source Term Scenario
Chemical Hazard Index
NA
NA
0.05
0.0004
20
100
Future Land
Use/Current
Source Term Scenario
Chemical Hazard Index
NA
NA
a The HI (500) was identical for the future land use/future source-term scenario.
b NA signifies not applicable.
0.002
300
500
2000
-------
6.1.4.2 Current Land Use Without Accesss Control/Future Source-Term Scenario

The receptor with the greatest total radiological risk is the groundskeeper (Table 6-6). The greatest
contribution under this scenario is from exposure to soil pathways (2 x 10 2). The total radiological risk
to the groundskeeper under this scenario is 3 x 10-2 (Table 6-6). The receptor with the greatest total
chemical risk is also the groundskeeper (Table 6-6). The greatest contribution is from exposure to soil
pathways (5 x 10-4) . The total chemical risk to the groundskeeper under this scenario is 6 x 10-4. The
total radiological plus chemical risk to the groundskeeper under this scenario is 3 x 102 Table 6-6). The
greatest HI is 20 to the groundskeeper (Table 6-7) and to the trespassing child (Table 6-6). The greatest
contribution to both receptors under this scenario is from exposure to air pathways.

6.1.4.3 Current Land Use With Access Control/Current Source-Term Scenario

This scenario most closely approximates current conditions at the FEMP site. However, the risk and HI
results for this scenario are numerically the same as the results for the current land-use scenario without
access controls assuming the current source term (Section 6.1.4.1). This is because the presence or absence
of access controls does not change the numerical values of exposure parameter values for receptors. The
trespassing child's exposure parameter values reflect the standard scenario specified by the EPA. Also, the
off-property resident farmer, and surface water user exposures are not impacted by the status of access
controls.

6.1.4.4 Future Land Use/Current Source-Term Scenario

The receptor with the greatest total radiological risk is the on-property resident child (Table 6-6). The
greatest contribution under this scenario is from exposure to external radiation while the receptor is on top
of the Silo 1 or 2 dome (9 x 10-3) . In addition, the receptor is exposed to air, soil, and surface water
pathways resulting in a radiological risk of 3 x 10-4, primarily from the soil pathway (2 x 10-4). The total
radiological risk to the on-property resident child is 9 x 10-3 plus 3 x 10-4 totaling 9 x 10-3. The
receptor with the greatest total chemical risk (8 x 10-2) is the RME on-property resident farmer able 6-6).
The greatest contribution under this scenario is from exposure to soil pathways (8 x 10-2) . The receptor
with the greatest total radiological plus chemical risk under this scenario (9 x 10-2, Table 6-6) is the RME
on property resident farmer. The greatest HI is 100 to the on-property resident child (Table 6-7). The
greatest contribution to chemical hazard under this scenario is from soil exposure pathways (100) .

6.1.4.5 Future Land Use/Future Source-Term Scenario,

This represents the most conservative scenario considered under the baseline risk assessment. Within this
scenario, a family is assumed to have established a residence within the Operable Unit 4 boundaries.
Additionally, the domes of Silos 1 and 2 are assumed to have failed and Silo 3 is assumed to have suffered
total structural failure, spreading its cons to the surface of Operable Unit 4. As described in Section D.3
of the Rl Report for Operable Unit 4, the failure of Silo 3 and the assumed distribution of its contents on
the surrounding surface makes it more appropriate to evaluate direct external exposure in a nuclide- specific
manner rather than as a large source. With the failure of the domes of Silos 1 and 2 it is no longer
appropriate to evaluate direct external radiation exposure at these locations. Therefore, the separate entry
in Table 6 for external radiation does not appear for the future source-term scenario.

The receptor with the greatest total radiological risk is the RME on-property resident farmer (Table 6-6).
The greatest contribution under this scenario is from exposure to soil pathways (approaching unity risk).
The total radiological risk to the RME on-property resident farmer under this scenario also approaches unity
(1) risk. The receptor with the greatest total chemical risk is also the RME on-property resident farmer
(Table 6-6) . The greatest contribution is from exposure to soil pathways (2 x 10-1) . The total chemical
risk to the RME on-property resident farmer under this scenario is 2 x 10-1. The total radiological plus
chemical risk to the RME on-property radiant farmer under this scenario exceeds unity (Table 6-6). The
greatest HI is 2000 to the on-property resident child (Table 6-7). The greatest contribution to this
receptor under this scenario is from exposure to soil pathways.
-------
6.1.5 Risk Assessment Uncertainties

The uncertainties in the risk assessment process are presented in detail in Section D.6.0 of Appendix D of
the RI Report for Operable Unit 4. These uncertainties are summarized below to enable a better understanding
of their impacts on the foregoing risk assessment.

Uncertainty is a factor in each step of the exposure and toxicicy assessment process. Such uncertainty can
involve variations in sample analytical results, the values of variables used as input to a given model, the
accuracy with which the model itself represents actual environmental or biological processes, the manner in
which the exposure scenario is developed, and the high-to-low dose and interspecies extrapolations for
dose-response relationships.

Generally, risk assessments carry two types of uncertainty. First, measurement uncertainty refers to the
usual variance that accompanies scientific measurements (such as the range of an exposure estimate) and
reflects the accumulated variances of the individual measured values used to develop the estimate. The
second form of uncertainty is due to the absence of information needed to complete the database for the
assessment. In some instances, the impact is significant, such as the absence of information on the adverse
effects or the biological mechanism of action of a chemical agent.

6.1.5.1 Sources of Uncertainty

As noted previously, uncertainties are associated with the information and data used in each phase of the
Operable Unit 4 baseline risk assessment. The first source of uncertainty arises from data gaps or limiious
in the data. For example, the data sa for soil is limited, and virtually nothing is known regarding
contaminants in the area of the former Drum-Handling Building. These limitations could result in failure to
identify some COCs which may result in underestimating risk. (This data limitation and its epected impact on
the baseline risk assessment is further discussed in greater detail in Section 7.5 of the RI Report for
Operable Unit 4).

Other sources of uncertainty include the conservative bias of parameters, parameter variability (random
errors or natural variations), and the necessity of using computer models to predict complex environmental
interactions. Uncertainties also arise from the use of animal data to predict the toxic effects and the
toxic potency in humans. Uncertainties associated with information and data are evaluated below to provide
the spectrum of information in regard to the overall guality of the risk assessment results. The
uncertainties are associated with exposure route selection, selection of COCs, exposure point concentrations,
and exposure factors.

6.1.5.2 Toxicity Assessment

Considerable uncertainty is associated with the gualitative hazard assessment) and guantitative
(dose-response) evaluations of a Superfund risk assessment. A hazard assessment deals with characterizing
the nature and strength of the evidence of causation, or the likelihood that a chemical that induces adverse
effects in animals will induce adverse effects in humans. Hazard assessment of carcinogenicity is evaluated
as a weight-of-evidence determination, using either the International Agency for Research on Cancer (IARC)
(1987) or EPA (1986) schemes. Positive cancer test data in experimental animals suggest that a human exposed
to the same agent may suffer adverse effects. However, animal data, may not accurately predict the same
response or the same target organ tissue for cancer in humans. Also, biochemical repair mechanisms present
in humans may inhibit or preclude an identical response. Accordingly the uncertainty of possible effects is
significant. In assessing noncancer effects, however, positive experimental animal data from well designed
studies in appropriate models suggest to the target tissues and type of effects that may be anticipated in
humans (EPA 1989a).

6.2 OVERVIEW OF THE BASELINE ECOLOGICAL RISK ASSESSMENT

The purpose of the ecological risk assessment, which was completed as a companion to the preliminary
site-wide baseline risk assessment in the Site-Wide Characterization Report (SWCR), was to estimate the
potential and future baseline risks of FEMP contaminants to ecological receptors.
-------
The EPA and DOE have agreed in the Amended Consent Agreement (September 1991) that the Site-Wide Ecological
Risk Assessment will be performed as part of the RI for Operable Unit 5. The Site-Wide Ecological Risk
Assessment in the RI for Operable Unit 5 will guantify and assess the possible risks from current
concentrations of site contaminants to ecological receptors inhabiting on-property and off-site areas not
presently targeted for remediation based on human-health concerns. More discussion on the Risk Assessment
and Ecological Risk issues specific to Operable Unit 4 can be found in the Operable Unit 4 Proposed Plan.

The ecological receptors potentially exposed to FEMP contaminants include all organisms, exclusive of humans
and domestic animals. The ecological risk focused on a group of indicator species selected to represent a
variety of exposure pathways and trophic positions. Terrestrial vegetation was represented by a generic
plant species. Terrestrial wildlife species to be evaluated were selected based on species abundance on the
FEMP site, trophic level position, and habitat reguirements. The species evaluated were the white-tailed
deer (Odocoileus virginianus), white-footed mouse (Peromyscus leucopus), raccoon (Procyon lotor), red fox
(Vulpes fulva), muskrat (Ondatra zibethica), American robin (Turdus migratorius), and red-tailed hawk (Buesto
jamaicensis).

The assessment examined risks to terrestrial organisms associated with contaminants in two environmental
media - surface soils, summarized for the entire site, and surface water in Paddys Run from the northern
boundary of the FEMP site to the confluence with the storm sewer outfall ditch. Risks to aguatic organisms
were evaluated for exposure to contaminants in Paddys Run, the Great Miami River, and in runoff into the
storm sewer outfall ditch. All nonradioactive and radioactive constituents of greatest human health risk
were considered to be of concern for the ecological risk assessment. Estimated ecological risks associated
with exposure to FEMP site COCs are primarily due to nonradioactive inorganic chemicals in soils, rather than
to organic chemicals or radionuclides. This is true for both terrestrial and aguatic organisms and for
plants as well as wildlife. In particular, estimated intakes of arsenic, cobalt, lead, and silver from FEMP
soils were all higher than the estimated No Observed Effect Levels (NOELs) for at least six of the seven
indicator species selected for this assessment. The relative hazards to individual species varied, but the
white-footed mouse consistently had the highest indices of these chemicals. This can be attributed to the
assumed intake by the mouse of insects (using earthworms as surrogates), which in turn were assumed to
assimilate chemicals from soil with a transfer coefficient of 1.0.

Estimated hazards to terrestrial organisms of exposure to COCs in FEMP surface waters were relatively low,
with His greater than one only for arsenic, lead, molybdenum, and silver. These chemicals presented hazards
of two, five, four and three to species, respectively, and the highest HI estimated was for lead intake by
the mouse.

Estimated doses to terrestrial organisms at the FEMP site, originating from soil uptake by plants and
earthworms, were below levels expected to cause detectable effects. However, as with inorganic chemicals,
this conclusion is sensitive to assumptions about muscle-to-muscle transfer of radionuclides. If perfect
transfer or biomagnification of uranium occurs (i.e., transfer factor eguals 1.0), it could expose
terrestrial wildlife at the FEMP to potentially harmful radiation levels. However, if more realistic
muscle-to-muscle transfer coefficient were assumed (i.e., 0.1), the estimated radiation doses would fiell
below the range likely to result in harmful effects. Radiation doses due to water intake were insignificant.

Exposure to radiological contaminants does not appear to pose a significant risk to aguatic organisms at the
measured concentrations in the surface waters and sediments impacted by the FEMP site. However, modeled
concentrations of radionuclides in runoff from the FEMP site into surface water would cause estimated
exposures to exceed the upper limit of 1 rad/day. A chronic dose rate of 1 rad/day or 3.65 x 10-5 mrad/year
or less to the maximally exposed member of a population of aguatic organs would ensure that there were no
deleterious effects from radiation on the population. The most affected organisms would be aguatic planes,
receiving a total dose from internal and external exposure of about 140 rad/day. The total dose to fish is
minimally over the limit, ae 1.6 rad/day, and the total dose to benthic macroinvertebrates is about 14
rad/day. The maximum concentrations calculated in the storm sewer outfall ditch was used in source runoff
calculations. Doses to aguatic organisms in the storm sewer outfall ditch may exceed the limit of 1 rad/day.
Doses in Paddys Run and the Great Miami River would be lower than that indicated in the storm sewer outfall
ditch and would be well below 1 rad/day. The measured concentrations of cadmium in Paddys Run and the Great
Miami River, copper in the Great Miami River, mercury in Paddys Run, the Great Miami River, and the storm
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sewer outfall ditch, and silver in Paddys Run water exceeded chronic toxicity criteria for the protection of
freshwater organisms.

Field studies on the impact of the FEMP site on terrestrial and aquatic communities do not indicate any
effects consistent with contaminant impacts except for above-background levels of arsenic and mercury
recorded in RI/FS plant samples. In addition, although potential impacts at the individual level were
predicted for wildlife species, detrimental or adverse impacts have not been observed in the field. This
suggests that the potential exposures predicted by modeling may not occur in the field or that the resulting
potential effects as a result of exposures may not occur. A comparison of the concentrations of inorganic
chemical concentrations in FEMP soils to regional background values indicate the mean FEMP concentrations may
be similar to the upper 95 percent confidence levels of background values. This indication suggests that
ecological risks estimated using background values of inorganics would be comparable to those estimated for
the FEMP site, and emphasizes the conservative nature of the method used.

In summary, although radionuclides are the most ubiguitous contaminants at the FEMP, estimated ecological
risks to both terrestrial and aguatic organisms are primarily associated with nonradioactive inorganic
chemicals. Although estimated risks are substantial in some instances, they are based on soil inorganic
chemical concentrations comparable to background levels, and deleterious effects have not been observed in
the field. This suggests that current FEMP site-specific ecological risks are low. However, remedial
actions are appropriate to address contaminants which have potential to cause harm in the future.

7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES

As previously discussed in Section 5.0, the waste materials within Operable Unit 4 exhibit a wide range of
properties. Most notable would be the elevated direct radiation associated with the moist to wet Silos 1 and
2 residues versus the much lower direct radiation associated with the dry, powdery cold metal oxides in Silo
3. Even more significant would be the much lower levels of contamination associated with the soils and
building materials, like concrete, within the Operable Unit 4 Study Area. To account for these differences
and for the varied cleanup alternatives applying to each type of waste, Operable Unit 4 was segmented into
three subunits. These subunits, which are listed below, were used through the detailed evaluation of
alternatives and the identification of the preferred alternative.

Subunit A: Silos 1 and 2 (K-65 residues and bentonite clay) and the sludge in the decant sump tank

Subunit B: Silo 3 (cold metal oxides)

Subunit C: Silos 1, 2, 3, and 4 structures; contaminated soils within the Operable Unit 4 boundary including
surface and subsurface soils and the earthen berm around Silos 1 and 2; the decant sump tank; the radon
treatment system; the concrete pipe trench and the miscellaneous concrete structures within operable Unit 4,
any debris (i.e., concrete, piping, etc.,) generated through implementing cleanup for Subunits A and B, and
any perched groundwater encountered during remedial activities.

With the exception of Alternatives 2A/Vit and 2A/Cem (see Section 11 for details) the remedial alternatives,
which went through detailed analysis during the FS for operable Unit 4, are summarized below. The
discussions presented here are based on the information used for detailed analysis of alternatives during the
FS. Actual methods used during the implementation of the selected alternative(s) will be determined during
detail engineering design described in the remedial design and may differ from the descriptions provided
below.

Section 121 of CERCLA requires that remedial actions be protective of human health and the environment, and a
level or standard of control that is consistent with federal or state environmental laws or state facility
siting regulations, which are termed applicable or relevant and appropriate requirements (ARARs). ARARs
pertain to all aspects of a remedial action, including the establishment of cleanup levels, the operation and
performance of treatment systems, and the design of disposal facilities.

The baseline risk assessment performed as part of the RI Report for Operable Unit 4, quantified the health
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risks to hypothetical human receptors due to exposure from chemical and radiological sources in Operable Unit
4 under the no-action alternative. A summary of the risk assessment and results is presented in Section 6.0.
Essentially, the results emphasize the need to effectively complete the selected remedial actions at Operable
Unit 4 in order to ensure overall protection of human health and the environment.

Potential remedial alternatives were developed and evaluated in the FS Report for Operable Unit 4 as to how
these risks would be eliminated, reduced, or controlled through treatment, engineering controls, or
institutional controls. Both long-term and short-term risks associated with implementing an alternative were
considered in determining whether a given alternative was protective. Each alternative evaluated provides a
description of its overall effectiveness in reducing risks to human health and the environment.

ARARs consist of two sets of reguirements, those that are applicable and those that are relevant and
appropriate. Applicable reguirements are those substantive standards that specifically address a situation
at a CERCLA site. Relevant and appropriate reguirements are standards that address problems sufficiently
similar to the situation at a CERCLA site that their use is well suited to the site. In certain cases,
standards may not exist in the promulgated regulation that address the proposed action or the constituents of
concern. In these cases, non-promulgated advisories, criteria, or guidance that were developed by the EPA,
other federal agencies, or states are to be considered (TBC) in establishing remedial action objectives that
are protective of human health and the environment.

A detailed discussion of all ARARs and TBC criteria associated with the remedial alternatives being evaluated
for Operable Unit 4 is presented in Appendix F of the FS Report for Operable Unit 4. From these detailed
lists, certain major ARARs and TBCs were selected based on their importance in protecting human health and
the environment. These include those associated with the protection of drinking water sources, the control
of radionuclide emissions, the design and siting of a solid waste disposal facility, the management of RCRA
hazardous waste, and compliance with NEPA. The major ARARs associated with the remedial alternatives
evaluated in this section, with the exception of the no action alternatives, are presented in Appendix A of
this ROD. These major ARARs are segregated into three types:

(a) Chemical-specific ARARs sre usually health- or risk-derived numerical values or methodologies that
establish an acceptable level or concentration of chemical or radionuclide that may remain in specific
environmental media after remediation is complete. These levels are deemed to be protective of human health
and are used to help establish remedial cleanup goals.

(b) Location specific ARARs generally restrict certain activities or dictate where certain activities may be
conducted, solely because of geographical, hydrologic, hydrogeologic, or land use concerns.

(c) Action-specific ARARs are usually technology or activity based reguirements or restrictions on the
conduct of certain activities or the operation of certain technologies at the site.

Appendix A identifies all remedial alternatives evaluated along with their major regulatory reguirements, the
rationale for designation of each regulatory reguirement as an ARAR/TBC, and the mechanism by which the
remedial alternative will comply with the reguirement.

7.1 NO-ACTION ALTERNATIVE FOR ALL SUBUNITS

The No-Action Alternative for Subunits A, B, and C is presented to provide a baseline for comparison with the
other alternatives per the President's Council on Environmental Quality and 40 CFR Part 300, the Nation Oil
and Hazardous Substances Pollution Contingency Plan regulations. Under the No-Action Alternatives, desiged
as OA, OB, and OC for each of the three subunits, the contaminated and/or uncontaminated materials within
each subunit would remain unchanged without any further waste removal, treatment, or containment activities.

Alternatives OA, OB, and OC do not provide for the monitoring of soil, groundwater, or radon emissions from
the Operable Unit 4 facilities or soils, and do not provide for access controls (e.g., physical barriers and
deed ) to reduce the potential for exposure to any human or ecological receptors. The No-Action Alternatives
would not decrease the toxicity, mobility, or volume of contaminants or reduce public health or environmental
risks. Also, goals for protecting the underlying groundwater aguifer would not be met. No costs are
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associated with the No-Action Alternative.

ARAR Compliance for No-Action Alternatives

Alternatives OA, OB, ad OC would not comply with a number of chemical-specific, location specific, or
action-specific ARARs. Under the no-action alternatives, Silos 1, 2, and 3 would eventually fail, resulting
in the release of silo contents to the air, soil, groundwater, and surface water. Fate and transport
modeling indicates that uranium and gross alpha and beta radiation would exceed safe drinking water limits
under 40 CFR §141. In addition, localized "hot spots" could exceed the limits established in 40 CFR §192.12.

7.2 SUBUNIT A - CONTENTS OF SILOS 1 AND 2 AND THE DECANT SUMP TANK

With the exception of Alternatives 2A/Vit and 2A/Cem (see Section 11 for details) this session presents the
alternatives which were evaluated for Subunit A during the detailed analysis of alternatives phase of the FS
for Operable Unit 4. These alternatives focus on the remediation of the K-65 residues contained in Silos 1
and 2 and the sludges in the decant sump tank.

All of the alternatives would provide overall protection of human health (assuming continued federal
government control) and the envnent by eliminating, reducing, or controlling risk through treatment,
engineering controls, or institutional controls. The selected remedy (3A.l/Vit) would provide greater
certainty for overall protection than other alternatives because the Subunit A residues would be vitrified
and removed to the NTS to reduce the potential for contaminant migration to human and ecological receptors.
The source of unacceptable risks to the Operable Unit 4 expanded trespasser and off-site farmer would be
eliminated, and in the event that the government lost control of the FEMP site, there would be no risk from
Subunit A residues to an on-property farmer.

Overall protection at the NTS would be maintained because the vitrified residues resist leaching and the NTS
is located in a climatic, demographic, and hydrogeologic setting which favors minimization of containment
migration to both human and environmental receptors.

7.2.1 Alternative 3A.l/Vit - Removal, Vitrification, and Off-Site Disposal - Nevada Test Site

Capital Cost: $38.3 Million (M)

O&M Costs:

During Remediation: $11.7 M

Post-Remediation: $0

Present Worth: $43.7 M

Years to Implement: 6

This alternative involves the removal, vitrification, and off-site disposal of the treated Silos 1 and 2
contents and decant sump tank sludge. Treated material would be transported by rail, then truck, to the NTS,
a DOE-owned facility that currently accepts low-level radioactive material from DOE Facilities for disposal.
Under Alternative 3A.l/Vit, approximately 6,796 m3 (8,890 yd3) of untreated residues would be removed from
Silos 1 and 2 and combined with approximately 3,785 Liters (L) (1,000 gallons) of sludge from the decant sump
tank and treated. Approximately 2,770 m3 (3,623 yd3) of vitrified material would be packaged in containers
and transported to the NTS for disposal. Disposal of contaminated materials from the berms, Silos 1 and 2
structures, the material removal eguipment, and the vitrification system would be managed under the selected
alternative for Subunit C. No five-year CERCLA reviews would be reguired under is alternative since no
Subunit A residue material would remain at the FEMP. The components of this alternative not previously
described are as follows.

Material Removal
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Silos 1 and 2 residues and decant sump tank sludge would be slurried and pumped to the vitrification plant
for processing. During the material removal phase, Silos 1 and 2 and the decant sump tank would be eguipped
with an off gas handling system to treat radon and other potential airborne contaminants. This off-gas
handling system would be operational during material removal and before personnel enter the area above the
silo domes to reposition material removal eguipment and conduct repairs or maintenance. The off-gas handling
system and operating procedures would be designed as necessary to minimize exposure to personnel located
overa the work areas and to prevent the escape of radon and radioactive particulates from the silos and the
decant sump tank to the atmosphere.

Material Stabilization

Silos 1 and 2 residues and decant sump tank sludge would be combined with glass forming agents, processed in
a high temperature furnace, and converted into a stable vitrified glass form exhibiting excellent durability
and constituent leaching characteristics. It should be noted that current planning focuses upon pouring the
molten glass directly into containers capable of withstanding the high temperature of the vitrified waste
form. The final waste form would continue to be optimized in pilot plant treatability studies and final
decision regarding the final waste form would be reached during the pilot plant treatability studies.
Process tanks/vessels and piping containing slurried K-65 residues would be designed to minimize potential
radon and particulate emissions to the atmosphere during treatment. The direct radiation associated with the
treated residues would remain relatively unchanged from the untreated form of the K-65 residues.

Interim Storage

The containerized vitrified product will reguire interim storage at the FEMP prior to its transportation to
the NTS for disposal. The purpose of this interim storage is two-fold; first, the vitrified product will
reguire verification sampling in order to certify that each production lot has met specific performance and
waste disposal criteria; and second, to provide the Fernald waste shipping program a buffer staging area
where the material can be safely managed prior to its shipment to NTS in accordance with DOE ALARA
principles, ARARs identified and included in the Operable Unit 4 ROD, as well as in a manner protective of
human health and the environment. It has been anticipated that the interim storage area will be needed to
accommodate the interim handling of approximaly 90 days of vitrification production.

Disposal of Treated Material

Off-site disposal for this alternative involves the packaging, loading, and shipping of the treated material,
in accordance with all reguired United States Department of Traosportation (DOT) specification regulations,
to the low-level radioactive waste disposal site at the NTS, a DOE-owned facility that currently accepts low
level radioactive material from DOE facilities for disposal. Shipment of the treated material to the NTS
would be performed by rail and/or truck transportation from the FEMP site. Currently, there are no direct
rail lines into the NTS. The treated material would be transported by rail to either a point near Las Vegas,
Nevada, or one of the areas north of Las Vegas. From either location, the containers carrying the treated
material would be transferred to trucks for transportation over roads to the NTS.

The NTS is located approximately 3,219 kilometers (km) [2,000 miles (mi)] from the FEMP site. Because the
vitrified residues resist leaching and the NTS is located in a sparsely populated, arid region, where depths
to groundwater are at least 235 m (771 ft) below the surface, disposal at the NTS would be very effective at
precluding human contact with and contaminant migration from the treated residues from Subunit A. The FEMP
site has an approved NTS waste shipment and certification program that is periodically audited by the NTS.
Efforts have been initiated to amend the current program to include Operable Unit 4 treated material. All
the NTS waste acceptance reguirements would need to be satisfied prior to any shipment of the Operable Unit 4
treated material to the NTS.

Implementation Time and Costs

Remedial action activities under Alternative 3A.l/Vit could be completed in approximately six years.
Approximely three years is projected for completion of site preparation, facilities construction, and
eguipment installation. Material removal and treatment activities would reguire about three years.
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Transportation and off-site disposal would conclude shortly after the completion of material processing.
Capital costs for Alternative 3A.l/Vit are estimated to be 38.3 million dollars. O&M costs during
remediation are estimated at 11.7 million dollars over three years. Due to the off-site disposal option,
there are no post-remediation O&M costs associated with this alternative. The total present worth cost for
this alternative is estimated at 43.7 million dollars.

7.2.2 Alternative 3A.l/Cem - Removal, Cement Stabilization, and Off-Site Disposal - NTS

Capital Cost: $71.8 M

O&M Costs:

During Remediation: $11.7 M

Post-Remediation $0

Present Worth: $73.1 M

Years to Implement: 6

This alternative is identical to Alternative 3A.l/Vit accept that the vitrification of the Silos 1 and 2
contents and decant sump tank sludge have been replaced by cement stabilization. Treated material and debris
would be transported by rail, then truck to the NTS: Under Alternative 3A.l/Cem, approximately 6,796 m3
(8,890 yd3) of untreated materials would be removed from Silos 1 and 2, combined with approximately 3,785 L
(1,000 gallons) of sludge ffom the decant sump tank, and treated. Approximately 18,166 m3 (23,760 yd3) of
cement stabilized product would be packaged in containers and transported to NTS for disposal. Disposal of
contaminated materials from the berms, Silos 1 and 2 structures, the material removal eguipment, and the
cement stabilization system would be managed under the selected alternative for Subunit C. No five year
CERCLA reviews would be reguired since all Subunit A materials would be removed from the site. The
components of this alternative not previously described under alternative 3A.l/Vit are as follows.

Material Stabilization

Silos 1 and 2 residues and the decant sump tank sludge would be combined with cement and other additives
necessary for stabilizing the materials into a cement form. Similar to Alternative 3A.l/Vit, process
tanks/vessels and piping containing slurried K-65 residues would be designed to minimize potential radon and
radionuclide particulate emissions to the atmosphere during treatment. Studies conducted on a small scale in
a laboratory, as part of the Operable Unit 4 RI/FS, indicate that an estimated 150 percent increase can be
expected in the volume of waste reguiring disposal following stabilization. This increase is a result of the
large volume of additives needed to effectively stabilize the silo residues and decant sump tank sludge in
cement. These studies have also concluded that the cement stabilization of the wastes does not effectively
reduce the radon emission rate from the waste and the tendency of the waste to leach contaminants into
groundwater. The direct radiation associated with the untreated residues would be slightly reduced due to
the effects of mixing the additives with the residues. The solidified materials would be packaged in
containers for disposal.

Implementation Time and Costs

Remedial action activities under Alternative 3A.l/Cem could be completed in about six years. Approximately
three years are projected for completion of site preparation, facilities construction, and eguipment
installation. Material removal and treatment activities would reguire about three years. Transportation and
off-site disposal would conclude shortly after the completion of material processing. Capital costs for
Alternative 3A.l/Cem are estimated to be 71.8 million dollars. O&M costs during remediation are estimated at
11.7 million dollars over three years. Due to the off-site disposal option, there are no post-remediation
O&M costs associated with this alternative. The total present worth cost of this alternative is estimated at
73.1 million dollars.
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7.3 SUBUNIT B - CONTENTS OF SILO 3

This section presents the alternatives which were evaluated for Subunit B during the detailed analysis of
alternatives phase of the Operable Unit 4 FS. These alternatives focus on the remediation of the cold metal
oxides contained in Silo 3.

As discussed in Section 6, this evaluation assumes that the federal government would continue to own the FEMP
site. For a cleanup remedy to be considered protective, it should not result in any unacceptable risks to an
Operable Unit 4 expanded trespasser or an off-site farmer.

All alternatives would provide overall protection of human health and the environment. These alternatives
will eliminate, reduce, or control the health or environmental risks resulting from constituents in Subunit B
materials. All of the action alternatives, except Alternative 4B, would limit exposure to contaminants by
removing the material, treating the material by either vitrification or cement stabilization, and then
disposing the treated naterial in an on-property above-grade disposal vault (Alternative 2B) or off site at
NTS (Alternative 3B.1). Alternative 4B's protection is based on removal and disposal in an on-property
above-grade vault, and by retaining institutional controls. Long-term effectiveness would be attained for
each of these alternatives.

In summary, the preferred alternative (3B.l/Vit) would provide for overall protection because the Subunit B
residues would be vitrified and removed to the NTS to reduce the potential for contaminant migration to human
and ecological receptors.

7.3.1 Alternative 2B/Vit - Removal, Vitrification, and On-Property Disposal

Capital Cost: $25.2 M

O&M Costs:

During Remediation: $4.9 M

Post-Remediation: $3.2 M

Present Worth: $28.0 M

Years to Implement: 4

This alternative reguires the removal, vitrification, and on-property disposal of the Silo 3 contents. Under
Alternative 2B/Vit,approximatelyy 3,890 m3 (5,088 yd3) of untreated materials would be removed from Silo 3
and stabilized in a vitrified glass form. Following treatment, approximately 1,471 m3 (1,924 yd3) of
vitrified material would be packaged in containers and placed in an on-property above-grade reinforced
concrete disposal vault. The Silo 3 structural materials, associated soils, the material removal system and
the vitrification system would be managed under the selected alternative for Subunit C. In accordance with
CERCLA 121(c) reguirements, after commencement of remedial activities, a review would be performed every five
years by the EPA to ensure the continued protection of human health and the environment.

Material Removal

Due to the powder-like chances of Silo 3 cold metal oxide residues, Alternative 2B/Vit would utilize a
pneumatic removal process to transport Silo 3 contents to the material processing facility. The pneumatic
removal system consists of a compressed air driven pump that displaces and removes the dry wastes. Air
entrained in the cold meter oxides, suctioned from Silo 3, would be separated using filter/receiver systems
allowing the cold metal oxides to be pneumatically "pushed" to the vitrification facility. A glove box
system will be used at the interface of the pneumatic removal system and the silo dome to function as
secondary containment. This arrangement, along with appropriate operations procedures, would be designed to
prevent releases to the atmosphere during operations.
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Material Stabilization

The vitrification process is identical to that described in Section 7.2.1 for Alternative 3A.l/Vit.
Bench-scale studies conducted in a laboratory as part of the RI/FS for Operable Unit 4 indicate that
vitrification can effectively reduce the tendency of the Silo 3 residues to leach inorganics and
radionuclides to groundwater. This testing also demonstrated that over a 50 percent reduction in the volume
of material reguiring disposal could be achieved through the application of vitrification technology to the
Silo 3 residues. The vitrified residues would be packaged in containers for disposal.

Disposal of Treated Material

Studies completed on a bench scale as part of the RI/FS project that the volume of material reguiring
disposal can be reduced by over 50 percent as a result of applying the vitrification process. The vitrified
material would be containerized and disposed in an above-grade reinforced concrete disposal vault located on
property. The vault would be constructed on a reinforced concrete mat and eguipped with a leachate
collection/detection system to facilitate the collection of any contaminated leachate after final closure.
The capping system would be composed of alternating composite soil liners and drainage layers to minimize the
potential release of contaminated leachate to the underlying Great Miami Aguifer. The proposed disposal
facility would be located at a suitable location of the FEMP site.

Final closure would be completed by the construction of a multimedia cap over the vault. This cap would
include a clay cover to eliminate radon emanation from the disposed materials to the atmosphere and a barrier
to preclude intrusion by burrowing animals and hypothetical future residents of the area. Upon completion of
the multimedia cap, security controls such as fencing would be installed. Monitoring wells would be
appropriately located to evaluate the effectiveness of the above-grade disposal vault in ensuring long-term
protection of human health and the environment.

To provide added assurance against any future activities by humans to intrude into the disposal vault,
permanent markers would be installed to identify the vault, and restrictions would be placed on the site.
Additionally, in order to ensure long-term protectiveness for this alternative, it is assumed that the
effected disposal areas at the FEMP would reguire the continued ownership by the federal government. While
the disposal vault would be designed to not reguire any continued active operations or maintenance, long-term
ownership would permit the government to continue to exercise the right to preclude any development or
drilling in areas where contaminated materials are disposed.

All facilities and eguipment installed and used by this alternative would be disassembled and decontaminated
during the post-remediation phase. Contaminated materials would be disposed in accordance with the selected
remedy for Subunit C.

Implementation Time and Costs

Remedial action activities under Alternative 2B/Vit could be completed in about four years. Site preparation
and construction activities would take approximely three years. Removal and material processing activities
would reguire about one year. Capital costs for Alternative 2B/Vit are estimated to be 25.2 million dollars.
O&M costs during remediation are estimated at 4.9 million dollars over one year, while post-remediation O&M
costs are estimated at 3.2 million dollars over a thirty year period. The total present worth cost for this
alternative is estimated at 28.0 million dollars.

7.3.2 Alternative 2B/Cem - Removal, Cement Stabilization, and On-Property Disposal

Capital Cost: $35.9 M

O&M Costs:

During Remediation: $4.9 M

Post-Remediation: $3.2 M
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Present Worth: $37.4 M

Years to Implement: 4

This alternative uses the material removal methodology presented in Alternative 2B/Vit, followed by treatment
of the Silo 3 contents by cement stabilization and on property disposal of the stabilized material. Under
Alterntive 2B/Cem, appoximately 3,890 m3 (5,088 yd3) of untreated materials would be removed from Silo 3 and
stabilized in a cement form. Approximately 5,999 m3 (7,846 yd3) of stabilized material would be packaged in
contains and placed in an on-property above-grade reinforced concrete disposal vault. The Silo 3 structural
materials, the material removal system, and the cement stabilization system and associated soils would be
remediatet with the selected alternative for Subunit C. In accordance with CERCLA 121(c) requirements, after
commencement of remedial activities, a review would be performed every five years by the EPA to ensure the
continued protection of human health and the environment. The components of this alternative not previously
discussed are as follows.

Material Stabilization

The cement stabilization process is identical to that described in Section 7.2.2 for Alternative 3A. 1/Cem
with the exception of differences in the cement formulations required to accommodate physical and chemical
differences between K-65 residues and Silo 3 cold metal oxides. The FS Report for Operable Unit 4, Appendix
C, discusses the results of bench scale treatability studies which indicate that cementation of the Silo 3
metal oxides would result in an approximately 50 percent increase in the volume of treated material requiring
disposal.

Implementation Time and Costs

Remedial action activities under Alternative 2B/Cem could be completed in about four years. Site preparation
and construction activities would take approximately three years. Removal and material processing activities
would require about one year. Capital costs for Alternative 2B/Cem are estimated to be 35.9 million dollars.
O&M costs during remediation are estimated at 4.9 million dollars over one year, while post-remediation O&M
costs are estimated at 3.2 million dollars over a thirty year period. The total present worth cost for this
alternative is estimated at 37.4 million dollars.

7.3.3 Alternative 3B.l/Vit - Removal, Vitrification, and Off-Site Disposal - NTS

Capital Cost: $26.8 M

O&M Costs:

During Remediation: $4.9 M

Post-Remediation: $0

Present Worth: $28 M

Years to Implement: 4

This alternative involves the removal, stabilization, and off-site disposal of the Silo 3 contents. This
alternative is identical to Alternative 2B/Vit, except the on-property disposal, monitoring, and
institutional controls have been replaced by the transportation of the treated material by rail and/or truck
to the NTS fr disposal. Under Alternative 3B.l/Vit, approximately 3,890 m3 (5,088 yd3) of untreated mataials
would be removed from the silo. Approximately 1,471 m3 (1,923 yd3) of vitrified material would be packaged
in containers and transported to NTS for disposal. Alternative 3B.l/Vit would have to meet applicable
off-site requirements, which include the NTS material acceptance criteria and DDI regulations pertaining to
the transport of hazardous and radioactive materials. No five-year reviews would be required since all
Subunit B wastes would be removed from the site under this alternative.
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Implementation Time and Costs

Remedial action activities under Alternative 3B.l/Vit could to be completed in about four years. Site
preparation and construction activities would take approximately three years. Removal activities would
require about one year. Transportation and off-site disposal would conclude shortly after the completion of
material processing. Capial costs for Alternative 3B.l/Vit are estimated to be 26.8 million dollars. O&M
costs during remediation are estimated at 4.9 million dollars over one year. Due to the off-site disposal
option, there are no post-remediation O&M costs associated with this alternative. The total present worth
cost of this alternative is estimated at 28 million dollars.

7.3.4 Alternative 3B.l/Cem - Removal, Cement Stabilization, and Off-Site Disposal - NTS,

Capital Cost: $36.8 M

O&M Costs:

During Remediation: $4.1 M

Post-Remediation: $0

Present Worth: $36 M

Years to Implement: 4

This alternative is identical to Alternative 3B.l/Vit (Section 7.3.3), except that Silo 3 contents would be
stabilized in cement prior to off-site disposal at NTS as described for Alternative 2B/Cem (Section 7.3.2).
Under Alternative 3B.l/Cem, approximately 3,890 m3 (5,088 yd3) of contaminated materials would be removed
from Silo 3. Approximately 5,999 m3, (7,846 yd3), of stabilized material would be transported to NTS for
disposal. No five-year reviews would be required since all Subunit B wastes would be removed from the site
under this alternative.

Implementation Time and Costs

Remedial action activities under Alternative 3B.l/Cem could be completed in about four years. Site
preparation and construction activities would take approximately three years. Removal activities would
require about one year. Transportation and off-site disposal would conclude shortly after the completion of
material processing. Capital costs for Alternative 38.1/Cem are estimated to be 36.8 million dollars. O&M
costs during remediation are estimated at 4.1 million dollars over one year.

Due to the off-site disposal option, there are no post-remediation O&M costs associated with this
alternative. The total present worth cost of this alternative is estimated at 36 million dollars.

7.3.5 Alternative 4B - Removal and On-Property Disposal

Capital Cost: $21.8 M

O&M Costs:

During Remediation: $1.1 M

Post-Remediation: $3.2 M

Present Worth: $22.0 M

Years to Implement: 2

This alternative requires removal of the Silo 3 contents, packaging, and on-property disposal of the
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untreated material. This alternative is identical to Alternative 2B, with the exception that it does not
include treatment. Under Alternative 4B, approximately 3,890 m3 (5,088 yd3) of contaminated materials would
be removed from Silo 3 and packaged in containers for disposal in an on-property above grade reinforced
concrete disposal vault. The Silo 3 structural materials, associated soils, and removal system would be
managed under the Subunit C alternative. In accordance with CERCLA 121(c) reguirements, after commencement
of remedial activities, a review would be performed every five years by the EPA to ensure the continued
protection of human health and the environment.

Implementation Time and Costs

Remedial action activities under Alternative 4B could be completed in about two yesrs. Site preparation and
construction activities would take approximately one year. Removal and packaging activities would reguire
about one year. Capital costs for Alternative 4B are estimated to be 21.8 million dollars. O&M costs during
remediation are estimated at 1.1 million dollars over one year. Post-remediation O&M costs are estimated to
be 3.2 million dollars. The total present worth cost of this alternative is estimated at 22 million dollars.

7.4 SUBUNIT C - SILOS 1,,2, 3, AND 4 STRUCTURES, SOILS, AND DEBRIS

This section presents the alternatives which were evaluated for Subunit C during the detailed analysis of
alternatives phase of the FS for Operable Unit 4. These alternatives focus on the remediation of Silos 1, 2,
3, and 4 structures, contaminated soils within the Operable Unit 4 boundary including surface and subsurface
soils and the earthen berms around Silos 1 and 2, the existing Ration Treatment System (RTS), the K-65 Drum
Handling Building pad, standing water within Silo 4 (if any), the decant sump tank, the process piping and
trenches, and any rubble or debris [i.e., decontamination and decommisioning (D&D) of the treatment facility]
generated conseguential to the implementation of remedial actions for all Operable Unit 4 subunits. The
volumes of soil, rubble, and debris to be generated under Subunit C are small in comparison to the volume of
similar materials that will be generated by other FEMP operable units. All the Subunit C alternatives
evaluated through detailed analysis consider integration of disposal activities with Operable Unit 3 and
Operable Unit 5. These integration efforts allow waste minimization initiatives developed for Operable Units
3 and 5 to be integrated into the final remedy chosen for Subunit C materials.

As discussed in Section 6, evaluations were conducted for future land uses with and without continued federal
ownership. For a cleanup remedy to be considered protective, it would not result in any unacceptable risks
to an Operable Unit 4 expanded trespasser or an off-site farmer under the future land use with continued
federal ownership scenario.

All of the evaluated alternatives would limit exposure to constituents by decontaminating, demolishing, and
removing the material to either an on-property above-grade disposal facility or off-site disposal facility,
and then excavating contaminated soils and placing clean fill over residual contaminated substance soils.
The placement of the clean fill was not used as a measure to limit exposures but rather to restore the
natural drainage patters and promote revegetation. Table 9-2 summarizes the proposed remedial levels for
soils, all of which wald be protective to the Operable Unit 4 expanded trespasser, trespassing child and
off-site resident over the long-term. Short-term risks would be higher for off-site disposal due to the
increased risk of transportation accidents. These action alternatives would be protective of all anticipated
receptors assumming continued federal government ownership and control of the area; this includes the
off-site farmer and the Operable Unit 4 expanded trespasser receptors.

The basic difference among the action alternatives is the disposal option. On-property disposal (Alternative
2C) would be in an above-grade disposal facility. Off-site disposal options include NTS (Alternative 3C.1)
and a permitted commercial disposal site (Alternative 3C.2).

The on-property, above grade disposal facility would be designed for a 1,000 year life with no active
maintenance. Fate and transport modeling using conservative assumptions concludes that protectiveness would
be maintained over the long-term. NTS and the permitted commercial disposal facility would incorporate
engineering controls to ensure protectiveness. Both are located in a climatic, demographic, and
hydrogeologic setting which favors minimization of constituent migration to human or environmental receptors.
Short-term risks to the public and workers are slightly greater for the off-site disposal options due to the
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increased risks of transportation accidents resulting in injuries or radiation exposure.

For all of the Subunit C alternatives, hazardous substances (i.e., contaminated soil or debris) will remain
on site at levels which preclude unlimited use or unrestricted exposure. Therefore, in accordance with the
requirements of CERCLA 121(c), all the Subunit C alternatives would require that a review be conducted every
five years, after commencement of remediation to ensure that the alternative continues to provide adequate
protection of human health and the environment.

7.4.1 Alternative 2C - Demolition, Removal, and On-Property Disposal

Capital Cost: $36.3

O&M Costs:

Durinq Remediation: $0

Post-Remediation: $3.6 M

Present Worth: $34.3 M

Years to Implement: 2

Alternative 2C involves the demolition of the Silos 1, 2, 3, and 4 structures and disposal of the materials
from the removal of the earthen berm, decant sump tank, process pipinq, and trenches. Alternative 2C further
addresses the excavation of contaminated subsurface soils within the operable unit boundary and disposal of
the debris qenerated as a result of implementinq remedial actions for Subunits A and B. Contaminated
material would be placed in an above-qrade disposal vault at the FEMP site. Under Alternative 2C,
approximately 34,956 m3 (45,748 yd3) of material would be placed in an on-property above-qrade disposal
vault.

Demolition and Decontamination of the Silo Structures

Before Silos 1, 2, 3, and 4 are demolished, loose interior materials and concrete would be removed from the
silo surfaces. Concrete exhibitinq hiqhly elevated direct radiation levels would be seqreqated from other
Subunit C waste and dispositioned as part of the selected remedy for Subunit A. Silo demolition would
consist of the systematic decontamination, removal, dismantlinq, and disposal of the Silos 1, 2, 3, and 4
domes, walls, floor slabs and footers. Removal would involve cuttinq each of the silo structures into
manaqeable pieces after appropriate bracinq has been installed. The demolition would beqin wth the
dismantlinq of Silo 4, since this silo has never been used, makinq it an ideal full-scale model to test and
confirm demolition methodoloqies with minimal risk of radioloqical release to the environment Based on
experience obtained throuqh the dismantlinq of Silo 4, demolition of Silos 1, 2, and 3 would proceed
accordinq to the sequencinq and procedures established durinq the remedial desiqn and remedial action phases.

Demolition and Decontamination of Other Operable Unit 4 Structures

The existinq RTS, Drum Handlinq Buildinq pad, sump lift station foundation, concrete pipe trench, and the
decant sump would also be removed and decontaminated. It is estimated that approximately 790 m (2,600 ft) of
process pipinq in the process pipinq trenches would be cut into manaqeable sections and disposed. It is
estimated that 280 m3, (365 yd3 of concrete from the trench, decant sump tank process pipinq, and existinq
RTS would be disposed. Additionally, all facilities constructed and equipment installed and used to
implement the selected alternatives for Subunit A and B would be dissasembled, decontaminated (if necessary),
and either recycled, reused, or disposed.

Non porous materials, such as steel fencinq and structural steel, attaininq the unrestricted use, free
release criteria defined in DOE Order 5400.5 would be released from the site as uncontaminated Materials not
attaininq these levels would be retained for disposal as contaminated waste consistent with the approved
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Operable Unit 3 Record of Decision.

Remediation of Soil

After the silos are demolished, the contaminated surface soils within the boundary of Operable Unit 4 would
be excavated to attain proposed remediation levels for each of the constituents of concern. After the silos
are demolished, the contaminated surface soils within the boundary of Operable Unit 4 would be excavated to
attain proposed remediation levels, as described in Section 9.2.2 of this ROD, for each of the contaminants
of concern. Attainment of these levels would be demonstrated applying regulatory guidance available at the
time. The cleanup levels are considered protective of the hypothetical expanded trespasser receptor. To
attain these goals, a minimum of 15 centimeters.(cm) [6 inches (in)] of soils across the entire operable unit
area would be excavated. Additional soils beneath the silos, decant sump tank, concrete pipe trench, or
other locations below this depth would be removed as necessy to attain these cleanup goals.

Soils exhibiting highly elevated direct radiation levels (i.e., potentially contaminated soils beneath Silos
1 and 2) would be segregated from other Subunit C wastes and dispositioned as part of the selected remedy for
Subunit A. Following excavation, the affected areas would be resumed to original grade with the placement of
clean backfill and seeded. The area would then be fenced and appropriate signs placed indicating no
trespassing and no hunting. Continued federal ownership with appropriate deed restrictions would be
implemented to ensure that any future transfer of property would be consistent with CERCLA 120(h).

Water Treatment

Wastewater generated as a result of this remedial action, along with water removed from the decant sump tank,
Silo 4 (if any), and any perched groundwater encountered during remedial activities would be collected,
pretreated if necessary, and sent to the FEMP Advanced Wastewater Treatment facility for treatment prior to
discharge to the Great Miami River. In accordance with the Amended Consent Agreement, groundwater
remediation will be handled by Operable Unit 5. Operable Unit 4 would only handle the cleanup of perched
water encountered during remedial action activities.

Disposal of Soil, Debris, and Rubble

The volume of contaminated soil, rubble, and debris to be addressed under Operable Unit 4 represents a small
fraction (less than one percent) of the total volume of similar wastes to be addressed under Operable Units 5
and 3. Operable Unit 3 is currently in the process of conducting a RI/FS which will include gaining
additional insight into the effectiveness of various decontamination technologies on building materials.
Additionally, the Operable Unit 3 RI/FS is evaluating the appropriate type and location of disposal for
contaminated rubble and debris. The decision on the Operable Unit 3 RI/FS is presently scheduled at a tune
which coincides with the implementation of remedial actions for Operable Unit 4.

Contaminated soil and debris generated from the selected remedy for Operable Unit 4 will be placed into
interim storage, if necessary, and final disposition of that material will be determined as part of the
Record of Decision for Operable Units 5 and 3. Placing the Operable Unit 4 on-property disposal decision in
abeyance permits an integrated site-wide (FEMP) disposal approach for soil and debris. In addition, Operable
Unit 4 would be able to take advantage of any applicable waste minimization initiatives developed for soil
and debris by Operable Units 5 and 3 respectively.

Implementation Time and Costs

Approximately three months would be reguired for site preparation; 15 months would be reguired to demolish
and decontaminate the silo structures as well as the surface soil, berm soils, subsurface soils, process
piping, and decant sump tank. Demobilization activities would extend the duration of the alternative to two
years. During this time frame, the above-grade disposal facility would also be constructed and capped.
Capital costs for Alternative 2C are estimated to be 36.3 million dollars. Post-remediation O&M costs are
estimated to be 3.6 million dollars. Tbe total present worth cost of this alternative is estimated at 34.3
million dollars.
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7.4.2 Alternative 3C. 1 - Demolition, Removal, and Off-Site Disposal - NTS

Capital Cost: $83.6 M

O&M Costs: $0

Present Worth: $75.5 M

Years to Implement: 2

This alternative is identical to Alternative 2C, except that the on-property disposal, monitoring, and
institutional controls have been replaced by packaging and off-site transportation of the material by rail or
truck to the NTS for disposal. Tbe off-site disposal option for Alternative 3C.1 involves the packaging,
loading, and shipping of the material generated by this alternative to the NTS.

Implementation Time and Costs

Remedial actions for Alternative 3C.1 could reguire about two years to complete, including the transportation
of the packaged materials to tbe NTS. Capital costs for Alternative 3C.1 are estimated to be 83.6 million
dollars. Due to the off-site disposal aspect of this alternative, there are no O&M costs anticipated. The
total present worth cost of this alternative is estimated at 75.5 million dollars.

7.4.3 Alternative 3C.2 - Demolition, Removal, and Off-Site Disposal (Permitted Commercial Disposal Site)

Capital Cost: $48.6 M

O&M Costs: $0

Present Worth: $44.0 M

Years to Implement: 2

This alternative is identical to Alternative 3C.1, except that the off-site disposal at the NTS has been
replaced by the off-site disposal at a permitted commercial disposal site and the waste will not be packaged,
but rather it would be shipped in bulk. One such site is located near Clive, Utah, approximately 3,058 km
(1,900 mi) from the FEMP site. The facility has been permitted by the State of Utah to accept mixed
hazardous waste and naturally occurring by-product materials such as those in Subunit C.

Disposal

Due to its relatively long distance from the FEMP site, coordination with several states for transportation
of Subunit C wastes would be reguired. Additionally, an exemption from DOE Order 5280.2A prohibiting
disposal of DOE wastes at a commercial facility would be needed for the Operable Unit 4 waste before it could
be transported to the disposal site.

Implementation Time and Costs

Remedial actions for Alternative 3C.2 would reguire about two years to complete, including the transportation
of the materials to a permitted commercial disposal site. Capital costs are estimated to be 48.6 million
dollars. Due to the off-site disposal option, no operation and maintenance (O&M) costs are anticipated for
Alternative 3C.2. The total present worth cost of this alternative is estimated at 44.0 million dollars.

8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

8.1 EVALUATION CRITERIA

Specific legal reguirements for remedial actions are specified under CERCLA Section 121. These reguirements
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include protection of human health and the environment, compliance with ARARs (unless a waiver is obtained),
a preference for permanent solutions which use treatment as a principal element (to the maximum extent
possible), and cost-effectiveness. To determine whether alternatives meet the requirements, EPA has
identified nine criteria in the National Oil and Hazardous Substances Pollution Contingency Plan that must be
evaluated for each alternative selected for detailed analysis. These criteria are as follows:

1. Overall protection of human health and the environment: Examines whether a remedy would provide
adequate overall protection to human health and the environment in the short- and lonq-term. Evaluates how
risks would be eliminated, reduced, or controlled through treatment, engineering controls, or institutional
controls included in the alternative.

2. Compliance with ARARs: Addresses whether the alternative attains compliance with federal and state
environmental laws and requirements, unless a waiver of an ARAR applies.

3. Long-term effectiveness and permanence: Evaluates the permanence of the remedy, long term
effectiveness and likelihood that the remedy will be successful.

4. Reduction of toxicity, mobility, or volume through treatment: Reviews the anticipated treatment
technologies to reduce the hazards of, prevent the movement of, or reduce the quantity of waste materials.

5. Short-term effectiveness: Evaluates the ability of a remedy to achieve protection of workers, the
public, and the environment during construction and implementation of the remedial action.

6. Implementability: Examines the practicality of carrying out a remedy, including the availability of
materials and services needed during implementation of the remedial action.

7. Cost: Reviews both estimated capital and operation and maintenance costs of the remedy. Costs are
presented as present worth costs. "Present worth" is defined as the amount of money that, if invested in the
first year of implementing a remedy and paid out as needed, would be sufficient to cover all costs associated
with the remedy over its planned life. Present worth costs allow remedies that would occur over different
time periods to be compared on an even basis.

8. State Acceptance: Evaluates the technical and administrative issues and concerns that the State of
Ohio may have regarding each of the alternatives; and the State comments on ARARs or proposed use of waivers.

9. Community Acceptance: Evaluates the issues and concerns the public may have regarding each of the
alternatives, including which parts of the alternatives are supported or opposed.

The first two criteria are considered threshold criteria and must be met by the final remedial action
alternatives for Operable Unit 4 (unless a specific ARAR is waived). The next five criteria are considered
primary balancing criteria and are considered together to identify significant tradeoffs that must be
addressed. The last two are considered modifying criteria which are considered in final remedy selection.
The alternatives comparison for each subunit is summarized in Table 8-1.

8.2 COMPARATIVE ANALYSIS OF ALTERNATIVES

The following sections summarize the information presented in Section 5.0 of the FS Report for Operable Unit
4 and rely upon the detailed analysis of alternatives presented in Section 4.0 of the same report.

8.2.1 Analysis for Subunit A

8.2.1.1 Threshold Criteria

The analysis of the Subunit A alternatives against the threshold criteria of overall protection of human
health and the environment and compliance with ARARs is summarized below.

Overall Protection of Human Health and the Environment. As part of the FS, two potential future land uses of
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the FEMP were evaluated to assess the ability of the individual alternative to adequately protect human
health and the environment. These land uses consider potential exposures to contaminants released during or
following the implementation of the alternatives and were evaluated for a range of viable receptors. These
scenarios included future land use with and without the assumption of continued federal ownership. With
continued government ownership, the FEMP land would not be available for residential or farming use. Access
to the site would be limited by fencing and physical markers, it would be reasonable to assume that an
Operable Unit 4 expanded trespasser would visit the site occasionally.

It is also assumed that the land surrounding the FEMP site would continue to be used for family farms. For a
cleanup remedy to be considered protective, it should not result in any unacceptable risks to an expanded
trespasser or an off-site farmer. The evaluation also considers the future possibility that the federal
government might not have control of the FEMP site. In that case, a farm might be established on the FEMP
property. The remedial alternatives were evaluated as to what risks might exist for a hypothetical
on-property farmer if government control is no longer present. The basis for and detailed results of these
evaluations are in Appendix D of the FS Report for Operable Unit 4.
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TABLE 8-1

COMPARISON OF REMEDIAL ALTERNATIVES

SUBUNIT A - SILOS 1 AND 2 CONTENTS

Overall Reduction of Total
Protection of Long-Term
Toxicity, Mobility Present
Human Health Compliance with Effectiveness and or volume Short-Term Worth
Alternative and Environment ARARs Permanence through
treatment Effectiveness Implementability Cost

OA - No Action Not Protective Does not comply Not effective or No
treatment; High Easy -0-
with all ARARs permanent
therefore, no

reduction

3A.l/Vit - Removal, Vitrification, Protective Complies with Effective and Reduces
toxicity, Medium Innovative $43.7M
Off-Site Disposal - Nevada Test all ARARs most reliable
mobility, and technology,
Site volume Difficult

3A.l/Cem - Removal, Cement
Stabilization, Off-Site Disposal - Protective Complies with Effective and most Reduces
mobility Medium Reliable $73.1M
Nevada Test Site all ARARs reliable technology,
Difficult

lAssessment of protectiveness adopts the use of continued federal government ownership and evaluates risk to
expanded trespasser and the off-property farmer.
2Assumes substantive technical reguirements for Ohio disposal facility siting are met.
Bold--Preferrred Remedial Action Alternative.
Shaded areas—Did not meet threshold criteria (Overall Protection or Compliance with ARARs), therefore, not
compared.
Protective—Risk is within the one in ten thousand to one million (104 to 106) EPA target risk range.
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FINAL
FEMP-OU4ROD-8

December 1994
SUBUNIT B - SILO 3 CONTENTS
Alternative

OB - No-Action
Overall
Protection of
Human Health
and environment
TABLE 8-1
(Continued)
Compliance with
ARARs
Reduction of Total
Long-Term Toxicity, Mobility
Effectiveness and or volume Short-Term
Permanence through treatment Effectiveness
reduction
Not Protective Does not comply Not effective or No treatment;
with all ARARs permanent therefore, no
High
Present
Worth
Implementability Cost

Easy -0-
2B/Vit - Removal, Vitrification, Protectivel
Reduces toxicity, Medium Innovative
On-Property Disposal
Complies with all Effective and
$28M
ARARs2 reliable mobility, and
volume Moderately
Difficult
2B/Cem - Removal, Cement
Stabilization, On-Property Protectivel
Disposal ARARs2
3B.l/Vit - Removal, Protective
Reduces Medium Innovative $28M
Vitrification, Off-Site Disposal -
mobility and technology,
NTS

3B.l/Cem - Removal, Cement Protective
Reduces Medium Reliable $36M
Stabilization, Off-Site Disposal -
mobility technology,
Complies with all Effective and
reliable mobility
Complies with all Effective and most

ARARs reliable

volume

Complies with all Effective and most

ARARs reliable
Reduces
technology,
Easy
technology,
Medium
Reliable
$37.4M
Difficult
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NTS Difficult

4B - Removal and On-Property Protectivel Complies with all Effective and No
treatment; High Reliable $22M
Disposal ARARs2 reliable
therefore, no technology,
reduction Easy

lAssessment of protectiveness adopts the use of continued federal government ownership and evaluates risk to
expanded trespasser and the off-property farmer.
2Assumes substantive technical reguirements for Ohio disposal facility siting are met.
Bold--Preferrred Remedial Action Alternative.
Shaded areas—Did not meet threshold criteria (Overall Protection or Compliance with ARARs), threfore, not
compared.
Protective—Risk is within the one in ten thousand to one in a million USEPA target risk range.
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FINAL
FEMP-OU4ROD-8

December 1994
TABLE 8-1
SUBUNIT C - SILOS 1,2,3 and 4 STRUCTURES, SOILS, and DEBRIS
Alternative

OC - No Action
Overall
Protection of
Human Health
and Environment
Compliance
Permanence
(Continued)
Reduction of Total
Long-Term Toxicity, Mobility Present
Effectiveness and or volume Short-Term Worth
through treatment Effectiveness Implementability Cost
Not Protective
ARARs
Does not comply with all Not effective or No treatment;
permanent therefore, no
reduction
High
Easy
-0-
2C - Demolition, Removal,
On-Site Disposal
Protectivel Complies with all Effective and
ARARs2 reliable therefore, no
reduction
No treatment; Mediunm Reliable $34.3M
technology,
Easy
3C.1 - Demolition, Removal,
Off-Site Disposal - Nevada Protective Complies with all Effective and most
No treatment; Medium Reliable $75.5M
Test Site ARARs reliable
therefore, no technology,
reduction Moderately
difficult
3C.2 - Demolition, Removal, Protective Complies with all
No treatment; Medium Reliable $44M
Off-Site Disposal - Permitted ARARs
Commercial Facility
Effective and most

therefore, no

difficult
reliable
reduction
technology
Moderately
lAssessment of protectiveness adopts the use of continued federal government ownership and evaluates risk to
expanded trespasser and the off-property farmer.
2Assumes substantive technical reguirements for Ohio disposal facility siting are met.
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Bold--Preferrred Remedial Action Alternative.
Shaded areas—Did not meet threshold criteria (Overall Protection or Compliance with ARARs), threfore, not
compared.
Protective—Risk is within the one in ten thousand to one in a million USEPA target risk range.
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All of the alternatives would provide protection of human health and the environment by eliminating,
reducing, or controlling risk through treatment, engineering controls, or institutional controls. The
preferred alternative (3A.l/Vit) would provide for overall protection, because the Subunit A residues would
be treated and removed to the NTS. The source of risks to the Operable Unit 4 expanded trespasser and
off-site farmer would be eliminated, and in the event that the government lost control of the FEMP site,
there would be no risk from Subunit A residues to an on-property farmer. Overall protection at the NTS would
be maintained because the vitrified residues resist leaching and the NTS is located in a sparsely populated,
arid region, where depths to groundwater are at least 235 m (771 ft) below the surface.

Compliance with ARARs. CERCLA reguires that remedial actions achieve a standard or level of control that is
consistent with federal and state environmental laws or state siting regulations, which are termed applicable
or relevant and appropriate reguirements (ARARs). ARARs apply to all aspects of remedial action, including
the establishment of cleanup levels, the operation and performance of treatment systems, and the design of
disposal facilities. In addition to meeting ARARs, operations at DOE-owned facilities must be conducted
according to DOE Orders. Although DOE Orders are not promulgated standards, the technical reguirements may
be adapted if they cover areas not addressed by other laws, or if they improve protection of human health and
the environment because they are more stringent than existing laws. Detailed discussion of compliance with
ARARs is provided in Appendix F of the FS Report for Operable Unit 4.

With the exception of Alternatives 2A/Vit, 2A/Cem (see Section 11 for details) and the no action alternative,
all of the Subunit A alternatives would meet ARARs. Since the preferred alternative, Alternative 3A.l/Vit,
includes off-site disposal at NTS, there would be no long-term compliance issues associated with the FEMP
site. For example, off-site disposal would eliminate the need to demonstrate that drinking water MCLs are
attained for Subunit A residues. In the short-term, the on-property remediation activities during removal
and treatment would address the operational reguirements for airborne emissions, soil pathways, and
penetrating radiation by engineered controls.

For Alternative 3A.l/Vit, the packaging and transportation of the treated waste would comply with the
reguirements for the protection of worker and public safety from the radiological hazards (49 CFR §171-177).
This alternative would also comply with other off-site reguirements, such as the waste acceptance criteria
specified by NTS, to meet their disposal reguirements. The probability of an inadvertent intruder coming in
contact with the Subunit A residues at NTS is less than that for the FEMP site, based on the demographic
characteristics of both locations.

8.2.1.2 Primary Balancing Criteria

Those alternatives which satisfy the threshold criteria comparative analysis were carried forward to the
primary balancing criteria for further comparative analysis. Because Alternative OA (No Action) did not
satisfy either of the threshold criteria, and Alternatives 2A/Vit and 2A/Cem (see Section 11 for details) do
not satisfy compliance with specific ARARs, these alternatives were not considered further in this analysis.

Long-Term Effectiveness and Permanence. Alternatives 3A.l/Vit and 3A.1/Cem would ensure long-term
protectiveness to human health and the environment because residual risks to viable receptors (off-site
farmer and expanded trespasser) would be less than a 10-6 incremental lifetime cancer risk, and no
non-carcinogenic effects (hazard index less than 0.2) would be indicated for either receptor.

All alternatives involve the removal and treatment of Subunit A residues by either vitrification or cement
stabilization. The preferred alternative would be most effective based on the results of bench-scale
treatability studies conducted during the RI/FS (Feasibility Study Report for Operable Unit 4, Appendix C) on
the Subunit A materials which demonstrated that vitrification would be effective in reducing radon emanadon
and in minimizing the leaching of constituents. Tests using cement stabilization demonstrated that this
process would be effective in preventing the movement of constituents from the stabilized form; however,
there was little or no reduction in radon emanation rates. The vitrified material is expected to have
greater durability over the long term.

The characteristics (i.e., demographics, climate, geology, groundwater level) of the NTS would provide for
greater certainty than FEMP on-properny disposal over the long term, that the treated residues would not
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affect human health and the environment.

Reduction of Toxicity, Mobility, or Volume through Treatment. Alternative 3A.1/Vit would use the
vitrification process to treat the Subunit A material. This technology would physically bind the
contaminants in a glass-like matrix which would significantly reduce contaminant mobility and material
volume. Mobility would be reduced because the contaminants would be bound in the matrix and the volume of
the treated material would be less than 50 percent of the untreated material volume. Vitrification would
also destroy organic contaminants in the treated material. Although most contaminants in the treated
material would be incorporated into the vitrified product to reduce mobility over the long term, some
contaminants would be released during the vitrification process and must be treated through an off-gas
treatment system. The material generated through the off-gas treatment system may reguire stabilization to
limit subseguent contaminant mobility.

Alternative 3A.1/Gem-would use the cement stabilization process to treat contaminated material. This
technology will physically and chemically bind the constituents in a cement-like matrix, so the mobility of
constituents via leaching from this treated material would be greatly reduced. However, organic constituents
would not be destroyed. The total volume of material would increase by approximately 150 percent as a result
of adding the cement stabilizing and setting agents.

Alternative 3A.l/Vit is favored over Alternative 3A.1/Cem because they would: reduce the toxicity of organic
comaminants; more effectively reduce the radon emanation from the treated material; generate a treated form
which has very good resistance to leaching; and significantly reduce the volume of Subunit A materials.

Short-Term Effectiveness. Alternatives 3A.l/Vit and 3A.l/Cem, the various removal, treatment, and disposal
activities will result in increased short-term risks for exposures (compared to no action). The short-term
effectiveness of the material removal operations is expected to be the same among all alternatives for
Subunit A. There is some uncertainty associated with controlling and treating the off- gases generated by
the vitrification process. The on-property risks for 3A.l/Cem from transportation would be higher than
3A.l/Vit, because the increased volume of the treated material would increase the number of potential
transportation accidents. Short-term impacts at the NTS associated with the transportation and off-loading
of the treated residues would be indistinguishable from normal operations.

In summary, Alternative 3A.l/Cem is favored over Alternative 3A.l/Vit because of the uncertainty associated
with off-gas control and treatment for the vitrification process.

Implementability. The removal and treatment activities in Alternative 3A.l/Cem could be implemented using
standard eguipment, procedures, and readily available resources. Hydraulic removal is a standard mining
technology that is normally reliable and uses readily available eguipment. The cement stabilization
technology has been applied successfully at a number of remedial sites. EPA considers cement stabilization a
demonstrated treatment technology and has approved its use in the final remedy for many NPL sites. This
technology has also been applied at other sites that have radioactively contaminated waste. The cement
stabilization process would reguire large guantities of cement, flyash, and blast furnace slag, which are
available.

Although removal and disposal are the same for Alternative 3A.1/Vit as for Alternative 3A.l/Cem, the
vitrification process is more difficult to implement than the cement stabilization process. The
vitrification process would reguire fewer chemical reagents than the cement stabilization process, but larger
amounts of energy (electricity). Vitrification would allow the re-processing of off-specification treated
materials compared to cement stabilization. However, the vitrification process eguipment would be more
complex to construct and operate than that of the cement stabilization process. There is limited experience
available for the types and guantities of the material from the silos and decant sump tank on which to base
an assessment of the likely performance of the vitrification technology. The vitrification technology is not
as widely available as the cement stabilization technology. Off-gas treatment is also an additional
complexity with vitrification where delays could occur. However, operational experience is being gained as
part of the structured RI/FS treatability studies and planned vitrification pilot studies currently in
progress.
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Alternatives 3A.l/Vit and 3A.l/Cem involve off-site transportation and disposal at the NTS. While
technically straightforward, off-site transportation would require coordination efforts with a number of
states located along the transportation route, as well as the State of Nevada. Demonstrated compliance with
the NTS waste acceptance criteria would be required prior to shipping the Subunit A materials. The
transportation of this material would also comply with the off-site acceptability amendment to CERCLA's
implementing regulations, the National Contingency Plan [58 FR 49200 (September 22, 1993)].

In summary, Alternative 3A.l/Cem would be favored over Alternative 3A.1/Vit, based on relative overall
implementation.

Cost. The estimated total present worth costs for the Subunit A alternatives are provided on Table 8-2, and
include a breakdown of capital and operating and maintenance costs. The present worth cost of Alternative
3A.l/Cem is approximately 67 percent more expensive than Alternative 3A.l/Vit, primarily due to the
additional packaging, transportation, and disposal for the larger volume of cement-stabilized material.

8.2.1.3 Modifying Criteria

State Acceptance

The State of Ohio reviewed the preferred remedial alternative for Subunit A that was provided in the PP, and
concurs with the selection of Alternative 3A.l/Vit. A letter from the OEPA conditionally approving the FS
and PP for Operable Unit 4 can be found in Appendix E of this ROD.

Community Acceptance

DOE solicited input from the community on the preferred remedial alternative for Subunit A that was provided
in the PP. Verbal comments received during the public meeting indicated support of the chosen remedial
alternative. Written comments received during the public comment period are addressed in the responsiveness
summary (see Appendix C).

8.2.1.4 Subunit A Comparative Analysis Summary

Alternative 3A.l/Vit is identified as the preferred alternative because it would result in the permanent
treatment and volume reduction of Subunit A materials and it is cost effective. It would provide overall
protection of human health and the environment with fewer uncertainties over the long-term.

8.2.2 SUBUNIT B

8.2.2.1 Threshold Criteria

Subunit B alternatives would employ the same removal, treatment, and disposal options as those for Subunit A
materials. Many of the factors considered and discussed under the Subunit A analysis are identical for
Subunit B. Therefore, frequent references will be made to the information presented previously in Section
8.2.1. Only those factors unique to remediation of the Subunit B materials will be emphasized. This
approach will be applied to the discussions under the primary balancing criteria as well.
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TABLE 8-2
OPERABLE UNIT 4 REMEDIAL ALTERNATIVE COST SUMMARY (MILLION $)
ALTERNATIVE

Subunit A - Silos 1 and 2 Contents
OA - No Action

3A.l/Vit - Removal, Vitrification, Off-Site Disposal -
Nevada Test Site

3A.l/Cem - Removal, Cement Stabilization, Off-Site
Disposal - Nevada Test Site

Subunit B - Silo 3 Contents

OB - No action 0

2B/Vit - Removal, Vitrification, On-Property Disposal

2B/Cem - Removal, Cement Stabilization, On-Property
Disposal

3B.l/Vit - Removal, Vitrification, Off-Site Disposal -
Nevada Test Site

3B.l/Cem - Removal, Cement Stabilization, Off-Site
Disposal - Nevada Test Site
OPERATING & MAINTENANCE TOTAL
PRESENT
SHORT-TERM LONG-TERM WORTH
(During Remediation) (Post Remediation) COST
CAPITAL
0 0

38.3
11.7
71.8
11.7
0

25.2

35.9

26.8
0

4.9
4.9
4.9
36.8
4.1
4B - Removal, On-Property Disposal 21.8

Subunit C - Silos 1,2,3, and 4 Structures, Soils, and Debris

OC - No Action 0 0

2C - Demolition, Removal, On-Property Disposal
1.1
3.2
43.7
73.1
3.2
36
22
37.4
28
28
36.3
3.6
34.3
3C.1 - Demolition, Removal, Off-Site Disposal - Nevada
Test Site
48.7 0
83.6
44
75.5
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3C.2 - Demolition, Removal, Off-Site Disposal - Permitted
Commercial Facility

NOTES:
The accuracy of thew cost estimates are between +50% and -30%.
Estimates of capital and operations and maintenance costs are expressed in terms of total costs. The total
present worth costs are calculated from the total cost figures applying
a discount rate of 7 percent and an operating and maintenance period of 30 years.
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The comparison of the Subunit B alternatives against the threshold criteria of overall protection of human
health and the environment and compliance with ARARs is summarized below.

Overall Protection of Human Health and the Environment. As discussed in Section 8.2.1.1, this evaluation
assumes that the federal government would continue to own the FEMP site. For a cleanup remedy to be
considered protective, it should not result in any unacceptable risks to an expanded trespasser or an
off-site farmer.

All alternatives, with the exception of the no-action alternative (OB), would provide overall protection of
human health and the environment. These alternatives will eliminate, reduce, or control the health or
environmental risks resulting from constituents in Subunit B materials. Except for Alternative 4B, the
alternatives would limit exposure to contaminants by removing the material, treating the material by either
vitrification or cement stabilization. The treated material is disposed in an on-property above grade
disposal vault for Alternative 2B or off-site at NTS for Alternative 3B.1. Alternative 4B's protection is
based on removal and disposal in an on-property above-grade vault and institutional controls. All
alternatives would attain long-term effectiveness.

In summary, Alternatives 3B.l/Vit and 3B.l/Cem would provide overall protection to the expanded trespasser
and off-site farmer because they would remove the Subunit B residues from the FEMP site.

Compliance with ARARs. With the exception of the no-action alternative, Subunit B alternatives would comply
with all pertinent ARARs. Under the no-action alternative, Silo 3 would eventually fail, resulting in the
release of cold metal oxides to the environment. This scenario would likely result in radiological releases
to the air, soil, groundwater, and surface water (via storm water runoff. For example, fate and transport
modeling for this scenario indicates that the safe drinking water limits (MCLs in 40 CFR §141) would be
exceeded for uranium, and gross alpha and beta radiation.

For those alternatives that include on-property disposal, an Alternative 4B is the least favorable on-
property alternative because the material is not treated.

In summary, Alternatives 2B/Vit, 2B/Cem, 3B.l/Vit, 3B.l/Cem, and 4B, would meet all pertinent ARARs. Because
the uncertainly associated with demonstrating that the FEMP on-property disposal vault would provide for the
long-term protection of inadvertent intruders, Alternatives 3B.l/Vit and 3B.l/Cem are favored over 2B/Vit,
2B/Cem, and 4B.

8.2.2.2 Primary Balancing Criteria

Those alternatives that satisfy the threshold criteria comparative analysis were carried forward to the
primary balancing criteria comparative analysis. Because Alternative OB (No Action) did not satisfy either
of the threshold criteria, it is not considered further in this analysis.

Long-Term Effectiveness and Permanence. All Subunit B alternatives would ensure long-term protectiveness to
human health and the environment. For all alternatives, projected FEMP site residual risks to viable
receptors (off-site farmer and expanded trespasser) would be less than 10-6 incremental lifetime cancer risk,
and no non-carcinogenic effects (hazard index less than 0.2) would be indicated for either receptor.

The characteristics of the treated residue form (vitrification or cement stabilization) and the disposal
options (on-property or off-site at NTS) are similar to those discussed under long-term effectiveness for
Subunit A materials. Long-term environmental impacts are also the same as those considered for Subunit A.

In summary, Alternatives 3B.l/Vit and 3B.l/Cem provide a greater degree of long-term effectiveness than
Alternatives 2B/Vit, 2B/Cem, and 4B.

Reduction of Toxicity, Mobility, or Volume through Treatment. Alternatives 2B/Vit and 3B.l/Vit would use the
vitrification process to treat the Subunit B material. This technology would physically bind the
contaminants in a glass-like matrix, which would significantly reduce contaminant mobility and material
volume. Mobility would be reduced since the contaminants would be bound in the matrix and the volume of the
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treated material would be approximately 62 percent of the untreated material volume.

Alternatives 2B/Cem and 3B.l/Cem would use the cement stabilization process to treat the Subunit B material.
This technology will physically and chemically bind the constituents in a cement-like matrix, so the mobility
of constituents (via leaching from) in this treated material would be greatly reduced. However, the total
volume of material will increase by 55 percent as a result of adding the cement stabilizing and setting
agents.

Alternative 4B does not reduce toxicity, mobility, or volume because it does not include the treatment. In
summary, Alternatives 2B/Vit and 3B.l/Vit are favored over Alternatives 2B/Cem, 3B.l/Cem, and 4B because they
would generate a treated form which has very good resistance to leaching and would significantly reduce the
volume of the Subunit B materials.

Short-Term Effectiveness. For the Subunit B action alternatives, the various removal, treatment, and
disposal activities would result in increased short-term risks (compared to no action). The short-term
effectiveness of removal operations is expected to be the same among all alternatives for Subunit B. There
is some degree of uncertainty associated with controlling and treating the off-gases generated by the
vitrification process.

The increased risks due to off-site transportation of the treated residues to NTS and the short-term
environmental impacts associated with removal, treatment, and disposal are similar to those described in
Section 8.2.1.2. Alternative 4B provides the highest short-term effectiveness because no treatment is
provided.

In summary, Alternative 4B is the favored alternative, and Alternatives 2B/Cem and 3B.l/Cem are favored over
Alternatives 2B/Vit and 3B.l/Vit because of the uncertainty associated with off-gas control and treatment for
the vitrification process.

Implementability. The removal and treatment activities for all Subunit B action alternatives could be
implemented with standard eguipment, procedures, and readily available resources. Pneumatic removal would be
employed for the Subunit B materials and it is a standard technology that is typically reliable and uses
readily available eguipment. All other aspects of implementing the action alternatives for Subunit B are
identical to those discussed for Subunit A under the implementability criterion in Section 8.2.1.2.

In summary, Alternative 4B would be favored and Alternatives 2B/Vit and 3B.l/Vit would be the least favored,
based on relative overall implementability.

Cost. The estimated total present worth costs for Subunit B Alternatives are provided in Table 8-2 and
include a breakdown of capital and operating and maintenance costs.

Alternative 4B is the least expensive action alternative. The present worth costs of Alternatives 2B/Vit and
3B.l/Vit are approximately the same, and are about 6 million dollars higher than that of Alternative 4B.
This is due to the treatment component of those alternatives not included in Alternative 4B. Alternatives
3B.l/Cem and 2B/Cem are approximately 30 percent and 34 percent more expensive, respectively, than
Alternatives 3B.l/Vit and 2B/Vit, respectively. Alternative 3B.l/Cem is more expensive than Alternative
3B.l/Vit primarily due to the additional packaging, transportation, and disposal of the larger volume of
cement-stabilized material.

8.2.2.3 Modifying Criteria

State Acceptance

The State of Ohio reviewed the preferred remedial alternative for Subunit B that wss provided in the Proposed
Plan, and concurs with the selection of alternative 3B.l/Vit. A letter from the OEPA conditionally approving
the FS and PP for Operable Unit 4 can be found in Appendix E of this ROD.

Community Acceptance
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DOE solicited input from the community on the preferred remedial alternative for Subunit B that was provided
in the Proposed Plan. Verbal comments received during the public meeting indicated support of the chosen
remedial alternative. Written comments received during the public comment period are addressed in the
responsiveness summary (see Appendix C).

8.2.2.4 Subunit B Comparative Analysis Summary

Alternative 3B.l/Vit is the preferred alternative because it is cost-effective and would result in the
permanent treatment and volume reduction of Subunit B materials. Alternative 3B.l/Vit would provide overall
protection of human health and the environment with fewer uncertainties over the long-term.

8.2.3 Subunit C

8.2.3.1 Threshold Criteria

The analysis of the Subunit C alternatives against the threshold criteria of overall protection of human
health and the environment, and compliance with ARARs is summarized below.

Overall Protection of Human Health and the Environment. Alternative OC would not provide adeguate protection
of human health and the environment. As discussed in Section 8.2.1.1, evaluations were conducted for future
land uses with and without continued federal ownership. For a cleanup remedy to be considered protective, it
would not result in any unacceptable risks to an expanded trespasser or an off-site farmer under the future
land use with continued federal ownership scenario, or an on-property farmer under the future land use
without continued federal ownership.

All of the action alternatives (Alternatives 2C, 3C.1, and 3C.2) would limit exposure to constituents by
decontaminating, demolishing, and removing the material to either an on-property above-grade disposal
facility or off-site disposal facility, and then excavating contaminated soils and placing clean fill over
residual contaminated subsurface soils. Section 9.2 presents and discusses the soil cleanup levels, all of
which would be protective to the expanded trespasser and off-site resident over the long term. Short-term
risks would be higher for off-site disposal due to the increased risk of transportation accidents.

The on-property, above-grade disposal facility would be designed for a 1,000 year life with no active
maintenance. Fate and transport modeling using conservative assumptions concludes that protectiveness would
be maintained over the long term.

NTS and the permitted commercial disposal facility would incorporate engineering controls to ensure
protectiveness. Both are located in a climatic, demographic, and hydrogeologic setting which favors
minimization of constituent migration to human or environmental receptors.

In summary, Alternatives 3C.1 and 3C.2 would provide overall protectiveness because they would remove the
Subunit C excavated soils and debris from the FEMP site.

Compliance with ARARs. All alternatives, other than Alternative OC (No Action) would meet all pertinent
ARARs. Under the no-action alternative, it would be likely that constituents would continue to be released
to the air, groundwater, and surface water. There would also be a risk for direct contact with contaminated
soil and exposure to direct radiation.

For Alternative 2C, an exemption to Ohio Administrative Code (OAC) rule 3745-27-07(B)(5) may be granted on
the basis of meeting certain technical reguirements. Supporting technical data for the proposed location of
the disposal facility on the FEMP site must be developed to satisfy the reguirements of OAC rule
3745-2747(B)(5).
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In summary, Alternatives 3C.1, and 3C.2 would meet all pertinent ARARs. Alternative 2C would require a
waiver of OAC rule 3745-27-07(B) (5) based on demonstration that it would meet certain technical requirements.

8.2.3.2 Primary Balancinq Criteria

Those alternatives that satisfy the threshold criteria of compliance with ARARs and overall protection of
human health and environment were carried forward to the primary balancinq criteria comparative analysis.
Because Alternative OC (No Action) did not satisfy either of the threshold criteria, it is the only
alternative not considered further in this analysis.

Lonq-Term Effectiveness and Permanence. All Subunit C alternatives would ensure lonq-term protectiveness to
human health and the environment. For all alternatives, projected FEMP site residual risks to viable
receptors (off-ilte farmer and expanded trespasser) would be less than 10-6 incremental lifetime cancer risk
and no non-carcinoqenic effects (hazard index less than 0.2) would be indicated for either receptor.
Althouqh residual contamination would remain in the Operable Unit 4 Study Area, the level of risk from the
contaminated soil would be controlled by excavatinq soil that exceeds proposed cleanup levels, by placinq
clean soil over the excavated areas, and by providinq appropriate access controls and deed restrictions.

Alternative 2C would employ an on-property disposal facility desiqned to minimize leachate qeneration from
water infiltration and contact with contaminated soil and debris. Fate and transport modelinq usinq
conservative assumptions demonstrates that both risk- and ARAR-based protective levels would be maintained
for the Great Miami Aquifer over the lonq term.

Alternatives 3C.1 (NTS) and 3C.2 (permitted commercial disposal facility) would provide lonq-term
protectiveness because the residual soils and debris would be removed from the FEMP site.

Followinq completion of remedial operations, impacted areas would be restored; lonq-term environmental
impacts are expected to be minor. Alternative 2C would result in permanent commitment of approximately 4.7
hectares (11.6 acres) of land for the disposal facility.

In summary, Alternatives 3C.1 and 3C.2 would provide a qreater deqree of lonq-term effectiveness than
Alternative 2C.

Reduction of Toxicity, Mobility, or Volume throuqh Treatment. Alternatives 2C, 3C.1, and 3C.2 will isolate
the material from the environment by containment. Treatment of the contaminated silo structures, berm
material, or soils is not included in any of the alternatives, so no reduction in toxicity, mobility, or
volume would be achieved.

Short-Term Effectiveness. For all alternatives, the various demolition and removal activities would result
in increased short-term exposures compared to no action. Alternatives 3C.1 and 3C.2 would pose additional
risks to the public and workers associated with off-site shipment to the NTS or the permitted commercial
disposal facility.

Durinq the implementation of any of the action alternatives, the qeneral public is not likely to be exposed
to contaminants because of the distance from the work area, the very low levels of contamination, and the
methods proposed to control emission dust durinq demolition and excavation. Potential short-term
environmental impacts resultinq from the implementation of Alternatives 2C, 3C.1, and 3C.2 include qeneration
of fuqitive dust, increased sediment in surface runoff, and disturbance and/or displacement of wildlife as a
result of noise, dust, and human activity. Enqineerinq controls would be used to minimize these potential
short-term impacts.

In summary, Alternative 2C is favored over Alternatives 3C.1 and 3C.2. The short-term risks to the public
and workers for constructinq the on-property disposal facility would offset the increased risks to the public
and workers associated with off-site transportation of the contaminated soils and debris.

Implementability. Alternatives 2C, 3C.1, and 3C.2 would all employ the same decontamination, demolition, and
excavation operations. With the exception of the remotely controlled operations proposed for decontaminatinq
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Silos 1, 2, and 3, all operations are standard construction activities which would be easily implemented.
The remote silo decontamination operations would be used on the uncontaminated Silo 4 first to main improved
worker familiarity with the operation processes and identify any potential operational difficulties.

Alternative 2C involves on-propaty disposal facility construction, which would employ standard construction
services and materials. The off-site disposal alternatives (3C.1 and 3C.2) would involve standard
transportation practices for radioactive materials. Alternatives 3C.1 and 3C.2 would be more
administratively difficult to implement than Alternative 2C due to the coordination required with those
states through which shipment would pass to the off-site locations. Additional efforts would be required to
ensure that the Subunit C materials complied with criteria established by either the NTS or the permitted
commercial disposal facility. Alternative 2C would require coordination with the State of Ohio to ensure
that all technical requirements for the on-property disposal facility were met.

In summary, Alternative 2C is favored over Alternatives 3C.1 and 3C.2 based on relative overall
implementability.

Cost. The estimated total present worth costs for Subunit C alternatives are provided in Table 8-2, and
include a breakdown of capital and operating and maintenance cost.

Alternative 2C, which includes an on-property disposal, is the least expensive action alternative.
Transportation to the NTS (Alternative 3C.1) or to a permitted commercial disposal facility (Alternative
3C.2) are both more expensive than constructing an on-property vault. However, the overall cost of disposal
at a permitted commercial disposal facility is anticipated to be approximately 60 percent lower than the cost
of disposal at a DOE-owned facility. This is primarily due to the packaging requirements of the DOE-owned
facility. Tbe commercial disposal facility accepts bulk shipment of material.

8.2.3.3 Modifying Criteria

State Acceptance

The State of Ohio reviewed the preferred remedial alternative for Subunit C that was provided in the Proposed
Plan, and concurs with the decision that the final disposition of the Subunit C contaminated soil and debris
would be placed in abeyance to take full advantage of planned and in progress waste minimization treatment
processes. Tbe contaminated soil and debris would either be processed through the selected Operable Unit 5
and Operable Unit 3 remedy identified by the respective Operable Unit 5 and Operable Unit 3 ROD or placed in
interim storage to await the finalization of the disposal decisions for soils and debris under Operable Unit
5 and Operable Unit 3. For the sole purpose of evaluating the performance of an overall preferred remedial
alternative for Operable Unit 4, the State of Ohio concurs with the identification of Alternative 2C as the
preferred alternative for Subunit C.

Community Acceptance

DOE solicited input from the community on the preferred remedial alternative for Subunit C that was provided
in the Proposed Plan. Verbal comments received during the public meeting indicated support of the chosen
remedial alternative. Written comments received during the public comment period are addressed in the
responsiveness summary (see Appendix C).

8.2.3.4 Subunit C Comparative Analysis Summary

Alternatives 2C and 3C.2 are relatively equal, as both would be cost-effective, and would provide overall
protection of human health and the environment both in the short-term and the long-term. For evaluation
purposes only, Alternative 2C has been identified as the preferred alternative for Subunit C. The decision
regarding the final disposition of the Operable Unit 4 Subunit C contaminated soil and debris would be placed
in abeyance to take full advantage of planned and in progress waste minimization treatment processes. The
contaminated soil and debris would either be processed through the selected Operable Unit 5 and Operable Unit
3 remedy identified by the respective Operable Unit 5 and Operable Unit 3 ROD or placed in interim storage to
await the finalization of the disposal decisions for soils and debris under Operable Unit 5 and Operable Unit
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3.

9.0 SELECTED REMEDY

On the basis of the evaluation of final alternatives, the selected remedy to be used at Operable Unit 4 at
the FEMP is a compilation of the selected alternatives from each subunit; i.e., Alternatives 3A.l/Vit -
Removal, Vitrification, and Off-site Disposal - NTS; 3B.l/Vit - Removal, Vitrification, and Off-site Disposal
- NTS; and 2C - Demolition, Removal and On-Property Disposal. The selected remedy will satisfy the
requirements of both CERCLA and NEPA for the protection of human health and the environment; will comply with
all regulatory requirements; will be cost-effective; will utilize permanent solutions to the maximum extent
practicable; and will utilize treatment as a principal element of the response. The discussions presented
here are based on the information used for detailed analysis of alternatives durinq the FS for Operable Unit
4. Actual methods used durinq the implementation of the remedy will be determined durinq detailed
enqineerinq desiqn described in the remedial desiqn and may differ from the descriptions provided below.

9.1 KEY COMPONENT'S
The major components of the selected remedy consist of the followinq:

! Removal of the contents of Silos 1, 2, and 3 (K-65 residues and cold metal oxides) and
the decant sump tank sludqe.

! Vitrification (qlassification) to stabilize the residues and sludqes removed from the
silos and decant sump tant.

! Off-site shipment for disposal at the NTS of the vitrified contents of Silos 1, 2, 3,
and the decant sump tank.

! Demolition of Silos 14 and decontamination of the qross and loose contamination, to the
extent practicable, of the concrete rubble, pipinq, and other qenerated construction
debris.

! Removal of the earthen berms and excavation of contaminated soils within the boundary of
Operable Unit 4, to achieve proposed remediation levels. Placement of clean backfill
followinq excavation (i.e. structure, foundations or larqe excavations which affect
local topoqraphy).

! Seqreqation of non-contaminated soils, demolition of the vitrification treatment unit
and associated facilities after use. Decontamination or recyclinq of debris prior to
disposition.

! On-property interim storaqe of excavated contaminated soils and remaininq contaminated
debris in a manner consistent with the approved Work Plan for Removal Action 17
(improved storaqe of soil and debris).

! Continued access controls and maintenance, and monitorinq of the stored wastes
inventories.

! Institutional controls of the Operable Unit 4 area such as deed and land use
restrictions.

! Potential additional treatment of stored Operable Unit 4 soil and debris usinq Operable
Unit 3 and 5 waste treatment systems.

! Pumpinq and treatment of any contaminated perched qroundwater encountered durinq
remedial activities.

! Disposal of remaininq Operable Unit 4 contaminated soils and debris consistent with the
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selected remedies for Operable Units 5 and 3, respectively.

9.1.1 Removal of Silo 1, 2 and 3, and Decant Sump Tank Contents

The K-65 residues in Silos 1 and 2, the cold metal oxides in Silo 3, and the sludge in the decant sump tank
will be removed. Approximately 6,796 m3 (8,890 yd3) of K-65 residues from Silos 1 and 2, 3,785 L (1,000
gallons) of sludge from the decant sump, and 3,890 m3 (5,088 yd3) of cold metal oxides from Silo 3 will be
removed. The silos and the decant sump will be eguipped with an off-gas treatment system(s) designed to
handle radon emissions generated during removal.

9.1.2 Vitrification of Silo 1, 2 and 3, and Decant Sump Tank Contents

The major treatment component of the selected remedy consists of a vitrification system to stabilize the
wastes from Silos 1, 2, and 3 and the decant sump tank. The wastes removed from the silos and the decant
sump will be transferred to a vitrification processing facility which will be constructed on site. The
wastes will be thickened as necessary for vitrification and then mixed with glass forming agents and placed
into a vitrification melter. The vitrification process will convert the contents of the silos and the decant
sump into a very durable glass form which is extremely resistant to the effects of time and weather. The
process will destroy organic contaminants and the vitrified waste form will significantly reduce both the
tendency of the waste to leach contaminants into the environment and the emission rate of radon gas. The
direct radiation associated with the treated residues will remain relatively unchanged from the untreated
form of the wastes. Off gases produced as a result of the high operating temperatures of the vitrification
melter will be routed through an off-gas treatment system designed to remove solid particles and treat
gaseous emissions such as radon. Treatability studies, conducted on a small scale as part of the RI/FS,
indicate that the volume of vitrified material reguiring disposal can be reduced by as much as 50 percent of
the volume of untreated material removed from the silos and the decant sump.

9.1.3 Off-Site Shipment and Disposal of Treated Material

Approximately 2,770 m3 (3,623 yd3) of vitrified material from Silo 1 and 2 and the decant sump, along with
approximately 1,471 m3 (1,923 yd3) of vitrified material from Silo 3, will be packaged and transported to
the NTS for disposal.

The NTS is a DOE owned and operated disposal site located near Las Vegas, Nevada. The treated material will
either be transported by rail to a destination near to or north of Las Vegas, Nevada or directly to the NTS
by truck. If by rail, the waste containers carrying the treated material will be reguired to be transferred
to trucks for transportation over roads to the NTS.

The NTS is located approximately 3,219 kilometers (km) [2,000 miles (mi)] from the FEMP. The FEMP has an
approved NTS waste shipment and certification program, for low-level radioactive wastes, that is periodically
audited by the NTS. Technical oversight of the waste management activities at the NTS is provided by the
State of Nevada. This existing waste shipment disposal program will be modified and amended to indude the
shipment and disposal of treated Operable Unit 4 wastes.

All off-site shipments will comply with the DOT regulations found in 49 CFR Parts 171 - 178 pertaining to
transportation of hazardous and radioactive materials. Additionally, all the NTS waste acceptance
reguirements will be satisfied. The off-site transport of materials would also comply with the off-site
acceptability reguirements under CERCLA.

The remedy specifies off-site disposal of vitrified contents of Silos 1, 2 and 3 at the NTS. At the time of
the signing of this ROD, the Department of Energy - Nevada Operations Office (DOE-NV) is in the process of
preparing a Sitewide Environmental Impact Statement (EIS) under NEPA for the NTS. Shipments of waste
generated from the cleanup of Operable Unit 4 are not proposed to begin until after the expected completion
of the NTS site-wide EIS.

9.1.4 Demolition and Decontamination of Structures
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Demolition of the silo structures will proceed with the systematic removal and dismantling of the Silos 1, 2,
3, and 4 domes, walls, floor slabs and footers. After removal of the silo contents and before Silos 1, 2, 3,
and 4 are demolished, loose interior residues and loose concrete will be removed from the surfaces of the
silos and transferred to the vitrification facility to be vitrified. Also, contaminated concrete from Silos
1 and 2, which exhibit highly elevated direct radiation fields, will be separated from the other Operable
Unit 4 concrete and construction debris and prepared for processing in the vitrification facility.
Contaminated piping, steel fencing, and other non-porous materials will be decontaminated to facilitate
segregation for possible unrestricted release or disposal in a permitted commercial landfill. Only
non-porous materials attaining the unrestricted use, free release criteria defined in DOE Order 5400.5 or any
subseguent DOE order or amendment or final promulgated regulation addressing free release, will be released
from the site as uncontaminated.

9.1.5 Demolition and Decontamination of Other Operable Unit 4 Structures

The existing RTS, Drum Handling Building pad, sump lift station foundation, concrete pipe trench, and decant
sump tank will be removed and decontaminated. Additionally, all vitrification facilities constructed and
eguipment installed and used for the implementation of this remedy will be disassembled, decontaminated (if
necessary), and dispositioned. Conventional decontamination and decommission technigues and eguipment would
be employed for these facilities. Uncontaminated materials attaining the unrestricted use, free release
criteria defined in DOE Order 5400.5 will be released from the site for unrestricted use or for disposal in a
commercial landfill.

9.1.6 Disposition of Demolished Structures and Debris

The selected remedy as defined under Alternative 2C specifies on-property disposal for Operable Unit 4
contaminated rubble and debris. However, this final action will be held in abeyance until a decision is
reached in the Operable Unit 3 ROD for the final treatment and disposal of rubble and debris. The final
decision on disposal of rubble and debris, generated from the demolition of the Operable Unit 4 silos and
other facilities, will be determined as part of the ROD for Operable Unit 3. The Operable Unit 4 waste will
be managed consistent with the disposal remedy put forth in the Operable Unit 3 ROD for contaminated rubble
and debris. In the unlikely event unforeseen circumstances preclude the integration of Operable Unit 4
rubble and debris into the Operable Unit 3 treatment and disposal decision, the disposal decision for
Operable Unit 4 rubble and debris will be documented in a ROD amendment for Operable Unit 4 in accordance
with Section 117(c) of CERCLA and EPA guidance. The ROD amendment will provide the public and the EPA
further opportunity to review and comment on the on-property disposal option for Operable Unit 4 rubble and
debris. A ROD amendment to the Operable Unit 4 ROD will not be necessary in the event the Operable Unit 3
remedy for rubble and debris can be feasibly implemented by Operable Unit 4.

Holding action on the Operable Unit 4 on-property disposal decision in abeyance fosters an integrated
site-wide disposal program for rubble and debris. The volume of rubble and debris to be generated from
Operable Unit 4 is anticipated to be less than 1 percent of the volume expected to be generated site wide.
The largest volume of rubble and debris from the site will be generated from Operable Unit 3, making it more
appropriate to fully develop the on-property disposal option for rubble and debris through the Operable Unit
3 ROD. Additionally, Operable Unit 4 will be able to take advantage of any available waste minimization
initiatives developed for rubble and debris which are identified in the Operable Unit 3 ROD.

Demolition and removal of Operable Unit 4 structures and facilities will proceed as described above.
Operable Unit 4 rubble and debris will be dispositioned according to the selected remedy identified in the
Operable Unit 3 ROD. Rubble and debris generated prior to finalization of the Operable Unit 3 ROD will be
placed in interim storage to await finalization of the disposal decision for rubble and debris under Operable
Unit 3. The design and management of interim storage facilities will be consistent with the approved Work
Plan for FEMP Removal Action No. 17 - Improved Storage of Soil and Debris.

9.1.7 Soil Removal

After the silos are demolished, the surface and subsurface soils within the boundary of Operable Unit 4 will
be excavated to attain reguired remediation levels for each of the constituents of concern. These soil
-------
remediation levels are considered preliminary until final soil remediation levels can be established through
the Operable Unit 5 ROD. As indicated earlier, Operable Unit 5 has site-wide responsibility for soil
cleanup. Also, the anticipated volume of soil to be removed from Operable Unit 4 will be less than 1 percent
of the anticipated volume of soil to be remediated for the entire site. The surface and subsurface soils
within Operable Unit 4 will be excavated to achieve the preliminary remediation levels presented and
discussed in Section 9.2. These Operable Unit 4 soil remedial levels are based upon information available at
the time of preparation of this ROD, from the Operable Unit 5 RI/FS. In the event that the Operable Unit 5
ROD determines that lower soil remediation levels are required, further remedial action will be conducted on
the Operable Unit 4 residual soils to achieve the lower remediation levels for those COCs which are affected.

Soils exhibiting elevated direct radiation levels (i.e., potentially contaminated soils beneath Silos 1 and
2) will be segregated from other soils and transported to the vitrification facility for processing.
Following excavation, the affected areas will be returned to original grade with the placement of clean
backfill and revegetated to control erosion.

9.1.8 Soil Disposition

The selected remedy as defined under Alternative 2C specifies on-property disposal for Operable Unit 4
contaminated soils. However, this final action will be held in abeyance until a site-wide decision is
reached in the Operable Unit 5 ROD for the final disposal of contaminated soils. The final decision on
disposal of contaminated soils generated from Operable Unit 4 will be determined as part of the Record of
Decision for Operable Unit 5. The Operable Unit 4 soils will be managed consistent with the disposal remedy
put forth in the Operable Unit 5 ROD for contaminated soils. In the event unforeseen circumstances preclude
the integration of Operable Unit 4 contaminated soils into the Operable Unit 5 disposal decision, the final
disposal decision for Operable Unit 4 contaminated soils will be documented in a ROD amendment for Operable
Unit 4 in accordance with Section 117(c) of CERCLA and EPA guidance. The ROD amendment will provide the
public and the EPA further opportunity to review and comment on the final disposal option for Operable Unit 4
contaminated soils. A ROD amendment to the Operable Unit 4 ROD will not be necessary in the event the
Operable Unit 5 remedy for contaminated soils can be feasibly implemented by Operable Unit 4.

Holding the Operable Unit 4 final disposal decision in abeyance fosters an integrated site-wide disposal
approach for contaminated soils. The largest volume of contaminated soils from the site will be generated
within Operable Unit 5, making it more appropriate to fully develop the final disposal option for
contaminated soil through the Operable Unit 5 ROD. Additionally, Operable Unit 4 will be able to take
advantage of any applicable waste minimization initiatives developed for contaminated soils under the
Operable Unit 5 ROD.

Excavation and removal of Operable Unit 4 contaminated soils will proceed as described above. Operable Unit
4 contaminated soils will be disposed in accordance with the selected remedy identified in the Operable Unit
5 ROD for soils. Contaminated soils generated prior to finalization of the Operable Unit 5 ROD will be
placed in interim storage to await finalization of the disposal decision for contaminated soils under
Operable Unit 5. The design and management of interim storage facilities will be consistent with the
approved Work Plan for FEMP Removal Action No. 17 -

Improved Storage of Soil and Debris. The management of Operable Unit 4 contaminated soils will include
measures to ensure future identification and retrieval of these wastes for final disposition.

Water Treatment

Wastewater generated as a result of this selected remedy along with water removed from the decant sump tank,
Silo 4 (if any), and any contaminated perched water encountered during remediation will be treated at the
FEMP wastewater treatment facility prior to discharge. In accordance with the Amended Consent Agreement,
groundwater cleanup will be handled by Operable Unit 5. Operable Unit 4 would only handle the cleanup of
perched water encountered during implementation of the selected remedy.

9.1.9 Cost
-------
The total estimated present worth cost for the selected remedy is 91.7 million dollars. Table 9-1 summarizes
the capital and the operating and maintenance costs. The total estimated present worth cost is less than the
sum of the total costs of the preferred alternatives for Subunit A, B, and C. This is because Subunits A and
B will share common costs for site preparation, construction of the silo contents removal work platform and
processing facilities, and packaging and transportation.

9.2 SOIL CLEANUP CRITERIA

After the silos are demolished, the surface and subsurface soils within the Operable Unit 4 boundary will be
excavated to attain reguired remediation levels for each of the constituents of concern. These soil
remediation levels are preliminary until final soil remediation levels can be established through the
Operable Unit 5 ROD. In the event that the Operable Unit 5 ROD determines that lower soil remediation levels
are reguired, further remedial action will be conducted on the Operable Unit 4 residual soils to achieve the
lower remediation levels for those COCs that are affected.

9.2.1 Land Use and Receptor Description

Preliminary remediation levels for soil cleanup were developed for an expanded trespasser receptor under a
future land use with continued federal ownership to represent post remediation conditions at Operable Unit 4
and, therefore, provide the basis for establishing cleanup levels.

The future land use with continued federal ownership scenario represents a government reserve which remains
under U.S. government control with no future development intended. Active access controls currently in place
at the FEMP site (i.e. fencing, security access control, signs, etc.) will be discontinued, but the federal
government will exercise the right to preclude site development through deed restrictions. This land use
scenario was not included in the Baseline Risk Assessment. It was developed in a part of the FS for Operable
Unit 4 to facilitate evaluation of long-term risks with continued land use restrictions. In addition to deed
and land development restrictions, fences will be erected and eguipped with signs posted to prohibit
trespassing.
-------
TABLE 9))1

COMBINED COST ESTIMATE FOR SELECTED REMEMDY

DESCRIPTION
CAPITAL COSTS
SITE PREPARATION
WASTE PROCESSING
VITRIFICATION EQUIPMENT
HYDRAULIC /PNEUMATIC REMOVAL SYSTEM
DEMOLITION & REMOVAL
TRANSPORTATION
DISPOSAL
PACKAGING (3,694 PKGS . @ $995/PKG)
DISPOSAL VAULT
TOTAL CAPITAL
RISK BUDGET
SUBTOTAL
CONTINGENCY (20.0%)
TOTAL ESTIMATED INSTALLED COST
DIRECT
COST

$768, 600
$1,695,800
$2,935,500
$6,655,400
$3,980,400

$2,360,200
$975,200
$6,410,200
$27, 696,300
$3,046,600
$30,742,900
$6,148,600
$36,891,500
INDIRECT
COST

$660,000
$1,427,700
$1,703, 600
$14,068,800
$5,977,000
$1,915,000

$2,552,600
$10,914,800
$37,304,500
$4,103,500
$41,408,000
$8,281,600
$49, 689, 600
TOTAL
COST

$1,428, 600
$3,123,500
$4, 639,100
$20,724,200
$9,957,400
$1,915,000
$2,360,200
$3,527,800
$17,325,000
$65,000,800
$7,150,100
$72,150,900
$14,430,200
86,581,100
OPERATION AND MAINTENANCE (O&M) COSTS
DURING CONSTRUCTION
POST - REMEDIATION

TOTAL PRESENT WORTH COST (CAPITAL AND O&M @ 7%)
$16, 615,500
$3,567,000
$91,738,000
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The expanded trespasser receptor was developed to represent an adult and/or child that visits the site
despite restrictions imposed under continued federal ownership. The possible activities of this receptor
include hiking, roaming, bird watching, and other similar activities. An expanded trespasser may be exposed
to Operable Unit 4 residual contaminants through the following pathways:

! Inhalation of fugitive dust, volatile organic compounds, and radon;
! Incidental ingestion of soil;
! Dermal contact with contaminants in soil; and
! External radiation exposure from radionuclides in soil.

9.2.2 Preliminary Remediation Levels

Tables 9-2 and 9-3 provide preliminary remediation levels for soil cleanup and the estimated risk to affected
receptors from the residual contaminants left in the soils. Specific details on the development of these
preliminary remediation levels are provided in the FS Report for Operable Unit 4.

As mentioned earlier, the future land use scenario for Operable Unit 4 will be as a government reserve with
continued federal ownership. The on-property receptor of concern under this scenario will be an expanded
trespasser. Cancer risks and chemical hazard to the expanded trespasser, from residual contaminants, are
presented in Tables 9-2 and 9-3. For comparison, cancer risks and chemical hazard to an on-property farmer
under a future land use scenario without federal ownership are also presented. Proposed remediation goals
(PRGs), based on an ILCR of 10-6 and an HI of 0.2 were developed in the FS. These PRGs, presented in Tables
9-2 and 9-3 for the expanded trespasser, represent allowable incremental concentrations above background for
these COCs based on targets of 10-6 incremental risk and hazard index of 0.2.

For radionuclide constituents of concern, the PRG was added to the background concentration to derive the
preliminary remediation level. Based on the contaminant concentrations found in Operable Unit 4 soils, PRLs
were not reguired for non-radionuclide contaminants as indicated in Table 9-3.
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TABLE 9-2

PRELIMINARY REMEDIATION LEVELS IN SOILS - RADIONUCLIDES
Constituent
of
Concern
Pb-210
+2 progeny
Ra-226
+5 progeny
Ra-228
+1 progeny
Sr-90
+1 progeny
Tc-99
Th-228
U-238
+2 progeny
Expanded
Trespasser
10-6 ILCR
PRG
pCi/g
77
0.37
0.77
1420
38700
0.4
59
Background
(95th
Percentile)
pCi/g
1.33
1.45 5
15
1.19
ND
ND
1.43
1.22
ARAR
Target
pCi/g
NA
(top 6" soil)
(max. below 6")
NA
NA
NA
NA
NA
Max. Detected Soil
Concentration, pCi/g
Level a
Surface Subsurface
4.5 101
88 206
0.48 1.24
1.8 0.8
3.6 3.6
2.9 1.3
37 53
Proposed
Remediation
pCi/g
Levelb
78
2
2
NR
NR
2
60
ILCR above
to an Expa:
Trespasser
Proposed R'
1.0x10-6
1.0x10-6
1.0x10-6
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TABLE 9-3

PRELIMINARY REMEDIATION LEVELS IN SOILS - CHEMICALS
Constituent
of
Concern

Antimony
Arsenic
Barium
Cadmium
Chromium (III)
Molybdenum
Nickel
Silver
Thallium
Vanadium
Zinc
Expanded
Trespasser
HI = 0.2
PRG
mg/kg

31
510
>10000
26
NA
930
8300
130
31
1700
>10000
Expanded Background
Trespasser (95th
10-6 ILCR percentile)
PRG
mg/kg mg/kg

N/A
23
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A

7.7
8.45
91.3
0.82
15.5
2.6
20.9
2.6
0.58
30.4
62.2
ARAR
Target
mg/kg

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Max. Detected Soil Proposed
Concentration, Remediation
mg/kg Levels
mg/kg
Surface Sub
surface

32
10
112
6
23
25
39
10
0.5
28
65
Levela
32
12
142
7
25
30
39
18
0.5
33
67

NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
HI to an
Expanded Risk to an
Trespasser from Expanded
Proposed Trespasser from
Remediation Proposed
Levels Remediation

0 . 2 N/A
N/A
-------
Expanded
Expanded
Trespasser Trespasser
HI = 0.2
PRG
ing/ kg

NA
NA
NA
NA
NA
NA
10-6 ILCR
PRG
ing/ kg

61
8.8
72
2000
7.9
32
Background
(95th
percentile)

ing/ kg

ND
ND
ND
ND
ND
ND
Max. Detected Soil
ARAR
Target

ing/ kg

NA
NA
NA
NA
NA
NA
Concentration,
ing/ kg

Surface

4.7
5.2
9.7
3.5
0.9
4.2

Sub
surface
Level a
ND
ND
ND
ND
ND
ND
Proposed
Remediation
Levels
ing/ kg

NR
NR
NR
NR
NR
NR
HI to an
Expanded
Trespasser from
Proposed
Remediation
Levels

N/A
N/A
N/A
N/A
N/A
N/A

Risk to an
Expanded
Trespasser from
Proposed
Remediation

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The clean-up levels presented in Tables 9-2 and 9-3 are preliminary. The development of final soil clean-up
levels for Operable Unit 4 will be addressed in the Operable Unit 5 Record of Decision. These final clean-up
levels will be consistent with the overall site approach for the development of soil clean-up levels as
approved by the USEPA.

In those cases where a target concentration level specified by an ARAR is less than the proposed remedial
level, the ARAR level was adopted as the remediation level. Remediation would be required for COCs that are
present in the surface and subsurface soil at higher concentrations than the preliminary remediation level.

Based on the preliminary remediation levels, the COCs driving soil cleanup are Pb-210 and Ra-226. Soil
remediation targeted at achieving the preliminary remediation levels for Pb-210 and Ra-226 will generate the
largest volume of excavated soils.

9.3 MEASURES TO CONTROL ENVIRONMENTAL IMPACTS

All practical measures will be employed at the FEMP site to minimize environmental impacts during the
implementation of the Operable Unit 4 Remedial Action. In accordance with DOE regulations for implementing
the NEPA (10 CFR §1021), DOE has factored environmental impacts into the decision making process for the
Operable Unit 4 Remedial Action.

Measures to control environmental impacts have been identified in the Operable Unit 4 FS/PP-DEIS and will be
implemented during remedial design and remedial action to minimize impacts to on-property natural resources
(e.g., wildlife and wildlife habitat, cultural resources, wetlands, surface water, groundwater). Operable
Unit 4 remedial activities would not impact floodplain areas at the FEMP. The 100- and 500-year floodplain
of Paddys Run is located near the silos and associated support facilities. Direct physical impact to the
floodplain will not occur; however, the implementation of engineering controls will eliminate any indirect
impact such as runoff and sediment deposition to the floodplain. Changes in flood elevation will not occur.
The following provides a discussion of the measures that will be taken to minimize impacts to the environment
on and adjacent to the FEMP Site.

Excavation activities and the construction and operation of the various support facilities (e.g., waste
processing facility and storage facility) will result in the disturbance of 1.0 ha (2.5 acres) of terrestrial
and managed field habitat and the potential for increased erosion and sediment loads to surface water i.e.,
Paddys Run. However, appropriate engineering controls such as silt fences, vegetative cover, and runoff
control systems will be utilized to minimize runoff to Paddys Run and its associated aguatic habitat,
including the state-threatened Sloan's crayfish (orconectes sloanii). In addition, appropriate High
Efficiency Particulate Air (HEPA) filtration systems will be utilized during operation of the vitrification
facility to minimize the potential for increased emissions to the ambient air and potential impacts to
surrounding riparian habitat.

Groundwater, surface water, and air monitoring will be performed before, during, and after remedial
activities. If adverse effects are detected in any of these environmental media, work will be immediately
stopped until the effects are controlled and/or the appropriate response actions are executed.

The selected remedy for Operable Unit 4 includes the removal of the contaminated surface soil from the entire
Operable Unit 4 Area and the replacement with clean fill material. Therefore, the primary residual
contaminant would be uranium below the PRL in the subsurface soil. Because the contact of ecological
receptors is limited (near background levels) to surface soil and surface waters, residual ecological risks
associated with the Operable Unit 4 preferred alternative would be indistinguishable from those risks posed
by background levels in the soil.

10.0 STATUTORY DETERMINATIONS

In accordance with the statutory requirements of Section 121 of CERCLA, as amended, remedial actions taken
pursuant to Sections 104 and 106 must satisfy the following:

! Be protective of human health and the environment.
-------
! Comply with all ARARs established under federal and state environmental laws (or
justify a waiver).

! Be cost-effective.

! Utilize permanent solutions and alternative technologies or recovery technologies
to the maximum extent practicable.

! Satisfy the statutory preference for remedies that utilize treatment and also
significantly reduce the toxicity, mobility, and volume of the hazardous
substances, pollutants, or contaminants.

In addition, CERCLA reguires five year reviews to determine if adeguate protection of human health and the
environment is being maintained where remedial actions result in hazardous substances remaining on-site above
health-based levels. A discussion is provided below on how the selected response actions for Operable Unit 4
satisfy these statutory reguirements.

10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

The selected remedy achieves the reguirement of being protective of human health and the environment by: (1)
removing the sources of contamination, (2) treating and stabilizing the materials giving rise to the
principal threats from Operable Unit 4, (3) disposing of treated materials at an off-site location which
provides the appropriate level of protectiveness, and (4) remediating contaminated soils and debris to levels
which are protective. The contents of Silos 1, 2, and 3 and the Decant Sump Tank will be removed and treated
through a vitrification process and disposed at the NTS. Vitrification will stabilize these materials and
inhibit leaching of contaminants to the environment when they are disposed. All silo structures and other
facilities will be removed from Operable Unit 4 and disposed of in a manner consistent with the forthcoming
ROD for Operable Unit 3. Contaminated soil will also be removed and disposed in a manner consistent with the
Operable Unit 5 ROD.

Baseline cancer risks from current conditions exceed the 10-4 to 10-6 acceptable risk range. Under current
conditions, the dominant risk is 5 x 10-3 to the trespassing child. Under the future land use scenario of
continued federal ownership and the expanded trespasser receptor, the residual cancer risk from Operable Unit
4 will be reduced to less than 1 x 10-6. There are no short-term threats associated with the selected remedy
that cannot be readily controlled. In addition, no adverse cross-media impacts are expected from the remedy.

10.2 COMPLIANCE WITH LEGALLY APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

In accordance with Section 121 of CERCLA, the selected remedy will achieve a standard or level of control
consistent with all federal and State of Ohio ARARs and TBCs. The selected remedy will also be performed in
accordance with all pertinent DOE Orders as well as other reguirements. Appendix B provides a listing of the
chemical-, action-, and location-specific ARARs and TBCs which are invoked by this remedy.

Removal, treatment by vitrification, and shipment for off-site disposal of silo material will be conducted in
accordance with ARARs identified in this ROD. Disposition of rubble and debris from OU4 will be determined
by the ROD for OU3, and will be conducted in accordance with the ARARs identified in that ROD; similarly,
disposition of soils from OU4 will be determined by the ROD for OU5 and will be conducted in accordance with
ARARs established in that ROD. Any interim storage of rubble and debris or soils, prior to final disposition
under the RODs for OU3 and OU5, respectively, will be in accordance with ARARs identified in tbis OU4 ROD,
pertinent DOE orders, and applicable site procedures.

Although RCRA is cited as an ARAR for remediation of Operable Unit 4, the silo residues destined for
remediation are by-product material as defined under Section 11 (e) (2) of the Atomic Energy Act of 1954, and
as such, are excluded from RCRA regulation [40 CFR § 261.4(a) (4)]. By-product material, as defined by the
AEA, includes tailings or wastes produced by the extraction or concentration of uranium and thorium from any
ore processed primarily for its source material content (42 U.S.C. 2014).
-------
Since the residues are excluded from regulation as solid or hazardous waste, the requirements under RCRA are
not applicable to Operable Unit 4 remedial actions. However, analytical data from Silos 1, 2, and 3 material
exceed toxicity characteristic levels for various toxicity characteristic metals under RCRA. Because the
residues are sufficiently similar to hazardous waste regulated by RCRA and some RCRA requirements are
appropriate for the circumstances of the release or potential release, certain substantive requirements of
RCRA are relevant and appropriate for management of these residues, and are included in the table of ARARs.

10.3 COST EFFECTIVENESS

The selected remedial alternatives for each subunit have been determined to be protective of human health and
the environment, and to be cost effective. The present worth cost for this remedy is 91.7 million dollars.

The off-site alternatives selected for the contents of Silos 1, 2, and 3 had a lower cost than the on-
property disposal alternative for these materials. This is due to the fact that costs associated with
construction of a facility that would provide the needed level of protection to human health and the
environment from the silo contents would be greater due to the increased intruder protection requirements in
the event of a trespasser. Also, the packaging and transportation costs associated with the vitrified
material were lower than those for the cement stabilized material. Vitrification is more cost effective than
cementation because the reduction in volume of vitrified product minimizes the amount of waste requiring
handling, resulting in reduced transportation and disposal costs.

Conversely, transportation and disposal costs associated with disposing Operable Unit 4 soils and debris at
NTS or a commercial facility are higher than the costs associated with construction of an engineered facility
designed to manage the material on-property. Also, integration of the Operable Unit 4 disposal remedy for
soils and debris with Operable Units 5 and 3 respectively, allows for economies of scale through treatment by
processes developed for larger volumes of soil and debris.

10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE

The EPA and the State of Ohio have determined that the selected remedy for Operable Unit 4 represents the
maximum extent to which permanent solutions and treatment technologies can be utilized in a cost effective
manner. Of those alternatives that are protective of human health and the environment and comply with ARARs,
EPA, and the State of Ohio have determined that this selected remedy provides the best balance of tradeoffs
among the alternatives in terms of long-term effectiveness and permanence, reduction in toxicity, mobility,
and volume through treatment, short-term effectiveness, implementability, and cost. The selected remedies
also meet the statutory preference for treatment as a principal element, and meet state and community
acceptance.

Vitrification and off-site disposal will provide permanent treatment and volume reduction for the silo
contents. By physically binding the contaminants into a glass-like matrix, the mobility of the contaminants
and the emanation of radon gas would be greatly reduced. Vitrification will also significantly reduce the
leachability of metal contaminants of concern to levels that are below RCRA regulatory thresholds.
Vitrification will destroy any organic contaminants in the waste material due to the operating temperature of
the treatment process. In addition, the treated material would be less than 50 percent of its original
volume. As a result, the selected remedy would meet the CERCLA requirement for permanent solutions that
reduce the toxicity, mobility, or volume through treatment.

Part of the remedy selected for contaminated soils and debris may also involve treatment of the waste
material prior to disposal. The soil and debris will be placed into interim storage pending finalization of
the disposal decision for these wastes through the RODs for Operable Units 3 and 5. This allows for the
implementation of any applicable resource recovery technologies for these wastes, which are developed and
included in the RODs for these operable units.

10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
-------
By treating the contents of Silos 1, 2, and 3 in a vitrification process, and providing for treatment of
contaminated debris and soils should treatment become the selected remedy for these wastes in the Operable
Units 3 and 5 RODs, the selected remedy mitigates the principal threats posed by Operable Unit 4 through the
use of treatment technologies. Therefore, the statutory preference for remedies that employ treatment as a
principal element is satisfied.

10.6 UNAVOIDABLE ADVERSE IMPACTS

A number of unavoidable adverse impacts (Table 10-1) would occur when any of the action alternatives are
implemented. As stated in the alternatives and in Table 10-1, many of these impacts would only be temporary.
In addition, it should be noted that these impacts are presented for those remedial actions that will be
implemented under the selected remedy. Those impacts associated with the final disposition of Subunit C
material (soil and debris) will be identified and evaluated as part of the Records of Decision OUs 3 and 5.
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TABLE 10-1 UNAVOIDABLE ADVERSE IMPACTS ON RESOURCES
Affected Resource
Soil and Geology
Water Quality and
Hydrology
Impact Type
Soil at the FEMP site and the NTS would be disrupted by construction
and excavation activities. Many impacts would be temporary, pending
completion of remedial activities and restoration programs. The
implementation of the selected remedy would temporarily disturb
approximately 1.0 ha (2.5 acres) at the FEMP (e.g., excavation and
construction). A permanent disruption of approximately 8 ha (20 acres)
at the NTS would occur. All areas disturbed at the FEMP site would be
regraded and revegetated. The regional geology of the FEMP site and
surrounding area would not be affected by the selected remedy.
Implementation of off-site disposal would not affect the regional geology
of the NTS or surrounding areas.
Potential short-term impacts (e.g., release of sediment and fugitive
on water guality and hydrology would be minimal regrading and
revegetation around the silos to mimimize potential water guality impacts
would occur. Assuming monitoring and maintenance activities continue
at the NTS, no long-term impacts would be expected from waste disposal
at the NTS.
Air Quality
Biotic/Ecological
Resources
Wetlands and
Floodplains
Some temporary impacts to air guality at the FEMP site would result
from fugitive dust emissions associated with construction and excavation
activities (e.g., grading, compacting, loading). Lesser impacts would
also be incurred from vehicle and eguipment exhausts. These impacts are
not expected to affect human health or the environment. No long-term
impacts on air guality would be expected from activities associated with
the selected remedy. Disturbed areas would be restored (e.g., regraded
and revegetated) after completion of the remedial activities, thus
minimizing the potential for the fugitive dust release. The off-site waste
disposal facility would be designed to prohibit emission from stored
waste. Only in the case of an accident during remedial actions would
appreciable air guality impacts occur.

Short-term disturbance of terrestrial, managed field, riparian and a
habitat would be expected. Approximately 1.0 ha (2.5 acres) of habit
at the FEMP site would be disturbed during excavation and construction
activities. Habitat at the NTS is limited and it is believed little
displacement of native species would occur.

Alternative 2C would not impact wetlands. Direct floodplain impacts
resulting in a change of flood elevations would also not occur.
Engineering controls would be implemented to minimize or eliminate
indirect floodplain impacts. No wetlands or floodplains are present at the NTS.
-------
TABLE 10-1
(Continued)
Affected Resource

Socioeconomics and
Land Use
Visual Resources
Impact Type

Minimal short-term impacts (e.g., increased traffic noise) to the
socioeconomics and land use would occur. The long-term socioeconomic
and land use impacts for the FEMP site would be positive because the
waste would be isolated and controlled, thus no changes from current
land use would be expected. Removing waste from the site would help to
eliminate impacts on future populations and economic growth at the
FEMP site. Disposal of this waste at the NTS would not be expected to
impact socioeconomics or land use. Total present worth costs of the
selected remedy is $91.7M. For this analysis, it is assumed that all
resources reguired for remedial activities can be found within the thirteen
county Consolidated Metropolitan Statistical Area (CMSA). The
cumulative operating budget for the CMSA was approximately
$805,000,000.00. The collectible revenue for the CMSA would increase
up to approximately 11.4%.

Construction and excavation activities would result in some minor
incremental increases over the current visual and aesthetic impacts of the
FEMP site. Short-term impacts would also be incurred at the NTS
during construction, excavation, and transportation activities. The
majority of impacts would be temporary and would cease following
completion of remedial action activities and site restoration; however,
aesthetic impacts would occur from the implementation of waste disposal
facilities.
Noise
Ambient noise levels would temporarily increase as a result of
construction, excavation, and transportation activities. All noise impacts
would be temporary and would cease following completion of remedial
activities.
-------
10.7 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES

Implementing the selected remedy will result in permanent commitment of on-property land and associated
natural resource services for material disposal at the FEMP site and off-site land at the NTS.

Soil at the FEMP site and the NTS will be disturbed by construction and excavation activities. Many impacts
will be temporary, pending completion of remedial activities and restoration programs. The implementation of
the selected remedy will temporarily disturb approximately 1.0 ha (2.5 acres) at the FEMP site. Furthermore,
implementation of this remedy will permanently commit 8 ha (20 acres) at the NTS. All areas disturbed at the
FEMP site will be regraded and revegetated.

Approximately 1.0 ha (2.5 acres) of habitat at the FEMP site will be disturbed during excavation and
construction activities. Approximately 89 ha (220 acres) are expected to be permanently committed on a
site-wide basis, with another twenty to thirty acres subject to temporary disturbances. It is assumed that
processes such as revegetation and regrading are successful; however, the loss of habitat will result in a
permanent displacement or loss of wildlife and associated services. Terrestrial habitat at the off-site
disposal areas is limited, and little displacement of species is expected to occur.

Wetlands and associated natural resource services will not be injured by the selected remedy. Long-term
direct impacts to the floodplain resulting in changes of flood elevations will not occur. Engineering
controls would be implemented to minimize or eliminate any indirect impacts. There will be no impacts to
wetlands or floodplains with disposal at the off-site disposal areas.

Consumptive use of geological resources (e.g., guarried rock, sand, and gravel) and petroleum products (e.g.,
diesel fuel and gasoline) will be reguired for removal, construction, and disposal activities of the selected
remedy. Supplies of these materials will be provided by the construction contractor. Additional fuel use
will result from off-site transport of the materials. However, adeguate supplies are available without
affecting local reguirements for these products.

The treatment processes for the selected remedy will reguire the consumptive use of materials and energy.
The vitrification process will be energy-intensive and reguire commitment of a considerable supply of
electricity. Electricity can be obtained from the local utility.

Maintenance activities will be performed as necessary. Long-term environmental impacts would not be expected
to occur from the Operable Unit 4 selected remedy. Monitoring and periodic site inspections would be
performed to ensure long-term protection of human health and the environment.

11.0 DOCUMENTATION OF SIGNIFICANT CHANGES

11.1 REPROMULGATION OF 40 CFR §191

Repromulgation of the 40 CFR §191 reguirements for Management and Disposal of Spent Nuclear Fuel, High-Level,
and Transuranic Wastes has caused changes to be made to the ARARs as described in the Draft Final FS/PP-DEIS,
conditionally approved by the EPA on February 9, 1994. DOE chooses not to submit revision pages to the
FS/PP-DEIS; all changes to the ARARs for that document and any impacts from the repromulgation are discussed
in this section of the ROD. Since the repromulgation resulted in relevant and appropriate, rather than
applicable reguirements, the repromulgation of 40 CFR §191 will not impact the proposed off-site alternative
for disposition of the K-65 material. However, the on-property disposal alternatives (Alternatives 2A/Vit
and 2A/Cem) that were previously retained, having passed the threshold criteria of the detailed analysis, are
no longer able to meet the threshold criteria of compliance with ARARs, and are conseguently dropped from
-------
further consideration. Subsequently, all references to Alternative 2A are therefore deleted from reference
in the text of the ROD, and in Appendix A.

The only relevant and appropriate requirement from 40 CFR §191 that is retained as an ARAR in this ROD
(Appendices A and B) for the proposed alternative is 40 CFR §191.03(b), which establishes dose limits for
manaqement and storaqe of the K-65 material. However, since this ARAR is relevant and appropriate, rather
than applicable, it will pertain only to the on-property portions of the remedial activities conducted under
this action.

11.1.1 Backqround

The United States Department of Enerqy - Fernald Field Office (DOE-FN) received conditional approval of the
Draft Final FS/PP-DEIS for Operable Unit 4 from USEPA on February 9, 1994. Included in the FS/PP-DEIS
applicable or relevant and appropriate requirements (ARARs) was a reference to 40 CFR §191, "Environmental
Radiation Protection Standards for Manaqement and Disposal of Spent Nuclear Fuel, Hiqh-Level, and Transuranic
Wastes". This reference to 40 CFR §191 was modified in the Operable Unit 4 FS/PP-DEIS, submitted in February
1994 in response to the conditional approval letter, to reflect the chanqes to the requlation that occurred
upon its repromulqation on December 20, 1993. It still accommodates the specific direction previously
provided by the USEPA reqardinq incorporation of the 40 CFR §191 requirements as an ARAR/TBC ("Operable Unit
4 Screeninq Dispute Resolution U.S. DOE Fernald", Catherine McCord, USEPA, to Andy Avel, DOE, dated October
18, 1990). The final rule became effective on January 19, 1994, durinq final revision of the Operable Unit 4
FS/PP-DEIS, and aqency comments did not address the repromulqation of the rule. This fact was discussed with
the USEPA, and a DOE position paper on the incorporation of 40 CFR §191 as an ARAR for Operable Unit 4
remediation was submitted to the USEPA for concurrence. The USEPA disaqreed with the draft position proposed
by DOE, and responded with a directive to incorporate the substantive elements of the repromulqated rule into
the ROD, with an option to resubmit chanqe paqes to the FS/PP-DEIS ("Application of 40 CFR §191 to OU #4",
Jim Saric, USEPA, to Jack Craiq, DOE, dated April 25, 1994). DOE elected not to revise the FS/PP-DEIS, but
rather to describe in this section of the ROD chanqes to the table of ARARs and associated impacts on
selection or implementation of remedial alternatives that have occurred between the time the Draft Final
FS/PP-DEIS was conditionally approved, and the submittal of the ROD to the USEPA and OEPA. The list of ARARs
in the ROD, and proposed approach to compliance with the substantive elements thereof, once approval by the
USEPA is obtained, will be the final approved list of applicable or relevant and appropriate requirements for
final remediation of Operable Unit 4.

11.1.2 Impacts of Repromulqation

Since 40 CFR §191 cannot be considered a leqally "applicable" class of ARAR for this CERCLA remediation, §191
is not applicable to any Operable Unit 4 waste streams. Since compliance with only applicable requirements
is required to be demonstrated for off-site remedial alternatives proposed under CERCLA, these requirements
will not impact the proposed off-site alternative for disposal of the treated K-65 material at the NTS.

DOE previously included 40 CFR §6191 Subpart A as a relevant and appropriate requirement, and Subpart B as to
be considered (TBC) criteria for manaqement of K-65 material in accordance with quidance received from the
USEPA. Subpart A of §191, entitled "Environmental Standards for Manaqement and Storaqe" includes public dose
rate standards for protection of the public from radiation hazards posed by spent nuclear fuel, hiqh-level,
or transuranic waste material. The repromulqation of the Final Rule did not materially affect the sections
of Subpart A referenced in the Operable Unit 4 FS/PP-DEIS; the Subpart A requirement referenced in the
Operable Unit 4 FS/PP-DEIS remains unchanqed in the table of ARARs as a relevant and appropriate requirement
for the on-property portion of the remedial activities to be conducted on the K-65 material.

Prior to repromulqation, Subpart B requirements were in remand, and were therefore considered TBCs in the
FS/PP-DEIS submitted to the aqencies. Since Subpart B of §191, entitled "Environmental Standards for
Disposal", has been repromulqated, the USEPA has directed that sections must now be considered as relevant
and appropriate requirements for any on-property disposal alternatives. Since it could not be demonstrated
that the on-property disposal of treated K-65 material would comply with specific requirements of this
Subpart, those alternatives involvinq on-property disposal (Alternatives 2A/Vit and 2A/Cem) were no lonqer
able to meet the threshold criteria of compliance with these ARARs, and were consequendy dropped from further
-------
consideration. All descriptions to Alternative 2A are therefore deleted from reference in the text of the
ROD, and in Appendix A.

A new Subpart C of §191 "Environmental Standards for Groundwater Protection", was created by the
repromulgated rule. As with Subpart B, this new Subpart pertains only to disposal systems. The elements of
this Subpart must now be considered as relevant and appropriate requirements; however, since the on-property
disposal alternatives to which this Subpart pertains were dropped from further consideration on the basis of
non-compliance with Subpart B requirements, and since Subpart C will not pertain to any off-site disposal
alternatives, these requirements will not be included in the Appendix A or B tables of ARARs. Subpart C will
therefore have no effect on the selected alternative, which includes off-site disposal.

REFERENCES

International Aqency for Research on Cancer (IARC), 1987, IARC Monoqraphs on the Evaluation of Carcinoqenic
Risks to Humans. Overall Evaluations of Carcinoqenicity: An Updatinq of IARC Monoqraphs Vol. 1 to 42.
Preamble. Supplement 7. World Health Orqanization: Lyon, France, pp. 17-34.

National Council on Radiation Protection and Measurements, 1991, "Effects of lonizinq Radiation on Aquatic
Orqanisms, "NCRP Report No. 109, NCRP, Bethesda, MD.

U.S. Anny Corps of Enqineers, 1987, "Wetlands Delineation Manual".

U.S. Dept. of Enerqy, 1992, "Risk Assessment Work Plan Addendum, "Final Draft, FEMP, Remedial Investiqation
and Feasibility Study, DOE, Fernald Field Office, Fernald, OH.

U.S. Dept. of Enerqy, 1993a, "Remedial Investiqation Report for Operable Unit 4, "U.S. Department of Enerqy,
Fernald Field Office, November 1993.

U.S. Dept. of Enerqy, 1993b, Site-Wide Characterization Report FEMP, Fernald, OH, Remedial Investiqation and
Feasibility Study, Draft, DOE, Fernald Field Office, Fernald, OH, March 1993.

U.S. Dept. of Enerqy, 1994, "Feasibility Study Report for Operable Unit 4, "U.S. Dept. of Enerqy, Fernald
Field Office, February 1994.

U.S. Dept. of Enerqy, 1994, "Proposed Plan for Remedial Actions at Operable Unit 4, "U.S. Dept. Of Enerqy,
Fernald Field Office, February 1994.

U.S. Environmental Protection Aqency (EPA), 1986, Guidelines for Carcinoqen Risk Assessment. Federal
Reqister 51(1851 pp. 33992-34003.

U.S. Environmental Protection Aqency (EPA), 1989a, "Risk Assessment Guidance for Superfund: Human Health
Evaluation Manual, Part A, Interim Final," EPA/540/1-89/002, EPA, Office of Emerqency and Remedial Response,
Washinqton, DC.

U.S. Environmental Protection Aqency (EPA), 1989b, "Guidance on Preparinq Superfund Decision Documents: The
Proposed Plan, the Record of Decision, Explanation of Siqnificant Differences, the Record of Decision
Amendment," Interim Final, EPA/540/G-89/007, EPA, Office of Emerqency and Remedial Response, Washinqton, DC.

U.S. Environmental Protection Aqency, 1992a Inteqrated Risk Information System (IRIS), on-line data service.
EPA, Washinqton, DC.

U.S. Environmental Protection Aqency, 1992b Health Effects Assessment Summary Tables, Annual Update FY 1992,
includinq Supplement A, July 1992, OERR 9200.6-303 (92-1)

U.S. Environmental Protection Aqency (EPA), 1992c, "Community Relations in Superfund: A Handbook,"
EPA/540/R-92/009, EPA, Office of Emerqency and Remedial Response, Washinqton, D.C.
Volf, M.B. 1984, "Chemical Approach to Glass (Glass Science and Technoloqy: Vol. 7)," Elsevier, New York.
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APPENDIX A

SUMMARY OF MAJOR ARARs FOR OPERABLE UNIT 4
REMEDIAL ACTION ALTERNATIVES

TABLE OF CONTENTS
Page
List of Tables

List of Acronyms

A. 1.0 Introduction
A-l-1
LIST OF TABLES

Page

A.1-1 Summary of Major ARARs/TBCs for Operable Unit 4 Remedial Action
Alternatives - Chemical-Specific A-l-2

A.1-2 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Location-Specific A-l-5

A. 1-3 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Action-Specific A-l-7
LIST OF ACRONYMS
ALARA As Low As Reasonably Achievable
ARAR Applicable or Relevant and Appropriate Reguirements
AWWT Advanced Waste Water Treatment Facility
CAMU Corrective Action Management Unit
CFR Code of Federal Regulation
DOE United States Department of Energy
FEMP Fernald Environmental Management Project
HEPA High-Efficiency Particulate Air (filter)
HLRW High Level Radioactive Waste
m meter
MCL Maximum contaminant level
MCLG Maximum contaminant level goal
NEPA National Environmental Policy Act
NESHAP National Emission Standards for Hazardous Air Pollutants
OAC Ohio Administrative Code
ORC Ohio Revised Code
OU4 Operable Unit 4
pCi picoCuries
psi/1 picoCuries per liter
pCi/m2/s2 picoCuries per sguare meter per second
RCRA Resource Conservation and Recovery Act
SWMU Solid Waste Management Unit
TBC to be considered
TRU Transuranic
TSD Treatment, Storage, or Disposal Facility
TU Temporary Unit
-------
UMTRCA Uranium Mill Tailings Radiation Control Act
WWTS Waste Water Treatment System

A. 1.0 INTRODUCTION

This appendix presents a summary of the key Applicable or Relevant and Appropriate Requirements (ARARs) and
to be considered (TBCs) which pertain to the remedial alternatives which were retained in the Detailed
Analysis of Alternatives (Section 4) of the Feasibility Study Report for Operable Unit 4, and described in
Section 7 of the Record of Decision. This table includes ARARs established under federal and state
environmental laws, and TBC criteria which were determined to be necessary to ensure protection of human
health and the environment.

The appendix has three tables in accordance with the three types of ARARs: Chemical-Specific, Location-
Specific, and Action-Specific. The layout of the tables is as follows: the retained alternatives are listed
in the first column, followed by the regulatory citation and classification as applicable, relevant and
appropriate, or TBC. Next the basis for selection and determination of the class of ARAR is described,
followed finally by the strategy for compliance with the ARAR during implementation of the alternative. This
format and contained information is consistent with the United States Environmental Protection Agency (EPA)
Interim Final Guidance on Preparing Superfund Decision Documents: the Proposed Plan, Record of Decision,
Explanation of Significant Differences, and Record of Decision Amendment (OERR; EPA/540/G-89/007, July
1989b).

Summary tables listing all the ARARs/TBCs specifically identified for the selected remedy are provided in
Appendix B. A detailed listing, and discussion of compliance with ARARs is provided in Appendix F of the
Feasibility Study Report for Operable Unit 4.
-------
TABLE A.1-1
SUMMARY OF MAJOR ARARs FOR OPERABLE UNIT 4 REMEDIAL ACTION ALTERNATIVES
Chemical-Specific
Alternative
Number

2B, 4B
2C
Regulatory Title
And Citation
ARAR/TBC
Inorganic Chemicals in Drinking
Water
40 CFR § 141.11, 40CFR §
141.15,
40 CFR § 141.16, 40 CFR §
141.51, and 40 CFR § 141.62
and 143.3
(OAC 3745-81-11,3745-81-15,
and 3745-81-16)
Relevant
and
Appropriate
Rationale for Determination
as ARAR/TBC

These reguirement are not applicable since no
public water system (as defined in 40 CFR § 141) is
involved. They are relevant and appropriate to
protecting drinking water sources from the same
contaminants found in the operable unit. These
contaminants might migrate or leach into the MCLGs.
underlying aguifer as a conseguence of various
alternatives.
Basis for Compliance
Fate and transport modeling, for
the proposed disposal facility,
predicts that potential future
releases to the aguifer from the
facility will not exceed MCLs or
This is primarily due to
the presence of approximately 9 in
(30 ft) of low hydraulic
conductivity glacial till, that has no
significant hydrologic connections
with the underlying aguifer,
beneath the proposed disposal
facility.
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TABLE A.1-1
(Continued)

2B, 4B
2C
40 CFR § 141.61
(OAC 3745-81-12)
Organic Chemicals in Drinking
Water
Relevant
and
Appropriate
3A.1 Radionuclide Emissions (Except Applicable
2B, 3B.1, 4B Airborne Radon-222)
2C, 3C.1 40 CFR § 61, Subpart H
3C.2
The reguirement is not applicable since no public
water system (as defined in 40 CFR§ 141) is
involved, it is relevant and appropriate to protect
drinking water sources from the same contaminants
found in the operable unit. These contaminants
might migrate or leach into the underlying aguifer as
a conseguence of remedial actions.
Radioactive materials within this operable unit might
contribute to the dose to members of the public from
the air pathway during implementation of remedial
actions. This reguirement is applicable to remedial
actions implemented in Operable Unit 4, since
NESHAP applies to operating units.
Fate and transport modeling, for
the proposed disposal facility,
predicts that potential future
releases to the aguifer from the
facility will not exceed MCLs.
This is primarily due to the
presence of approximately 9 m (30
ft) of low hydraulic conductivity
glacial till, that has no significant
hydrologic connections with the
underlying aguifer, beneath the
proposed disposal facility.

The pollution control eguipment
for the silos and treatment system
for off-gas emissions will be
designed to limit the discharge of
radionuclides to acceptable levels.
-------
TABLE A.1-1
(Continued)
Alternative
Number

3A.1
2B, 3B.1, 4B
2C
Regulatory Title
and Citation

Radon-222 Emissions
40 CFR § 61 Subpart Q
ARAR/TBC Rationale for Determination
as ARAR/TBC

Applicable Facilities such as the silos within this operable unit
might qualify as sources since they might contain
radium-226 in sufficient concentrations to emit
radon-222. This requirement is applicable only to
storage and disposal of radium-bearing material.
Basis for Compliance
The radon-222 flux rate standard
of 20 pCi/m2/s would be met
during storage and/or disposal.
This is due to the presence of a
bentonite layer in the silos (prior
to treatment), and the stabilized
nature of the treated waste.
2B, 4B
2C
Standards for Control of Residual Relevant
Radioactive Material and
40 CFR § 192, Subpart A Apropriate
40 CFR § 192.02(b)
Radioactive materials in this operable unit are
residual radioactive material from uranium
processing. However, the FEMP site is not an ore
processing site designated under the UMTRCA;
therefore, management of these residues is relevant
and appropriate under this regulation.
Radon-222 emissions would
comply with the 20 pCi/m2/s
release flux rate and the 0.5 pCi/L
concentration above background at
the disposal site boundary. This is
due to the presence of a bentonite
layer in the disposal cell, and the
stabilized nature of the treated
waste.
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TABLE A.1-2

SUMMARY OF MAJOR ARARs FOR OPERABLE UNIT 4 REMEDIAL ACTION ALTERNATIVES

Location-Specific
Alternative
Number

2B, 4B
2C
Regulatory Title ARAR/TBC
and Citation

Solid, Nonhazardous Waste Relevant
Disposal Facility Design and
Considerations Appropriate
OAC 3745-27-07
3A.1 Compliance
2B, 3B.1, 4B
2C, 3C.1,
3C.2
Applicable
Floodplain/Wetlands
Environmental Review
Requirements
10 CFR § 1022
(Executive Order 11990)
Rationale for Determination
as ARAR/TBC

The State of Ohio solid waste rules are relevant and
appropriate to the disposal of silo residues,
demolition debris, and other solid wastes generated
by the implementation of a remedial alternative
within a CAMU.
Creation of a solid waste landfill requires that the
technical location requirements of the State of Ohio
be satisfied. On-site disposal alternatives might
trigger this part of the Ohio requirements, which are
more stringent than the federal counterparts.

The FEMP site is over a sole source aquifer as
defined in OAC 3745-27-07. An exemption to this
prohibition by demonstration of compliance with the
technical criteria in this rule is permitted under
ORC 3734.02(G).

This requirement is applicable because the FEMP is
a DOE facility subject to the NEPA requirements
for environmental activities at federal facilities.
Several alternatives might result in destruction or
modification of wetland areas.
Basis for Compliance
The proposed disposal vault meets
the technical considerations used to
grant exemptions: approximately 9
m (30 ft) of low hydraulic
conductivity glacial till lies beneath
the proposed liner, saturated zones

in the glacial till have no
significant hydrologic connections
with the underlying aquifer, and
fate and transport modeling
predicts that potential future
releases to the aquifer from the
facility will not adversely impact
human health or safety or the
environment.
These alternatives would comply
with all NEPA evaluation and
documentation requirements.
NEPA documentation will also
specify public notice requirements,
wetland assessments, and any
mitigative measures that may be
required.
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TABLE A.1-3

SUMMARY OF MAJOR ARARs FOR OPERABLE UNIT 4 REMEDIAL ACTION ALTERNATIVES

Action-Specific
Alternative
Number

3A. 1
2B, 3B.1, 4B
2C, 3C.1, 3C.2 40
2B, 4B
2C
3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
Regulatory Title
and Citation

Treatment, Storage, or Disposal
Facility (General Standards)
CFR § 264, Subpart B
(OAC 3745-54-13 through 16)

Releases from Solid Waste
Management Units
40 CFR § 264, Subpart F
OAC 3745-54-91 through 99;
and OAC 3745-5501 through Oil)

Closure
40 CFR § 264, Subpart G
40 CFR § 264.111, .114, and
.116
(OAC 3745-55-11, -14, and -16)
ARAR/TBC

Relevant
and
Appropriate
Relevant
and
Appropriate
Relevant
and
Appropriate
Rationale for Determination
as ARAR/TBC

Residues, which exhibit a charateristic similar to
RCRA hazardous waste, removed from this
operable unit might be treated, stored, and disposed
in accordance with TSD facility standards.

This reguirement is relevant and appropriate
because the residues stored in the silos are
sufficiently similar to hazardous waste.
These reguirements are relevant and appropriate
because the residues are sufficiently similar to
hazardous waste and the remedial alternatives might
reguire closure of units used to manage waste
materials.
Basis for Compliance
These alternatives would undertake
actions to comply with the TSD
Facility general standards.
These alternatives would install
monitoring wells to comply with
the groundwater monitoring
reguirements.
These alternatives would design,
construct, operate, and monitor the
disposal facility to meet the closure
performance standard;
decontaminate all eguipment used
in closure, and file a survey plot
showing location of disposal
facility.
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TABLE A.1-3
(Continued)

2B, 4B
2C
3.A1
2B, 3B.1, 4B
2C, 3C.1, 3C.2 I
Post-Closure

40 CFR § 264.117
(OAC 3745-55-17)
40 CFR § 264.119
(OAC 3745-55-19)

Container Storage
40 CFR § 264.171 - 178 Subpart

(OAC 3745-55-71 through -78)
Relevant
and
Appropriate
These reguirements are relevant and appropriate
because the residues are sufficiently similar to
hazardous waste and some remedial alternatives
might leave residues in place.
Relevant
and
Appropriate
These reguirements pertain to alternative utilizing
containers for storage, or treatment of hazardous
waste in containment buildings. The reguirements
are relevant and appropriate because the residues in
the silos are sufficiently similar to hazardous waste.
These alternatives would comply
with the post-closure reguirements
for units involved in disposal,
including continued monitoring,
access controls, and deed

restrictions.
These alternatives would take
measures to comply with the
hazardous waste container
reguirements.
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TABLE A.1-3
(Continued)
Alternative
Number

3A.1
2B, 3B.1
Regulatory Title
and Citation ARAR/TBC

Tank Systems Relevant
40 CFR § 264, Subpart J and
(OAC 3745-55-91 throught 96) Appropriate
Rationale for Determination
as ARAR/TBC

These reguirements pertain to alternative utilizing
treatment or storage in a tank. These reguirements
are relevant and appropriate because the residues in
the silos are sufficiently similar to hazardous waste.
2B, 4B
2C
Landfill Capping
40 CFR § 264.310
(OAC 3745-57-10)
Relevant Land disposal of hazardous waste constitutes closure
and as a landfill, which reguires a cap to prevent
Appropriate migration of waste constituents due to leaching.
This reguirement is relevant and appropriate
because the residues are sufficiently similar to
hazardous wastes.
Basis for Compliance
All process tanks will be
constructed with durable material
that is compatible with the waste
and treatment process for which
the tank is designed. The tank
design will include secondary
containment capable of detecting
and collecting releases. Approved
inspection and maintenance
procedures, which include
scheduled visual inspection of all
tanks will be established prior to
management of waste in the tanks.

Compliance would be achieved
through proper design,
construction, and implementation
of institutional controls at the
disposal vault. These controls
would include continued
inspection, monitoring, and
maintenance of the disposal facility
and surveyed benchmarks.
-------
TABLE A.1-3
(Continued)
Alternative
Number

3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
Regulatory Title
and Citation

Corrective Action for SWMUs
(CAMU and TU)
40 CFR §, Subpart S
40 CFR § 264.552-.553
ARAR/TBC

Relevant
and
Appropriate
3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
Radiation Dose Limit (All
Pathways)
DOE Order 5400.5, Chapter II,
Section l.a
To be
considered
from this DOE facility.
Rationale for Determination
as ARAR/TBC

During the process of remediation, waste materials
might reguire management in or consolidation in
land based units for the purpose of staging, treating
or disposing the material. All of the materials
generated from remediation of Operable Unit 4 are
considered remediation wastes, amenable to
management under this reguirement. Some of the
waste material might exhibit a RCRA characteristic,
or otherwise be sufficiently similiar to hazardous
waste to make this reguirement relevant and
appropriate.

Radiation sources within this operable unit might
contribute to the total dose to members of the public
This reguirement
establishes limits for allowable exposure of the
public to radiation sources from all pathways as a
result of routine DOE activities. It is included as
TBC to ensure adeguate protection of human health
and the environment from sources of radioactivity.
Basis for Compliance
These alternatives would
demonstrate they can meet the
seven criteria reguired for use of a
CAMU, and would use only tanks
or containers as temporary units.
Where appropriate, the treatment
facility design will include HEPA
filters to control radioactive
particulate emissions. Excavations,
excavated soil, and other sources
of particulate emissions will be
controlled, as appropriate, through
good construction practices.
Releases to water will be
controlled by design and operation
of secondary containment features
and treatment in the FEMP WWTS
and AWWT. Treatment of the
waste source will reduce
contributions to dose from radon
gas, and reduce the likelihood of
migration of radionuclides.
-------
TABLE A.1-3
(Continued)
Alternative
Number
Regulatory Title
and Citation
ARAR/TBC
Rationale for Determination
as ARAR/TBC
Basis for Compliance
3A.1
Environmental Radiation
Protection Standards for Mgt.
and Disposal of HLRW, Spent
Nuclear Fuel, and TRU Wastes
40 CFR § 191, Subpart A
40 CFR § 191.03(b)
Relevant
and
Appropriate
As directed by the U.S. EPA letter, "Applicable of
40 CFR § 191 to OU4", Jim Saric, U.S. EPA to
Jack Craig, DOE, dated April 25, 1994.
This reguirement would be met
through the use of treatment for
waste stabilization and management
and storage of vitrified material
prior to off-site disposal in
accordance with ALARA concepts,
proper engineering design, and the
use of administrative controls.
3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
NEPA Implementation
10 CFR § 1021.2
Applicable
This reguirement is applicable because the FEMP
a DOE facility, subject to NEPA evaluation for
specific actions at DOE facilities.
NEPA evaluations and
documentation will be prepared for
the selected remedial alternatives in
accordance with established site
procedures.
-------
TABLE A.1-3
(Continued)
Alternative
Number
Regulatory Tide
and Citation
ARAR/TBC
Rationale for Determination
as ARAR/TBC
Basis for Compliance
2B, 4B
2C
2C, 3C.1, 3C.2
3A.1, 2B
3B.1, 4B, 2C
3C.1, 3C.2
Standards for Control of Residual Relevant
Radioactive Material and
40 CFR § 192, Subpart A Appropriate
40 CFR § 192.02(a)
Standards for Cleanup of Lands Relevant
Contaminated with Residual and
Radioactive Materials Appropriate
40 CFR § 192, Subpart B
40 CFR § 192.12(a)
Implementation of Health and Relevant
Environmental Protection and
Standards for Uranium Mill Appropriate
Tailings
40 CFR § 192, Subpart C
Radioactive materials in this operable unit are
residual radioactive material from uranium
processing. However, the FEMP site is not on ore
processing site designated under the UMTRCA;
therefore, management of these residues is relevant
and appropriate under this regulation.

Radioactive materials in this operable unit are
residual radioactive material from uranium
processing. However, the FEMP site is not on ore
processing site designated under the UMTRCA;
therefore, management of these residues is relevant
and appropriate under this regulation.
Treatment of the waste and
disposal in a properly designed
disposal facility will control
residuals for 200-1000 years.
This reguirement would be met by
removing contaminated soil down
to reguired levels, and disposal of
the residues in an engineered vault
with a 3 m (10 ft) thick multimedia
cover.

These alternatives would use this
guidance during implementation.
-------
APPENDIX B

SUMMARY OF ARARS FOR THE OPERABLE UNIT 4
REMEDIAL ACTION

TABLE OF CONTENTS
List of Tables

List of Acronyms

B.1.0 Introduction

LIST OF TABLES
Page

b-i

b-ii

B-l-1
Page
B.l-1 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Chemical-Specific

B.l-2 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Location-Specific

B.l-3 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Action-Specific

LIST OF ACRONYMS

A Applicable
AEA Atomic Energy Act
ARAR Applicable or Relevant and Appropriate Reguirements
CAA Clean Air Act
CAMU Corrective Action Management Unit
CFR Code of Federal Regulation
CWA Clean Water Act
DCG Derived Concentration Guide
DOE United States Department of Energy
EDE Effective Dose Eguivalent
HLRW High Level Radioactive Waste
NEPA National Environmental Policy Act
OAC Ohio Administrative Code
ORC Ohio Revised Code
pCi/1 picoCuries per liter
pCi/m2/s2 picoCuries per sguare meter per second
R&A Relevant and Appropriate
RCRA Resource Conservation and Recovery Act
SDWA Safe Drinking Water Act
SWMU Solid Waste Management Unit
TBC to be considered
TSD Treatment, Storage, or Disposal Facility
TU Temporary Unit
UMTRCA Uranium Mill Tailings Radiation Control Act

B.1.0 INTRODUCTION
3-1-2
B-l-4
3-1-5
-------
Appendix B presents a summary of ARARs/TBCs associated with the remedial action alternatives selected for
Operable Unit 4. These tables group the ARARs/TBCs according to type (i.e., Chemical-specific,
Location-specific, and Action-specific) and by the governing regulatory act (e.g., CAA, CWA, RCRA, etc.).
The tables identify all selected remedial alternatives associated with the regulatory reguirement, a brief
description of the reguirement, and the classification of the ARAR/TBC.

It will be noted that several ARARs identified for the selected alternative include reguirements that pertain
to siting or operation of an on-site disposal facility for debris, rubble, or soils from remediation of OU4
(referenced as Alternative 2C in the tables). Disposition of rubble and debris (e.g., from demolition of the
silos) from OU4 will be conducted in accordance with the ARARs identified in the ROD for OU3; disposition of
soils from OU4 will be in accordance with ARARs established in the ROD for OU5. Any interim storage of
soils, rubble, or debris prior to final disposition under the RODs for OU3 and OU5 will be in accordance with
ARARs identified in this ROD, as well as pertinent DOE orders and applicable site procedures.
-------
TABLE B.l-1
SUMMARY OF ARARS FOR OPERABLE UNIT 4 SELECTED REMEDIAL ACTION ALTERNATIVES
Chemical-Specific
Regulatory
Alternative

3A.1 Vit
3B.1 Vit
2C
3A.1 Vit
3B.1 Vit
2C
3A.1 Vit
3B.1 Vit
2C
Program

CAA
CAA
CWA
Regulatory Title and
Citation

Radionuclide Emissions
(Except Airborne Radon-222)
40 CFR§ 61, Subpart H
Radon-222 Emissions
40 CFR§ 61, Subpart Q
Ohio Water Quality
Standards (Five Freedoms of
Surface Waters)
OAC 3745-1-04
Regulatory Description

Operating units shall establish
procedures to prevent a member of the
public from receiving an EDE of 10
mrem per year.

Storage and disposal activities for
radimn-bearing by-product material
shall establish measures to ensure
emissions of radon are maintained
below 20 pCi/m2/s.

Establishes reguirements for
maintaining integrity and useability of
surface water.
ARAR/TBC
A
A
R&A
3A.1 Vit
3B.1 Vit
2C

2C
2C
2C
CWA
RCRA
Sub. D
RCRA
Sub. C
SDWA
Ohio Water Quality
Standards
OAC 3745-1-07

Chemicals in Drinking Water
(Solid Waste Disposal
Facility)
40 CFR§ 257.3-4
[OAC 3745-27-10(0)]

Chemicals in Drinking Water
(Hazardous Waste Disposal
Facility)
40 CFR§ 264.94
(OAC 3745-5094)
Inorganic Chemicals in
Drinking Water
40 CFR§ 141.11
40 CFR§ 141.15,
Establishes allowable limits on A
discharges or releases to Paddys Run
and the Great Miami River.

Establishes reguirements to protect R&A
underground drinking water sources
from operation of the proposed
disposal facility for Subunit C material.
Establishes reguirements to assure R&A
groundwater concentrations of
hazardous constituents do not exceed
regulatory levels due to operation of
the proposed disposal facility for
Subunit C material.

Establishes reguirements to assure R&A
protection of drinking water sources
from inorganic contaminants.
-------
Regulatory
Alternative

2C
2C
Program

SDWA
UMTRCA
141.16, 141.51, 141.62 and
143.3
(OAC 3745-81-11,
OAC 3745-81-15, and
OAC 3745-81-16)

Regulatory Title and Citation
Organic Chemicals in
Drinking Water
40 CFR§ 141.61
(OAC 3745-81-12)

Standards for Control of
Residual Radioactive
Material
40 CFR§ 192.02 (b)
Regulatory Description

Establishes reguirements to assure
protection of drinking water sources
from organic contaminants.
Establishes standards for managing
residual radioactive material from
inactive uranium processing sites so the
average release rate of radon-222 does
not exceed 20 pCi/m2/s or the average
concentration in air outside facility
boundary does not exceed 0.5 pCi/L
above background following
remediation activities.
ARAR/TBC
R&A
R&A
3A.1 Vit
3B.1 Vit
2C
3A.1 Vit
3B.1 Vit
2C
3A.1 Vit
3B.1 Vit
2C
DOE
DOE
DOE
Radiation Protection of the
Public and the Environment
(DCGs for Water)
DOE Order 5400.5 Chapter
III
Radiation Protection of the
Public and the Environment
(DCGs for Air)
DOE Order 5400.5 Chapter
III
Residual Radioactive
Material (Interim Storage)
DOE Order 5400.5
Chapter IV 6.b
Establishes allowable residual TBC
concentrations of radicouclides in
water. Included as TBC to ensure
adeguate protection of human health
and the environment from sources of
radioactivity.

Establishes allowable residual TBC
concentrations of radionuclides in air.
Included as TBC to ensure adeguate
protection of human health and the
environment from sources of
radioactivity.

Establishes allowable coocentrations of TBC
radon-222 in air during interim storage
of waste material. Included as TBC to
ensure adeguate protection of human
health and the environment from
sources of radioactivity.
-------
TABLE B.l-2

SUMMARY OF ARARS EOR OPERABLE UNIT 4 SELECTED REMEDIAL ACTION ALTERNATIVES
Regulatory
Alternative

3A.1 Vit
3B.1 Vit
2C
3A.1 Vit
3B.1 Vit
2C
2C
Program

NEPA/
DOE
NEPA/
EPA
RCRA
Sub. D
Location-Specific

Regulatory Title and
Citation

Compliance with
Floodplains/Wetlands
Environmental Review
Reguirements
10 CFR§ 1022
(Executive Order 11990)

Endangered Species
Protection
50 CFR§ 402
(OAC 1518, 1513.25)
(OAC 1501-18-1-01)

Solid, Nonhazardous Waste
Disposal Facility Design
Considerations
OAC 3745-27-07
Regulatory Description

Establishes reguirements for DOE to
evaluate potential adverse effects DOE
actions might have on wetlands.
Remedial actions must not jeopardize
the continued existence of any
endangered or threatened species, or
potential habitat of threatened or
endangered species.

Establishes reguirements for the
design, construction, and operation of
the proposed disposal facility for
Subunit C material.
ARAR/TBC
A
R&A
R&A
2C
RCRA
Sub. D
Protection of Wetlands (Solid
Waste Disposal Facility)
40 CFR§ 258.12
Establishes restrictions on the location R&A
of a solid waste disposal facility with
respect to potential impacts on
wetlands.
TABLE B.l-3
SUMMARY OF ARARS FOR OPERABLE UNIT 4 SELECTED REMEDIAL ACTION ALTERNATIVES

Action-Specific
Regulatory
Alternative

3A.1 Vit
3B.1 Vit
2C
Program

CAA
Regulatory Title and
Citation

Prevention of Air Pollution
Nuisance
ORC 3704.01-.05
OAC 3745-15-07
Regulatory Description

Reguires control of emissions of air
pollutants during remediation that could
endanger health, safety, or welfare of
the public.
ARAR/TBC
A
-------
3A.1 Vit
3B.1 Vit
3A.1 Vit
3B.1 Vit
2C
CAA
CAA
Control of Visible Particulate
Emissions from Stationary
Sources
OAC 3745-17-07

Control of Fugitive Dust
OAC 3745-17-08
Establishes requirements to prevent A
discharge of air emissions of a shade
or density greater than 20 percent
opacity during treatment operations.

Visible emissions of fugitive dust R&A
generated during grading, loading, or
construction activities must be minimized.
3A.1 Vit
3B.1 Vit
CAA
Restriction on Particulate
Emissions from Industrial
Processes
OAC 3745-17-11
Treatment operations shall maintain
emissions below specified particulate
material release limits.
A
3A.1 Vit
3B.1 Vit
2C
CWA
Nationwide Permit Program
33 CFR§ 330
Establishes requirements for dredge
and fill activities in jurisdictional
wetlands.
A
3A.1 Vit
3B.1 Vit
2C
CWA
Discharge of Storm Water
Runoff
40 CFR§ 122.26
Establishes requirements for monitoring
and controlling runoff from
construction sites greater than five
acres.
A
3A.1 Vit
3B.1 Vit
2C
CWA
Discharge of Treatment
System Effluent (Best
Management Practices)
40 CFR§ 125.100
40 CFR§ 125.104
Program establishes measures to
prevent releases from spills or runoff
during the implementation of remedial
actions.
R&A
3A.1 Vit
3B.1 Vit
2C
NEPA/
DOE
NEPA Implementation
10 CFR§ 1021
Requires NEPA evaluation and
documentation for DOE activities.
A
2C
RCRA
Sub. D
Regulatory
Alternative

3A.1 Vit
3B.1 Vit
Program

RCRA
Sub. C
On-Site Solid Nonhazardous
Waste Management Facilities
(Design Standards)
40 CFR§ 241 Subpart B
(OAC 3745-27-08)

Regulatory Title and
Citation

Hazardous Waste
Determinations
Establishes design criteria for the
proposed disposal facility for Subunit C
material.
Regualtory Description

Establishes procedures for identifying
material as hazardous waste so that it
R&A
ARAR/TBC
R&A
(This
-------
2C
40 CFR§ 262.11
(OAC 3745-52-11)
may be stored, treated, and disposed in
accordance with RCRA requirements.
3A.1 Vit
3B.1 Vit
2C
3A.1 Vit
3B.1 Vit
RCRA
Sub. C
RCRA
Sub. C
3A.1 Vit
3B.1 Vit
2C
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
RCRA
Sub. C
Management of Empty
Containers
40 CFR§ 261.7
(OAC 3745-51-7)
Generators Who Transport
Hazardous Waste for Off-Site
Treatment, Storage, or
Disposal
40 CFR§ 262.20 - 262.33
and 263.20-31
(OAC 3745-52-20 through 33
and OAC 3745-53-20
through 31)

Treatment, Storage, or
Disposal (TSD) Facility
(General Stantards)
40 CFR§ 264, Subpart B
(OAC 3745-54-13 through
16)

TSD Facility (Preparedness
and Prevention)
40 CFR§ 264, Subpart C
(OAC 3745-54-31)
40 CFR§ 264.32
(OAC 3745-54-32)
40 CFR§ 264.33
(OAC 3745-54-33)
40 CFR§ 264.34
(OAC 3745-54-34)
40 CFR§ 264.35
(OAC 3745-54-35)
40 CFR§ 264.37
Requirements to ensure containers are
properly emptied and to ensure
residuals removed from the containers
are properly managed in accordance
with RCRA requirements.

Establishes standards for generators
shipping hazardous waste for off-site
treatment, storage, or disposal.
requirement
will be
applicable
to non-
excluded
solid
wastes)

R&A
A
Establishes general standards for the
proper management of material
determined to be hazardous waste.
Establishes standerds for preparedness
and prevention against fires,
explosions, or unplanned releases of
hazardous wasm at TSD facilities.
R&A
R&A
-------
(OAC 3745-54 37)
Regulatory
Alternative
Program
Regulatory Title and
Citation
ARAR/TBC
Regualtory Description
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
TSD Facility (Contingency
Plan and Emergency
Procedures)
40 CFR§ 264, Subpart D
40 CFR§ 264.51
(OAC 3745-54-51)
40 CFR§ 264.52
(OAC 3745-54-52)
40 CFR§ 264.55 and 56
(OAC 3745-54-55 through
56)
Establishes standards for contingency
plans and emergency procedures in
responding to fires, explosions, or
unplanned releases of hazardous waste
at TSD facilities.
R&A
2C
RCRA
Sub. C
3A.1 Vit
3B.1 Vit
2C
2C
RCRA
Sub. C
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
RCRA
Sub. C
Releases from Solid Waste
Management Units
40 CFR§ 264, Subpart F
(OAC 3745-54-91 through 99
and OAC 3745-55-01
through Oil)

Closure
40 CFR§ 264, Subpart G
40 CFR§ 264.111,.114, and
.116
(OAC 3745-55-11,-14, and -
16)

Post-Closure
40 CFR§ 264.117
(OAC 3745-55-17)
40 CFR§ 264.119
(OAC 3745-55-19)

Container Storage
40 CFR§ 264.171 - 178
Subpart I
(OAC 3745-55-71 through -
78)
Establishes groundwater monitoring
reguirements for assuring
concentrations of hazardous
constituents do not exceed regulatory
levels.
Establishes closure reguirements for
TSD facilities.
R&A
R&A
Establishes reguirements for the
protection of human health and the
environment following closure of the
facility.
Establishes standards for use and
management of containers of hazardous
waste.
R&A
R&A
-------
3A.1
3B.1
3A.1 Vit
3B.1 Vit
RCRA
Sub. C
RCRA
Sub. C
Tank Systems
40 CFR§ 264, Subpart J
(OAC 3745-55-91 through
96)

Closure Requirements for
Tanks
40 CFR§ 264.197
(OAC 3745-55-97)
Establishes standards for the tank R&A
systems used in the vitrification
treatment process.
Establishes closure and post-closure R&A
requirements for tank systems.
2C
RCRA
Sub. C
Landfill Capping
40 CFR§ 264.310
(OAC 3745-57-10)
Establishes design standards for closure R&A
of the proposed disposal facility for
Subunit C material.
Regulatory
Alternative
Program
Regulatory Title and
Citation
Regulatory Description
ARAR/TBC
3A.1 Vit
3B.1 Vit
RCRA
Sub. C
Miscellaneous Units
40 CFR§ 264, Subpart X
(OAC 3745-57-91 through
92)
Establishes standards for treatment,
storage, and disposal of hazardous
waste in miscellaneous units.
R&A
3A.1 Vit
3B. 1 Vit
2C
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
RCRA
Sub. C
Corrective Action for
SWMUs (CAMU and TU)
40 CFR§ 264, Subpart S
40 CFR§ 264.552 -.553

Containment Buildings
40 CFR§ 264, Subpart DD
Establishes requirements and criteria R&A
for corrective action management units
for management of remediation waste
during remediation activities.

Establishes standards for containment R&A
buildings used for interim storage and
management of material determined to
be hazardous waste during remediation
activities.
2C
RCRA Digging Where Hazardous or
Sub. C Solid Waste Was Located
ORC 3734.02 (H)
Establishes post-remedial action
institutional controls for on-site
disposal of Subunit C material.
A
3A.1 Vit
3B.1 Vit
2C
SDWA Ohio Water Well Standards
OAC 3745-9-10
Establishes standards for abandonment
of test borings, holes, and wells that
might be used and/or closed as part of
the remediation activities.
A
3A.1 Vit
AEA
Env. Rad. Protection Stds.
for Mgt. and Disposal of
Establishes standards for management
and storage for disposal of material
R&A
-------
2C
UMTRCA
2C
UMTRCA
HLRW, Spent Nuclear Fuel,
and TRU Wastes
40 CFR§ 191, Subpart A
40 CFR§ 191.03(b)
Standards for Control of
Residual Radioactive
Material
40 CFR§ 192, Subpart A
40 CFR§ 192.02(a)

Standards for Cleanup of
Lands Contaminated with
Residual Radioactive
Materials
40 CFR§ 192, Subpart B
40 CFR§ 192.12(a)
from Subunit A to ensure the combined
annual dose equivalent to any member
of the public does not exceed specified
limits. (This requirement pertains to
only the on-site portion of this
alternative).

Requires that controls for the residual
radioactive material in the proposed on-
site disposal facility be effective for
1000 years, where reasonably
achievable, or at least 200 years.

Establishes standards for remedial
actions to ensure residual concentration
of radium-226 in soils does not exceed
requlatory levels.
R&A
R&A
3A.1 Vit
3B.1 Vit
2C
UMTRCA
Implementation of Health and
Environmental Protection
Standards for Uranium Mill
Tailinqs OU4.
40 CFR§ 192, Subpart C
Establishes quidance for remedial
activities involvinq control and cleanup
of residual radioactive material from
R&A
Requlatory
Alternative

3A.1 Vit
3B.1 Vit
2C
Proqram

DOE
Order
Requlatory Title and
Citation

Radiation Dose Limit (All
Pathways)
DOE Order 5400.5, Chapter
II
Section l.a
Requlatory Description

Establishes limits for the allowable
exposure of the public to radiation
sources from all pathways as a result
of routine DOE activities. Included as
TBC to ensure adequate protection of
human health and the environment
from sources of radioactivity.
ARAR/TBC
TBC
-------
APPENDIX C

RESPONSIVENESS SUMMARY

TABLE OF CONTENTS
Page

List of Tables c-ii

List of Acronyms c-iii

C.1.0 Purpose C-l-1

C.2.0 Public Involvement for the FEMP C-2-1

C.3.0 Community Participation for Operable Unit 4 C-3-1

C.4.0 Summary of Issues and Responses C-4-1

C.5.0 Summary of Comments not Resulting in Issues C-5-1

Attachment C.I Written and Oral Comments C-I-1

Attachment C.II Errata Sheets and Changes to the Feasibility Study/
Proposed Plan - Draft Environmental Impact Statement C-II-1

Attachment C.III Final Environmental Impact Statement Distribution List C-III-1

Attachment C.IV Public Meeting Transcripts C-IV-1

LIST OF TABLES
Page

C.4-1 Formal Oral and Written Comments Received C-4-2

C.4-2 Impacts to the Public During Transportation of Vitrified Silos 1, 2 and 3
Waste to the NTS C-4-34

LIST OF ACRONYMS

AEA Atomic Energy Act
BAT Best Available Technology
CAB Citizen's Advisory Board
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
DOE United States Department of Energy
DOE-FN United States Department of Energy-Fernald Field Office
DOE-NV United States Department of Energy-Nevada Field Office
DOT United States Department of Transportation
EIS Environmental Impact Statement
EPA United States Environmental Protection Agency
FEIS Final Environmental Impact Statement
FEMP Fernald Environmental Management Project
-------
FERMCO Fernald Environmental Restoration Management Company
FFC Act Federal Facility Compliance Act
FRESH Fernald Residents for Environment, Safety, and Health
FS/PP-DEIS Feasibility Study/Proposed Plan-Draft Environmental Impact Statement
HEAST Health Effects Assessment Summary Table
MAWS Minimum Additive Waste Stabilization
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NEPA National Environmental Policy Act
NOI Notice of Intent
NTS Nevada Test Site
OAC Ohio Administrative Code
OATP Ohio Air Toxics Policy
OEPA Ohio Environmental Protection Agency
OHPO Ohio Historic Preservation Office
PEIC Public Environmental Information Center
RCRA Resource Conservation and Recovery Act
RI Remedial Investigation
RVFS Remedial Investigation/Feasibility Study
ROD Record of Decision
STEP Science, Technology, the Environment, and the Public
TCLP Toxicity Characteristic Leaching Procedure

C.1.0 PURPOSE

As stated in United States Environmental Protection Agency (EPA) Guidance on Preparing Superfund Decision
Documents (EPA 1989b), the responsiveness summary serves three important purposes. First, it provides United
States Department of Energy (DOE) with information about community preferences regarding both the proposed
remedial alternative and general concerns about the site. Second, it demonstrates how public comments were
integrated into the decision-making process. Third, it allows DOE to formally respond to public comments.

The Feasibility Study/Proposed Plan/Draft Environmental Impact Statement was conditionally approved on
February 9, 1994. In May 1994, five final concerns were received from the EPA on the document. In
responding to these five concerns, several pages in the document were revised and are included in Attachment
C.II.

This Responsiveness Summary has been prepared pursuant to the terms of the 1991 Amended Consent Agreement
between DOE and the EPA, as well as other requirements, including:

! The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the
Superfund Amendments Reauthorization Act, 42 United States Code, Sections 9601, et. seq. ;

! National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 Code of Federal Regulations
(CFR), Part 300;

! Community Relations in Superfund: A Handbook, January 1992c, EPA/540/R-92/009; and

! Guidance on Preparing Superfund Decision Documents: The Proposed Plan, The Record of Decision,
Explanation of Significant Differences, The Record of Decision Amendment, Interim Final, July 1989b,
EPA/540/G-89/007.

This Responsiveness Summary is used as the mechanism for DOE to identify and document the public involvement
with the Operable Unit 4 Feasibility Study/Proposed Plan - Draft Environmental Impact Statement. After
public comments and concerns had been formally submitted to DOE, in oral and written form, the comments were
summarized into issue statements and responded to accordingly. The actual comments received are included in
Attachment C.I of Appendix C.

Section C.2.0 of this Responsiveness Summary gives an overview of public involvement for the Fernald
-------
Environmental Management Project (FEMP). Section C.3.0 gives an overview of the public's involvement in the
development and approval of the Operable Unit 4 Feasibility Study/Proposed Plan- Draft Environmental Impact
Statement. Section C.4.0 discusses the development of the issue statements and presents the public concerns
and DOE responses. Section C.5.0 presents comments which did not result in issues.

C.2.0 PUBLIC INVOLVEMENT FOR THE FEMP

Environmental issues at Fernald first became public in 1984 when the site reported that nearly 300 pounds of
uranium oxide had been inadvertently released to the atmosphere from the Plant 9 dust-collector system. It
was also disclosed during this time that three privately-owned off-property groundwater wells south of
Fernald had been found to be contaminated with uranium in 1981. In 1984, the citizens group called Fernald
Residents for Environment, Safety and Health (FRESH) was formed and expressed concerns over these events and
lack of public notification. In response to this public concern, the FEMP initiated a community relations
program in 1985 aimed at informing the community of the mission of the facility and the ongoing and planned
operations.

As part of this program, four community meetings were held in 1985 to open communication channels with the
members of the public residing near the FEMP. As a result of these meetings and the need to prepare a
community relations plan to support the planned Remedial Investigation/Feasibility Study (RI/FS), a community
assessment was conducted in early 1986. The community assessment consisted of a series of interviews with
local community members to define their informational needs, their concerns regarding the environmental
issues at the site, and viable mechanisms to gain public involvement in the RI/FS decision-making process.
As work on the RI/FS continued, DOE authorized the operating of an information repository called the Public
Environmental Information Center (PEIC) in the JAMTEK building, 10845 Hand. 11on-Cleves Highway, Harrison, Ohio
45030. The administrative record, on which cleanup decisions are based, is also located at the JAMTEK
building; another administrative record is maintained at EPA Region V headguarters in Chicago, Illinois.

A RI/FS Commnunity Relations Plan was issued in January 1986 detailing the initiatives that would be
undertaken by the FEMP to promote community participation in the RI/FS decision-making process. This plan
has been progressively revised, as necessary, to accommodate regulatory agency input, the changing concerns
of the community, and emerging concepts on improved vehicles for facilitating community participation.

On May 15, 1990, a Notice of Intent (NOI) was published [55 Fed. Reg. 20183 (May 15, 1990)] indicating the
intent of DOE to prepare an Environmental Impact Statement (EIS) consistent with the National Environmental
Policy Act (NEPA) to evaluate the environmental impacts associated with the cleanup actions for the lead FEMP
operable unit (i.e., Operable Unit 4). The NOI further defined the intent of DOE to prepare integrated
CERCLA/NEPA documents for the remaining operable units that will tier from the lead document. The public,
interested organizations, and federal, state, and local agencies were invited to provide oral comments at two
EIS scoping meetings held on June 12-13, 1990, and to submit written comments until the close of the scoping
period on June 29, 1990.

As a result of the scoping meetings, an EIS Implementation Plan was issued by DOE. The EIS Implementation
Plan includes: a description of the proposed actions and remedial alternatives; a list of environmental
issues to be considered in the EIS (including those identified during the scoping period); a list of proposed
agency consultations; a responsiveness summary to comments received during scoping; and a discussion on the
interrelationship between the NEPA compliance process and CERCLA project planning and decision-making.
Consistent with the NOI and the EIS Implementation Plan, the resulting integrated process and documentation
package developed for Operable Unit 4 is termed a Feasibility Study/Proposed Plan-Draft Environmental Impact
Statement (FS/PP-DEIS).

In summary, several community relations activities are and have been conducted in support of local
organizations at Fernald including:

! A community assessment (June -July 1989);
! A Community Relations Plan (August 1992 version approved October 15, 1992);
! Public reading rooms and administrative record;
! Regular briefings at local township trustee meetings;
-------
! Presentations to the local community group, FRESH;
! Community meetings held approximately each guarter;
! Workshops and roundtable discussions for interested parties;
! Press releases, fact sheets and a newsletter;
! Public comment periods for decision documents and responsiveness summaries;
! Site tours, as reguested;
! Open house events;
! Annual joint emergency response exercises;
! Annual environmental monitoring reports; and
! The Fernald Citizens Task Force.

C.3.0 COMMUNITY PARTICIPATION FOR OPERABLE UNIT 4

As indicated earlier, a community assessment was conducted in early 1986 which consisted of a series of
interviews with local community members to define their informational needs, their concerns regarding the
environmental issues at the site, and viable mechanisms to gain public involvement in the RI/FS decision
process. Significant concerns associated with Operable Unit 4 facilities identified during these interviews
included:

! The significantly elevated direct penetrating radiation field in the vicinity of the
silos.

! The chronic emissions of significant guantities of the radioactive gas, radon, to the
atmosphere from the silos.

! The structural instability of the silos' domes and the age of the remaining portions of
the structures.

! The potential for leaching of the stored residues to the underlying sole-source aguifer.

To adeguately identify and address community concerns, several initiatives have been undertaken by the FEMP
to ensure community involvement in the decision-making process for the remediation of Operable Unit 4.

The draft Remedial Investigation (Rl) Report for Operable Unit 4 was released to the public for review and
comment in April 1993. The document was made available to the public at the PEIC and the EPA offices in
Chicago. The notice of availability for the Rl Report for Operable Unit 4 was published in local newspapers
near the FEMP site on April 19, 1993. A public comment period was conducted for the Rl Report for Oposble
Unit 4 from April 19, 1993 through May 19, 1993. No comments were received on the Rl Report for Operable
Unit 4.

On September 9, 1993, the draft Feasibility Study/Proposed Plan-Draft Environmental Impact Statement was made
available at the Public Environmental Information Center, and stakeholders were encouraged to provide
informal comments on the preliminary documents. Encouraging public inspection and informal comment on these
preliminary documents, prior to EPA approval, provided a genuine opportunity for stakeholders to identify
issues, voice their concerns and learn about proposed cleanup plans for Operable Unit 4. The informal
opportunity for the public to provide input enabled DOE to address some stakeholder guestions and concerns in
advance of the formal public comment period.

In addition, a two-way information exchange on the Operable Unit 4 Risk Assessment occurred at the October
19, 1993, Science, Technology, the Environment and the Public (STEP) session on "Risk." Again, Fernald
personnel addressed the stakeholders' guestions and concerns presented at the meeting. Information about the
Operable Unit 4 Remedial Investigation Report was also provided at DOE's October 21, 1993, RI/FS public
-------
meeting and at local township trustee meetings.

In response to stakeholder reguests at the January 5, 1994, formal public hearing on the Operable Unit 3
(Production Area) Interim Record of Decision, a public roundtable to discuss integration of CERCLA and NEPA
was held January 24, 1994. The roundtable included discussions on differences between environmental
assessments and environmental impact statements; approximately 45 stakeholders attended.

On February 21, 1994, invitations to attend the March 21, 1994, formal public hearing on the Operable Unit 4
FS/PP-DEIS were mailed to approximately 2,000-plus Fernald stakeholders. The Proposed Plan for Remedial
Actions at Operable Unit 4 Fact Sheet was enclosed with each invitation.

On February 24, 1994, advance copies of the Proposed Plan for Remedial Actions at Operable Unit 4 were mailed
to several key stakeholders. Also on February 24, copies of the final FS/PP-DEIS and Proposed Plan fact
sheets were mailed to the United States Department of Energy-Nevada Field Office (DOE-NV) and to the State of
Nevada Clearinghouse. The DOE Operable Unit 4 Branch Chief personally distributed several advance copies of
the Proposed Plan to attendees of the February 24, 1994, FRESH meeting. In addition, she provided an update
on Operable Unit 4 activities, plans and progress, and was available for an informal guestion-and-answer
session.

To encourage stakeholders to review and offer input on the final FS/PP-DEIS, a Notice of Availability for
formal public comment was published in March 1994 in the Federal Register and three local newspapers: The
Cincinnati Enguirer, the Journal-News and the Harrison Press. On March 1, 1994, the, FS/PP-DEIS became
available at the PEIC.

On March 2, 1994, Ohio EPA representatives discussed the FS/PP-DEIS with members of the Fernald Citizens Task
Force and FRESH.

On March 4, 1994, a Fernald site news release titled "Key Fernald Cleanup Plan Receives Conditional EPA
Approval" was sent to local electronic and print media, as well as local elected officials, FRESH and the
Fernald Citizens Task Force. Articles were published in local newspapers.

On March 7, 1994, the formal 45-day public comment period on the Operable Unit 4 FS/PP-DEIS officially began.

On March 8, 1994, Fernald representatives met formally with officials of the DOE-NV and the Nevada Division
of Environmental Protection and provided a presentation on the Operable Unit 4 FS/PP-DEIS.

Display advertisements announcing the March 21, 1994, formal public hearing were published in three local
newspapers: The Cininnati Enguirer, March 18, 1994 and March 20, 1994; the Cincinnati Post, March 18, 1994;
and the Journal-News, March 18, 1994.

On March 21, 1994, approximately 80 people attended the formal public hearing on the Operable Unit 4
FS/PP-DEIS. Formal oral public comments were documented by a court reporter and are available in a written
transcript at the PEIC and in Attachment C.IV of Appendix C. In addition, several stakeholders submitted
formal written comments. All formal written and oral stakeholder comments and guestions asked informally
during the March 21, 1994, public hearing, as well as DOE's responses, are documented in the Operable Unit 4
Responsiveness Summary.

During April 1994, the DOE received a reguest from the State of Nevada to extend the public comment period
for sixty (60) days to allow a newly formed Citizen's Advisory Board (CAB) additional time to review and
comment on the Operable Unit 4 FS/PP-DEIS. In accordance with the reguirements of the NCP and the Amended
Consent Agreement, the DOE granted a 30-day extension of the public comment period from April 20, 1994 to May
20, 1994 to accommodate this reguest.
-------
On May 11, 1994, the DOE-NV conducted a public meeting in Las Vegas, Nevada. In attendance were members from
the DOE, EPA (Region V), Ohio EPA, CAB and the public. This meeting was the first meting of the
newly-organized CAB. As part of the meeting's agenda, the DOE conducted two presentations. One of the
presentations, furnished by the DOE-FN, discussed the Operable Unit 4 FS/PP-DEIS and summarized the proposal
to transport and dispose of low-level radioactive wate, which would be generated by the cleanup and
environmental restoration of the FEMP site as a whole (including Operable Unit 4), at the NTS. The other
presentation was furnished by the DOE-NV which summarized the current low-level radioactive waste management
program at the NTS.

Each presentation was followed by a formal guestion and answer session, during which the following concerns
were discussed:

! Adeguacy of characterization process of all FEMP waste shipped to the NTS.
! Classification of the K-65 by-product material as 11 (e) (2) material.
! Availability of any alternative disposal sites for the Operable Unit 4 remedial wastes.
! 40 CFR §191 "relevance" to Operable Unit 4 remedial wastes by EPA.
! Transportation and containerization of the Operable Unit 4 remedial wastes.
! Benefits to be derived by the State of Nevada for disposing of the waste at the NTS.

The complete transcript of this meeting is included in Attachment C.IV of Appendix C.

During the meeting, the CAB noted that they had not received a copy of the Operable Unit 4 FS/PP-DEIS for
renew and comment. It was noted that a copy of the Operable Unit 4 FS/PP-DEIS was available in the DOE-NV
Reading Room. Copies of the Proposed Plan and Proposed Plan Fact Sheet were distributed to members at the
meeting. A copy of the Operable Unit 4 FS/PP-DEIS was provided to the CAB on May 12, 1994.

In addition, the CAB verbally reguested in the meeting that the comment review period for the Operable Unit 4
FS/PP-DEIS be extended an additional thirty days to provide the CAB adeguate time to review the document.
Subseguently, on May 19, 1994, DOE submitted to EPA a second reguest for extension in the submittal of the
Operable Unit 4 ROD. The EPA reviewed this reguest pursuant to Section XVIII of the 1991 ACA, which reguires
EPA to determine whether good cause exists for a schedule extension based upon, among other things,
information submitted by DOE. In response to the CAB reguest, the DOE on May 20, 1994 formally granted the
thirty-day extension of the public comment period from May 20, 1994 to June 19, 1994. On May 26, 1994, the
EPA granted the 30-day extension for submittal of the Proposed Draft ROD from July 10, 1994, to August 9,
1994.

On August 8, 1994, DOE submitted the Proposed Draft Record of Decision for Remedial Actions at Operable Unit
4 and the Responsiveness Summary to the EPA.

C.4.0 SUMMARY OF ISSUES AND RESPONSES

This Responsiveness Summary document has focused on the formal comments submitted during the public comment
period and oral comments received during the March 21, 1994 community meeting held in Harrison, Ohio and the
May 11, 1994 public meeting held in Las Vegas, Nevada. Within this Responsiveness Summary, oral and written
comments (see Attachment C.I) were categorized into significant issues. For each of these issues, an issue
statement has been prepared that addresses the concerns expressed by one or more of the commentors. In many
instances, the issue statements are paraphrased from the original comments to succinctly represent the
combined concerns of several commentors. The issues resulting from formal comments have been compared with
the guestions raised during the public guestion and answer sessions to ensure that all significant issues
have been represented by the issue statements.

For the purpose of developing issue statements, a comment is considered significant if it involves:
-------
! The definition of the preferred alternative,
! Public or state acceptance of the preferred alternative,
! The implementation or impacts of the preferred alternative,
! Conclusions drawn from evaluations or assessments provided within the document,
! Safety of the work performed, or the
! Enforceability of the decision reached.

At the end of each issue statement, the specific comment letter(s) or oral comment(s) in which the issue was
raised is identified in parentheses. The comments are referred to by an alphabetic identifier. These
comments are also part of the administrative record for this action. Table C.4-1 provides a cross-reference
of the alphabetic identifiers with the commentors.
-------
TABLE C.4-1
FORMAL ORAL AND WRITTEN COMMENTS RECEIVED

PAGE
ITEM COMMENTOR NUMBER

FORMAL ORAL COMMENTS

A Norma Nungester, resident and FRESH member C-I-8

B Vicky Dastillung, resident and FRESH Vice President C-I-19

C Lou Bogar, resident, Hamilton, Ohio C-I-20

D Edwa Yocum, resident and FRESH Secretary C-I-28

FORMAL WRITTEN COMMENTS

E Maud Naroll, State of Nevada, State Clearinghouse (April 18, 1994) C-I-31

F Jack and Roberta Warndorf, resident, Okeana, Ohio C-I-34

G Edwa Yocum, resident and FRESH Secretary, Harrison, Ohio C-I-36

H J. E. Walther, resident, Hamilton, Ohio C-I-36

I Martha J. Raymond, Department Head, Technical Review Services, Ohio C-I-38
Historic Preservation Office

J Lisa Crawford, resident and FRESH President C-I-40

K Lawrence L. Stebbins, resident, Hamilton, Ohio C-I-41

L Maud Naroll, State of Nevada, State Clearinghouse (April 5, 1994) C-I-43

M James K. O'Steen, Director, Office of Hazardous Materials Technology, U.S. C-I-45
Department of Transportation

N William L. Vasconi, Acting Chairman, Nevada Test Site Citizens Advisory C-I-47
Board

0 Nevada Test Site Citizens Advisory Board C-I-48

P-l Nichole Davis, 1600 E. University #151, Las Vegas, NV 89119 C-I-49

P-2 Shellie Michael, 2800 S. Eastern #717, Las Vegas, NV 89109 C-I-49

P-3 Lynn Rohl, P.O. Box 12303, Las Vegas, NV 89112 C-I-50

P-4 Ted Mucha, 301 Orland #8, Las Vegas, NV 89107 C-I-50

P-5 Mark Michael, 2800 S. Eastern #717, Las Vegas, NV 89109 C-I-51

P-6 Kathleen Guise, 4124 Seville St., Las Vegas, NV 89121 C-I-51

P-7 Jo Anne Moran, 3128 E. Flamingo #203, Las Vegas, NV 89121 C-I-52
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P-8 Catherine A. McLaughlin, 1721 Howard Ave., Las Vegas, NV 89104 C-I-52

P-9 Nancy Gott, 3212 Brahns Dr., Las Vegas, NV 89102 C-I-53

P-10 Rebecca Webber, 5070 River Glen Dr. #457, Las Vegas, NV 89103 C-I-53

P-ll Tanya Carr, 2032 Shadow Brook Way, Las Vegas, NV 89014 C-I-54

P-12 Jim Macklin, 5178 Silverheart Ave., Las Vegas, NV (no zipcode provided) C-I-54

PAGE
ITEM COMMENTOR NUMBER

P-13 Cindy Weatherby, 1760 N. Decatur #69, Las Vegas, NV 89108 C-I-55

P-14 Rebecca Heider, 6941 W. Forest Vista St., Las Vegas, NV 89117 T C-I-55

P-15 Troy Weatherby, 1760 N. Decatur #69, Las Vegas, NV 89108 C-I-56

P-16 Abraham Hartman, 1872 Pasadena Blvd., Las Vegas, NV 89115 C-I-56

P-17 Vicki Cassman, P.O. Box 72634, Las Vegas, NV 89170 C-I-57

P-18 Art Goldberg, 14810 Living Desert Dr., Las Vegas, NV 89119 C-I-57

P-19 Jillian Beth Wright, 6435 lorn Bark Lane (address provided incomplete) C-I-58

P-20 Linda Strange, 4830 Nara Vista Way #102, Las Vegas, NV 89103 C-I-58

P-21 Ronnie Strange, 4830 Nara Vista Way #102, Las Vegas, NV 89103 C-I-59

P-22 Mindy Brummett, 6397 Spring Meadow Dr., Las Vegas, NV 89103 C-I-59

P-23 LaLori Rossi, 1929 Frasklis Ave. (address provided incomplete) C-I-60

P-24 Taryn Cunningham, 7383 Newcrest Cir., Las Vegas, NV 89117 C-I-60

P-25 Tiffany Brummett, 6397 Spring Meadow Dr., Las Vegas, NV 89103 C-I-61

P-26 Janet Zimmerman, 1912 Spangle Dr., Las Vegas, NV 89108 C-I-61

P-27 Janene Zimmerman, 1912 Spangle Dr., Las Vegas, NV 89108 C-I-62

P-28 Patricia Bishop, 1400 S. Casino Ct. #19, Las Vegas, NV 89104 C-I-62

P-29 Daniel J. Fedor, 185 Swaab, Las Vegas, NV 89115 C-I-63

P-30 Michael Carrigan, 7217 Tempest PI., Las Vegas, NV 89128 C-I-63

P-31 Renee Halm, 1000 King Richard, Las Vegas, NV 89119 C-I-64

P-32 Tubiola Lopez, 1508 Living Desert Dr., Las Vegas, NV 89119 C-I-64

P-33 Doreina Saenz, 2111 Fairfield #6, Las Vegas, NV 89102 C-I-65

P-34 Jerome Brenberg, 5668 Divot PI., Las Vegas, NV 89130 C-I-65
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P-35 Ravon Rodriguez, 538 Kolson Cr. #"A" (address provided incomplete) C-I-66

P-36 Carmen E. Rodriguez, 538 Kolson Cr. #"A" (address provided incomplete) C-I-66

P-37 Kimba Rutledge, 399 Steelhead Lane, Las Vegas, NV 89110 C-I-67

P-38 Sheila Rutledge, 399 Steelhead Ln., Las Vegas, NV 89110 C-I-67

P-39 S. Humhe, 9285 Sunten Ct., Las Vegas, NV (address provided incomplete) C-I-68

P-40 Michelle Lynn Berry, 370 E. Harmon Apt. E310, Las Vegas, NV 89109 C-I-68

P-41 L. Jean McCoy, 6710 Wild Horse Rd., Las Vegas, NV 89108 C-I-69

P-42 Tammy Smith, 6710 Wild Horse Rd., Las Vegas, NV 89108 C-I-69

P-43 Henry B. (?), 1982 N. Rainbow #194, Las Vegas, NV 89108 (name C-I-70
unreadable)

P-44 Stan Greene, 7845 La Cienega, Las Vegas, NV 89123 C-I-70

ITEM COMMENTOR PAGE
NUMBER

P-45 Frances Bruno, 486 Sierra Vista Dr. #24 (address provided incomplete) C-l-71

P-46 Betty Hay, 1241 South 7th St., Las Vegas, NV 89104 C-I-71

P-47 David Geerts, 3940 S. Algonguin Dr. #83, Las Vegas, NV 89119 C-I-72

P-48 John Engle, 4441 Escondido St. Apt. #4205 (address provided incomplete) C-I-72

P-49 Alison Orr, 7053 Cheerful Circle, Las Vegas, NV 89117 C-I-73

P-50 David Gohas, P.O. 46204, Las Vegas, NV 89114 C-I-73

P-51 Finu Noms-Coray, 4801 Spencer #56, Las Vegas, NV 89119 C-I-74

P-52 Elizabeth Petit, 2362 N. Green Valley Parkway #141P, Henderson, NV 89014 C-I-74

P-53 Sonja Swenson, 4444 Midway Lane, Las Vegas, NV 89108 C-I-75

P-54 Ron Schaefer, 3950 Mountain Vista #146, Las Vegas, NV 89121 C-I-75

P-55 Victoria Pinkston, 1771 Charnut Lane (address provided incomplete) C-I-76

P-56 Kathy Granousky, 3355 Dakota Way, Las Vegas, NV 89109 C-I-76

P-57 Emilee Rogers, 1105 Washington (address provided incomplete) C-I-77

P-58 Michael LoCorriere, 7201 W. Girard Drive, Las Vegas, NV 89117 C-I-77

P-59 Sheri LoCorriere, 7201 W. Girard Drive, Las Vegas, NV 89117 C-I-78

P-60 Breck Nester, 24252 Sparrow, El Toro, CA 92630 C-I-78

P-61 Dana Robbins, 5028 S. Rainbow #101, Las Vegas, NV 89118 C-I-79
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P-62 Huy Phan, 3719 Central Park Circle, #4 (address provided incomplete) C-I-79

P-63 Sandra Travez, 30 Tierra Buena Drive, Las Vegas, NV 89110 C-I-80

P-64 Steve Zahn, 8305 Greshen, Las Vegas, NV (no zipcode provided) C-I-80

P-65 Lisa Nunag, 1009 Spire CNYN, Las Vegas, NV 89128 C-I-81

P-66 Tim Jagua, 3273 E. Flamingo #102, Las Vegas, NV 89121 C-I-81

P-67 Shelli McKenney, 4640 Victoria Beach Way, Las Vegas, NV (no zipcode C-I-82
provided)

P-68 Carmen Davis, 6666 W. Washington #463, Las Vegas, NV 89107 C-I-82

P-69 Nasreen Bakhtary, 2165 E. Rochelle #71, Las Vegas, NV 89119 C-I-83

P-70 Maribel McAdory, 2529 Pacific Avenue, Las Vegas, NV (no zipcode provided) C-I-83

P-71 Merlinda Gollegos, 5625 W. Flamingo #2005, Las Vegas, NV 89103 C-I-84

P-72 Chad Hunt, 8222 Beaverbrook Way, Las Vegas, NV 89123 C-I-84

P-73 Barb Brentz, 1015 Franklin Avenue, Las Vegas, NV 89104 C-I-85

P-74 Mayte Villanueva, 1805 Evelyn Avenue, Henderson, NV 89015 C-I-85

P-75 James Min, 5315 Heatherbrook Circle, Las Vegas, NV 89120 C-I-86

P-76 David Johnson, 3632 Hamlin, Las Vegas, NV 89030 C-I-86

PAGE
ITEM COMMENTOR NUMBER

P-77 Laura Yada, 4770 Gym Road, Las Vegas, NV 89119 C-I-87

P-78 Shannon Conners, 1213 Sloop Drive, Las Vegas, NV 89128 CC-I-87

P-79 Sherri Caron, 3913 Courtside, Las Vegas, NV 89105 C-I-88

P-80 Stevi Carroll, 6505 Burgundy Way, Las Vegas, NV 89107 C-I-88

P-81 Margaret Bean, 3060 Ramrod, Las Vegas, NV 89108 C-I-89

P-82 Patrice L. Harvey, 7412 Summer Crest Lane, Las Vegas, NV 89129 C-I-89

P-83 Robin Wayne, 3400 Turguoise Road, Las Vegas, NV 89108 C-I-90

P-84 George A. Bean, 3060 Ramrod Street, Las Vegas, NV 89108 C-I-90

P-85 Robert Pierson, 2974 Liberty Avenue, Las Vegas, NV 89121 C-I-91

P-86 Tim Bartlett, 4504 Fireside Lane, Las Vegas, NV 89110 C-I-91

P-87 Selma and Chuck Umnuss, 8504 Glenmount Drive, Las Vegas, NV 89134- C-I-92
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P-88 Rob Marchant, 650 Whitney Ranch, Henderson, NV (no zipcode provided) C-I-92

P-89 Jeff Van Ee, 2092 Heritage Oaks, Las Vegas, NV 89119 C-I-93

P-90 Tiffany Braun, 1635 Westwind Circle (address provided incomplete) C-I-93

P-91 Jeffrey M. Steinbeck, 294 Davis Hill Court, Henderson, NV 89014 C-I-94

P-92 Catherine Tillman, 3107 Lamega Drive, Henderson, NV 89014 C-I-94

P-93 Madelaine Dayton, 2253 Castleberry, Las Vegas, NV 89115 C-I-95

P-94 Lori Johnson, 274 Camino Verde, Henderson, NV 89014 C-I-95

P-95 Sharlyn Anderson, 551 Eiger Way #1312, Henderson, NV 89014 C-I-96

P-96 Kathleen Womack, 56S2 S. Latigo, Las Vegas, NV 89119 C-I-96

P-97 S. Gomez, 4255 Tamarus #286, Las Vegas, NV 89119 C-I-97

P-98 Melony Haynes, 1308 N. Jones, Las Vegas, NV 89108 C-I-97

P-99 Michele Gilbreth, 2391 Callahan Avenue, Las Vegas, NV 89119 C-I-98

P-100 Mary E. July, 5250 E. Lake Mead #26, Las Vegas, NV 89115 C-l-98

P-101 Grace K. Tao, P.O. Box 60384, Boulder City, NV 89005 C-I-99

P-102 Julia L. Winkler, 1127 E. Toni Avenue #18, Las Vegas, NV 89119 C-I-99

P-103 John Heormey, 419 Desert Inn Road, Las Vegas, NV (address provided C-I-100
incomplete and last name hard to read)

P-104 James Holmes, 604 Freeman (address provided incomplete) C-I-100

P-105 Merlyn Huguet, 2021 Peyton, Las Vegas, NV 89104 C-I-101

P-106 Barbara Roth, 112 Temple Drive, Las Vegas, NV 89107 C-I-101

P-107 John Wells, 6983 Antell Circus, Las Vegas, NV (address provided incomplete) C-I-102

PAGE
ITEM COMMENTOR NUMBER

P-108 Al Roth, 112 Temple Drive, Las Vegas, NV 89107 C-I-102

P-109 Louis Lavietes, 3401 E. Bonanza Road (address provided incomplete) C-I-103

P-110 Jeff Cooley, 8257 Bermuda Beach Drive, Las Vegas, NV 89128 C-I-103

P-lll James P. Foster, 817 Lauren Patt, Henderson, NV 89104 C-I-104

P-112 Giovanni Duley, 6251 Viewpoint Drive, Las Vegas, NV 89115 C-I-104

P-113 Trisa Higgins, 1075 Legato Drive, Las Vegas, NV 89123 C-I-105

P-114 Maggie Breki, 3237 E. Flamingo, Las Vegas, NV 89121 (last name hard to C-I-105
-------
read)

P-115 Joel Delmendo, 3138 Gaucho Drive, Las Vegas, NV 89008 (zip code hard to C-I-106
read)

P-116 Katherine Garder, 5050 Tamanas #267, Las Vegas, NV 89119 C-I-106

P-117 Jason Benatz 6317 Hobart, Las Vegas, NV 89107 C-I-107

P-118 Ebony Samerkand, 549 Kristin Lane, Henderson, NV 89015 C-I-107

P-119 Stacy Smith 4223 Grove Circle #4, Las Vegas, NV 89119 C-I-108

P-120 Sanena Shelling, 1445 E. Rochelle (address, provided incomplete) C-I-108

P-121 Gerald F. Cuetkovic, 135 Grandview Drive, Henderson, NV 89015 C-I-109

P-122 Judy Cuetkovic, 135 Grandview Drive, Henderson, NV 89015 C-I-109

P-123 Michael Cuetkovic, 135 Grandview Drive, Henderson, NV 89015 C-I-110

P-124 Mrs. G. Michakel, 4079 El Segundo Avenue, Las Vegas, NV 89121-1703 C-I-110

P-125 Willene De Langis, 758 Willow Avenue, Henderson, NV 89015 C-I-111

P-126 Donald A. De Langis, 758 Willow Avenue, Henderson, NV 89015 C-I-111

P-127 Robert Tonelli, 1004 University Ridge, Reno, NV (no zipcode provided) C-I-112

P-128 Ruth Lindahl, 9457 S. Las Vegas Blvd. S. #93, Las Vegas, NV 89123 C-I-112

P-129 Melody Derrick, 330 S. 10th St., Las Vegas, NV 89107 C-I-113

P-130 Doug Jablin, 3559 Markan St., Las Vegas, NV 89121 C-I-113

P-131 Anthony Bondi, 135 Albert Avenue St. E. #16, Las Vegas, NV (no zipcode C-I-114
provided)

P-132 T. Jones, Box 73215, Las Vegas, NV 89170 C-I-114

P-133 John A. Loeffler, P.O.Box 832, Searchlight, NV 89046 C-I-115

P-134 Christopher Mercer, 2517 Huber Hts., Las Vegas, NV 89128 C-I-115

P-135 Kurt Buchida, 325 Maryland Parkway, Las Vegas, NV 89101 C-I-116

P-136 Liz Marion, 6824 Adobe Court, Las Vegas, NV 89102 C-I-116

P-137 Dennis A. Dewitt, Box 5371, Reno, NV 89513 C-I-117

PAGE
ITEM COMMENTOR NUMBER

P-138 Brenda Weksler, 7904 Marbella Circle, Las Vegas, NV 89128 C-I-117

P-139 Cheryl Frossa, 3450 Erva St. #101, Las Vegas, NV 89117 C-I-118
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P-140 Harriet R. Gagliano, 2713 Gilmary Avenue, Las Vegas, NV 89102 C-I-118

P-141 Kathy Poma, 2113 Fountain Springs Drive, Henderson, NV 89014 C-I-119

P-142 Stacey Hallenberg, 2245 Maple Rose Drive, Las Vegas, NV 89134 C-I-119

P-143 Kelli Koerwitz, 909 Willowtree, Las Vegas, NV 89128 C-I-120

P-144 Trish Taylor, 2113 Fountain Springs Drive, Henderson, NV 89014 C-I-120

P-145 Heather Davis, 2031 E. Windmill Lane, Las Vegas, NV 89123 C-I-121

P-146 Marilyn Benoit, 3461 Pointe Willow, Las Vegas, NV 89120 C-I-121

P-147 Richard Lewnau, 2950 S. Decatur D-3, Las Vegas, NV 89102 C-I-122

P-148 Susan Thornton, 1412 Golden Spur Lane, Las Vegas, NV 89117 C-I-122

P-149 Lee Dazey, 72 Keystone Avenue, Reno, NV 89503 C-I-123

P-150 Pete Mastin, P.O. Box 92, Verdi, NV 89439 C-I-123

P-151 Tracie K. Lindeman, P.O. Box 1672, Fallen, NV 89407 C-I-124

P-152 David L. Platerio/Tosa-wi-e, P.O. Box 822, Elko, NV 89803 C-I-124

P-153 Jo Ana Garrett, P.O. Box 130, Baker, NV 89311 C-I-125

P-154 Margaret Norman, 2332 Grant Street, Berkeley, CA 94703 C-I-125

P-155 Judy Treichel, 3926 Bushnell Drive #71, Las Vegas, NV 89103 C-I-126

P-156 Lorry C. Johns, 2090 Westwind Road, Las Vegas, NV 89102 C-I-126

P-157 Steve Frishman, 208 N. Hwy. 95A, Yerington, NV 89447 C-I-127

P-158 William Rosse Sr., HC61 Box 6240, Austin, NV 89310-9301 C-I-127

P-159 Corbin Hanuf (?), P.O. Box 1255, Nevada City, CA 95959 (name was hard C-I-128
to read)

P-160 Shawn Black, 650 Whitney Ranch #1423, Las Vegas, NV (no zipcode C-I-128
provided)

P-161 Lawrence Skinner, 1604 E. Evans, Las Vegas, NV 89030 C-I-129

P-162 Mary L. Johns, 2090 Westwind Road, Las Vegas, NV 89102 C-I-129

P-163 Bob Fulkerson, 725 McDonald Drive, Reno, NV 89503 C-I-130

P-164 Carla Baker Wallace, 3245 Mallard, Las Vegas, NV 89107 C-I-130

P-165 Louise (?), 4255 Tamarus #217, Las Vegas, NV 89119 (name was hard to C-I-131
read)
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P-166 Margaret (?), 1526 Darryl Avenue, Las Vegas, NV 89123 C-I-131

P-167 (?), 1526 Darryl Avenue, Las Vegas, NV 89123 (name unreadable) C-I-132

PAGE
ITEM COMMENTOR NUMBER

P-168 (?), 1381 E. University Avenue (address incomplete and name unreadable) C-I-132

P-169 (?), 4801 Spencer #56, Las Vegas, NV 89119 (name unreadable) C-I-133

P-170 (?), 1431 E. Charleston, Las Vegas, NV 89104 (name unreadable) C-l-133

P-171 Jamie B. (?), 4630 White Rock Drive, Las Vegas, NV 89121 (name C-I-134
unreadable)

P-172 (name and address unreadable) C-I-134

P-173 (name and address unreadable) C-I-135

P-174 (left blank) C-I-135

P-175a Geoff Holton, 2332 Grant Street, Berkeley, CA 94703 C-I-136

P-176a Richard Glasman, 2212 18th Avenue South, Seattle, WA 98144 C-I-136

P-177a Kathleen Glasman, 2212 18th Avenue South, Seattle, WA 98144 C-I-137

Q Pam Dunn, Harrison, OH C-I-138

R Thomas A. Schneider, Ohio Environmental Protection Agency C-I-145

S Michael W. MacMullen, U.S. EPA Region 5, Planning and Management C-I-147
Division
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Issue 1 - Public Participation Process

(a) A formal request was made by Maud Naroll, State of Nevada, Department of Administration, State
Clearinghouse, on the behalf of the Nevada Test Site (NTS) Citizens Advisory Board (CAB) to extend the public
review period for the Operable Unit 4 FS/PP-DEIS for at least 60 days. The CAB was recently formed and held
its first organizational meeting on March 8, 1994. Because of the key role the CAB will play in advising the
DOE-NV about stakeholder concerns, the requested extension to the public comment period would allow the CAB
adequate time to address the Operable Unit 4 document. (Commentor: L)

(b) On May 17, 1994, a formal request was made by William L. Vasconi, Acting Chairman, NTS CAB to extend
the public review period for the Operable Unit 4 FS/PP-DEIS. The NTS CAB had the opportunity to meet with
representatives of the Fernald Environmental Management Project on May 11, 1994. The CAB stated that this
meeting was the first time it had an opportunity to receive any information about the Operable Unit 4
FS/PP-DEIS. Because the CAB had not yet reviewed the Operable Unit 4 documents and the May 20, 1994 deadline
for public comments was near, the extension of time was necessary in order that the CAB may provide
substantive input into the process. (Commentor: N)

Response: (a) The United States Department of Energy (DOE) considered the request for extension of the
public review period to be in accordance with the provision of the National Oil and Hazardous Pollution
Contingency Plan, 40 CFR 300.430(f) (3)i) (C) as follows:

"Upon timely request, the lead agency [DOE] will extend the public comment period by a minimum of 30
additional days;.."

The DOE recommended that a 30-day extension, as opposed to the 60-day extension, be granted in an effort to
minimize schedule impacts, as well as providing adequate time for the CAB to review the Operable Unit 4
document. In accordance with Sections XVIII.B.5 and XVIII.D of the Amended Consent Agreement (1991), the DOE
requested concurrence from the EPA for the 30-day schedule extension to the public review period. The EPA
vabally concurred with the DOE 30-day request for schedule extension on April 18, 1994, and followed up with
a written concurrence on April 29, 1994. The DOE issued formal notification of the 30-day extension to the
State of Nevada on May 3, 1994. This documentation can be found in the Administrative Record.

(b) The DOE considered the CAB request for extension of the public review period to be in accordance with
the provision of the National Oil and Hazardous Pollution Contingency Plan, 40 CFR 300.430(f)(3)(i)(C) as
follows:

"Upon timely request, the lead agency [DOE] will extend the public comment period by a minumum of 30
additional days;.. "

On May 20, 1994, the DOE granted an additional 30-day extension to the public review period for the Operable
Unit 4 FS/PP-DEIS. In accordance with Sections XVIII.B.5 and XVIII.D of the Amended Consent Agreement
(1991), the DOE requested concurrence from the EPA for the 3o-day schedule extension to the public review
period. The EPA provided written concurrence on the DOE 30-day extension request on May 26, 1994. This
documentation can be found in the Administrative Record.

Issue 2 - Characterization of Silo Residues During the March 21, 1994 Operable Unit 4 public meeting,
questions were raised by Mr. Lou Bogar, a resident of the City of Hamilton Ohio, about perceived
discrepancies in the isotopic uranium data reported for some of the silo residues. He also expressed
concerns about the inorganic chemical data for the silo residues. His specific concerns were as follows:

(a) Why does the analytical data on the silos presented report Uranium 235/236? Do the silos contain
uranium-236 (U-236)?

(b) There seems to be a discrepancy in the ratio of U-234 to U-238. The ratio of these isotopes should be
close to unity. The U-234/U-238 ratio for Silo 2 appears to be correct however, the ratio for Silo 1 does
not appear to be right.
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(c) Is there a full list of inorganic constituents for Operable Unit 4? Why isn't gold listed as one of
the analytes? Are there other elements, for which analysis was not done, that may impact the vitrification
process? In particular, what about rare earths (the lanthanide series of elements)? Could these affect
vitrification?

(Commentor: C)

In addition, on June 24, 1994, DOE received significant comments from a member of the Nevada Test Site
Citizens Advisory Board (CAB). The CAB expressed the following four concerns over the physical
characteristics of the untreated silo residues and the treated waste form:

Based on the presence of RCRA regulated metals and organics in the waste, we are concerned that the waste
contains both hazardous and radioactive constituents.

(d) Please list the radionuclide and inorganic and organic chemical constituents of the waste.

(e) Please identify the concentration of each constituent.

(f) Please identify the risk resulting from each constituent.

(g) Please describe how the proposed treatment and disposal mechanism address both the radionuclide and
chemical constituents of the waste.

(Commentor: 0)

Response: (a) The Silos do not contain U-236. U-236 is a by-product of nuclear reactor processing. The
residues in the silos were generated exclusively from the chemical processing of pitchblende ores and uranium
concentrates to extract uranium. Conseguently, the residues in silos would not contain U-236.

The U-235 analysis was done using the standard radiochemistry technique of alpha spectroscopy. Because the
energies emitted by U-235 and U-236 are very close in intensity, it is difficult for the laboratory to
individually resolve between U-235 and U-236 activity concentrations. As a result it is accepted laboratory
convention to report radiochemical results for these isotopes as U-235/236. The analytical data for U-235
concentrations in the silos were reported from the laboratory using this convention. This was not intended
to imply that the silos contain U-236.

(b) In his comments made during the March 12, 1994 Operable Unit 4 Public Hearing, Mr. Bogar pointed out
that there appeared to be some anomalies in the isotopic uranium data presented during that meeting. The
data provided during the public meeting represented average activity concentrations calculated from
individual sample results contained in Volume 2 of the Operable Unit 4 Remedial Investigation Report
(available for review in the PEIC). Through process knowledge it is known that the K-65 Silos contain
natural uranium which resulted from the processing of pitchblende ores and uranium concentrates. As such,
the activity concentration ratio of U-238 to U-234 in any sample obtained from the silos should be
approximately 1. In the data presented for Silo 1, however, the ratio of U-238 to U-234 is 0.8, implying
that the uranium contained in Silo 1 may be enriched.

This apparent anomaly is caused by a combination of two factors: the use of average activity concentrations
to represent activity concentration ratios and apparent errors in the U-234 activity concentrations reported
by the laboratory for four of the Silo 1 samples. While average activity concentrations are adequate for
gross estimates of the silo contents, using activity concentration ratios calculated from these average
activity concentrations is inappropriate, due to the heterogeneous nature of the silo contents (it should
also be noted that averaging of the data can propagate the inherent uncertainty in the analytical data for
individual samples). Instead, the activity concentration ratios of U-238 to U-234 should be addressed on a
sample-by-sample basis.

Review of the individual sample data (contained in Volume 2 of the Operable Unit 4 RI Report) will indicate
that the ratios of U-234 and U-238 are close to unity as expected for natural uranium (within the limits of
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the total propagated uncertainty) for 16 of the 20 samples taken. The remaining four samples demonstrated
higher U-234 values, which yielded U-238 to U-234 ratios in the range of 0.4 to 0.6. This knowledge should
have been sufficient to reject the analytical results for these four samples. The sample results, however,
had already been validated using standard EPA protocols and the determination had been made to publish and
use all validated analytical results. While this decision could have been overturned, it was further
determined that these apparently anomalous U-234 analytical results for these four samples had no impact on
the risk assessment for Operable Unit 4 and, as a result, would have no impact on the evaluation of remedial
action alternatives within the Operable Unit 4 Feasibility Study.

(c) Volume 2 of the Operable Unit 4 Remedial Investigation Report presents a full listing of all
analytical data collected during the remedial investigation. The data presented in the public meeting on
March 21, 1994 were taken from the Operable Unit 4 Remedial Investigation Report. These data primarily
provide critical information used in the risk assessment process to determine the nature and magnitude of
potential chemical hazards and/or cancer risk posed by the contents of the silos. Treatability studies were
conducted using actual silo residues to determine the effectiveness of the vitrification process in
stabilizing these materials (the Operable Unit 4 Treatability Study Report for the Vitrification of Residues
from Silos 1, 2, and 3 is available for review in the PEIC). Analysis was performed on the silo residues
during the treatability studies to provide information pertinent to determining the effectiveness of
vitrification.

The DOE does have historical data on the gold content of the K-65 residues. The vitrification process can be
affected if there are large amounts of noble metals such as gold present. However, the gold present in the
silo residues does not pose a problem as evidenced by the results of the vitrification treatability studies.

"Rare earths" or elements in the lanthanide series are known to improve the durability of glass [reference,
Volf, M.B. 1984, Chemical Approach to Glass (glass Science and Technology: Vol 7), Elsevier, New York].
Analysis was conducted for some "rare earth" elements such as cerium and lanthanum during the treatability
studies.

(d, e) The material contained in Silos 1 and 2 (K-65 material), and Silo 3 is by-product material or residue
resulting from the processing of uranium ore and is specifically exempt from regulation as solid waste under
RCRA 40 CFR §261.4(a)(4). The State of Nevada has expressed similar concerns over the regulatory
classification of the Operable Unit 4 remedial wastes. A detailed discussion of these regulatory issues is
presented under Issue 4 - State of Nevada Regulatory Concerns.

A complete list of radionuclide, inorganic and organic chemical constituents of the Silos 1, 2 and 3 wastes
and their respective concentrations can be found in Tables A.1-1, A.1-5, A.1-6, A.1-7, A.2-1 and A.2-6 in
Appendix A of the FS Report for Operable Unit 4 (FS/PP-DEIS).

(f) Appendix D, Section D.2.0 of the FS Report for Operable Unit 4 (FS/PP-DEEIS) presents a summary of
risk characterization results from the Operable Unit 4 Baseline Risk Assessment, as reported in the Remedial
Investigation Report for Operable Unit 4. The Baseline Risk Assessment was performed, in accordance with
available EPA guidance for conducting CERCLA risk assessments and methodology described in the EPA-approved
Risk Assessment Work Plan Addendum for performing risk assessments at the FEMP. The complete list of
radionuclide, inorganic and organic chemical constituents of the Silos 1, 2 and 3 wastes were evaluated along
with information describing their toxicity, mobility and environmental persistence. The baseline risk
characterization indicates that baseline conditions do not meet acceptable public health risk criteria.

Appendix D, Section D.3.0 of the FS Report for Operable Unit 4 (FS/PP-DEIS) evaluates the short-term and
long-term risks associated with implementing the various remedial alternatives considered for Operable Unit
4. The detailed analysis of the Operable Unit 4 remedial action alternatives is presented in Section 4.0 of
the FS Report for Operable Unit 4 (FS/PP-DEIS), where each alternative is evaluated relative to the nine
criteria of the NCP. Two of these criteria are short-term effectiveness and long-term effectiveness.

The short-term effectiveness criterion addresses the effect of an alternative during the construction and
implementation phase until the remedial action objectives are achieved. The evaluation considers the effects
on human health and the environment posed by operations conducted during the remedial action. The long-term
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effectiveness criterion evaluates the extent to which an alternative achieves an overall reduction in risk to
human health and the environment after the remedial action objectives have been met.

The risk assessment presented in Appendix D supports the application of these criteria through the Section
4.0 evaluation of human health risks resulting from potential short-term and long-term exposures associated
with the Operable Unit 4 remedial action alternatives. This includes the preferred remedy for disposing of
the treated Operable Unit 4 residues at the NTS.

(g) Appendix C, Section C.3.0 of the FS Report for Operable Unit 4 (FS/PP-DEIS) presents a summary of all
the vitrification treatability study tests which were carried out in support of the Operable Unit 4 RI/FS
process at the FEMP. The tests were completed as specified by the EPA-approved Operable Unit 4 Treatability
Study Work Plan for the Vitrification of Residues from Silos 1, 2, and 3 (DOE 1992b). The purpose of these
tests was to allow the performance of vitrification of the Silos 1, 2, and 3 residues to be compared to other
remediation technologies for the silo residues. The criteria upon which this comparison was to be based were
the leachability of the waste form, the waste volume reduction achieved, and the reduction in radon emanation
from the waste.

The Toxicity Characteristic Leaching Procedure (TCLP) results for the vitrified wastes demonstrated the
effectiveness of glass as a durable leach resistant waste form for Operable Unit 4 remedies. Leachate
concentrations of hazardous metals were below regulatory limits for all of the glasses made in these tests,
including the leachate concentration of lead which was reduced about 500 times less than from the untreated
waste. Radionuclides (in particular, Ra-226) were found to leach from the glasses at the same rate as the
major glass constituents, indicating the absence of selective leaching of radionuclides.

Appendix C, Table C.3-13 of the FS Report for Operable Unit 4 (FS/PP-DEIS) reports the specific gravity of
the vitrified waste along with the calculated volume reduction. The volume reduction is based upon the
difference between the volume of the final glass product (including additives) and the initial volume of the
waste in its current state. The waste volume was calculated using the wet, compacted density, which is
assumed to be the most representative of the material in its current state. Significant volume reductions
ranging from 50 percent to 68 percent are achieved through vitrification of the waste. In summary, the final
waste volume ranged from 32 percent of the initial waste volume in the best case to only 50 percent of the
initial waste volume in the worst case.

The radon emanation rate from the vitrified K-65 material ranged from 0.01 to 0.06 pCi/m2/s, more than two
orders of magnitude less than the EPA limit of 20 pCi/m2/s for radon emanation from uranium mill tailings.
The measured radon emanation rate from the glass is approximately egual to the emanation rate from natural
building materials such as brick and concrete, even though the radium content of the waste glass is 103 to
106 times greater than that of natural building materials.

The NTS has established waste acceptance criteria which consider disposal site characteristics consistent
with an appropriate level of protectiveness to human health and the environment. The Operable Unit 4
remedial waste will comply with these waste acceptance criteria and the NTS will also perform evaluation to
assure that the acceptance criteria are met.

Issue 3 - Public Participation During Post-RI/FS Activities

The current FEMP Community Relations Plan does not adeguately define the public's role, nor its nature and
extent of opportunities for participation during post-RI/FS activities. During the Operable Unit 4 formal
public comment period, members of the public and the Ohio EPA reguested formal definition of their level of
participation during the Remedial Design and Remedial Action processes. Members of the community expressed a
desire to continue their same level of involvement in post-RI/FS activities, as defined by the current
Community Relations Plan for the RI/FS program. (Commentors: A, B, D, G, J and R)

Response: The DOE is both actively and expeditiously pursuing the revision of the current FEMP Community
Relations Plan to include post-RI/FS public involvement activities throughout the Remedial Design and
Remedial Action processes. Until a comprehensive Community Relations Plan is finalized by the DOE, an
Interim (post-RI/FS) Community Relations Plan has been prepared as guidance to Fernald personnel on public
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involvement activities. A revised Community Relations Plan addressing post-RI/FS public involvement
activities will be issued by September 1994.

Issue 4 - State of Nevada Regulatory Concerns

The State of Nevada and a member for the Nevada Test Site Citizen's Advisory Board have expressed concerns
over the regulatory classification of the Operable Unit 4 remedial wastes, as discussed in the Operable Unit
4 Feasibility Study/Proposed Plan - Draft Environmental Impact Statement. More specifically, the State of
Nevada suggests that the Operable Unit 4 remedial wastes are "mixed wastes" [i.e., Resource Conservation and
Recovery Act (RCRA) hazardous and radioactive waste] rather than "by-product material" as defined by the
Atomic Energy Act (AEA), Section 11 (e) (2), excluded from being a RCRA hazardous waste. The CAB stated that,
"Based on the presence of RCRA regulated metals and organics in the waste, we are concerned that the waste
contains both hazardous and radioactive components." Accordingly, the State of Nevada contends that the
hazardous components of the Operable Unit 4 wastes are subject to regulation and control by an EPA-delegated
state having such authority. (Commentors: E, 0)

Response: The State of Nevada's comment concerns the classification of K-65 and Silo 3 material;
specifically with respect to its regulation as mixed waste. The following response first discusses in
general the issue regarding the classification; secondly, the response addresses specific State of Nevada
concerns described in the letter.

(a) General Discussion

The material contained in Silos 1 and 2 (K-65 material), and Silo 3 is by-product material or residue
resulting from the processing of uranium ore and is specifically exempt as defined from regulation as solid
waste under RCRA 40 CFR §261.4(a)(4). The referenced exclusion applies to"... source, special nuclear or
by-product material as defined in the ... AEA..." The AEA in part defines by-product as: ...the tailings
or waste produced by the extraction or concentration of uranium or thorium from any ore processed primarily
for its source material content. [AEA Section 11 (e) (2)] . Since a material must first be a solid waste in
order to be a hazardous waste, and since the material is excluded from regulation as solid waste, the subject
material cannot be considered hazardous waste.

The silos contain only residues from the chemical extraction (beneficiation) of uranium from ores; no other
solid or hazardous wastes were added to the silos or to the residues. Therefore, the contents of Silos 1, 2,
and 3 are pure "by-product materials" by definition, and not solid wastes or hazardous wastes subject to
regulation under RCRA. The metals found in the material were present in the natural ore, and were
unintentionally extracted from the parent ore along with the uranium during the process of beneficiation,
becoming more concentrated in the residue after the uranium was removed. The presence of naturally occurring
metals is expected in by-product material, and does not invalidate either the definition or the exclusion.
No metals from a non-ore source were added to the stream at any point in the beneficiation process; also, no
hazardous waste or waste constituent was added or created at any time during the beneficiation process. The
fact that several metals in the material fail the RCRA toxicity characteristic leaching procedure (TCLP) does
not cause the material to become subject to RCRA regulation due to a hazardous waste characteristic, since
the metals are not from an external source, but are associated with the parent material (whose residues,
including any ancillary metals, are excluded from the definition of solid waste).

(b) Specific State of Nevada Comments and Responses

1. Comment: The comment refers to "...thorium mill tailing waste, which is admitted to be mixed waste....

Response: The comment is unclear, since there is no reference to any admission that the material is mixed
waste. The FS/PP-DEIS does not claim the material is mixed waste. Rather, the residues in the silos are
by-product material from the processing of ore material for its source material, primarily uranium. The
by-product material is not itself a mixed waste, nor is it mixed with a solid or hazardous waste which would
cause the material to be considered a mixed waste. As stated in the document, while they are not considered
applicable as ARARs for the management of this material, various sections of RCRA have been included in the
Operable Unit 4 FS/PP-DEIS as relevant and appropriate reguirements for the management of this material
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during CERCLA remediation, due to the similarity of this material to RCRA characteristic hazardous waste.
The adoption of various RCRA ARARs in the CERCLA documents does not confer or waive authorities agencies may
have to regulate the silo material under RCRA.

2. Comment: "In 1987, DOE promulgated regulations (10 CFR §962.1) stating that RCRA hazardous waste, mixed
with by-product material falling under the category defined in the AEA 142 USC 2014 (e) (1)], would be subject
to regulation ...." "However, the by-product material falling under the category given in 42 USC 2014 (e) (2)
that was mixed with RCRA hazardous waste, ... would not be subject to regulations by EPA...." " ....under the
Federal Facility Compliance Act (FFC Act), Congress defined mixed waste to mean 'waste that contains both
hazardous waste and source, special nuclear, or by-product material ...' This definition shows no
distinction between the two categories of by-product material mentioned above. Hence, the attempted
exemption from hazardous waste regulations of the hazardous components of mixed waste containing by-product
material ... has been invalidated."

Response: The DOE Final Rule in 10 CFR §962, promulgated in the May 1, 1987 Federal Register (52 FR 15937)
for clarification of the term "by-product material," was limited in scope to by-product material as defined
under 42 USC 2014(e) (1) meaning "radioactive material ... yielded in, or made radioactive by exposure to the
radiation incident to the process of producing or utilizing special nuclear material." An example would be
reactor fuel reprocessed for its enriched uranium. This rule does not affect materials that are defined as
by-product material under Section 11 (e) (2) of the AEA ("tailings or wastes produced by the extraction or
concentration of uranium or thorium from any ore processed primarily for its source material content"). The
silo material falls into this second category.

DOE Order 5400.3A further clarifies the DOE interpretive rule referenced above:

"DOE interprets these definitions to mean that whenever any hazardous waste identified or listed in 40 CFR
§261 is inadvertently mixed [emphasis added] with any source material, special nuclear material, or
by-product material, the hazardous waste component is subject to regulation under Subtitle C of RCRA. The
May 1, 1987 Federal Register notice did not affect materials that are defined as by-product material under
Section 11 (e) (2) of the AEA."

DOE Order 5820.2A contains definitions consistent with the above. Chapter IV, Management of Waste Containing
AEA 11 (e) (2) By-product Material and Naturally Occurring and Accelerator Produced Radioactive Material,
specifies:

"By-product 11 (e) (2) ... mixed [emphasis added] with the Resource Conservation and Recovery Act hazardous
chemicals, shall be managed consistent with both the Resource Conservation and Recovery Act and 40 CFR Part
192."

The FFC Act, DOE Order 5400.3A, and DOE Order 5820.2A are consistent in their interpretation of the
definition of mixed waste. The FFC Act simply reiterates that hazardous waste mixed with source, special
nuclear, or by-product material is subject to dual regulation under both the AEA and RCRA, and has no bearing
on Operable Unit 4 by-product material, since it is not mixed with a solid or hazardous waste (see General
Discussion). The K-65 and Silo 3 material consists of only by-product material as defined under Section 1
1(e)(2) of the AEA, and is therefore subject to the solid waste exclusion under RCRA.

3. Comment: "...EPA delegated to the states regulatory control over all maxed wastes without regard to
specific radionuclide content ... consistent with the expression of Congressional intent in defining mixed
waste under the FFC Act (see 51 FR, July 3, 1986, 24504-24505)..

Response: In the referenced July 3, 1986 Federal Register notice, EPA is requiring that states seeking
authorization to regulate under RCRA the "hazardous component" of radioactive mixed waste revise their
programs (if necessary) and demonstrate statutory authority to regulate said "hazardous component." This
notice was issued prior to the DOE interpretive rule of May 1, 1987. Although "hazardous component" is not
expressly defined, the notice is consistent with previous definitions, and implicitly restates the definition
of mixed waste as "wastes containing both hazardous waste and radioactive waste.. Again, this Federal
Register notice does not detract from the stated position, since the Operable Unit 4 silo material consists
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solely of by-product material, and is not mixed with a solid or hazardous waste that would be subject to
state regulation.

In summary, the Operable Unit 4 silo materials are expressly by-product material excluded from RCRA
regulation under 40 CFR §261.4(a)(4), on the basis of "tailings or waste produced by the extraction or
concentration of uranium or thorium from any ore processed primarily for its source material content" [AEA
Section 11 (e) (2)] .

NOTE: While not applicable as an ARAR for the management of this material, various sections of RCRA have
been included in the FS/PP-DEIS as relevant and appropriate reguirements for the management of this material
during CERCLA remediation, due to the similarity of this material to RCRA characteristic hazardous waste.
The proposed alternative for remediation of this material includes treatment by vitrification, which will
remove the "toxicity characteristic" due to the inadvertent presence of various metals in the material. The
adoption of various RCRA ARARs in the CERCLA documents does not accede the authority of RCRA to regulate the
silo material; these ARARs, among others, are selected on the basis of existing regulatory standards and
management practices to be followed during remediation to ensure adeguate protection of human health and the
environment.

Issue 5 - Off-Site Transportation of Waste to Nevada Test Site

Several members of the local community expressed concerns related to the transportation of the Operable Unit
4 treated wastes from the FEMP to the Nevada Test Site (NTS). One individual preferred rail shipments over
truck transportation, citing that truclc transportation is much more dangerous. Others reguested more
details on transportation (i.e., packaging specifications, and special handling reguirements and precautions)
and details related to notification when shipments will occur. (Commentors: A, F and Q)

Response: The preferred remedy for Operable Unit 4 reguires a combination of rail and truck transportation
for the shipment of treated silo residues off site for burial at the NTS. Currently, there are no direct
rail lines into the NTS. The treated material would be transported from the FEMP by rail to either a point
near Las Vegas, Nevada, or one of the areas north of Las Vegas. From either location, the waste contains
carrying the treated material would be transferred to trucks for transportation ova roads to NTS. Consistent
with regulatory reguirements, the DOE will provide proper notification to all affected parties, including
emergency response teams, when off-site shipments begin.

Additionally, the DOE is engaged in a program to optimize a container design to meet specific performance
reguirements for a shipping/burial container and to provide additional protection to workers and the public,
for the eventual transport and disposal of the treated Operable Unit 4 wastes to be conducted between the
FEMP and the NTS. One of the program's goals are focussed upon the viability of utilizing recycled
contaminated scrap metal and other forms of metal for the fabrication of waste containers.

The success of the container investigation will be measured on the basis of achieving a balance of key design
parameters and reguirements such as:

! vitrified product mixture design
! final waste form of vitrified product
! waste loading of vitrified product
! waste additives of vitrified product
! packaging design
! shielding of package
! shipping limitations
! United States Department of Transportation (DOT) reguirements
! NTS Waste Acceptance Criteria
! cost

The optimized container design will be modelled in an effort to minimize the estimated short-term risks posed
to public by transporting the Operable Unit 4 wastes in the container.
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Issue 6 - Monitoring of Remedial Actions Several members of the local community and the Ohio EPA expressed
concerns that "real-time" monitoring should be implemented during the entire remedial action process. It was
recommended that the implementation of "real-time" monitoring should be integrated into short-term remedial
actions such as process controls, project specific health and safety procedures, emergency alarm systems,
standard operating procedures, and emergency response procedures, as well as, long-term actions involving
disposal and maintenance. Additionally, it was reguested that information gained from "real-time" monitoring
and related activities should be made readily available to the public. (Commentors: A, B, D, G, H, J and R)

Response: As part of the remedial design activities for the Operable Unit 4 remedial actions, a preliminary
and final safety assessment will be conducted by DOE to establish the safety basis and design objectives for
the construction and the operation of all remedial facilities. The safety basis includes those measures
(i.e., procedures, training, monitoring eguipment) necessary to ensure that facilities will be constructed
and operated in a safe manner and in compliance with applicable or relevant and appropriate reguirements.

It is the DOE policy in its conduct of operations to reguire facility operations procedures to be developed
and adhered to during all remedial actions. Training of personnel to those procedures will be paramount to
ensure safe conduct of all operations. The FEMP has developed and maintains the necessary emergency plans
and procedures to adeguately define the emergency management program, provide guidance for all emergency
responders, proper notification of the public, ensure adeguate monitoring and performance for critical
systems, and to meet all regulatory reguirements.

The use of "real-time" monitoring is an integral part of this process and will vary in degree for each system
or action to be consistent with the safety assessment recommendations and comply with applicable or relevant
and appropriate reguirements. For example, some systems may reguire 24-hour "real-time" monitoring (i.e.,
fire protection, meteorological stations, perimeter air monitoring stations, radon treatment system) while
others may only reguire "real-time" monitoring during normal operations (i.e., air emissions controls, waste
water discharge, vitrification process controls, disposal facilities etc.). These features will all be
developed and included in the remedial design and remedial action packages for review by the public, EPA, and
Ohio Environmental Protection Agency (OEPA) . Likewise, "real-time" monitoring data will be made available to
the public through the Public Environmental Information Center.

Issue 7 - Impacts to Sites of Archeological and Historical Importance

The Ohio Historical Preservation Office (OHPO) expressed two areas of concern for the identified Operable
Unit 4 remedial actions. Due to the FEMP site's proximity in an archeological sensitive area, the first area
of concern is the potential for impacts to archeological sites. Secondly, under the current criteria and
regulatory guidelines, the FEMP site itself is eligible for inclusion in the National Register of Historic
Places, thus the proposed demolition of the silos, or any other structure or facility, could have an adverse
effect on the FEMP site. The OHPO recommends the development of a programmatic agreement to address these
sitewide and Operable Unit 4-specific historic preservation concerns. (Commentor: I)

Response: It is recognized that the FEMP site does lie in an archaeologically rich area and sitewide
remedial activities will result in many ground disturbing and demolition activities. The DOE has effectively
coordinated with the OHPO on several projects at the Fernald site in the past. Therefore, until the
programmatic agreement has been developed between DOE and the OHPO, individual activities (e.g., the
construction of support facilities) will continue to be coordinated with the OHPO.

In response to the second area of concern, it is further recognized that the FEMP site as a whole has
recently been determined to be eligible for inclusion on the National Register of Historic Places.
Therefore, appropriate steps will be taken to coordinate with the OHPO all activities involving the
demolition of structures. The DOE will be pursuing a programmatic agreement with the OHPO in the near
future. However, until such an agreement can be put in place, DOE will be coordinating with the OHPO office
on an individual project-by-project basis.

Appropriate coordination activities associated with the remediation of Operable Unit 4 and the demolition of
structures on the site will be carried out with the OHPO.
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Issue 8 - Future Land Use at the FEMP

One member of the public expressed concern over any future development of the FEMP site (i.e., industrial
park) which would attract large concentrations of humans, in the event environmental problems would happen to
develop in the future (i.e., similar to Love Canal). (Commentor: F)

Response: The DOE, EPA, and OEPA are closely working with the local community (i.e., FRESH) to provide
technical guidance to participating community members, in an effort to logically reach a balanced decision
regarding the most feasible future land use(s) for the FEMP site. The Operable Unit 4 soil remediation
cleanup levels were established with the assumption that in the future, the federal government would maintain
ownership of the Operable Unit 4 area.

Issue 9 - Impact to Natural Resources

Members of the public expressed concern over the potential impact from the remedial actions to natural
resources surrounding the FEMP site (i.e., wetlands, migratory birds, etc.), and the mitigative measures
being taken by the DOE to minimize their effect. (Commentors: B and F)

Response: The end-use of the FEMP site is currently under consideration by the Fernald Citizens Task Force.
This task force, based on input from the public and various stakeholders, will make a recommendation to DOE
as to what the end-use of the Fernald site should be. This comment will be forwarded to the task force for
their consideration. The task force's recommendation will play a key role in determining what happens at the
site after remediation.

Depending on the types of environmental impacts that occur during remediation, it is possible that habitats
may need to be created as mitigative measures. The specific issue of the need for creating wetlands is
currently being evaluated by DOE and Fernald Environmental Restoration Management Company (FERMCO) and will
be discussed with the stakeholders and formally addressed in the Operable Unit 5 (Environmental Media)
Feasibility Study Report and Record of Decision.

Issue 10 - EPA Promulgation of Residual Soil Standards for Radionuclides

One local resident inguired whether the residual soil radiation levels, which the EPA has not yet published
in the Federal Register (originally scheduled to be published in March 1994), could possibly impact the
remediation decisions in Operable Unit 4. (Commentor: C)

Response: Residual soil standards for radionuclides are currently being finalized by the EPA. The EPA has
issued a draft proposal which recommends the establishment of an effective dose limit of 15 mrem/year from
residual soil radiation. Until the standards are finalized and promulgated by the EPA, it is uncertain
whether they will impact Operable Unit 4. Radionuclide cleanup levels have been established for Operable
Unit 4 which approach background concentrations for nearly all radionuclides. When the residual soil
standards for radionuclides are promulgated by the EPA, a review of their impact upon the Operable Unit 4
soil remediation will be conducted. Soil cleanup levels for Operable Unit 4 will be modified as directed by
the EPA.

Issue 11 - Air Emissions from Remedial Actions

One local resident, who lives downwind of the FEMP site, expressed concerns over the particulate matter and
off-gases which could be emitted through the exhausts of the Operable Unit 4 vitrification process. Specific
concerns were noted related to the performance of comprehensive site-wide air modeling which includes the
Operable Unit 4 vitrification facility contributions to sitewide emissions and the guantification of
subseguent risks to the local "downwind" community. (Commentor: K)

Response: Air pathway monitoring focuses on the airborne pollutants that may be carried from the Fernald
site as a particulate or gas and how these pollutants are distributed in the environment. Stack and building
vent emissions are obvious sources of pollutants, but dust from construction and remediation activities,
waste handling, and wind erosion are also important potential sources. The form and chemical makeup of
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pollutants influence how they are dispersed in the environment as well as how they may deliver radiation
doses. Airborne pollutants are subject to whatever weather conditions exist.

The meteorological data gathered at the FEMP site are primarily used to evaluate climatic conditions at the
site. Wind speed and direction, rainfall, and temperature play a role in predicting how pollutants are
distributed in the environment. The Fernald Environmental Monitoring Program routinely uses atmospheric
models to determine how airborne effluents mix and disperse; these models, in turn, are used to assess the
impact of operations on the surrounding environment, in accordance with DOE reguirements. Based upon
modeling results, risks to the public are calculated based upon exposure from the pollutants emitted from the
FEMP site. The 1992 Fernald Site Environmental Report provides detailed breakdown of sitewide emissions,
doses to the public, and their associated risks. This report is updated annually and may be available in the
Administrative Record.

To date, computer modeling for expected radionuclide emissions from the proposed vitrification facility has
not been conducted due to insufficient engineering design data. However, during remedial design, when these
design data become available, this information will be entered into the appropriate air models to determine
compliance with 40 CFR §61 Subpart H for radionuclides, including radium under the Clean Air Act. In
addition, Ohio Administrative Code (OAC) 3745-31 05 (A) (3) reguires the use of Best Available Technology (BAT)
to control process emissions. Compliance with the reguirement to employ BAT will be determined by
evaluating, according to the Ohio Air Toxics Policy (OATP), emission data collected from performance testing
of the Operable Unit 4 vitrification facility.

Modeling will be conducted on the vitrification facility both prior to startup and during operation. The
preliminary modeling will provide estimates of dose levels based on engineering design and expected removal
efficiencies. Corroborative modeling conducted during operation will be based on actual data collected
during stack performance testing, and will verify engineering design and compliance with the regulatory
standard. Risks associated with these dose levels will be evaluated and compared to the other alternatives.
Upon comparison a determination will be made to implement design criteria to minimize risk associated with
the vitrification facility or if necessary to amend the selected alternative to one which poses less of a
risk to the surrounding community.

Air emission modelling specific to the Operable Unit 4 vitrification processing facility will be performed as
part of the remedial design process, to ensure that the vitrification facility is designed to meet these air
emission ARARs and pertinent DOE Orders. In addition, portable air monitors will be strategically located
around the perimeter of field activities during construction of remedial facilities. The air monitors will
provide real time data regarding the effectiveness of controls to mitigate fugitive dust emissions.

Issue 12 - Determination of Risk Levels

A local resident guestioned the reason the CERCLA elected to use such small risk levels as 10-6 (one in a
million). In addition, the differences in methodologies like Health Effects Assessment Summary Tables
(HEAST) and Biological Effect of Ionizing Radiation result in "vast orders of magnitude" differences in
estimated risks. (Commentor: C)

Response: In accordance with the NCP (40 CFR 300), Operable Unit 4 is reguired to comply with the
reguirement that the excess risk, posed to humans exposed to carcinogenic materials in Operable Unit 4, would
not be greater than one in ten thousand to one in a million. The lower bound of the range, one in a million
(10-6) incremental risk, is the most desired level of residual risk to be posed by a clean-up action. This
risk refers not to "fatal" cancer risk but the risk of the induction of incremental cancers, over and above
the normal risk of contracting cancer, during one's lifetime. Operable Unit 4 is also legally reguired to
utilize the methodologies defined by the United States Environmental Protection Agency for calculating the
cancer risk posed by Operable Unit 4.

Issue 13 - Compliance with DOT Transportation Regulations

The U.S. Department of Transportation (DOT) provided two comments regarding compliance with DOT regulations.
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(a) The first comment was related to classification of the materials as Low Specific Activity (LSA) and
stated, "We [DOT] believe the expected physical form of the material transported will result in the
radiological risk to the public being egual to or less than most LSA shipments transported in the Country.
However, from Volume Two, Appendix A, Table A. 1-1, it appears that the activity per gram of material for some
of the package contents might exceed the limits for LSA materials in 49 CFR 173.403(n)."

(b) The second comment expressed concern with the sampling and analysis to be performed prior to shipment.
The comment stated "After material vitrification, the external radiation dose rates will clearly be the
indications of the most significant radiological hazards of the materials during transportation. However,
since the identity of the radionuclides and the activity of the content in each package is reguired by the
regulations, documentation with technical reasoning will be needed to relate the results of pre-vitrification
radioassays to the contents of the packages." (Commentor M)

Response:

(a) The initial classification and container selection of the vitrified materials as LSA was used to
perform cost estimates for the remedial alternatives evaluated in the FS for Operable Unit 4. These cost
estimates were developed with an intended accuracy of plus 50 percent/minus 30 percent as reguired by CERCLA.
Therefore these cost estimates were considered adeguate for alternative evaluation. Since the initial
distribution of the FS/PP-DEIS, the FEMP has initiated a study which will further specify the DOT
classification of the vitrified material and container types reguired for shipment of the vitrified material.
The final selection of container type is contingent upon several factors, including; the Curie content of the
container, its classification under DOT regulations, the ability of the container to reduce external dose
rate, and the acceptance of the container by the Nevada Test Site.

(b) Demonstration of compliance with regulations is the basis for the sampling and analysis program to be
developed for Operable Unit 4 remediation. Sampling and analysis will be performed on the vitrified gems 1)
to assure compliance with waste disposal reguirements, 2) to demonstrate success of waste treatment, 3) to
assure compliance with DOT reguirements, 4) and to complete waste characterization of the vitrified
materials. Specific parameters for testing will be determined in the Project Specific Sampling and Analysis
Plans to be prepared during Remedial Action. The selection of parameters for analysis will include those
which will demonstrate compliance with the activity limitations for containers per DOT regulations.

Issue 14 - Consideration of Disposal Sites for the K-65 Material On June 24, 1994, DOE received significant
comments from a member of the Nevada Test Site Citizens Advisory Board (CAB). The CAB stated that the
Operable Unit 4 FS/PP-DEIS documents did not discuss the full range of possible alternatives (e.g., disposal
at Hanford, reprocess to recover materials, dispose of all mataial at the NTS). The member of the CAB
further guestioned "...Why were these options rejected? What is the full list of options initially
considered and why was each option rejected?" (Commentor: 0)

Response: Identification, screening, and evaluation of potentially applicable technologies and process
options are key steps early in the FS process. The primary objective of this phase of the FS is to develop
an appropriate range of remedial technologies and process options that will be developed into preliminary
remedial alternatives. The criteria for identifying potentially applicable technologies are provided in EPA
guidance and in the NCP. There is strong statutory preference for remedies that will result in a permanent
solution; a significant decrease in toxicity, mobility, or volume; and provide long-term protection as
identified in Section 121 of CERCLA, as amended. The primary reguirements for the final remedy are that it
be both protective of human health and the environment and comply with applicable or relevant and appropriate
regulatory reguirements.

The Operable Unit 4 FS/PP-DEIS presented information to support the selection of the most appropriate
remedial alternative. The broad range of alternatives considered for remediation in the FS/PP-DEIS were
developed in accordance with EPA guidance by following a series of logical steps that involved developing, in
succession, more specific definitions of potential remedial alternatives. The steps included the following:

! Development of contaminant- and media-specific remedial action objectives (RAOs) and preliminary
remediation goals (PRGs).
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! Identification of general response actions (GRAs).

! Identification of volumes and/or areas of waste media to be addressed.

! Identification and screening of remedial technologies and process options.

! Evaluation and screening of process options within each technology.

! Assemblage of a wide range of remedial alternatives using the selected process options within each
remedial technology.

! Evaluation of initial screening to determine which alternatives will be analyzed more fully in the
detailed analysis phase of the FS.

The detailed analysis of alternatives was performed in Section 4 of the FS on those alternatives which were
retained through the preliminary screening of alternatives step described above. The detailed and
comparative analysis consisted of the analysis and presentation of the relevant information needed to allow
decision makers to select a remedial alternative.

The Operable Unit 4 FS/PP-DEIS considered several disposal options for each of the on-property and off-site
disposal technologies evaluated for the K-65 material as follows:

On-Property Disposal Technology
! Engineered Disposal Facility (Below-grade)
! Above grade Disposal Vault

Off-Site Disposal Technology
! New Facility within 483 km (300 mi) of the FEMP site
! New Facility Adjacent to the Site
! Permitted Commercial Disposal Site
! Nevada Test Site

In addition, in-situ and no-action alternatives were considered and evaluated as potential disposal
alternatives. Sections 2.6.7.2 and 2.6.7.3 of the Operable Unit 4 FS discuss these representative options
and the results of their preliminary screenings. Subseguently, repromulgation of 40 CFR Part 191 led to
changes in the list of relevant and appropriate reguirements affecting on-property disposal as discussed in
Attachment C.II.

It is the DOE Defense Waste Management Policy at the Nevada Test Site, "...to approve generators and to
receive, store and dispose of radioactive wastes generated by DOE defense programs in a manner consistent
with DOE Order 5820.2A, "Radioactive Waste Management," and applicable federal, state, and local regulations
and reguirements."1 Chapter III of DOE Order 5820.2A provides that low-level waste should go to a DOE
low-level waste disposal site, such as the NTS. This policy ensures that low-level wastes will be handled
properly in accordance with applicable standards and DOE guidelines. Exemptions from the DOE Order to allow
shipments to commercial disposal facilities can be granted by the U.S. Department of Energy Assistant
Secretary for Environmental Management on an ad hoc basis. Fernald has made shipments of waste in the past
to the Nevada Test Site and to the commercial facility operated by Envirocare, Inc. in Clive, Utah.

1U.S. Department - Nevada Field Office, June 1992, Nevada Test Site Defense Waste Acceptance Criteria,
Certification, and Transfer Reguirements, Publication NVO-325, Rev. 1, Page 1.

In this case, however, the Operable Unit 4 vitrified silo wastes from Fernald do not meet the waste
acceptance criteria for existing commercial facilities. The U.S. Department of Energy Office of
Environmental Restoration asked for and is in the process of receiving a determination by the U.S. Department
of Energy Office of Waste Management that the silo wastes constituted a small guantity of by-product material
under Chapter III of DOE Order 5820.2A and therefore, may be disposed at a DOE low-level waste disposal site,
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such as the Nevada Test Site. Also, it has been a long-standing DOE policy that "defense related wastes"
would be disposed at the Nevada Test Site and non-defense related waste disposed at Hanford.

That option, which is the preferred alternative, has been evaluated in this environmental impact statement as
a potential alternative for waste disposal, along with a potential option for commercial disposal. Disposal
at another DOE site, such as Hanford, was considered by DOE to be less feasible than shipment to the NTS,
given past experience with shipping legacy wastes from Fernald to the NTS, which has been ongoing since 1985.
In addition, an appropriate disposal facility is not currently available at Hanford to receive the Operable
Unit 4 waste.

The reprocessing of silo wastes to recover radiological or inorganic constituents was determined not to be
feasible due to poor treatability test results involving chemical separation technigues.

It should be noted that all of the Operable Unit 4 remedial wastes (i.e., Silos 1, 2 and 3 residues,
contaminated soil and debris) were considered for disposal at the NTS. However, it was determined that only
treated silo residues should be disposed at the NTS under the Operable Unit 4 FS/PP-DEIS (although disposal
of contaminated soil and debris is to be determined in subseguent RODs).

The selection of the NTS for disposal of Operable Unit 4 waste is supported by a process option evaluation
presented in Appendix B (Description of Technologies and Process Options) of the FS/PP-DEIS. This evaluation
concluded that based on considerations such as geology, demographics, levels of precipitation, and depth to
groundwater the NTS provided the best location for disposal. Also, the results of treatability studies
conducted on the vitrified waste form indicate that the vitrified waste fully satisfies current NTS waste
acceptance criteria and in general would provide a high level of long term protectiveness when disposed at
the NTS.

Issue 15 - FEMP Waste Disposal Program

On June 21, 1994, DOE received a package of 174 postcards from Citizen Alert. Three additional postcards
were received on July 5, 1994. The majority of the postcards were from concerned citizens of Nevada
expressing their comments related to the shipment and disposal of Fernald waste at the NTS. One of their
comments stated that, "...the more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in containers adeguate to protect the
local populace. Nevadans should not be reguired to accept additional risk on top of that already present at
the Nevada Test Site." (Commentors: P1-P177)

Response: As part of the FEMP Waste Disposal Program, disposal of waste at the NTS is only one of several
disposal locations being considered for waste resulting from the remediation of the Fernald site. Other
disposal locations include both on-site disposal and commercial facilities.

The overall remediation of Fernald is expected to generate over 2.6 million cubic yards of waste reguiring
treatment and/or disposal. Of the estimated 2.6 million cubic yards, 1.4 million cubic yards are to be
managed at the Fernald site, 900,000 cubic yards are to be shipped to commercial facilities, and 300,000
cubic yards may be shipped to the NTS (including approximately 5580 cubic yards of the Operable Unit 4
remedial wastes). Therefore, only about 10 percent of the waste from the remediation of Fernald might be
shipped to the NTS. Additionally, these shipments would occur over a projected 30 year period.

Currently, Fernald is shipping low-level waste to the NTS at a rate of about 18,000 cubic yards of waste per
year (based on the most recent 6 year average). The projected rate for disposal of the Fernald remedial
waste at the NTS is estimated at a rate of approximately 10,000 cubic yards per year, with the highest
estimate for a single year being approximately 16,000 cubic yards for 1995.

Furthermore, the 300,000 cubic yard estimate is a highest case estimate which, in reality, may not happen.
Fernald is marring an effort to minimize waste generation and to explore other disposal options, thereby
minimizing waste reguiring shipment to the NTS, as well as other locations. Disposal of waste at the NTS is
utilized only when these options have been evaluated and determined unfeasible. These minimization efforts
include recycling, decontamination for free-release of material, volume reduction through treatment, disposal
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of the waste on-site, and use of commercial disposal facilities.

Despite these efforts, the Operable Unit 4 FS/PP-DEIS has concluded after a detailed evaluation that
approximately 5580 cubic yards of silo residues are more appropriately disposed at the NTS. This is driven by
several factors, including the location of the Fernald site over a sole-source aquifer (State of Ohio
regulations prevent the establishment of a disposal facility over a sole source aguifer); the close proximity
of the site to large populations and agricultural land; and the lack of commercial disposal facilities which
may accept these wastes. As discussed in the Operable Unit 4 FS/PP-DEIS, these wastes include the treated
residues from Silos 1, 2, and 3.

The State of Ohio recognizes that the final disposition of some Fernald wastes may be on site. In a letter
written to the U.S. EPA, the State of Ohio said: "Large volumes of contaminated construction and demolition
debris, soil, fly ash and bottom ash, and possibly some solid waste will have to be disposed onsite at
Fernald."

The disposal of some wastes at the NTS is one part of a balanced waste management effort for the Fernald
remedial activities. Although Fernald is committed to the minimization of wastes and finding alternative
disposal options for its wastes, Fernald proposes to rely on the NTS for disposal of certain wastes.

Issue 16 - Evaluation of Transportation Risks

Response: The FS/PP-DEIS for Operable Unit 4, Section 4, contains a complete detailed analysis of all the
remedial alternatives evaluated for off-site transportation of wastes, which included both long-term and
short-term risks. The preferred remedy for Operable Unit 4 involves the transportation of the treated silo
residues to the NTS by a combination of rail and truck. The material would be shipped exclusively by use of
rail from the FEMP to Las Vegas, Nevada [a distance of 3562 km (2270 mi)], then by truck from Las Vegas to
the NTS [179 km (111 mi)].

The FS/PP-DEIS for Operable Unit 4, Appendix D, contains a detailed discussion of the long-term and
short-term risks associated with each remedial alternative which underwent detailed analysis. The RADTRAN IV
computer code was used to evaluate potential short-term risks, including risks to the public during the
transportation of the vitrified Silos 1, 2 and 3 material to the Nevada Test Site Through Sandia National
Laboratory's TRANSNET system, RADTRAN IV simulates the transportation route, the length of time members of
the public are exposed to radiation, and the dose equivalent delivered for the trip. This exposure is to
members of the public sharing the road with the truck, people living along the rail and truck route, and
people encountering the truck at truck stops The alternatives call for packaging the treated material in
metal boxes meeting U.S. Department of Transportation packaging requirements of 49 CFR Part 173 The
radiological impacts associated with the transportation of the waste to the NTS for disposal are summarized
in Table C 4-2
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TABLE C.4-2

IMPACTS TO THE PUBLIC DURING TRANSPORTATION OF VITRIFIED SILOS 1, 2 AND 3 WASTE TO THE NTS

Transportation to the Nevada Test Site
ESTIMATED IMPACT

Routine Transport

RME Individual dose (mrem)

Risk-ILCRb

Transportation Accidents

Public dose from radioactive
material releases following truck
accident, (person - rem)

Public dose from radioactive
material releases following train
accident, (person - rem)

Truck Associated Injuriesa

Truck Associated Fatalitiesa

Train Associated Injuriesa

Train Associated Fatalitiesa
Vitrified Silos 1 and 2
Material
0.0085

8.32x10-10

1.9x10-5

0.026

0.013

0.0014

0.15

0.038
Vitrified Silo 3
Material
0.00014

1.71x10-11

3.8x10-6

0.0053

0.0068

0.00074

0.077

0.020
a Nonradiologial impacts.
b ILCR - Incremental Lifetime Cancer Risk Above Background.
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The estimated dose exposure and subsequent risks were calculated and reported as an incremental lifetime
cancer risk (ILCR) to the public from the transportation of the vitrified Silos 1, 2 and 3 material to the
Nevada Test Site. Consistent with the goals of CERCIA, it is desirable to have the risks resulting from
remediation to fall within all ILCR range of 1 x 10-6 to 1 x 10-4 above background. For example, if a member
of the public has an additional 1 chance in 1,000,000 of contracting cancer due to exposure to radiation
during transportation, the probability of developing cancer is expressed as a 1 x 10-6 (1 in 1,000,000) risk.
As presented in Table C.4-2, all short-term risks from exposure to radiation meet these criteria.

In addition to risks from the radiological exposure from the transportation of Silos 1, 2 and 3 material to
the NTS, accidental injuries and fatalities are predicted to occur because trucks and/or trains would be used
for material transportation to the Nevada Test Site. The following risk coefficients below were used to
evaluate non-radiological risks to truck drivers and rail crews:

Driver/Crew Truck Rail
injury/mile 4.1 x 10-8 4.6 x 10-6
death/mile 2.1 x 10-9 4.6 x 10-8

Likewise, the following risk coefficients presented below were used to evaluate non-radiological risks to the
public:

Public Truck Rail
injury/mile 1.2 x 10-7 6.8 x 10-6
death/mile 1.3 x 10-8 1.8 x 10-6

It should be noted that the risk coefficients for truck and rail transport are not strictly comparable, since
far more waste is transported per mile of rail transport than per mile of truck transport. These risks
parameters were used consistent with standard risk calculation methodologies as identified in the Final Risk
Assessment Work Plan Addendum, (June 1992),2 which referenced the aforementioned published statistics by the
U.S. Department of Transportation Federal Highway Administrations and U.S. Department of Transportation
Federal Railroad Administration.4

As before, RADTRAN IV computer code was utilized to calculate the short-term impacts of injuries and
fatalities. These impacts are also presented in Table C.4-2 for the transportation of Silos 1, 2 and 3 to
the Nevada Test Site.

RADTRAN IV also assesses the impacts from accidental releases of the radioactive material in the transport
containers. The code assesses the total impacts for eight accident severity categories. It assesses
collective radiological impacts to the public from direct radiation exposure from contamination on the
ground, inhalation of contaminants in a plume and resuspended from the ground, direct radiation exposure from
contaminants in a plume, and ingestion of food grown in the contamination area. The impacts from a single
truck and train accident are included in Table C.4-2.

Issue 17 - Socioeconomic to the Waste Receptor Community

On June 21, 1994, DOE received a package of 174 postcards from Citizen Alert. Three additional postcards
were received on July 5, 1994. The majority of the postcards were from concerned citizens of Nevada
expressing their comments related to the shipment and disposal of Fernald waste at the NTS. One of their
comments stated that, "Socioeconomic impacts on the receptor community should be thoroughly evaluated and
balanced against the desires of Ohio to move Fernald waste." (Commentors: P1-P177)

Response: The importance of evaluating the Socioeconomic impacts of the Operable Unit 4 Remedial Action
Alternatives on affected off-site locations is recognized by DOE. It is DOE's view that this issue has been
adequately evaluated in the Operable Unit 4 FS/PP-DEIS.

Section 4.0 of the Operable Unit 4 FS/PP-DEIS provides a thorough discussion of the alternatives. For the
alternatives that consider disposal at the NTS, impacts on socioeconomics wae evaluated.
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2U.S. Department of Energy, June 1992, "Risk Assessment Work Plan Addendum," U.S. Department of Energy -
Fernald Field Office, Fernald, Ohio.

3U.S. Dept. of Transportation Federal Highway Administration, Office of Motor Carriers, 1986, Accidents of
Motor Carrier of Property, Publication No. FHWA-MC-88-008, DOT, Washington, DC.

4U.S. Dept. of Transportation Federal Railroad Administration, Office of Safety, 1988, Accident/Incident
Bulletin, Publication No. 157, DOT, Washington, DC.

Population demographics, land use of areas adjacent to the site, and potential risks to the surrounding
population are discussed. In addition, impacts on groundwater, soil and geology, biotic resources, etc., are
also presented.

Additional discussion of the NTS is also provided in Appendix B of the Operable Unit 4 FS/PP-DEIS,
Description of Process Options and Technologies. This discussion provides additional detail on the natural
and socioeconomic characteristics of the NTS and the surrounding area. This information formed the basis for
the impacts presented in Section 4.0 of the Operable Unit 4 FS/PP-DEIS.

Additionally, on August 10, 1994, DOE published a Notice of Intent to prepare a site-wide EIS for NTS (59 FR
40897). This notice invites the public to participate in the scoping process for the NTS EIS.

Issue 18 - Disposal of DOE Waste at the Nevada Test Site

On June 24, 1994, DOE received comments from a member of the Citizens Advisory Board for Nevada Test Site
Programs which expressed concerns over the current decision process for considering DOE waste for disposal at
the NTS. More specifically, the comment stated as follows:

The shipments of waste from Fernald are the first of potentially many other shipments to the NTS. Rather
than marring decisions on a piecemeal basis, we want to see the full picture before we are asked to mane
decisions on individual pieces. That is, we want to first consider the total impact of all of the waste that
is being considered for disposal at the NTS. Following that, we want to consider each individual piece."
(Commentor: 0)

Response: A Notice of Intent to prepare a site-wide EIS for the NTS was published on August 8, 1994. The
purpose of this Notice is to invite the participation of federal, state and local agencies, affected Indian
tribes, and other interested persons in the process DOE will follow to solicit public comments on the
proposed scope and content of the NTS EIS. The site-wide EIS will address the impacts of all waste disposal
activities at the NTS. Shipments of waste generated from the cleanup of Operable Unit 4 are not proposed to
begin until after the expected completion of the NTS site-wide EIS.

Issue 19 - Funding for Technical Oversight and Impact Mitigation

On June 24, 1994, DOE received comments from the Citizens Advisory Board for Nevada Test Site Programs which
expressed their belief that:

(a) funds should be provided for technical oversight of waste management activities.

(b) the State of Nevada and affected Counties are entitled to impact mitigation payments as compensation
for costs arising from management of this material. (Commentor: 0)

Response: (a) The first issue regards funding for technical oversight. DOE currently has a program
established for providing such funds. This program is detailed in an "Agreement in Principle, with the State
of Nevada, one of several such agreements between DOE and the states in which DOE facilities are located.
This agreement includes the provision of funding for technical oversight by the State of Nevada for waste
management activities at the NTS.

(b) The second issue is related to providing impact mitigation payments for management of waste in Nevada to
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the State of Nevada and affected counties. Mitigation payments are associated with actions whose
implementation will have significant impact on human health and the environment. Since no significant
impacts are expected to result from the transportation and disposal of the vitrified Operable Unit 4 waste at
the Nevada Test Site, no mitigation payments for management of the waste in Nevada are anticipated at this
time.

C.5.0 SUMMARY OF COMMENTS NOT RESULTING IN ISSUES

Commentors A, B, D, G, H, and J inguired as to the possibility of covering the silos and ensuring pollution
prevention measures are implemented during remediation. Through the remedial design process, appropriate
measures will be evaluated, utilized, and monitored to maintain air emissions resulting from all remedial
actions at or below the regulatory reguirements.

Commentors A and H wanted assurance that waste from other sites would not be brought to Fernald's
vitrification facility to be treated nor stored at the FEMP for future disposition. At this time, no plans
have been made to treat waste from other DOE sites through the Operable Unit 4 Vitrification Facility or
store materials at the FEMP. However, as part of a treatability study under the Uranium Soils Integrated
Demonstration program, DOE is considering a program that would involve importation of uranium-contaminated
soil samples from Portsmouth, Ohio to be tested at Fernald and returned to the point of origin. This study
would be conducted as an extension of the current Minimum Additive Waste Stabilization (MAWS) program, which
is part of Operable Unit 4 remediation program. These tests are an essential component of FEMP's ability to
conduct necessary research in support of DOE technology development.

The purpose of doing this test work is to make use of the investment which DOE has already made in eguipment
and experience at Fernald; to produce valuable remediation information for a nearby Ohio site; and to avoid
duplication of the resources already available at Fernald.

The pilot-scale soil decontamination work at the FEMP is part of DOE's Uranium Soils Integrated
Demonstration, a DOE Office of Technology Development program aimed at developing and applying new and
enhanced technologies by demonstrating them at one test site.

Currently, a proposed test plan is being circulated for review within DOE and FERMCO management to solicit
comments on approach, feasibility and acceptability. No action has been taken or will be taken without
stakeholder input.

Commentors D and G wanted to suggest the possibility of setting up a trust fund for monitoring and
maintenance of the on-property disposal facilities. A trust fund would not be a viable option due to the
manner in which money is budgeted and allocated to the FEMP cleanup. The United States Congress annually
reviews and approves the funding that the FEMP will receive through the DOE for remediation activities. A
trust fund which would cover the cost of future routine operations and maintenance would not be viable under
the current budgetary process.

Commentor A asked how the vitrified silo residue waste form could emanate radon at the same rate as building
materials, when the waste itself is much more radioactive. She also reguested clarification on the interim
storage process. The glass matrix of the vitrified Operable Unit 4 waste form retains radon much more
efficiently than porous building materials such as concrete and masonry. Therefore, the Operable Unit 4
vitrified material releases radon at a similar rate of building materials despite the greater guantity of
radon emanating radionuclides contained within the vitrified waste form.

Contaminated soil and debris would either be processed in accordance with the selected Operable Unit 5
(Environmental Media) and Operable Unit 3 (Production Area) remedy identified in the Operable Unit 5 and
Operable Unit 3 ROD or placed in an interim storage facility to await the finalization of the disposal
decisions for soils and debris under Operable Unit 5 and Operable Unit 3. The interim storage would be
managed pursuant to the approved work plan for Removal Action 17 - (Improved Storage of Soil and Debris).

The decision regarding the final disposition of the remaining Operable Unit 4 contaminated soil and debris
has been placed in abeyance to take full advantage of planned and in-progress waste minimization treatment
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processes. Further, this FEMP remedial management strategy enables the proper integration of disposal
decisions on a sitewide basis. As planned treatment facilities become available under Operable Units 3 and 5
remedial actions, full consideration would be given to applying these systems to the inventoried contaminated
materials from Operable Unit 4. Following the application of available waste minimization processes, the
remaining Operable Unit 4 contamimated soil and debris would be disposed consistent with the selected
remedies for Operable Units 5 and 3, respectively.

Commentor D wanted to know if the 250 acres calculated to be disturbed during the implementation of the
preferred alternative for Sub 2C included loss of habitat. Tbe 250 acres discussed in the Feasibility Study
Report for Operable Unit 4 represents the cumulative sitewide acreage of land that will be disturbed as a
result of the implementation of all five operable unit's preferred remedial actions. An estimated 220 acres
out of the total 250 acres would be lost in the long term, with the remaining 30 acres only rendered
temporarily unusable during the implementation of the sitewide remedial actions. Therefore, only 220 acres
would be permanently committed as a result of implementing these remedial alternatives.

The State of Nevada (Commentor E) noted that," . . . the cost estimates of long-term storage/disposal of
mixed waste at the NTS were not properly accounted for in the Draft EIS. The assumptions, for example, under
which storage/disposal of mixed waste at the NIS could be considered "free" when compared to a commercial
facility, were not presented in the document. The cost for disposal of FEMP waste at the NTS are incurred by
the FEMP. NVO-325 (Nevada Test Site Defense Waste Acceptance Criteria, Certification, and Transfer
Reguirements), Section 3.5 discusses the methods of payment which generators will use to cover the cost of
disposal operations for their waste at the NTS. Specifically, NVO-325 states "... disposal charges are
based upon the estimated volumes listed on their (generator's) "Three-Year Waste Shipment Forecast multiplied
by the corresponding disposal charge per cubic foot. . ."

The "Three-Year Waste Shipment Forecast" is prepared annually by the generator and it estimates the guantity
of waste to be shipped to NTS by that generator each year for the next three years. These forecasts are then
used by the NTS to project operating costs for operations related to disposal of the waste for the upcoming
years. Therefore, although the NTS disposal site is a non-commercial, non-profit government facility, the
cost for operations is funded by the generators and is not provided "free of charge." It should be noted
that, as stated in the response to Issue 4, the Opaable Unit 4 by-product material for disposal at the NTS is
not mixed waste.

Commentor B guestioned how NEPA was being addressed within these documents. More specifically, how NEPA
volumes were being integrated into the CERCLA process for the Operable Unit 4 FS/PP-DEIS. When the Operable
Unit 4 EIS process was initiated, it was DOE's policy to integrate the NEPA reguirements into the procedural
and documentation reguirements of CERCLA whenever practicable. On June 13, 1994, the Secretary of Energy
modified DOE's approach to National Environmental Policy Act (NEPA) compliance for actions taken under the
authority of CERCLA. As a general policy, DOE will now rely on the CERCLA process for review of remedial
actions to be taken under CERCLA, incorporating NEPA values into CERCLA documents to the extent practicable.
DOE may choose, however, to integrate the NEPA and CERCLA processes for specific proposed actions. For
Operable Unit 4 at the FEMP, DOE has chosen to prepare integrated CERCLA/NEPA documents. This decision was
based on the longstanding interest on the part of local stakeholders to prepare an EIS on the restoration
activities at the FEMP and on the recognition that the draft document was issued and public comments
received. Therefore, an integrated Feasibility Study/Proposed Plan - Final Environmental Impact Statement
(FS/PP-FEIS) has been completed which evaluates alternatives for the treatment and disposal of radioactive
residues contained in storage silos at FEMP.

In accordance with both CERCLA and NEPA processes, these documents are made available to the public for
comment. Public involvement is an important factor in the decision-making process for site remediation.
Public comments will be considered in the selection of remedy for each operable unit, which will be presented
in a ROD. Applying the integrated approach for CERCLA and NEPA, DOE plans to prepare and issue a single ROD
to be signed by both DOE and EPA. The contents of the documents prepared for the remedial actions at the FEMP
are not intended to represent a statement on the legal applicability of NEPA to remedial actions conducted
under CERCLA.

Commentor Q provided twenty comments on the Proposed Plan. Some of these continents were addressed in the
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issue discussions presented in Section C.4.0 of this document. The remaining comments were basically
requests for clarification of the technical content of the document and did not have significant impact on
the document. The comments are distinguished by the letter and the response to the comments immediately
follows.

(a,l) Comments: The responses to Comments "a" and "1" were similar in content and, therefore, have been
combined. The comments are related to the differences in cost and implementation between alternatives with
the same treatment technologies. The commentor stated that". . . there are variances in the capital cost for
the same treatment alternatives with the only difference being on-site versus off-site disposal. What is the
source of this variance?. Furthermore the commentor stated: ". . .comparison of remedial alternatives,
state differences in implementing identical treatments with different disposal options. Is this difference
related to transportation issues for off-site rather than on-site? Please explain these differences. Also
Subunit C lists no treatment for all alternatives; please demonstrate why no treatment is acceptable.

Response: The variances of the capital costs are primarily due to the difference in the disposal methods.
The on-site disposal alternative includes the capital costs associated with the construction of a disposal
vault. The off-site alternative has no capital cost associated with the construction of the disposal vault,
but does include capital costs associated with the transportation and disposal of the waste at the off-site
disposal facility. The implementation of these alternatives is also affected by the same factors.

No treatment response actions were utilized in the development of alternatives for Subunit C waste (i.e.,
soils and debris). This decision is consistent with the FEMP site-wide waste management strategy. This
strategy is designed to coordinate the disposal of similar waste between operable units. From a site-wide
perspective, the estimated quantity of soils and debris requiring management by Operable Unit 4 in comparison
with the total estimated quantity of soils and debris to be managed by Operable Units 5 and 3 respectively,
is quite small. Therefore, as opposed to Operable Unit 4 developing its own treatments methods for soils and
debris, the disposition of these wastes will be integrated with the disposal methods and any treatment
methods developed by Operable Units 3 and 5.

(b,d) Comment: The responses to Comments "b" and "d" were similar in content and, therefore, have been
combined. These comments are related to post-remediation monitoring and site reviews for alternatives which
include on-property disposal. The commentor asked: ". . .EPA would review on-property disposal every five
years in accordance with CERCLA requirements. Who and how often would a review be performed in other years?.
and also asked: "Post remediation O&M cost are estimated over a thirty year period. What about the
remaining years for which this material will require monitoring?"

Response: The EPA requires a five-year review under the CERCLA as follows ". . .if a remedial action is
selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels
that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less
often than every five years after initiation of the selected remedial action." The on-property disposal
alternatives for Operable Unit 4 include the five-year reviews. The on-property disposal facility for the
Operable Unit 4 materials would be designed to preclude the need for active operation, maintenance, and
monitoring. However, during the active operational phase of the overall FEMP site remedial activities
(approximately 30 years), the disposal facility will be monitored. It is anticipated that such operations,
maintenance, and monitoring and associated costs would not be warranted (i.e., no water infiltration will
have been observed) beyond that timeframe.

The Operable Unit 4 selected remedy has adopted preliminary soil cleanup levels with exhumed soils being
placed into on-property storage, pending the establishment of final remediation levels and a disposition
strategy through the Operable Unit 5 Record of Decision (ROD). The Draft Operable Unit 5 ROD is scheduled
for submittal to the USEPA and OEPA on July 2, 1995. Since this soil disposition strategy has been adopted,
it is not considered appropriate to specify in the Operable Unit 4 ROD the long-term operation, maintenance
and monitoring requirements for any residual concentrations of hazardous substances in soils in the Operable
Unit 4 footprint.

The Operable Unit 5 ROD will establish final remediation levels for soil and the associated long term
operation, maintenance, monitoring and institutional requirements for the site. The scope and duration of
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these requirements will be consistent with the contemplated future land use for the FEMP property and the
final remediation levels documented in the Operable Unit 5 ROD. Active operation, maintenance and monitoring
for the soils staged in the interim storage facility are contemplated as part of the Operable Unit 4 remedy.

(c) Comment: "There is no mention of retri[e]vability of the materials which would be disposed of in the
on-site dispasal vault. Is this option being considered, and if not, why?"

Response: The on-property disposal facility is designed with an intruder barrier and permanent markings to
inhibit purposefill or inadvertent human intrusion of the facility's engineered protective features and to
eliminate water infiltration. This design is utilized to provide permanent disposal of the wastes and does
not include a means to readily retrieve the waste. Designing a means to easily retrieve the waste would
compromise the integrity of the cap and would present an easier access for intrusion into the disposal
facility.

(e) Comment: "Alternative 2B and 4B have an identical post remediation cost, with Alternative 4B being
untreated. Please explain how cost can be the same for treated versus untreated materials disposed in an
on-site vault?"

Response: Post-remediation cost cover the costs associated with the monitoring and maintenance of the
disposal facility. The monitoring and maintenance requirements and the disposal facilities for both
alternatives are the same. Therefore, the post-remediation cost associated with these activities are also
the same.

(f) Comment: "There is discussions of interim storage. What is the estimated time for this interim
storage?"

Response: The use of interim storage is identified for Subunit C alternatives waste only. Interim storage
would be utilized only if the waste could not immediately be managed by the remedial alternatives selected
for Operable Units 3 and 5. If interim storage is required, the duration of the storage would be contingent
upon the schedule for implementation of the preferred remedy identified in the Operable Units 3 and 5 ROD.
The interim storage would not exceed the date for final remediation of the FEMP site which is currently
estimated to be completed in 30 years.

(g) Comment: "Alternative 2C states that the contaminated materials would be placed in bulk (without
packaging) into the on-site disposal vault. Please expand on why this material would not be packaged and
state the advantages/disadvantages of packaged versus unpackaged."

Response: The soils and debris considered for disposal into the disposal vault would be contaminated with
relatively low levels of contamination. The disposal facility for the contaminated material from Alternative
2C would be designed to be protective of the environment without the use of packaging. The use of bulk
disposal eliminates the unnecessary cost of the packaging and also reduces the cost of construction by
requiring a much smaller disposal facility.

Comment: "It is stated that non-porous materials will be released from the site as uncontaminated per DOE
Order 5400.5. Will this material be checked for contamination prior to release or just assumed to be
uncontaminated and release?"

Response: As per DOE Order 5400.5, any material which has been used or stored in a radiation area is to be
considered potentially contaminated. Prior to free-release of any potentially contaminated material, the
material will be surveyed to determine whether the removable or total surface contamination is within
specific limits as established in DOE Order 5400.5, NRC Regulatory Guide 1.86, and FEMP site procedures. The
establishment of these limits is based on the primary objective to prevent an effective dose equivalent to
the public in excess of 100 mrem per year. This standard is considered protective of public health and the
environment.

(i) Comment: "Will wastewater generated during remediation be treated for non-radioactive contaminates
prior to discharge in the Great Miami River? To what extent will radioactive and non radioactive elements be
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removed prior to discharge?"

Response: All waste water generated at the FEMP, including waste water generated during Operable Unit 4
remedial activities, is subject to compliance with the FEMP National Pollution Discharge Elimination System
(NPDES) permit. The NPDES permit limits the amount of contaminants, both radioactive and non-radioactive,
which may be discharged through waste water effluent into the environment. In compliance with the NPDES
permit, all waste water generated from the remedial activities for Operable Unit 4 will be treated to comply
with the FEMP NPDES permit standards.

(j) Comment: "A material variance in the cost associated with Subunit C exist between 3C.1 and 3C.2 with
the only apparent difference being 3C.1 disposal at NTS and 3C.2 at Envirocare in Utah. Please explain this
variance and if this is partially due to more stringent reguirements at NTS, should these more stringent
reguirements also be reguired at a commercial facility? Which reguirements is more protective? It is also
stated that an exemption from DOE Order 5820.2A (this is transposed as 5280.2A in document, page 56) is
needed to dispose at a commercial facility; has this been granted?"

Response: The variance in the cost between Alternative 3C.1 and 3C.2 is primarily due to the elimination of
packaging for the Permitted Commercial Disposal Facility as opposed to the use of packaging for the NTS. The
elimination of the purchase cost of the packaging and the reduction of reguired transportation significantly
decreases the costs of Alternative 3C.2 as opposed to 3C.1. The NTS currently does not accept waste in bulk
form (i.e., unpackaged railcar) and therefore, the disposal alternative for the NTS does not recognize the
same cost savings. Because both disposal facilities operate within their permits, and the environments in
which they are located are similar, both disposal facilities are considered egually protective.

An exemption from DOE Order 5820.2A, which excludes the use of commercial disposal facilities for DOE waste,
has not been specifically pursued for the disposal of Operable Unit 4 remedial wastes. The evaluation of the
alternatives in the FS/PP-DEIS, indicated that other alternatives were preferred over the alternatives which
included the Permitted Commercial Disposal Facility. Therefore, a reguest to grant an exemption from this
DOE Order was not reguired. However, exemptions from this order have been granted and commercial disposal
facilities have been utilized for other FEMP wastes.

(c) Comment: "Will notification of these shipments be given to the areas involved in the transportation
routes for both rail and truck, and what precautions for protection will be employed?"

Response: Response to this comment is provided in Issue 5 on page C-4-20.

(m) Comment: "Is there a potential for failure of the vitrified material has the radionuclides trapped
continue to decay, and if so, what is that risk?"

Response: The weathering behavior of volcanic glass (a natural analog to the Operable Unit 4 vitrified
product) can provide some measure of the long-term stability and durability of the vitrified product. Only
very thin weathering rinds develop on volcanic glass over a period of several million years. The slowness in
the overall degradation of a glass grain suggests that the diffusion coefficient or leachability index would
remain relatively unchanged over time. Data on the long-term stability of vitrified material are not
available, and the life expectancy of the vitrified product is difficult to estimate from short-term leach
rates. However, on the basis of the longevity of volcanic glass and diffusion calculations, the vitrified
product would be expected to withstand direct environmental exposure for thousands of years. Furthermore,
past studies have shown that the decay of radioactive materials do not affect the durability of the vitrified
product.

(n) Comment: "It states that the capital cost associated with the on-site disposal facility has been
removed. Where is (will) this cost be accounted for?"

Response: This comment refers to a sentence in the Proposed Plan (page 67, line 6) which was erroneous and
scheduled to be deleted from the text. However, this deletion was inadvertently overlooked and the sentence
was left in the text. The capitol cost of the on-site disposal facility is included in the total estimated
cost of the preferred remedy. This cost is identified in Table 9-1 of this document.
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(o) Comment: "Line 14, page 67 reads ". . .results in significant a reduction in the volume. . . ," this
would read better if the "a", preceded significant/rather than follow."

Response: This comment is duly noted. However, it has no significant impact on the document.

(p) Comment: "Please define the following statement (line 16, page 67) utilize permanent solutions to
the maximum extent practical. What viable permanent solutions presently exist?"

Response: The intent of the statement" . . .permanent solutions to the maximum extent practical. . ."
alludes to the fact that, based on available technology, this remedy provides the most feasible and permanent
solution for the remediation of Operable Unit 4. A potential remedial alternative's ability to achieve long
term permanence is one of nine criteria used to evaluate a remedy in terms of the risk remaining at the site
after response objectives have been met. The primary focus of this evaluation is the extent and
effectiveness of the controls that may be required to manage the risk posed by treatment wastes.

As discussed in the Operable Unit 4 Feasibility Study and Proposed Plan, the preferred remedy (removal,
vitrification of the waste and offsite disposal at the Nevada Test Site) would be the most effective based on
treatability studies conducted on the silo residues which demonstrated that vitrification would be effective
in reducing radon emanation, radionuclide leachability, and significantly reducing the residue volume by
approximately 50 percent. Off-site disposal at the NTS would provide a greater certainty than on-property
disposal over the long term that the treated residues would not affect human health and the environment.

(q) Comment: "Basis for stating long-term environmental impacts of permanent disposal at NTS are minor
and no long-term impacts of biota expected from disposal activities at NTS. It is stated that to reduce U-238
to essentially background is not feasible; it also states that it is assumed that the federal government
retain ownership of the FEMP site to consider clean-up protective. While I do not have a problem with these
statements, it does bother me that no formal statement has been made publicly concerning this. These two
statements present future land use constraints which must be addressed. Why hasn't the DOE adopted a formal
position concerning this issue and communicated this to both the Fernald Citizens Task Force and the
community?"

Response: The DOE and the EPA recognize that future land use for the FEMP site is currently under
consideration by the Fernald Citizens Task Force and is actively involved in and supports this effort.
However, due to the stipulations of the Amended Consent Agreement, Operable Unit 4 is required to put forth a
remedy for cleanup of soils within the operable unit boundary prior to completion of the Fernald Citizens
Task Force effort.

As discussed in the Proposed Plan, Section 5.4.1, the preferred remedy for Operable Unit 4 requires cleanup
of contaminated soils to the proposed remediation levels presented in Table 5-2. In addition to this, it is
indicated that these cleanup levels for soils may be adjusted to lower values, if necessary, to insure
protectiveness of human health and the environment. The level of protectiveness required by the soils will
be dictated by the final land use selected for the entire FEMP site, including that for Operable Unit 4, by
the Citizens Task Force, and the ongoing feasibility study modelling efforts being performed by Operable Unit
5. Factoring in the Fernald Citizens Task Force recommendations, Operable Unit 5 will evaluate and determine
the final cleanup levels required for soils on a site-wide basis. Accordingly, the Operable Unit 4
FS/PP-DEIS recommends that the decision for final disposition of the contaminated soils be put in abeyance
until the Record of Decision for Operable Unit 5 is issued, at which time the final soils cleanup levels will
be established.

(r) Comment: "Line 13, page 76 reads". . .would not be. . .", should that read . . . would not be..."?

Response: This comment is duly noted. However, it has no significant impact on the document.

(s) Comment: "It states the on-site, above-grade disposal facility would be designed for a 1000 year
life with no active maintenance. What is the half-lives or duration for which the radionuclide and chemical
contaminants are a threat to the environment; do they exceed 1000 years? Also explain why no active
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maintenance is assumed for 1000 years?

Response: The half-lives of the radioactive constituents in the Operable Unit 4 waste range from 3 to 4 days
for Radon-222 to over 1.4 x 1010 years for Thorium-232 well in excess of 1000 years.

On-site disposal of contaminated soils and debris in an above-grade disposal facility was evaluated in the
Operable Unit 4 Feasibilig Study (FS) and also presented in the Proposed Plan (PP). For purposes of the
FS/PP, tbis disposal facility would be designed for a life of 1000 years. This vault would be designed to
preclude the need for long-term active maintenance for the duration of its design life of 1000 years. An
assessment of the risks to human health, presented in Appendix D of the Operable Unit 4 FS, indicates that
for the extended trespasser the residual risk from soil remaining in Operable Unit 4 in addition to risks
posed by disposal of contaminated soils and debris in this facility would be well within the reguired risk
range of 1 x 10-4 to 1 x 10-6. However, it should be noted that the final disposition of soil and debris
will be determined by the Records of Decision (RODs) for Operable Units 3 and 5. In accordance with the
reguirements of CERCLA, the Operable Units 3 and 5 RODs will define the appropriate level of protectiveness
reguired for final disposition of Operable Unit 4 debris and contaminated soil respectively.

(t) Comment: "Has an exemption to the Ohio solid waste facility reguirement been reguested, and if not
when will such a reguest be made? Also line 28, page 79, would read better if "the" or "a" were added to
precede disposal. (For disposal facility on the FEMP site.)

Response: Operable Unit 4 will not be creating a new solid waste disposal unit for management of Operable
Unit 4 remediation waste as part of the Operable Unit 4 preferred remedy. Rather, the decision to
treat/dispose of Operable Unit 4 wastes on site will be part of the Operable Units 3 and 5 RODs, since the
disposition of Operable Unit 4 demolition debris and soils for remediation will be deferred to those
respective operable units. Therefore, compliance with the Ohio siting reguirement is not germane to the
Operable Unit 4 FS/PP-DEIS.

Discussions with the EPA and OEPA have taken place regarding exemptions and possible waiver to this
reguirement. At this time, the issue of technical exemption under Ohio statute, versus ARAR waiver by EPA
has not been resolved.

The editorial comment on the text contained in Line 28, Page 79, has been noted. However, it does not have
any impact on the document.

The Ohio EPA (Commentor R) noted that DOE should attempt to incorporate pollution prevention activities
whenever possible during the design and operation of the OU4 remedial action system. In addition, the Ohio
EPA commented that all available methods to reduce or eliminate discharges from the treatment system should
be considered during the design of the system. It is DOE policy, in accordance with Executive Order 12856,
whenever feasible to apply pollution prevention and waste minimization principles into the design and
operation of all its facilities. The DOE is committed to employing all available methods and technigues to
minimize waste and/or eliminate discharges from remedial treatment systems in a manner protective of human
health and the environment.

The Ohio EPA (Commentor P) stated that, . . . "The OU4 Proposed Plan is the culmination of efforts by U.S.
DOE, Ohio EPA, and U.S. EPA to understand and develop a plan for mitigating releases to the environment from
OU4. The alternative selected in the Proposed Plan will address potential and actual releases in a manner
protective of human health and the environment." The DOE acknowledges the Ohio EPA comment and believes that
the implementation of the preferred alternative identified in the Proposed Plan will address the remediation
of the Operable Unit 4 area in a manner protective of human health and the environment.

The US EPA, Planning and Management Division (Commentor S) stated that, ... "the only comments on the record
from our agency are those previously supplied to you by our Waste Management Division. At this point in
time, given the reguirements of NEPA and its implementing regulations, those comments will have to suffice as
our agency's comments. Provided that the comments previously provided by our Waste Management Division are
complied with, and further provided that facility in guestion is subseguently operated in full accordance
with applicable local, State, and Federal reguirements, it appears unlikely at this tune that any
-------
significant adverse impacts on the environment can reasonably be foreseen." The DOE previously addressed the
US EPA Region 5, Waste Management comments on the Operable Unit 4 FS/PP-DEIS in May 1994. These comments
were satisfactorily resolved with the US EPA Waste Management Division at that time. Section 11 of this
responsiveness summary details the significant changes reguired by the resolution of the US EPA Waste
Management Division comments.
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ATTACHMENT C.I

WRITTEN AND ORAL COMMENTS

TABLE OF CONTENTS

Page
List of Tables c-I-ii
C.I.I Introduction C-I-1

LIST OF TABLES
Page

C.I. 1-1 Formal Oral and Written Comments Received C-I-1

C.I WRITTEN AND ORAL COMMENTS

C.I.I INTRODUCTION

The written comments received on the Operable Unit 4 FS/PP-DEIS during the March 7, 1994 - June 19, 1994
comment period and the verbal comments received during the March 21, 1994 public meeting at The Plantation in
Harrison, Ohio are contained in this appendix. In addition, all late comments received as of July 5, 1994
are included in this appendix. Each specific comment letter, oral statement, and submitted attachments are
referenced by an alphabetic identifier as noted in Table C.I.1-1. These comments are a formal part of the
Administrative Record for this action.
-------
TABLE C.I.1-1
FORMAL ORAL AND WRITTEN COMMENTS RECEIVED

PAGE
ITEM COMMENTOR NUMBER

FORMAL ORAL COMMENTS

A Norma Nungester, resident and FRESH member C-I-8
B Vicky Dastillung, resident and FRESH Vice President C-I-19
C Lou Bogar, resident, Hamilton, Ohio C-I-20
D Edwa Yocum, resident and FRESH Secretary C-I-28

FORMAL WRITTEN COMMENTS

E Maud Naroll, State of Nevada, State Clearinghouse (April 18, 1994) C-I-31
F Jack and Roberta Warndorf, resident, Okeana, Ohio C-I-34
G Edwa Yocum, resident and FRESH Secretary, Harrison, Ohio C-I-35
H J. E. Walther, resident, Hamilton, Ohio C-I-36
I Martha J. Raymond, Department Head, Technical Review Services, Ohio C-I-38
Historic Preservation Office
J Lisa Crawford, resident and FRESH President C-I-40
K Lawrence L. Stebbins, resident, Hamilton, Ohio C-I-41
L Maud Naroll, State of Nevada, State Clearinghouse (April 5, 1994) C-I-43
M James K. O'Steen, Director, Office of Hazardous Materials Technology, U.S. C-I-45
Department of Transportation
N William L. Vasconi, Acting Chairman, Nevada Test Site Citizens Advisory C-I-47
Board
0 Nevada Test Site Citizens Advisory Board C-I-48
P-l Nichole Davis, 1600 E. University #151, Las Vegas, NV 89119 C-I-49

P-2 Shellie Michael, 2800 S. Eastern #717, Las Vegas, NV 89109 C-I-49

PAGE
ITEM COMMENTOR NUMBER

P-3 Lynn Rohl, P.O. Box 12303, Las Vegas, NV 89112 C-I-50
P-4 Ted Mucha, 301 Orland #8, Las Vegas, NV 89107 C-I-50
P-5 Mark Michael, 2800 S. Eastern #717, Las Vegas, NV 89109 C-I-51
P-6 Kathleen Guise, 4124 Seville St., Las Vegas, NV 89121 C-I-51
P-7 Jo Anne Moran, 3128 E. Flamingo #203, Las Vegas, NV 89121 C-I-52
P-8 Catherine A. McLaughlin, 1721 Howard Ave., Las Vegas, NV 89104 C-I-52
P-9 Nancy Gott, 3212 Brahns Dr., Las Vegas, NV 89102 C-I-53
P-10 Rebecca Webber, 5070 River Glen Dr. #457, Las Vegas, NV 89103 C-I-53
P-ll Tanya Carr, 2032 Shadow Brook Way, Las Vegas, NV 89014 C-I-54
P-12 Jim Macklin, 5178 Silverheart Ave., Las Vegas, NV (no zipcode provided) C-I-54
P-13 Cindy Weatherby, 1760 N. Decatur #69, Las Vegas, NV 89108 C-I-55
P-14 Rebecca Heider, 6941 W. Forest Vista St., Las Vegas, NV 89117 C-I-55
P-15 Troy Weatherby, 1760 N. Decatur #69, Las Vegas, NV 89108 C-I-56
P-16 Abraham Hartman, 1872 Pasadena Blvd., Las Vegas, NV 89115 C-I-56
P-17 Vicki Cassman, P.O. Box 72634, Las Vegas, NV 89170 C-I-57
P-18 Art Goldberg, 14810 Living Desert Dr., Las Vegas, NV 89119 C-I-57
P-19 Jillian Beth Wright, 6435 lorn Bark Lane (address provided incomplete) C-I-58
P-20 Linda Strange, 4830 Nara Vista Way #102, Las Vegas, NV 89103 C-I-58
P-21 Ronnie Strange, 4830 Nara Vista Way #102, Las Vegas, NV 89103 C-I-59
P-22 Mindy Brummett, 6397 Spring Meadow Dr., Las Vegas, NV 89103 C-I-59
P-23 LaLori Rossi, 1929 Franklin Ave. (address provided incomplete) C-I-60
-------
P-24 Taryn Cunningham, 7383 Newerest Cir., Las Vegas, NV 89117 C-I-60
P-25 Tiffany Brummett, 6397 Spring Meadow Dr., Las Vegas, NV 89103 C-I-61
P-26 Janet Zimmerman, 1912 Spangle Dr., Las Vegas, NV 89108 C-I-61
P-27 Janene Zimmerman, 1912 Spangle Dr., Las Vegas, NV 89108 C-I-62
P-28 Patricia Bishop, 1400 S. Casino Ct. #19, Las Vegas, NV 89104 C-I-62
P-29 Daniel J. Fedor, 185 Sweab, Las Vegas, NV 89115 C-I-63
P-30 Michael Carrigan, 7217 Tempest PI., Las Vegas, NV 89128 C-I-63
P-31 Renee Halm, 1000 King Richard, Las Vegas, NV 89119 C-l-64
P-32 Tubiola Lopez, 1508 Living Desert Dr., La Vegas, NV 89119 C-I-64
P-33 Doreina Saenz, 2111 Fairfield #6, Las Vegas, NV 89102 C-I-65
P-34 Jerome Brenberg, 5668 Divot PI., Las Vegas, NV 89130 C-I-65
P-35 Ravon Rodriguez, 538 Kolson Cr. #"A" (address provided incomplete) C-I-66

PAGE
ITEM COMMENTOR NUMBER

P-36 Carmen E. Rodriguez, 538 Kolson Cr. #"A" (address provided incomplete) C-I-66
P-37 Kimba Rutledge, 399 Steelhead Lane, Las Vegas, NV 89110 C-I-67
P-38 Sheila Rutledge, 399 Steelhead Ln., Las Vegas, NV 89110 C-I-67
P-39 S. Humhe, 9285 Sunten Ct., Las Vegas, NV (address provided incomplete) C-I-68
P-40 Michelle Lynn Berry, 370 E. Harmon Apt. E310, Las Vegas, NV 89109 C-I-68
P-41 L. Jean McCoy, 6710 Wild Horse Rd., Las Vegas, NV 89108 C-I-69
P-42 Tammy Smith, 6710 Wild Horse Rd., Las Vegas, NV 89108 C-I-69
P-43 Hermy B. (?), 1982 N. Rainbow #194, Las Vegas, NV 89108 (name C-I-70
unreadable)
P-44 Stan Greene, 7845 La Cienega, Las Vegas, NV 89123 C-I-70
P-45 Frances Bruno, 486 Sierra Vista Dr. #24 (address provided incomplete) C-I-71
P-46 Betty Hay, 1241 South 7th St., Las Vegas, NV 89104 C-I-71
P-47 David Geerts, 3940 S. Algonguin Dr. #83, Las Vegas, NV 89119 C-I-72
P-48 John Engle, 4441 Escondido St. Apt. #4205 (address provided incomplete) C-I-72
P-49 Alison Orr, 7053 Cheerful Circle, Las Vegas, NV 89117 C-I-73
P-50 David Gohas, P.O. 46204, Las Vegas, NV 89114 C-I-73
P-51 Finu Norris-Coray, 4801 Spencer #56, Las Vegas, NV 89119 C-I-74
P-52 Elizabeth Petit, 2362 N. Green Valley Parkway #141P, Henderson, NV 89014 C-I-74
P-53 Sonja Swenson, 4444 Midway Lane, Las Vegas, NV 89108 C-I-75
P-54 Ron Schaefer, 3950 Mountain Vista #146, Las Vegas, NV 89121 C-I-75
P-55 Victoria Pinkston, 1771 Charnut Lane (address provided incomplete) C-I-76
P-56 Kathy Granousky, 3355 Dakota Way, Las Vegas, NV 89109 C-I-76
P-57 Emilee Rogers, 1105 Washington (address provided incomplete) C-I-77
P-58 Michael LoCorriere, 7201 W. Girard Drive, Las Vegas, NV 89117 C-I-77
P-59 Sheri LoCorriere, 7201 W. Girard Drive, Las Vegas, NV 89117 C-I-78
P-60 Breck Nester, 24252 Sparrow, El Toro, CA 92630 C-I-78
P-61 Dana Robbins, 5028 S. Rainbow #101, Las Vegas, NV 89118 C-I-79
P-62 Huy Phan, 3719 Central Park Circle, #4 (address provided incomplete) C-I-79
P-63 Sandra Travez, 30 Tierra Buena Drive, Las Vegas, NV 89110 C-I-80
P-64 Steve Zahn, 8305 Greshen, Las Vegas, NV (no zipcode provided) C-I-80
P-65 Lisa Nunag, 1009 Spire CNYN, Las Vegas, NV 89128 C-I-81
P-66 Tim Jagua, 3273 E. Flamingo #102, Las Vegas, NV 89121 C-I-81

PAGE
ITEM COMMENTOR NUMBER

P-67 Shelli McKenney, 4640 Victoria Beach Way, Las Vegas, NV (no zipcode C-I-82
provided)
P-68 Carmen Davis, 6666 W. Washington #463, Las Vegas, NV 89107 C-I-82
P-69 Nasreen Bakhtary, 2165 E. Rochelle #71, Las Vegas, NV 89119 C-I-83
P-70 Maribel McAdory, 2529 Pacific Avenue, Las Vegas, NV (no zipcode provided) C-I-83
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P-71 Merlinda Gollegos, 5625 W. Flamingo #2005, Las Vegas, NV 89103 C-I-84
P-72 Chad Hunt, 8222 Beaverbrook Way, Las Vegas, NV 89123 C-I-84
P-73 Barb Brentz, 1015 Franklin Avenue, Las Vegas, NV 89104 C-I-85
P-74 Mayte Villanueva, 1805 Evelyn Avenue, Henderson, NV 89015 C-I-85
P-75 James Min, 5315 Heatherbrook Circle, Las Vegas, NV 89120 C-I-86
P-76 David Johnson, 3632 Hamlin, Las Vegas, NV 89030 C-I-86
P-77 Laura Yada, 4770 Gym Road, Las Vegas, NV 89119 C-I-87
P-78 Shannon Conners, 1213 Sloop Dirve, Las Vegas, NV 89128 C-I-87
P-79 Sherri Caron, 3913 Courtside, Las Vegas, NV 89105 C-I-88
P-80 Stevi Carroll, 6505 Burgundy Way, Las Vegas, NV 89107 C-I-88
P-81 Margaret Bean, 3060 Ramrod, Las Vegas, NV 89108 C-I-89
P-82 Patrice L. Harvey, 7412 Summa Crest Lane, Las Vegas, NV 89129 C-I-89
P-83 Robin Wayne, 3400 Turguoise Road, Las Vegas, NV 89108 C-I-90
P-84 George A Bean, 3060 Ramrod Street, Las Vegas, NV 89108 C-I-90
P-85 Robert Pierson, 2974 Liberty Avenue, Las Vegas, NV 89121 C-I-91
P-86 Tim Bartlett, 4504 Fireside Lane, Las Vegas, NV 89110 C-I-91
P-87 Selma and Chuck Umnuss, 8504 Glenmount Drive, Las Vegas, NV 89134- C-I-92
8648
P-88 Rob Marchant, 650 Whitney Ranch, Henderson, NV (no zipcode provided) C-I-92
P-89 Jeff Van Ee, 2092 Heritage Oaks, Las Vegas, NV 89119 C-I-93
P-90 Tiffany Braun, 1635 Westwind Circle (address provided incomplete) C-I-93
P-91 Jeffrey M. Steinbeck, 294 Davis Hill Court, Henderson, NV 89014 C-I-94
P-92 Catherine Tillman, 3107 Lamega Drive, Henderson, NV 89014 C-I-94
P-93 Madelaine Dayton, 2253 Castleberry, Las Vegas, NV 89115 C-I-95
P-94 Lori Johnson, 274 Camino Verde, Henderson, NV 89014 C-I-95
P-95 Sharlyn Anderson, 551 Eiger Way #1312, Henderson, NV 89014 C-I-96
P-96 Kathleen Womack, 5652 S. Latigo, Las Vegas, NV 89119 C-I-96
P-97 S. Gomez, 4255 Tamarus #286, Las Vegas, NV 89119 C-I-97

PAGE
ITEM COMMENTOR NUMBER

P-98 Melony Haynes, 1308 N. Jones, Las Vegas, NV 89108 C-I-97
P-99 Michele Gilbreth, 2391 Callahan Avenue, Las Vegas, NV 89119 C-I-98
P-100 Mary E. July, 5250 E. Lake Mead #26, Las Vegas, NV 89115 C-I-98
P-101 Grace K. Tao, P.O. Box 60384, Boulder City, NV 89005 C-I-99
P-102 Julia L. Winkler, 1127 E. Toni Avenue #18, Las Vegas, NV 89119 C-I-99
P-103 John Heormey, 419 Desert Inn Road, Las Vegas, NV (address provided C-I-100
incomplete and last name hard to read)
P-104 James Holmes, 604 Freeman (address provided incomplete) C-I-100
P-105 Merlyn Huguet, 2021 Peyton, Las Vegas, NV 89104 C-I-101
P-106 Barbara Roth, 112 Temple Drive, Las Vegas, NV 89107 C-I-101
P-107 John Wells, 6983 Antell Circus, Las Vegas, NV (address provided incomplete) C-I-102
P-108 Al Roth, 112 Temple Drive, Las Vegas, NV 89107 C-I-102
P-109 Louis Lavietes, 3401 E. Bonanza Road (address provided incomplete) C-I-103
P-110 Jeff Cooley, 8257 Bermuda Beach Drive, Las Vegas, NV 89128 C-I-103
P-lll James P. Foster, 817 Lauren Patt, Henderson, NV 89104 C-I-104
P-112 Giovanni Duley, 6251 Viewpoint Drive, Las Vegas, NV 89115 C-I-104
P-113 Trisa Higgins, 1075 Legato Drive, Las Vegas, NV 89123 C-I-105
P-114 Maggie Breki, 3237 E. Flamingo, Las Vegas, NV 89121 (last name hard to C-I-105
read)
P-115 Joel Delmendo, 3138 Gaucho Drive, Las Vegas, NV 89008 (zip code hard to C-I-106
read)
P-116 Katherine Garder, 5050 Tamanas #267, Las Vegas, NV 89119 C-I-106
P-117 Jason Benatz, 6317 Hobart, Las Vegas, NV 89107 C-I-107
P-118 Ebony Samerkand, 549 Kristin Lane, Henderson, NV 89015 C-I-107
P-119 Stacy Smith, 4223 Grove Circle #4, Las Vegas, NV 89119 C-I-108
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P-120 Sanena Shelling, 1445 E. Rochelle (address provided incomplete) C-I-108
P-121 Gerald F. Cuetiovic, 135 Grandview Drive, Henderson, NV 89015 C-I-109
P-122 Judy Cuetkovic, 135 Grandview Drive, Henderson, NV 89015 C-I-109
P-123 Michael Cuetkovic, 135 Grandview Drive, Henderson, NV 89015 C-I-110
P-124 Mrs. G. Michakel, 4079 El Segundo Avenue, Las Vegas, NV 89121-1703 C-I-110
P-125 Willene De Langis, 758 Willow Avenue, Henderson, NV 89015 C-I-111
P-126 Donald A. De Langis, 758 Willow Avenue, Henderson, NV 89015 C-I-111
P-127 Robert Tonelli, 1004 University Ridge, Reno, NV (no zipcode provided) C-I-112

PAGE
ITEM COMMENTOR NUMBER

P-128 Ruth Lindahl, 9457 S. Las Vegas Blvd. S. #93, Las Vegas, NV 89123 C-I-112
P-129 Melody Derrick, 330 S. 10th St., Las Vegas, NV 89107 C-I-113
P-130 Doug Jablin, 3559 Markan St., Las Vegas, NV 89121 C-I-113
P-131 Anthony Bondi, 135 Albert Avenue St. E. #16, Las Vegas, NV (no zipcode C-I-114
provided)
P-132 T. Jones, Box 73215, Las Vegas, NV 89170 C-I-114
P-133 John A. Loeffler, P.O. Box 832, Searchlight, NV 89046 C-I-115
P-134 Christopher Mercer, 2517 Huber Hts., Las Vegas, NV 89128 C-I-115
P-135 Kurt Buchida, 325 Maryland Parkway, Las Vegas, NV 89101 C-I-116
P-136 Liz Marion, 6824 Adobe Court, Las Vegas, NV 89102 C-I-116
P-137 Dennis A. Dewitt, Box 5371, Reno, NV 89513 C-I-117
P-138 Brenda Weksler, 7904 Marbella Circle, Las Vegas, NV 89128 C-I-117
P-139 Cheryl Frossa, 3450 Erva St. #101, Las Vegas, NV 89117 C-I-118
P-140 Harriet R. Gagliano, 2713 Gilmary Avenue, Las Vegas, NV 89102 C-I-118
P-141 Kathy Poma, 2113 Fountain Springs Drive, Henderson, NV 89014 C-I-119
P-142 Stacey Hallenberg, 2245 Maple Rose Drive, Las Vegas, NV 89134 C-I-119
P-143 Kelli Koerwitz, 909 Willowtree, Las Vegas, NV 89128 C-I-120
P-144 Trish Taylor, 2113 Fountain Springs Drive, Henderson, NV 89014 C-l-120
P-145 Heather Davis, 2031 E. Windmill Lane, Las Vegas, NV 89123 C-I-121
P-146 Marilyn Benoit, 3461 Pointe Willow, Las Vegas, NV 89120 C-I-121
P-147 Richard Lewnau, 2950 S. Decatur D-3, Las Vegas, NV 89102 C-I-122
P-148 Susan Thornton, 1412 Golden Spur Lane, Las Vegas, NV 89117 C-I-122
P-149 Lee Dazey, 72 Keystone Avenue, Reno, NV 89503 C-I-123
P-150 Pete Mastin, P.O. Box 92, Verdi, NV 89439 C-I-123
P-151 Trade K. Lindeman, P.O. Box 1672, Fallen, NV 89407 C-I-124
P-152 David L. Platerio/Tosa-wi-e, P.O. Box 822, Elko, NV C-I-124
P-153 Jo Ana Garrett, P.O. Box 130, Baker, NV 89311 C-I-125
P-154 Margaret Norman, 2332 Grant Street, Berkeley, CA 94703 C-I-125
P-155 Judy Treichel, 3926 Bushnell Drive #71, Las Vegas, NV 89103 C-I-126
P-156 Lorry C. Johns, 2090 Westwind Road, Las Vegas, NV 89102 C-I-126
P-157 Steve Frishman, 208 N. Hwy. 95A, Yerington, NV 89447 C-I-121
P-158 William Rosse Sr., HC61 Box 6240, Austin, NV 89310-9301 C-I-121
ITEM
COMMENTOR
PAGE
NUMBER
P-159 Corbin Hanuf (?), P.O. Box 1255, Nevada City, CA 95959 (name was hard C-I-128
to read)
P-160 Shawn Black, 650 Whitney Ranch #1423, Las Vegas, NV (no zipcode C-I-128
provided)
P-161 Lawrence Skinner, 1604 E. Evans, Las Vegas, NV 89030 C-I-129
P-162 Mary L. Johns, 2090 Westwind Road, Las Vegas, NV 89102 C-I-129
P-163 Bob Fulkerson, 725 McDonald Drive, Reno, NV 89503 C-I-130
P-164 Carla Baker Wallace, 3245 Mallard, Las Vegas, NV 89107 C-I-130
P-165 Louise (?), 4255 Tamarus #217, Las Vegas, NV 89119 (name was hard to C-I-131
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read)
P-166 Margaret (?), 1526 Darryl Avenue, Las Vegas, NV 89123 C-I-131
P-167 (?), 1526 Darryl Avenue, Las Vegas, NV 89123 (name unreadable) C-I-132
P-168 (?), 1381 E. University Avenue (address incomplete and name unreadable) C-I-132
P-169 (?), 4801 Spencer #56, Las Vegas, NV 89119 (name unreadable) C-I-133
P-170 (?), 1431 E. Charleston, Las Vegas, NV 89104 (name unreadable) C-I-133
P-171 Jamie B. (?), 4630 White Rock Drive, Las Vegas, NV 89121 (name C-I-134
unreadable)
P-172 (name and address unreadable) C-I-134
P-173 (name and address unreadable) C-I-135
P-174 (left blank) C-I-135
P-175a Geoff Holton, 2332 Grant Street, Berkeley, CA 94703 C-I-136
P-176a Richard Glasman, 2212 18th Avenue South, Seattle, WA 98144 C-I-136
P-177a Kathleen Glasman, 2212 18th Avenue South, Seattle, WA 98144 C-I-137
Q Pam Dunn, Harrison, OH C-I-138
R Thomas A. Schneider, Ohio Environmental Protection Agency C-I-145
S Michael W. MacMullen, U.S. EPA Region 5, Planning and Management C-I-147
Division

a Postcards were received by the DOE on July 5, 1994.
-------
Commentor A

Norma Nungester: (Questions & formal oral, March 21, 1994)

1 few more of us from Ohio EPA. We're hiring some

2 more staff, so hopefully that will be a little more

3 proactive to your needs and help you out as far as

4 information you night need. So like I said, feel

5 free to contact me outside of this at the office or

6 wherever. Thanks.

7 MR. STEGNER: Thank you. What we'll

8 do now is, we'll have an informal guestion and

9 answer session. It might be best if you use a

10 microphone back there. If you don't feel

11 comfortable, just stand up and shout it. We have a

12 recorder here tonight. Please just state your name

13 and the guestion, and we'll let the panel pick it

14 up. So whoever wants to be first, feel free.

15 MS. NUNGSTER: I'm Norma

16 Nungester. I'm a Fernald resident, and a member of

17 Fresh. I have a guestion of Dennis Nixon. He made

18 the statement that I don't agree with, and I

19 wondered if he could clarify for me. He said that

20 when you vitrify waste, it reduces radon emanation

21 to that of building materials. To my

22 understanding, when you vitrify radionuclides, that

23 they still are very, very hot.

24 MR. NIXON: That's correct. The

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Commentor A (Cont.)

1 concentrate, due that reduction, is the radon

2 generation from the treated waste itself that is

3 significantly reduce. The radon is actually held

4 up, and the surface area is significantly reduced.

5 Did you get every other word?

6 You're exactly right, that due to

7 that fact that there's a significant volume

8 reduction, you actually concentrate the

9 radionuclides, so you have a higher concentration

10 of say uranium in a set volume, but the radon

11 itself is such less. The generation or the

12 emanation from the vitrified waste is such less

13 than in its natural form.

14 MS. NUNGESTER: Okay, thank you.

15 MS. YOCUM: Edwa Yocum, Fresh member

16 and a resident of the Fernald area. I was asking a

17 guestion, this concerns Subunit C2 on your

18 preferred alternative demolition removal on

19 property disposal. When you were talking about the

20 OU4 NEPA compliance with the substantive cumulative

21 impact up to 250 acres of surface disturbance, does

22 that mean that would be what would be part of where

23 the waste will be put?

24 MS. WOODS: Yeah. Again, we looked

SPANGLER REPORTING SERVICES

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1 at an LRA and assumed on-site disposal.

2 MS. YOCUM: Okay.

3 MR. WOODS: And that acreage would

4 incur areas where waste would be disposed of.

5 MS. YOCUM: Okay. Then, you also

6 are talking about the loss of 220 acres of

7 habitat. Is that included in the 250 acres?

8 MR. WOODS: Yeah. That 250 would be

9 a total that would occur during the short term, in

10 other words, during excavation activities. Once

11 remediation is completed, we would look at

12 approximately 220 acres being permanently

13 committed, so yes, that' a correct.

14 MS. YOCUM: Okay, all right, that's

15 what I wanted to know.

16 MS. NUNGESTER: Can you expand on

17 that permanently committed? I missed something.

18 Permanently committed for what, waste disposal

19 facility?

20 MR. WOODS: Yeah, correct.

21 MS. NUNGESTER: Not for the waste

22 itself but for the —

23 MR. WOODS: For the facilities that

24 would house the waste.

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Commentor A (Cont.)

1 MS. NUNGESTER: That's the inground

2 facility, the upgrade vault, as you so say?

3 MR. WOODS: Correct

4 MS. NUNGESTER: Now can you give me

5 an explanation of what is in an upgrade vault?

6 MR. WOODS: The alternatives that we

7 used for the evaluation utilized the vault concept,

B which would be a portion of the waste being

9 disposed of below grade, and, you know, basically a

10 portion above. There would be facilities that the

11 waste could be retrieved from, and what we used was

12 the calculation of the area.

13 MS. NUNGESTER: Disposal means

14 permanent?

15 MR. WOODS: Yes.

16 MS. NUNGESTER: But now you're

17 talking interim?

18 MR. WOODS: Well, what I'm saying is

19 the design of the facility wasn't as important as

20 the area that the facility could include. Designs

21 are going to be finalized as we go through the

22 remedial process.

23 MS. NUNGESTER: Well, this is

24 another thing, when you go through the RA and

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Commentor A (Cont.)

1 that's where the final decision and designs are

2 actually made --

3 MR. WOODS: Correct.

4 MS. NUNGESTER: — how can you come

5 out with a Record of Decision before you actually

6 know what the vault is going to look like and if it

7 is really going to do the job?

8 MR. WOODS: No, you cannot reach a

9 Record of Decision until, you know, we've gone

10 through the full analysis of what the vault will be

11 designed like and how it will work. What we did is

12 utilize the alternatives that were avallabla at

13 that time for the purpose of the evaluation, which

14 is really the best we can do. We can't foresee.

15 MS. NUNGESTER: Okay. As of today?

16 MR. WOODS: That's correct, that's

17 correct. As we go through the various operable

18 units and decisions are made as to the final design

19 of the vaults and changes are made to the area,

20 that may be required. We'll update the analysis

21 and provide it in the future integrated documents

22 for the other operable units.

23 MS. NUNGESTER: Okay. So than our

24 decisions of the -- So your alternative for the

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Commentor A (Cont.)

1 Unit 4 can change by the time after arriving at a

2 decision?

3 MR. NIXON: We were specific with

4 the subunit wastes the Record of Decision. For

5 Operable Unit 4, specifically the Record of

6 Decision, the proposed plan in the future Record of

7 Decision will be that the Subunit C waste is -- you

8 remember us talking about being held in abeyance or

9 delayed operable units, the Subunit C waste will be

10 handled in accordance with the Records of Decisions

11 for Operable Unit 3 and Operable Unit 5,

12 respectively. Okay.

13 So as far as our Record of Decision,

14 essentially we carry it through the removal of the

15 soil, interim storage of that soil in accordance

16 with Removal Action 17, which is the management of

17 those soils, demolition of the structures and

18 storage of that debris in interim until OU3 comes

19 up with a final decision for the debris.

20 OU5 will have a final decision on how

21 the soils will be treated, and those all integrate

22 very well. When we start that remediation process,

23 when we have those soils excavated and stored, at

24 that time Oparable Unit 3 and 5 Records of

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Commentor A (Cont.)

1 Decisions will be in place, and we'll have very

2 good integration.

3 At that point we'll be able to

4 deliver — Theoretically, we'll be able to take the

5 soils out and take those to a Operable Unit 5

6 facility for treatment. They'll be disposed of in

7 accordance with their Record of Decision, and that

8 may or may not be on-site disposal.

9 MS. NUNGESTER: Okay. You're

10 saying, you're taking the debris, the structure,

11 the eguipment, the surface soil, you're putting

12 them all in the underground vaults?

13 MR. NIXON: Oparable Unit 4 is

14 delaying that decision. That's going to be

15 actually be stored in an interim fashion --

16 MS. NUNGESTER: Okay

17 MR. NIXON: — until OU5 and OU3

18 have records of decision. Now, their Record of

19 Decision may very well be that we will treat soil

20 by washing it and disposing of that on site.

21 MS. NUNGESTER: Right, but it

22 doesn't say that, that it's going to be interim

23 until Unit 5 is considered.

24 MR. NIXON: The proposed plan does

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Commentor A (Cont.)

1 clearly state, as well as the Record of Decision

2 will clearly state those, that integration.

3 MS. NUNGESTER: It does?

4 MR. NIXON: Yes, it does.

5 MS. NUNGESTER: Okay. Well, I know

6 on the proposed plan booklet on page 43 talks about

7 that specific issue.

8 MR. NIXON: Right.

9 MS. NUNGESTER: If anybody has that

10 book, and they want to look at it, they can, but I

11 don't believe it says -- It says something about

12 that it will be combined with 5, Unit 5, but it

13 does not say that would be interim disposal until

14 5.

15 MR. NIXON: Disposal, it is interim

16 storage.

17 MS. NUNGESTER: Or storage, but they

18 use "disposal" as the word throughout the whole --

19 MR. NIXON: In the proposed plan,

20 the proposed plan has, for Subunit C waste, it has

21 a selected or preferred alternative which is

22 on-site disposal identified and the reason that's

23 in there is because on-site and off-site disposal

24 was so close we had to select the one for the sake

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Commentor A (Cont.)

1 evaluating the full alternative from start to

2 finish. Okay.

3 Later in the document it talks about

4 the integration effort that will occur with OU3 and

5 OU5, and puts -- holds that decision in abeyance

6 for final disposal of those debris and soil until

7 OU3 and OU5 have their Records of Decision.

8 MR. ALLEN: The confusion could be

9 the fact sheet on page 12 states that the soil

10 debris will be disposed of on site.

11 MR. NIXON: There is an error in the

12 fact sheet on page 12, the last paragraph I

13 believe.

14 MS. NUNGESTER: Then, this shows

15 more of a reason why the public should have a

16 comment period before -- after — in between the

17 ROD's and even during the remedial, the RA, then,

18 to underatand it. Thank you.

19 MR. STEGNER: Other questions?

20 UNIDENTIFIED SPEAKER: I have one,

21 and it goes to back to when you were talking about,

22 Randi about, the community and stake holders or

23 public or whatever we're called these days, plays a

24 part in this process. I'll echo what Edwa just

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Commentor A (Cont.)

1 MR. STEGNER: Is Lee Bolver still

2 here?

3 UNIDENTIFIED SPEAKER: He left.

4 MR. STEGNER: Bob, do you have

5 something to say?

6 UNIDENTIFIED SPEAKER: I'll turn it

7 in later.

8 MR. STEGNER: Bob Gessel — Godsel,

9 I'm sorry? Going very well so far. Tom Wagner,

10 Citizens Task Force? Okay. We have an open mike,

11 folks, if anyone wants to make a comment.

12 MS. NUNGESTER: You want my address,

13 too?

14 MR. STEGNER: Not necesaary, as long

15 as we have your name.

16 MS. NUNGESTER: Norma Nungester,

17 Fernald resident and Fresh group. I have several

18 comments. First of all, I want to cover again what

19 was stated in the guestion and answer period. I

20 think between the draft ROD and the final ROD we

21 need a public comment official time, and you need

22 to formalize this. On down here below you say the

23 public involvement, public involvement, that means

24 nothing to us. You need to formalize that.

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Commentor A (Cont.)

1 And you also need more details on

2 your RD/RA work plan. We want to know more details

3 on transportation. We want to be notified when

4 you're transporting this stuff and talk about the

5 materials that are actually in the K-65 when

6 they're vitrified and when you start to ship them

7 out to Nevada.

8 Also this stuff that stays on site,

9 I'd like to know how they will be monitored, and

10 for how long of a period they're going to be

11 monitored. I guess I just want to express that we

12 want a guarantee that real-time monitoring will be

13 used.

14 Also a suggestion, how about covering

15 those silos when you start working on them? I

16 think this is one of the most important things you

17 could do for the community. I think that's about

18 it. I'm trying to read my notes that are chicken

19 scratch here.

20 Oh, one more thing. I'd like to be

21 diligent on referring large guantities of waste

22 from other sites. We don't want anything brought

23 in here from other plants to vitrify with our

24 material or to be put under the storage areas.

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Commentor B

Vicky Dastillung: (Formal oral, documented by Johnny Reising, DOE, March 4, 1994)

What capabilities do we have to do "real-time monitoring?"

Who has the authority to "shut down" the operation if the "monitoring" levels are high?

FRESH wants more public input on the RD/RA process (real "nitty gritty" of how things will be done).

How has NEPA been addressed? Where and how do we bring this out in the document (Proposed Plan)?

Vicky does not believe the last bullet on page 12 of the Proposed Plan fact sheet is correct. (Her point is
that we cannot pre-suppose that on-property disposal will be the result; it must be evaluated with Operable
Units 3 and 5.)
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Commentor C

Lou Bogar: (Formal oral, March 21, 1994)

1 unit, then.

2 UNIDENTIFIED SPEAKER: Okay. I'll

3 discuss it with you.

4 UNIDENTIFIED SPEAKER: I'm Lou

5 Bogart. I'm a resident of Ross. I have some

6 technical guestions. In looking at data tables for

7 Operable Unit 4, one of the things that strikes me

8 is that you always report uranium 254/236. Does

9 that mean there's U-236 there? If so, I don't

10 believe it because U-236 doesn't exist in nature.

11 Secondly, the ratio of U-234 to U-238

12 in many cases look very odd, odd in the sense that

13 in nature and in this ore and in the raffinate the

14 234, 238 ratio ought to be very close to unit. For

15 example, when in the table that you've given a

16 handout, the Silo 1 number looks pretty wrong. The

17 Silo 2 number is more acceptable.

18 And the reason I think that's

19 important is because you're going to focus the

20 clean-up levels on U-238. I don't guite know how

21 you're going to do that without doing some very

22 sophisticated isotopic analysis. But in any case

23 those numbers don't look right, and you see that in

24 many, many tables.

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Commentor C (Cont.)

1 On the inorganic chemicals, is there

2 somewhere in all the OU4 documentation a list of

3 all of the inorganic constituents? For example, I

4 note that in most of the recent documents you don't

5 list gold. Now you can. There is about, about

6 four times as much gold in this material as

7 silver.

8 Just as a side light for my own

9 amusement, I calculated this afternoon. There's

10 about $2.3 million worth of gold in those two

11 silos, and that may not be important, but what

12 other elements are not reported which may have some

13 impact on the processing of the material by

14 vitritication?

15 For example, there should be a fair

16 burden of rare earths, the whole lamprophyllite

17 series should be in these ores, and I don't see any

18 of that being reported. Anybody have an answer for

19 that one?

20 MR. NIXON: Well, you had about five

21 guestions, so I'll start in the beginning. One was

22 235 to 236, those are analysed and reported the

23 same. You are correct. We don't feel there is any

24 uranium-236 in the residues. It's a good point.

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Commentor C (Cont.)

1 Whether the ratio between U-234 and U-238 is

2 correct, I do not have the answer to that, but we

3 can discuss that and get back with you within the

4 next couple of days.

5 MR. BOGART: How about a complete

6 list of —

7 MR. NIXON: Complete list the

8 remedial investigation did do a complete list of

9 the organics, inorganics. Whether gold was

10 evaluated, I'm not sure. I'm looking at my team.

11 MR. BOGART: You were supplied gold

12 by TLCP.

13 MR. NIXON: But we also do a full

14 HSL, Hazardous Substance List, which gold would not

15 be part of. So I'n not sure whether gold was

16 particularly reported in the RI.

17 MR. BOGART: How about rare earths?

18 MR. NIXON: I couldn't answer that,

19 either. We've got a copy of the remedial

20 investigation here. whether these fellows can

21 guickly find answers to those guestions or again we

22 can get back with you.

23 Amy Engler I know is sitting out here

24 somewhere taking very good notes, and we'll respond

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Commentor C (Cont.)

1 to any of the questions which we don't have answers

2 to tonight. We've committed to have answers back

3 within 48 hours from this evening.

4 MR. BOGART: Well, I — not so much

5 for myself, but I think for the general public.

6 MR. NIXON: Any question that is

7 raised even in the informal conference will be

8 addressed in the responsiveness.

9 UNIDENTIFIED SPEAKER: Can we use

10 that gold as collateral, can we use that? You said

11 there'a like $2 million worth of gold. Can we use

12 that as collateral somehow?

13 MR. BOGART: It's going to cost 90

14 million bucks, maybe we can make it 88 million

15 bucks. On page 21 or whatever this thing is

16 called, the proposed plan, the spiral-bound thing,

17 on page 12 about the middle of the page is an

18 initiation of a discussion about risk.

19 And this is the area that conecrns me

20 the greatest, because although you point out

21 that -- And I presume in all cases you're talking

22 about fatal cancers because there are, of course,

23 nonfatal cancers also. And that's not terribly

24 clear in anything that's written.

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Commentor C (Cont.)

1 Risk from exposure, the radiation

2 naturally occurring in the environment is about 1

3 in 100 primarily from radon; however, incremental

4 risks targeted by the upper end of EPA range means

5 if all persons within a population of 10,000, 1

6 person might get cancer from the exposure, and

7 cancer is expected from all other causes. I think

8 the whole business of risk assessment needs to be

9 put into some kind of context.

10 If you look at the latest NCRP

11 guidance, 115 and I guess 116, you can talk about

12 risk in terms of about 4 or 5 times 10 to the minus

13 10 and you do the hocus-pocus chemists like to do.

14 And that turns out the average resident from

15 natural radon, that risk becomes about one half

16 times 10 to the minus 2 and the range is 0 to 90

17 years old. And when 90 years old, I guess cancer

18 is the last thing I'm going to worry about.

19 But in any event, you make the

20 statement that the normal cancer risk is about 10

21 to the minus 2, and then you proceed to march down

22 the road of things that are 2 to 4 to 5 orders of

23 magnitude smaller, and it's never put in context.

24 And I think these documents need to discuss what

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Commentor C (Cont.)

1 are we paying for, and that becomes a real

2 problem. I don't know how many people feel

3 comfortable with a 10 to the minus 6 risk, and I'm

4 not real sure that that's a fatal cancer risk.

5 There is a problem with the

6 methodology of using the health effect summary

7 table slope factor thing as opposed to methodology

8 that's used by people who do the beer studies and

9 the NCRP studies because we're talking about vast

10 orders of magnitude differences.

11 Now, the last comment I guess, I'd

12 like to see something in these documents that more

13 clearly explains why the CERCLA process has elected

14 to use such abominably small risk estimates.

15 My last comment perhaps goes to EPA

16 back in 1986, was a bad year for me, EPA published

17 a notice of intent that they were going to

18 promulgate residual regulation standards. It is

19 now 1994, and, to the best of my knowledge,

20 residual radiation level standards have not been

21 promulgated.

22 In 1993 in a GAO report to Congress

23 somebody in EPA said that in March of 1994 they

24 were going to finally publish residual radiation

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Commentor C (Cont.)

1 standards, not publish them, but they would take

2 them to OMB, which would be the fist step in

3 getting them published -- well, not the first step,

4 but a key step in getting them published in the

5 Federal Register.

6 March 1994 is now. My concern is, is

7 there one part of EPA working on residual radiation

8 level standards which may very well impact on the

9 clean-up levels that are being talked about here

10 for the clean-up of OU4?

11 MR. NIXON: Was there any response?

12 MR. SARCA: Yeah, I can answer that

13 from my understanding. One of the people involved

14 from the EPA perspective that works with me, he's

15 been commenting that he's involved in working on

16 some of those standards. Will they directly impact

17 this investigation, I don't know. I don't think

18 so. Hearing some of the numbers, I think they may

19 even be moving towards the side of being egually as

20 conservative, could be more conservative.

21 I don't know what the final will come

22 out with. When they do come out of the numbers,

23 they'll go to budget and move forward from there.

24 I do know that they are being worked on. One of

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Commentor C (Cont.)

1 the people from my office is doing that right now.

2 I don't know the exact state.

3 UNIDENTIFIED SPEAKER: If memory

4 serves, I think that the gold Lou was talking about

5 was contained in the pitch blend or whatever it was

6 that came over from Africa that the Unitad States

7 bought and dumped into the X-65 silos. I heard or

8 read that somewhere. You might want to check that

9 out.

10 MR. NIXON: It is in the X-65

11 materiel, yes.

12 MR. BOGART: It all came from one

13 mine.

14 UNIDENTIFED SPEAKER: The reason

15 they took that pitch was they wanted to strike

16 gold?

17 MR. BOGART: No, radium and gold.

18 UNIDENTIFIED SPEAKER: Aa far as I'm

19 concerned, it can be vitrified.

20 MR. BOGART: The guestion was, what

21 else is there?

22 UNIDENTIFIED SPEAKER: Okay. I just

23 have another guestion. When you said they were

24 filling the silos, especially 1 and 2, did they

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Commentor D

Edwa Yocum: (Formal oral, March 21, 1994)

1 concentrate, due that reduction, is the radon

2 generation from the treated waste itself that is

3 significantly reduce. The radon is actually held

4 up, and the surface area is significantly reduced.

5 Did you get every other word?

6 You're exactly right, that due to

7 that fact that there's a significant volume

8 reduction, you actually concentrate the

9 radionuclides , so you have a higher concentration

10 of say uranium in a set volume, but the radon

11 itself is much less. The generation or the

12 emanation from the vitrified wast is such less

13 than in its natural form.

14 MS. NUNGESER: Okay, thank you.

15 MS. YOCUM: Edwa Yocum, Fresh member

16 and a resident of the Fernald area. I was asking a

17 guestion, that concerns Subunit C2 on your

18 preferred alternative demolition removal on

19 property disposal. When you were talking about the

20 OU4 NEPA compliance with the substantive cumulative

21 impact up to 250 acres of surface disturbance, does

22 that mean that would be what would be part of where

23 the waste will be put?

24 MR. WOODS: Yeah. Again, we looked

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Commentor D (Cont.)
1 at an LRA and assumed on-site disposal.

2 MS. YOCUM: Okay.

3 MR. WOODS: And that acreage would

4 incur areas where waste would be disposed of.

5 MS. YOCUM: Okay. Then, you also

6 are talking about the loss of 220 acres of

7 habitat. Is that included in the 250 acres?

8 MR. WOODS: Yeah. That 250 would be

9 a total that would occur during the short term, in

10 other words, during excavation activities. Once

11 remediation is completed, we would look at

12 approximately 220 acres being permanently

13 committed, so yes, that's correct.

14 MS. YOCUM: Okay, all right, that'a

15 what I wanted to know.

16 MS. NUNGESTER: Can you expand on

17 that permanently committed? I missed something.

18 Permanently committed for what, waste disposal

19 facility?

20 MR. WOODS: Yeah, correct.

21 MS. NUNGESTER: Not for the waste

22 itself but for the —

33 MR. WOODS: For the facilities that

24 would house the waste.

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Commentor D (Cont.)

1 Thank you.

2 MR. STEGNER: Thank you, Norma.

3 Edwa?

4 MS. YOCUM: Edwa Yocum. Some of

5 this will sound repetitious, but I'm asking for a

6 public comment period between the ROD's, the draft

7 and final; and we need an official pubilc comment

8 period after the RA process. And also I'm asking

9 for a pubilc comment period between the beginning

10 and completion of remediation. And then, too, when

11 dismantling the K-65 silos and also the 3 and 4,

12 I'd like to have a protective cover be used around

13 tho silos.

14 And as far as I read in there, that

15 EPA would be reviewing the vault or the disposal

16 sites every five years, I'd like to know the

17 definition of "reviewing," and I would like

18 continuous monitoring and maintenance of on-site

19 disposal vaults or at lesat one time a year as long

20 as they're on site. And also, who would be paying

21 for this monitoring and maintenance? And this way

22 I recomment a trust fund for monitoring and

23 maintenance of the disposals.

24 MR. STEGNER: Thank you, Edwa. Open

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BOB MILLER STATE OF NEVADA JOHN P. COMEAUX
Governor Director

Commentor E
DEPARTMENT OF ADMINISTRATION
Capitol Complex
Carson city, Nevada 89710
FAX (702) 687-3982
(702) 687-4065

April 18, 1994

Mr. Ken Morgan
Public Information Director
ATTN: FS/PP-DEIS Comments
Fernald Field Office
U.S. Department of Energy
Post Office Box 398705
Cincinnati, Ohio 45239-8705

RE: Fernald Environmental Impact Statement, Operable Unit 4 Fernald, Ohio

Dear Mr. Morgan:

Thank you for providing the State of Nevada the opportunity to review the Department of Energy's Feasibility
Study/Proposed Plan Draft Environmental Impact Statement (EIS) for Remedial Action at Operable Unit (OU) 4 of
the Fernald Environmental Management Project (FEMP). As you know, the draft EIS assesses the potential
environmental impacts of removing and treating silo materials and surrounding environmental media at DOE's
Fernald plant in Ohio and sending these treated materials to the Nevada Test Site (NTS) for final disposal.
Following are the state's comments on this proposal.

As we understand the proposed action, DOE is taking the position that the thorium mill tailing waste, which
is admitted to be mixed waste, is not subject to Environmental Protection Agency (EPA) or State of Nevada
regulatory control. For the reasons specified below, we believe this position is not correct.
Commentor E
In 1987 DOE promulgated regulations (10 CFR 962.1) stating that RCRA hazardous waste, mixed
with byproduct material falling under the category defined in the Atomic Energy Act (42 USC
2014 (e) (1), would be subject to regulation (i.e. the hazardous components of the mixed
waste) by EPA and EPA-delegated States. However, the byproduct material falling under the
category given in 42 USC 2014 (e) (2) that was mixed with RCRA hazardous waste, while
constituting a mixed waste, would not be subject to regulations by EPA or EPA-delegated States.
We note promulgation of these regulations and associated restrictions were carried out prior to
the passage of the Federal Facility Compliance Act of 1992 (FFCAct).

As you know, under the FFCAct, congress defined mixed waste to mean "waste that contains both
hazardous waste and source, special nuclear, or by-product material subject to the Atomic
Energy ACT of 1954." This definition shows no destinction between the two categories of
byproduct material mentioned above. Hence, the attempted exemption from hazardous waste
regulations of the hazardous components of mixed waste containing byproduct material from
EPA/State regulatory control, has been invalidated.

We also note that EPA has delegated to the states regulatory control over all mixed wastes
without regard to specific radionuclide content, which is consistent with the expression of
Congressional intent in defining mixed waste under the FFCAct (See 51 FR, July 3, 1986,
-------
24504-24505) .

Based on these points, it is the State of Nevada's position that the regulatory issues described in the above
mentioned Draft EIS have not been adequately addressed.

We also note that the cost estimates of long-term storage/disposal of mixed waste at the NTS were not
properly accounted for in the Draft EIS. The assumptions, for example, under which storage/disposal of mixed
waste at the NTS could be considered "free" when compared to a commerical facility, were not presented in the
document.

Commentor E

In a related matter, we are still waiting for a response concerning our request for an extension of the
comment period for the subject Draft EIS. As you may recall, we recently requested the extension to
facilitate stakeholder involvement activities in southern Nevada.

Thank you for the opportunity to comment on the above mentioned Draft EIS.

Sincerely,

Maud Naroll
State Clearinghouse

MN/jbw
cc: Governors Office
Affected State Agencies
Nevada Congressional Delagation
Carol M. Borgstrom DOEHQ/NEPA
Joseph Flore, DOE/NV
Donald R. Elle, DOE/NV

Commentor F

COMMENT SHEET

DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility
Study/Proposed Plan-Draft Environmental Impact Statement for Remedial Action at Operable Unit 4. Please use
the space provided below to write your comments, then fold, staple or tape, and mail this form. We must
receive your comments on or before the close of the public comment period on April 20, 1994. If you have
questions about the comment period, please contact Ken Morgan, the DOE Public Information Officer at Fernald,
at (513) 648-3131.

Due to its proximity to the Great Miami River, this land is part of the migratory flyway. Ducks, geese and
other migratory birds fly over this area or use it as their residence many months of the year.

Presently, technology exists in landfill management using rubber (neoprene) liners to minimize water
seepage. This technology could be incorporated into the Fernald area to create ponds and wetlands.
Controlled water levels in ponds, reservoirs and wetlands could be regulated by the pumps and wells that are
now in place and being used in the aquifer clean-up.

Hazardous waste should be taken out by rail since the tracks are in place. Handling this waste by
transporting it by truck is much more dangerous.

I would discourage industrial development or development that would attract large concentrations of humans in
case problems would happen to develop in the future. We cannot afford to have another Love Canal. Our area
has had its fair share of negative press and peace of mind and good health is our wish for all.
-------
Name:

Address:

City/State/Zip:

Phone:

MAILING LIST ADDITION:

Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at
the Fernald Environmental Management Project:

YES NO
Commentator G

COMMENT SHEET

DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility
Study/Proposed Plan-Draft Environmental Impact Statement for Remedial Action at Operable Unit 4. Please use
the space provided below to write your comments, then fold, staple or tape, and mail this form. We must
receive your comments on or before the close of the public comment period on April 20, 1994. If you have
guestions about the comment period, please contact Ken Morgan, the DOE Public Information Officer at Fernald,
at (513) 648-3131.

Name:

Address:

City/State/Zip:

Phone:

MAILING LIST ADDITIONS:

Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at
the Fernald Environmental Management Project:

YES NO
3686 Cincinnati-Brookville Road
Hamilton, Ohio 45013
Commentor H
March 25, 1994

Mr. Ken Morgan
Director, Public Information
U.S. Department of Energy Field Office
P. 0. Box 398705
Cincinnati, Ohio 45239-8705

SUBJECT: PUBLIC COMMENTS ON PROPOSED PLAN FOR REMEDIAL ACTION OPERABLE UNIT 4 FEMP SILOS 1,2 AND 3
CONCERNING PREVENTION OF OFFSITE MIGRATION OF AIR POLLUTION AND NOISE
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Dear Mr. Morgan:

In order to prevent offsite contamination with respirable airborne cancer producing toxic gases, vapors,
fumes and particulate matter from Remedial Actions at Operable Unit 4, it is suggested that at a minimum the
following recommendations be adhered to regardless of which cleanup alternative is selected:

1. Construction of a fail safe containment facility maintained at negative air pressure (similar to a glove
box) to house all vitrification, bulk reduction and/or cement stabilization eguipment and associated HEPA
filters, scrubbers, and gas treatment, etc. as well as all packaging operations.

2. Use of real time alarm system with backup must be used to detect failure of eguipment including each and
every filter and scrubber unit. Air returned to the environment must be cleaned.

3. Use of real time alarm system with backup to detect any toxic chemical contaminated air leaking into the
total containment facility from malfunctioning eguipment and packaging operations. Contaiminated air must be
cleaned before being released into the environment. Dilution of highly toxic chemicals into the environment
can not be tolerated as a solution.

4. All alarm systems must be checked and calibrated daily and back up alarm systems in place and operative
at all times. Preventive maintenance of all eguipment must be done at reguired scheduled intervals and
checked by management.

5. To properly oversee the vitrification, bulk reduction, cement stabilization and packaging remediation
operations, a member of management from Fluor Daniel, D.O.E. and US EPA must all be present at all times to
guickly resolve any problems that are certain to come up, and to make certain that established safety
procedures are followed to the letter.

6. Should contaminated air be detected entering the environment from whatever source, a complete shut down
of the offending operation would be in order until corrected and Fernald neighbors be immediately notified
through site perimeter public address speakers and news media.

Commentor H

7. Toxic chemicals or mixed toxic waste by any other name must not be brought into the Fernald Site to
further contaminate it from anywhere else for any purpose whatsoever be it for testing, pilot runs, temporary
or permanent storage, decontamination vitrification, bulk reduction or cement stabilization, etc.

8. State-of-the-art engineering noise controls should be incorporated in the design of facilities and
eguipment used so that no noise from remedial actions is heard downwind offsite. Noise resulting from the
release of high pressure air or steam into the atmosphere must be attenuated through appropriate engineering
controls.

9. Shipment of toxic wastes should be made to Nevada Test Site as soon as possible. Temporary storage of
safely encapsulated toxic waste, contaminated soil and debris should be south of the production area as far
from the heavily traveled Route 126 (Cincinnati-Brookville Road) as is feasible.

Please include the above as part of the formal Public Comment for Remediation of Operable Unit 4 FEMP Silos
1, 2 and 3.

Thank you for your help.

Sincerely,

J. E. Walther

Ohio Historic Preservation Office
-------
Ohio Historacal Center
1982 Velma Avenue
Columbus, Ohio 43211-2497 Commentor I
614/297-2470
Fax: 297-2546

OHIO
HISTORICAL
SOCIETY
March 24, 1994 SINCE 1885

Mr. Ken Morgan
Public Information Director
ATTN: ES/PP-DEIS Comments
Fernald Field Office
U.S. Department of Energy
Post Office Box 398705
Cincinnati, OH 45239-8705

Re: Fernald Environmental Management Plan Butler and Hamilton Counties, Ohio

Dear Mr. Morgan

This is in response to correspondence from Carol M. Borgstrom of the Department of Energy dated February 24,
1994 (received March 1) regarding the above referenced project (a copy of the correspondence was also
submitted through the State Clearinghouse and received March 7, 1994). The comments of the Ohio Historic
Preservation Office (OHPO) are submitted in accordance with provisions of the National Historic Preservation
Act of 1966, as amended (16 U.S.C. 470 [36 CFR 800]); the U.S. Department of Energy serves as the lead
federal agency. My staff has reviewed this project and I offer the following comments.

OHPO has two areas of concern for the proposed clean-up at the Fernald facility. This particular part of the
clean up involves proposed demolition of storage silos in Operable Unit 4. Additional actions are under
consideration for several other operable units in the waste storage area. The first area of concern is the
potential for impacts to archaeological sites. The Fernald facility is located in an archaeologically
sensitive area and several archaeological studies have been completed for other actions related to the
clean-up in and around the Fernald facility. Until a programmatic agreement has been developed, each project
will reguire coordination with this office for archaeological resources. Coordination is anticipated
regarding the proposed demolition of the silos providing us sufficient information to make a recommendation
for archaeological investigations. At this time we have not determined that any archaeological work is
needed for any of the proposed or future actions in the waste storage area. The coordination should provide
detailed mapping, descriptions of the soils (to determine if any areas within the project area are relatively
undisturbed), descriptions of the proposed actions including ancillary work areas and any temporary storage
areas, and photographs of the facilities.

Mr. Ken Morgan
March 24, 1994 Commentor I
Page 2

The second area of concern relates to the Fernald facility as an integrated series of architectural
sturctures and facilities. It is our position under guidelines provided by the Advisory Council on Historic
Preservation, the National Council of State Historic Preservation Officers, and the Department of Defense,
that the Fernald Facility is eligible for inclusion in the National Register of Historic Places. It is our
position that the facility includes all of the structures and facilities within the 1000 plus acre tract.
The Fernald facility is eligible because of the important role it played in support of United States defense
programs during the Cold War, thus, the facility is a significant part of one of the most important aspects
of our history.
-------
The proposed demolition of the silos, or any other structure or facility, could have an adverse effect on the
Fernald facility. Coordination with this office is required prior to the implementation of any plan or
action resulting in demolition or changes to any structure or facility. OHPO recommends the development of a
programmatic agreement to address historic preservation concerns. Once we have established the context for
the Fernald facility and the limits of the contributing structures and facilities, then specific
recommendations can be made regarding proposed actions such as the proposed demolition of the silos. In the
interim, it is our recommendation that the silos should be regarded as contributing structures and we should
proceed under the assumption that the proposed demolition will have an adverse effect on a district eligible
for inclusion in the National Register of Historic Places. Coordination with this office is recommended to
begin preparing the necessary documentation for this action.

In summary, OHPO recommends changes to the Draft Environmental Impact Statement to include coordination with
this office under provisions of the National Historic Preservation Act.

Any questions concerning this matter should be addressed to David Snyder or Julie Quinlan at (614)297-2470,
between the hours of 8 am to 5 pm. Thank you for your cooperation.

Sincerely,

Martha J. Raymond, Department Head
Technical and Review Services

MJR/DMS:ds

xc: Carol M. Borgstrom, Department of Energy
State Clearinghouse (OH940225-X763-36.471)

Commentor J

April 17, 1994

TO: Ken Morgan, Public Relations, U.S. DOE, FEMP

FROM: Lisa Crawford, President. F.R.E.S.H., INC.

SUBJECT: O.U. 4 Comments on Proposed Plan

Listed below are my comments on the O.U. 4 Proposed Plan:

1.) DOE should include and or develop real-time monitoring for discharges to the environment resulting from
remedial actions.

2.) Information obtained from real-time monitoring and any other monitoring activities should be provided to
the public.

3.) DOE should incorporate pollution prevention activities whenever possible during the design and operation
of the OU 4 remedial action system.

4.) DOE must make certain that the public has involvement and it will continue during the RD/RA. DOE must
commit to continued public involvement during this period.

5.) DOE must revise the site community ralations plan to meet the need for continued public involvement
during the RD/RA.

6.) DOE must and will keep the public abreast of all decisions and any changes that occur during this
period.
-------
If you have questions, plesse feel free to contact me. Thank you.

LC:eac

cc: files

Commentor K

3944 Silax Dr.
Hamilton, OH 45013
April 20, 1994

Mr. K. L. Morgan
Public Information Officer
DOE Field Office, Fernald
U. S. Departmant of Energy
P. 0. Box 398705
Cincinnati, Ohio 45239-8705

After reviewing the Proposed Plan for Remedial Actions at Operable Unit 4 at Fernald, I would like to voice
to you some of my concerns as a resident who lives downwind of the proposed activity.

I would like to know if there have been any air pollution models run which show the distribution of the
contamination that will be caused as a result of these activities. Not screening types models, but
specifically comprehensive models which take into consideration terrain, windspeed, weather conditions,
mixing height and the deposition patterns.

My major concern is the emission of radium (not radon) in the exhaust gases and fugitive gases from the
proposed vitrification facility.

One of the important considerations for risk based calculations is that Elda Elementary School, the Ross
Middle School, and the Ross Senior High School are all in the direction of the prevailing wind pattern. I
would like to recommend that comprehensive air pollution modeling be done on the facility's impact to the
area's air quality. I would like to see the vitrification unit's risk from fugitive and exhaust emissions
quantified. I would like to see how the vitrification unit will impact the site's overall risk to the
community. Lastly, I would like to see the impact that this will have on the site's radionuclide air
emissions specifically with respect to radium emissions into the air.

I make these comments in good faith, and trust they will be received as a good faith effort to improve the
implementation of the proposed action, and that no effort will be make by any party to affect my employment
at the FEMP.

Respectfully yours,

Lawrence L. Stebbins

BOB MILLER STATE OF NEVADA
Governor

Commentor L
DEPARTMENT OF ADMINISTRATION
Capitol Complex
Carson city, Nevada 89710
FAX (702) 687-3982
(702) 687-4065
-------
April 5, 1994

Mr. Ken Morgan
Public Information Director
ATTN: FS/PP-DEIS Comments
Fernald Field Office
U.S. Department of Energy
P.O. Box 398705
Cincinnati, Ohio 45239-8705

RE: Fernald Environmental Impact Statement, Operable Unit 4 Fernald, Ohio

Dear Mr. Morgan:

Thank you for providing the State of Neveda the opportunity to review the Department of Energy's Feasibility
Study/Proposed Plan Draft Environmental Impact Statement (EIS) for Remedial Action at Operable Unit (OU) 4 of
the Fernald Environmental Management Project (FEMP). As you know, this "Draft EIS" assesses alternatives for
the removal, treatment, and disposal of radioactive material at DOE's Fernald site near Cincinnati, Ohio.

The proposed action analyzed in the Draft EIS is to assess the potential environmental impacts of DOE's
preferred alternative, which is to remove silo material and surrounding environmental media, stabilize the
product through vitrification, and sent the treated material to the Nevada Test Site (NTS) for final
disposal. According to information provided to officials from DOE's Nevada Operations Office (DOE/NV), if
the proposed action is implemented, over 300,000 cubic yards of radioactive waste would be disposed of at
NTS. Disposal activities would cover a period of approximately thirty years.

Commentor L

As you know, comments on the Draft EIS are due on April 20, 1994. However, for the reason discussed below,
we believe the comment due date should be extended to facilitate a more comprehensive stakeholder involvement
process for the citizens of Nevada.
Recently, a group of concerned Nevadans, affected Indian Tribes, and local government officials along with
officials from the State and DOE jointly participated in the establishment of a Site Specific Advisory Board
for DOE/NV's Environmental Restoration and Waste Management Program at the NTS. The group is officially
titled The Citizens Advisory Board for NTS Programs (CAB). This new CAB for NTS programs held its first
organizational meeting on March 8th, 1994.

Because the CAB will likely play a key role in advising DOE/NV about stakeholder concerns involving major
program decisions such as those proposed in the above mentioned document, we believe it is of paramount
importance that the CAB be given the opportunity to discuss the possibility of reguesting a briefing on the
proposed action and alternatives discussed in the Draft EIS.

You might recall that such a briefing was provided by DOE officials and contractors from FEMP to officials
from DOE/NV and the State of Nevada. Granting our reguest for an extended comments period of at least 60
days would allow the CAB to address this issue at its next meeting, which is scheduled for April 20, 1994.

We await your prompt decision concerning this reguest.

Sincerely,

Maud Naroll
State Clearinghouse
MN/jtw
Members, Citizene Advisory Board NTS Programs
Governors Office and Affected State Agencies
-------
Nevada Congressional Delegation
Carol M. Borgstrom DOEHQ\NEPA
Nick C. Aguilina, DOE/NV
Joseph Flore, DOE/NV
Donald R. Elle, DOE/NV

Commentor M

U.S. Department of Transportation

Research and Special Programs Administration

Apr 21 1994

Mr. Ken Morgan
Public Information Director
ATTN: FS/PP-DEIS Comments
Fernald Field Office
U.S. Department of Energy
P.O. Box 398705
Cincinnati, OH 45239-0705

Dear Mr. Morgan:

This letter is in response to the February 24, 1994 letter from Ms. Carol M. Borgstrom, Director, Office of
NEPA Oversight, Department of Energy to Ms. Kathleen C. DeMeter, Assistant Chief Council, National Highway
Traffic Safety Administration, Department of Transportation (DOT). Ms. DeMeter forwarded that letter to the
Research and Special Programs Administration (RSPA) , the Federal agency primarily responsible for hazardous
materials transportation regulations. That letter solicited review and comments on the Feasibility Study
(FS), the Proposed Plan (PP), and the Draft Environmental Impact Statement (DEIS) documents for remediation
of Operable Unit 4 of the Fernald Environmental Management Project (FEMP). Our review has focused on
elements associated with the transportation of radioactive materials resulting from the remediation
activities.

The reviewed documents are clearly of a general nature at this early phase of the program, and do not reflect
all details such as radioassay methods, materials classification, and packaging reguired for compliance with
the transportation regulations. There were no statements about any expected need for exemptions from the
reguirements of DOT regulations which are authorized under Title 49, Code of Federal Regulations (CFR), Part
107, rather, it is stated that all shipments will be made in full compliance with DOT regulations.

In the development of future documentation for the FEMP, it is suggested that technical attention be given to
two minor concerns we saw in the FS/DEIS. First, in Volume One, Section 2.5.7.1, Page 2-78, it was stated
that all materials transported would meet the definition of Low Specific Activity (LSA) radioactive materials
as defined in 49 CFR 173.403(n). We believe the expected physical form of the material transported will
result in the radiological risk to the public being egual to or less than most LSA shipments transported in
the country. However, from Volume Two, Appendix A, Table A. 1-1, it appears that the activity per gram of
material for some of the package contents might exceed the limits for LSA materials in 49 CFR 173.403(n).
The second concern is somewhat related to the activity per gram issue. In Volume One, Section 4.2.2, Page
4-25, it is noted that "sampling of the vitrified waste form would be limited to measurement of dose rate".
After material vitrification, the external radiation dose rates will clearly be the indications of the most
significant radiological hazards of the materials during transportation. However, since the identity of the
radionuclides and the activity of the content in each package is reguired by the regulations, documentation
with technical reasoning will be needed to relate the results of pre-vitrification radioassays to the
contents of the packages.
-------
From our limited review of the early phase planning documents, it appeared that there was not much
information about non-radioactive hazardous materials transportation compliance issues, or about hazardous
wastes subject to both DOT and Environmental Protection Agency regulations. Compliance with those
regulations should not be difficult, the radiological hazards appear to be the greatest concern.

Except for the two minor concerns mentioned above, the reviewed documents appear to be satisfactory with
respect to hazardous materials transportation.

Sincerely,

James K. O'Steen, Director
Office of Hazardous Materials Technology

cc: Carol M. Borgstrom

May 17, 1994

Mr. Ken Morgan
Director, Public Information
U.S. Department of Energy, Fernald Field Office P.O. Box 39705
Cincinnati, Ohio 45239-8705

SUBJECT: DOCUMENTS COMPRISING THE FINAL FEASIBILITY STUDY/PROPOSED PLAN - ENVIRONMENTAL IMPACT STATEMENT FOR
REMEDIAL ACTIONS AT OPERABLE UNIT 4, THE FERNALD ENVIRONMENTAL PROJECT (DOE/EIS-0195d)

Dear Mr. Morgan:

The Nevada Test Site (NTS) Citizens Advisory Board (CAB) had the opportunity to meet with representatives of
the Fernald Environmental Project at our May 11, 1994 meeting. The CAB is comprised of representatives from
the public, citizens groups, Native Americans, local governments and others. Fernald staff provided a useful
brief describing proposed shipments of radioactive material to the NTS. They and NTS Department of Energy
(DOE) personnel at the meeting noted, however, that the deadline for comments to the EIS is May 20, 1994.

The May 11, 1994 meeting was the first time that the CAB had an opportunity to receive any information about
the proposed shipments. The CAB has still not reviewed the documents. We would, therefore, have less than a
week to review the EIS. The CAB is, therefore, reguesting an extension of time to review the documents and
provide substantive input to the process.

The shipments of radioactive waste from Fernald are the first of potentially many other shipments to the NTS.
It is important, therefore, for the CAB to review the Fernald EIS proposal.

The CAB and citizens of Nevada trust that you will grant an extension of time for the review of the EIS
documents.

Sincerely,

William L. Vasconi, Acting Chairman
Citizens Advisory Board
m5 8 3.vi s

cc: James Sarit, Region V
Environmental Protection Agency

On June 24, 1994, the DOE received by facsimile transmission, the following four comments/issue statements on
the behalf of the Nevada Test Site Citizens Advisory Board (CAB), from an individual who identified herself
by telephone as Katherine Yuracko, a member of the CAB. As directed by Katherine Yuracko during the
telephone conversation, the facsimile was redacted by DOE to only include verbatim the substantive
-------
comments/issue statements pertinent to the Operable Unit 4 FS/PP-DEIS.

Issues

1. The shipments of waste from Fernald are the first of potentially many other shipments to the NTS. Rather
than making decisions on piecemeal basis, we went to see the full picture before we are asked to make
decisions on individual pieces. That is, we want to first consider the total impact of all of the waste that
is being considered for disposal at the NTS. Following that, we want to consider each individual piece.

2. The documents reviewed do not discuss the full range of possible alternatives. E.g.:
! disposal at Hanford
! reprocess to recover materials
! dispose of all material at the NTS

Why were these options rejected? What is the full list of options initially considered and why was each
option rejected?

3. We believe that:

! funds should be provided for technical oversight of waste management activities

! the State of Nevada and affected Counties are entitled to impact mitigation payments as
compensation for costs arising from management of this material

4. Based on the presence of RCRA regulated metals and organics in the waste, we are concerned that the waste
contains both hazardous and radioactive constituents.

a. Please list the radionuclide and inorganic and organic chemical constituents of the waste.

b. Please identify the concentration of each constituent.

c. Please identify the risk resulting from each constituent

d. Please describe how the proposal treatment and disposal mechanisms address both the radionuclide and
chemical constituents of the waste.

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

! The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

! Transportation risks need to be thoroughly evaluated.

! Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.

Name

Address

Keep Fernald Waste On-site in Ohio.. Comments on the Fernald Cleanup EIS.
-------
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name
-------

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among otherradio nuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

! Transportation risks need to be thoroughly evaluated.

! Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.

Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

! The more than 300,000 cubic yards of radioactive waste consisting of uranium,
-------
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name
-------
Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

-------
Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
-------
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consistinq of uranium,
thorium and radium amonq other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thorouqhly evaluated.
-------
Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address
-------
Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
-------
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
-------
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
-------
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
-------
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name
-------

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address
Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
-------
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
-------
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
-------
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
-------
Name

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

! Transportation risks need to be thoroughly evaluated.

! Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.

Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.
-------
Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

-------
Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
-------
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
-------
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
-------
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
-------
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

! Transportation risks need to be thoroughly evaluated.

! Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.

Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address
Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
-------
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
-------
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name
-------
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
-------
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adeguate to protect the local populace. Nevadans should not be
reguired to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name
-------

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

! Transportation risks need to be thoroughly evaluated.

! Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.

Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

-------
Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.
The more than 300,000 cubic yards of radioactive waste consisting of uranium,
thorium and radium among other radionuclides, should be kept on-site in
-------
containers adequate to protect the local populace. Nevadans should not be
required to accept additional risk on top of that already present at the Nevada
Test Site.

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thorouqhly evaluated.

Socioeconomic impacts on the receptor community should be thorouqhly evaluated
and balanced aqainst the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address

Transportation risks need to be thoroughly evaluated.

Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.
Name

Address
-------
Keep Fernald Waste On-site in Ohio..Comments on the Fernald Cleanup EIS.

! Transportation risks need to be thoroughly evaluated.

! Socioeconomic impacts on the receptor community should be thoroughly evaluated
and balanced against the desires of Ohio to move Fernald waste.

Name

Address

The following comments/issues were submitted by Pam Dunn, Harrison, Ohio. The Comments/issues were retyped
and alphabetically identified by DOE in order to facilitate developing comment responses. The original hand
written comments have also been included as matter for the record.

June 20, 1994
Mr. Ken Morgan
U.S. Dept. of Energy Fernald Field Office
P.O. Box 398705
Cincinnati, OH 45239-8705

RE: Comments Proposed Plan For Remedial Action OU4.

! (a) In reviewing the Proposed Plan for OU4 there are variances in the capital cost for the same
treatment alternatives with the only difference being on-site versus off-site disposal. What is the
source of this variance?

! (b) It is stated that EPA would review on-property disposal every five years in accordance with
CERCLA reguirements. Who and how often would a review be performed in the other years?

! (c) There is no mention of retri[e]vability of the materials which would be disposed of in the
on-site disposal vault. Is this option being considered, and, if not, why?

! (d) Post-remediation O&M cost are estimated over a thirty-year period. What about the remaining
years for which this material will reguire monitoring

! (e) Alternatives 2B and 4B have identical post-remediation cost, with Alternative 4B being untreated.
Please explain how cost can be the same for treated versus untreated materials disposed in an on-site
vault.

! (f) There is discussions on interim storage. What is the estimated time for this interim storage?

! (g) Alternative 2C states that the contaminated materials would be place in bulk (without packaging)
into the on-site disposal vault. Please expand on why this material would not be packaged and state
the advantages/disadvantages of packaged versus non-packaged.

! (h) It is stated that non-porous material will be released from the site as uncontaminated per DOE
Order 5400.5. Will this material be checked for contamination prior to release or just assumed to be
uncontaminated and released?

! (i) Will the wastewater generated during remediation be treated for non-radioactive contaminates
-------
prior to discharge in the Great Miami River? To what extent will radioactive and non-radioactive
elements be removed prior to discharge?

! (j) A material variance in the cost associated with Subunit C exist between 3C.1 and 3C.2 with the
only apparent difference being 3C.1 Disposal at NTS and 3C.2 at Envirocare in Utah. Please explain
this variance and if this is partially due to more stringent reguirements at NTS, should these more
stringant reguirements also be reguired at a commercial facility? Which reguirements is more
protective? It is also stated that an exemption from DOE Order 5820.2A (this is transposed as 5280.2A
in document, Page 56) is needed to dispose at a commercial facility; has this been granted?

! (k) Will notification of these shipments be given to the areas involved in the transportation routed
for rail and truck, and what precautions for protection will be employed?

! (1) Table 6-1 comparison of remedial alternatives, state differences in implementing identical
treatments with different disposal options. Is this difference related to transportation issues for
off-site rather than on-site? Please explain these differences. Also, Subunit C lists no treatment
for all alternatives; pleese demonstrate why no treatment is acceptable.

! (m) Is there potential for failure of the vitrified material has the radionuclides trap[p]ed continue
to delay, and if so, what is that risk?

! (n) It states that the capital cost associated with the on-site disposal facility has been removed.
Where is (will) this cost be accounted for?

! (o) Line 14, Page 67 reads results in significant reduction in the volume... This would read better
if the "a" preceded significant/rather than follow.

! (P) Please define the following statement (Line 16, Page 67) utilize permanent solutions to the
maximum extent practical. What viable, permanent solutions presently exist?

! (g) Basis for stating long-term environmental impacts of permanent disposal at NTS are minor and no
long-term impacts of biota expected from disposal activities at NTS. It is stated that to reduce
U-238 to essentially background is not feesible; it also states that it is assumed that the federal
government retain ownership of the FEMP site to consider clean-up protective. While I do not have a
problem with these statements, it does bother me that no formal statement has been made publicly
concerning this. These two statements present future land use constraints which must be-addressed.
Why hasn't the DOE adopted a formal position concerning this issue and communicated this to both the
Fernald Citizens Task Force and the community?

! (r) Line 13, Page 76, reads "... would bot be ...", should that read "... would not be ..."?

! (s) It states the on-site, above-grade disposal facility would be designed for a 1000 year life with
no active maintenance. What is the half-lives or duration for which the radionuclei and chemical
contaminants are a threat to the environment; do they exceed 1000 years? Also, explain why no active
maintenance is assumed for 1000 years.

! (t) Has an exemption to the Ohio Solid Waste Facility reguirement been reguested, and if not, when
will such a reguest be made? Also, Line 28, Page 79 would read better if "the" or "a" were added to
precede disposal. (For disposal facility on the FEMP site.)

Should you have any guestions concerning these comments, feel free to contact me at the address given below:

Submitted by
Pam Dunn
7781 New Haven Rd.
Harrison, Ohio 45030
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cc:
Mr. John Applegate
F.R.E.S.H., Inc.
File

OhioEPA
State of Ohio Environmental Protection Agency

Southwest District Office
40 South Main Street
Dayton, Ohio 45402-2066
(513)286-6357 George V. Voinovich
FAX (513)285-6404 Governor

April 19, 1994 RE: PUBLIC COMMENTS
O.U.4 PROPOSED PLAN

Mr. Ken Morgan
Public Relations
U.S. DOE FEMP
P.O. Box 398705
Cincinnati, OH 45329-8705

Dear Mr. Morgan:

The purpose of this letter is to provide official comments on the Operable Unit 4 Proposed Plan:

1. The OU4 Proposed Plan is the culmination of efforts by U.S. DOE, Ohio EPA, and U.S. EPA to understand and
develop a plan for mitigating releases to the environment from OU4. The alternative selected in the Proposed
Plan will address potential and actual releases in a manner protective of human health and the environment.

2. DOE should commit to including and/or developing real-time monitoring for discharges to the environment
resulting from remedial actions including any treatment system. DOE should attempt to incorporate any new
developments in real-time monitoring from the Office of Technology Development. Data obtained from real-time
monitors and any additional monitoring activities should be provided to the Ohio EPA and public in a timely
manner.

3. DOE should attempt to incorporate pollution prevention activities whenever possible during the design and
operation of the OU4 remedial action system. All available methods to reduce or eliminate discharges from
the treatment system should be considered during the design of the system.

4. DOE must ensure the public that their involvement will not be diminished during Remedial Design and
Remedial Action (RD/RA). DOE should commit to continued public involvement during RD/RA within the Record of
Decision for OU4.

5. DOE should revise the site Community Relations Plan to address the need for continued public involvement
during the RD/RA. Ohio EPA looks forward to working with DOE to revise this document.

Ohio EPA Comments OU4 PP
April 19, 1994
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If you have any questions about these comments please contact me.

Sincerely,

Thomas A. Schneider
Project Manager

TAS

cc: Lisa Crawford, FRESH
Jack Van Kley, Ohio AGO
Jim Saric, USEPA
Ken Alkema, FERMCO
Lisa August, Geotrans
Jean Michaels, PRC
Jenifer Kwasniewski, OEPA/DERR
Jeff Hurdley, OEPA/Legal
Robert Owen, ODH

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590

REPLY TO THE ATTENTION OF:
AUG 02 1994
Ms. Randi Allen ME-19J
Department of Energy
Post Office Box 398704
Cincinnati, Ohio 45239-8704

Dear Ms. Allen

This will confirm the substance of our recent telephone conversations concerning this Agency's review of the
Department of Energy's proposal for implementing activities including reactivation of certain power
generating facilities at the Fernauld site.

As discussed with you, the Draft Environmental Impact Statement (EIS) for this project was never received in
this Branch. In this regard, the Planning and Assessment Branch has been designated as the official contact
point within Region V for provision of comments on Federal projects as required pursuant to Section 309 of
the Clean Air Act and/or the National Environmental Policy Act. The official comment period for this
Fernauld project expired 45 days from the date a notice of the EIS's availability was published in the
Federal Register. In the meantime, however, the document was received, reviewed, and commented upon by staff
of our Waste Management Division with regard to those aspects of the project for which Waste Management
Division has special concern.

Given expiration of the official NEPA comment period for this project's EIS, the only comments on the record
from our Agency are those previously supplied to you from our Waste Management Division. At this point in
time, given the requirements of NEPA and its implementing regulations, those comments will have to suffice as
our Agency's comments. Provided that the comments previously provided by our Waste Management Division are
complied with, and further provided that facility in question is subsequently operated in full accordance
with applicable local, State, and Federal requirements, it appears unlikely at this time that any significant
adverse impacts on the environment can reasonably be foreseen.

We look forward to receipt of the project's forthcoming Final EIS. OUr Agency's comments on the Final EIS
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will be provided on a timely basis. If you have any questions, please do not hesitate to contact me at
312/886-7342.

Sincerely yours,

Michael W. Mac Mullen
Senior Environmental Scientist
Planning and Assessment Branch
Planning and Management Division
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ATTACHMENT C.II

ERRATA SHEETS AND CHANGES TO THE FEASIBILITY STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT

TABLE OF CONTENTS
Page

C.II.l Repromulgation of 40 CFR § 191 C-II-1

C.II.2 Errata Shests to the Operable Unit 4 Feasibility
Study/Proposed Plan - Draft Environmental Impact Statement C-II-3

C.II ERRATA SHEETS AND CHANGES TO THE FEASIBILITY STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT

The FS/PP-DEIS for Operable Unit 4 was released for public comment in March 1994. The DOE reviewed all
written and oral comments submitted during the public comment period. Upon review of these comments, it was
determined that no significant changes to the remedy, as was originally identified in the FS/PP-DEIS, were
necessary. However, it should be noted that the repromulgation of 40 CFR §191 by the EPA, did result in
minor changes in the comparative analysis of alternatives presented in the FS/PP-DEIS. Likewise, in May 1994
five final concerns were received from the EPA on the Operable Unit 4 FS/PP-DEIS. In responding to these
five concerns, Table D.3-5 in Appendix D of the Operable Unit 4 FS/PP-DEIS was revised. The revised table is
included in this Attachment. The following discussion addresses the nature and extent of these changes.

C.II.l REPROMULGATION OF 40 CFR §191

Repromulgation of the 40 CFR §191 requirements for Management and Disposal of Spent Nuclear Fuel, High-Level,
and Transuranic Wastes has caused changes to be made to the ARARs as described in the Draft Final FS/PP-DEIS,
conditionally approved by the EPA on February 9, 1994. DOE chooses not to submit revision pages to the
FS/PP-DEIS; all changes to the ARARs for that document and any impacts from the repromulgation are discussed
in this section of the Draft ROD. Since the repromulgation resulted in relevant and appropriate, rather than
applicable requirements, the repromulgation of 40 CFR §191 will not impact the proposed off-site alternative
for disposition of the K-65 material. However, the on-property disposal alternatives (Alternatives 2A/Vit
and 2A/Cem) that were previously retained, having passed the threshold criteria of the detailed analysis, are
no longer able to meet the threshold criteria of compliance with ARARs, and are consequently dropped from
further consideration. Subsequently, all references to Alternative 2A are therefore deleted from reference
in the text of the ROD, and in the Appendix A.

The only relevant and appropriate requirement from 40 CFR §191 that is retained as an ARAR in this ROD
(Appendices A and B) for the proposed alternative is 40 CFR §191.03(b), which establishes dose limits for
management and storage of the K-65 material. However, since this ARAR is relevant and appropriate, rather
than applicable, it will pertain only to the on-property portions of the remediation.

Background

The United States Department of Energy - Fernald Field Office (DOE-FN) received conditional approval of the
Draft Final FS/PP-DEIS for Operable Unit 4 from USEPA on February 9, 1994. Included in the FS/PP-DEIS
applicable or relevant and appropriate requirements (ARARs) was a reference to 40 CFR §191, "Environmental
Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level, and Transuranic
Wastes". This reference to 40 CFR §191 was modified in the Operable Unit 4 FS/PP-DEIS, submitted in February
1994 in response to the conditional approval letter, to reflect the changes to the regulation that occurred
upon its repromulgation on December 20, 1993. It still accommodates the specific direction previously
provided by the USEPA regarding incorporation of the 40 CFR §191 requirements as an ARAR/TBC ("Operable Unit
4 Screening Dispute Resolution U.S. DOE Fernald", Catherine McCord, USEPA, to Andy Avel, DOE, dated October
18, 1990). The final rule became effective on January 19, 1994, during final revision of the Operable Unit 4
FS/PP-DEIS, and agency comments did not address the repromulgation of the rule. This fact was discussed with
the USEPA, and a DOE position paper on the incorporation of 40 CFR §191 as an ARAR for Operable Unit 4
remediation was submitted to the USEPA for concurrence. The USEPA disagreed with the draft position proposed
-------
by DOE, and responded with a directive to incorporate the substantive elements of the repromulgated rule into
the ROD, with an option to resubmit change pages to the FS/PP-DEIS ("Application of 40 CFR §191 to OU #4",
Jim Saric, USEPA, to Jack Craig, DOE, dated April 25, 1994) . DOE elected not to revise the FS/PP-DEIS, but
rather to describe in this section of the ROD changes to the table of ARARs and associated impacts on
selection or implementation of remedial alternatives that have occurred between the time the Draft Final
FS/PP-DEIS was conditionally approved, and the submittal of the ROD to the USEPA and OEPA. The list of ARARs
in the Draft ROD, and proposed approach to compliance with the substantive elements thereof, once approval by
the USEPA is obtained, will be the final approved list of applicable or relevant and appropriate reguirements
for final remediation of Operable Unit 4.

Impacts of Repromulgation

Since 40 CFR §191 cannot be considered a legally "applicable" class of ARAR for this CERCLA remediation, §191
is not applicable to any Operable Unit 4 waste streams. Since compliance with only applicable reguirements
is reguired to be demonstrated for off-site remedial alternatives proposed under CERCLA, these reguirements
will not impact the proposed off-site alternative for disposal of the treated K-65 material at the NTS.

DOE previously included 40 CFR §191 Subpart A as a relevant and appropriate reguirement, and Subpart B as to
be considered (TBC) criteria for management of K-65 material in accordance with guidance received from the
USEPA. Subpart A of §191, entitled "Environmental Standards for Management and Storage" includes public dose
rate standards for protection of the public from radiation hazards posed by spent nuclear fuel, high-level,
or transuranic waste material. The repromulgation of the Final Rule did not materially affect the sections
of Subpart A referenced in the Operable Unit 4 FS/PP-DEIS; the Subpart A reguirement referenced in the
Operable Unit 4 FS/PP-DEIS remains unchanged in the table of ARARs as a relevant and appropriate reguirement
for the on-property portion of the remedial activities to be conducted on the K-65 material.

Prior to repromulgation, Subpart B reguirements were in remand, and were therefore considered TBCs in the
FS/PP-DEIS submitted to the agencies. Since Subpart B of §191, entitled "Environmental Standards for
Disposal", has been repromulgated, the USEPA has directed that sections must now be considered as relevant
and appropriate reguirements for any on-property disposal alternatives. Since it could not be demonstrated
that the on-property disposal of treated K-65 material would comply with specific reguirements of this
Subpart, those alternatives involving on-property disposal (Alternatives 2A/Vit and 2A/Cem) were no longer
able to meet the threshold criteria of compliance with these ARARs, and were conseguently dropped from
further consideration. All descriptions to Alternative 2A are therefore deleted from reference in the text
of the ROD, and in the Appendix A.

A new Subpart C of §191 "Environmental Standards for Groundwater Protection", was created by the
repromulgated rule. As with Subpart B, this new Subpart pertains only to disposal systems. The elements of
this Subpart must now be considered as relevant and appropriate reguirements; however, since the on-property
disposal alternatives to which this Subpart pertains were dropped from further consideration on the basis of
non-compliance with Subpart B reguirements, and since Subpart C will not pertain to any off-site disposal
alternatives, these reguirements will not be included in the Appendix A or B tables of ARARs. Subpart C will
have no effect on the selected alternative, which includes off-site disposal.

C.II.2 ERRATA SHEETS TO THE OPERABLE UNIT 4 FEASIBILITY STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT
STATEMENT

In the course of obtaining EPA's approval of the Operable Unit 4 Feasibility Study/Proposed Plan-Draft
Environmental Impact Statement, several iterations of specific comment responses were reguired to fully
address five remaining EPA concerns.

On May 9, 1994 the EPA approved the Final Operable Unit 4 Feasibility Study Report and Proposed Plan based
upon the satisfactory resolution of five remaining concerns. Only the resolution of one of the five
remaining concerns resulted in an action by the DOE, which involved the revision of two pages to the Operable
Unit 4 Feasibility Study Report/Proposed Plan-Draft Environmental Impact Statement.

In the May 9, 1994 approval letter, the EPA noted that previously agreed upon changes related to the Operable
-------
Unit 4 FS, Appendix D, Table D.3-5 were not made in the revised final document per resolution. Specifically,
the surface area (SA) values presented for the Dermal Contact While Bathing pathway in Table D.3-5, were not
reflected in the Final Operable Unit 4 Feasibility Study/Proposed Plan-Draft Environmental Impact Statement
document. In addition, the EPA noted that footnote "h" of Table D.3-5 was incorrect; the referenced pages
were not consistent with the cited EPA document.

The following DOE response was accepted by the EPA on this matter:

"This table (D.3-5) was derived from the OU4 Baseline Risk Assessment, but the latest change for this dermal
exposure pathway was not made for this table. This will have no impact on the OU4 FS risk assessment as the
only contaminant which was considered for the groundwater pathway was U-238. Since radionuclides are not
evaluated for dermal absorption pathways, this parameter change will not change the risk values."

In accordance with this resolution the DOE issued the following revised pages to Table D.3-5, which included
the corrected surface area value of 23,000 cm3 and the corrected footnote "h".
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ATTACHMENT C.III

FINAL ENVIRONMENTAL IMPACT STATEMENT DISTRIBUTION LIST

FEDERAL AGENCIES AND CONGRESS

NAME/LOCATION PHONE/FAX

Cheryl Allen 312-353-6196
United States Environmental Protection Agency
Region V (P-19J)
Superfund Community Relations Section
77 W. Jackson Blvd.
Chicago, IL 60604

The Honorable Tom Bevill
Chairman, Subcommittee on Energy and Water Development
Committee on Appropriations
Member, U.S. House of Representatives
2362 Rayburn
Washington, D.C. 20515

The Honorable James H. Bilbray
Member, U.S. House of Representatives
2431 Rayburn
Washington, D.C. 20515

The Honorable James H. Bilbray 702-792-2424
Member, U.S. House of Representatives
1785 E. Sahara, Suite 445
Las Vegas, Nevada 89104

The Honorable Michael Bilirakis
Ranking Minority Member
Subcommittee on Energy and Power
Committee on Energy and Commerce
Member, U.S. House of Representatives
2322 Rayburn
Washington, D.C. 20515

The Honorable John A. Boehner 513-894-6003
Member, U.S. House of Representatives
5617 Liberty Fairfield Road
Hamilton, Ohio 45011

NAME/LOCATION PHONE/FAX

The Honorable John A. Boehner
Member, U.S. House of Representatives
1020 Longworth
Washington, D.C. 20515

The Honorable Richard Bryan 702-388-6605
United States Senator
300 Las Vegas Boulevard, Suite 402
Las Vegas, Nevada 89101
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The Honorable Richard Bryan
United States Senate
364 Russell
Washington, B.C. 20510

Jonathan Deason, Director (18 Copies)
Office of Environmental Affairs
Attn: Lilian Stone
U.S. Department of the Interior
1849 C. Street, NW, Room 2340
Washington, D.C. 20240

The Honorable Ronald V. Dellums
Chairman, Committee on Armed Services
Member, U.S. House of Representatives
2120 Rayburn
Washington, D.C. 20515

Ms. Kathleen C. DeMeter
Assistant Chief Counsel/General Law
National Highway Traffic Safety Administration (NCC-30)
Room 5219 Nassif Building
400 7th Street, SW
Washington, D.C. 20590

The Honorable John D. Dingell
Chairman, Committee on Energy and Commerce
Member, U.S. House of Representatives
2125 Rayburn
Washington, D.C. 20515

NAME/LOCATION PHONE/FAX

The Honorable John D. Dingell
Chairman, Subcommittee on Oversight and Investigations
Committee on Energy and Commerce
Member, U.S. House of Representatives
2323 Rayburn
Washington, D.C. 20515

The Honorable Pete V. Domenici
Ranking Minority Member
Subcommitte on Energy Research and Development
Committee on Energy and Natural Resources
United States Senate
312 Dirksen
Washington, D.C. 20510

The Honorable J. James Exon
Chairman, Subcommittee on Nuclear
Deterrence, Arms Control & Defense
Intelligence Committee on Armed Services
United States Senate
528 Hart
Washington, D.C. 20510

Mr. Robert Fairweather
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Chief, Environmental Branch
Office of Management and Budget
725 17th Street, NW
Washington, B.C. 20503

The Honorable Wendell H. Ford
Chairman, Subcommittee on Energy
Research and Development
Committee on Energy and Natural Resources
United States Senate
312 Hart
Washington, B.C. 20510

The Honorable John H. Glenn 513-684-3265
United States Senator
550 Main Street, Room 10407
Cincinnati, Ohio 45202

NAME/LOCATION PHONE/FAX

The Honorable John Glenn
Chairman, Committee on Government Affairs
United States Senate
503 Hart
Washington, B.C. 20510

The Honorable John Glenn
United States Senate
503 Hart
Washington, B.C. 20510

The Honorable Tony P. Hall 513-225-2843
Member, U.S. House of Representatives
Federal Building, Room 501
200 West Second Street
Bayton, Ohio 45402

The Honorable Tony P. Hall
Member, U.S. House of Representatives
2236 Rayburn
Washington, B.C. 20515

Herbert Harback 608-874-0539
Army Corps of Engineers
Louisville Bistrict
Louisville, Kentucky 40201

The Honorable J. Bennis Hastert
Ranking Minority Member
Subcommittee on Environment, Energy, and Natural Resources
Committee on Government Operations
Member, U.S. House of Representatives
2453 Rayburn
Washington, B.C. 20515

The Honorable Mark 0. Hatfield
Ranking Minority Member
-------
Subcommittee on Energy and Water Development
Committee on Appropriations
United States Senate
711 Hart
Washington, B.C. 20510

NAME/LOCATION PHONE/FAX

Kevin Heanue 202-366-0100
Office of Environment
Department of Transportation
400 7th Street, SW
Washington, B.C. 10590

Sheila Huff 312-353-6612
Department of Interior
230 South Dearborn Street, Room 3422
Chicago, Illinois 60604

G. Jablonowski 312-886-0169
United States Environmental Protection Agency FAX 312-886-0617
Region V (AT-18J)
77 W. Jackson Boulevard
Chicago, Illinois 60604-3590

The Honorable J. Bennett Johnston
Chairman, Subcommitte on Energy and Water Development
Committee on Appropriations
United States Senate
136 Hart
Washington, D.C. 20510

The Honorable J. Bennett Johnston
Chairman, Committee on Energy and Natural Resources
United States Senate
304 Dirksen
Washington, D.C. 20510

Elaine Kaiser 202-927-5750
Interstate Commerce Commission
12th Street and Constitution Avenue
Washington, D.C. 20423

NAME/LOCATION PHONE/FAX

Ms. Marilyn W. Klein 202-366-0358
Senior Policy Analyst
Economic Studies Division
Federal Railroad Administration
Room 8302 Nassif Building
400 7th Street, SW
Washington, D.C. 20590

Dr. William Klesch
Office of Environmental Policy (CECW-PO)
Office of Chief of Engineers
Army Corps of Engineers
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Pulaski Building, Room 7116
20 Massachusetts Avenue, NW
Washington, B.C. 20314-1000

Don Klima 202-606-8503
Director, Eastern Office
Advisory Council on Historic Preservation
Old Post Office Bldg., Suite 809
1100 Pennsylvania Ave., NW
Washington, D.C. 20004

Bill Kurey 614-469-6923
U.S. Fish and Wildlife Service
6950-H American Parkway
Reynoldsburg, Ohio 43068

The Honorable Jon Kyi
Ranking Minority Member
Subcommittee on Military Application of
Nuclear Energy Panel
Committee on Armed Services
Member, U.S. House of Representatives
2440 Rayburn
Washington, D.C. 20515

Ugene Lehr 202-366-4861
Chief, Environmental Division
U.S. Department of Transportation
Room 9217
400 7th Street, SW
Washington, D.C. 20590-0001

NAME/LOCATION PHONE/FAX

The Honorable Trent Lott
Ranking Minority Member
Subcommittee on Nuclear Deterrence Arms
Control & Defense Intelligence
Committee on Armed Services
United States Senate
487 Russell
Washington, D.C. 20510

The Honorable David Mann 513-684-2723
Member, U.S. House of Representatives
1014 Vine Street
2210 Kroger Building
Cincinnati, Ohio 45202

The Honorable David Mann
Member, U.S. House of Representatives
503 Cannon
Washington, D.C. 20515

Mike MacMullen (ME-19J) 312-886-7342
Planning and Assessment Branch
Planning and Management Division
-------
U.S. Environmental Protection Agency - Region V
77 W. Jackson Blvd.
Chicago, Illinois 60604-3590

Ross McKay 202-646-2717
Federal Emergency Management Agency
500 C Street, SW
Washington, B.C. 20472

The Honorable Howard M. Metzenbaum 513-688-3894
United States Senator
10411 Federal Building
Cincinnati, Ohio 45202

NAME/LOCATION PHONE/FAX

The Honorable Howard M. Metzenbaum
United States Senate
140 Russell
Washington, B.C. 20510

J. Michaels 312-856-8700
PRC Environmental Management, Inc.
233 N. Michigan Ave., #1621
Chicago, IL 60601

The Honorable Carlos J. Moorhead
Ranking Minority Member
Committee on Energy and Commerce
Member, U.S. House of Representatives
2322 Rayburn
Washington, B.C. 20515

The Honorable John T. Myers
Ranking Minority Member
Subcommittee on Energy and Water Bevelopment
Committee on Appropriations
Member, U.S. House of Representatives
2372 Rayburn
Washington, B.C. 20515

The Honorable Sam Nunn
Chairman, Committee on Armed Services
United States Senate
228 Russell
Washington, B.C. 20510

James K. O'Steen, Birector
Office of Hazardous Materials Technology
U.S. Bepartment of Transportation
400 7th Street, SW
Washington, B.C. 20593

NAME/LOCATION PHONE/FAX

The Honorable Rob Portman 513-732-2948
Member, U.S. House of Representatives
-------
350 East Main Street
Batavia, Ohio 45103

The Honorable Rob Portman
Member, U.S. House of Representatives
238 Cannon
Washington, B.C. 20515

The Honorable Harry Reid
United States Senate
324 Hart
Washington, B.C. 20510

The Honorable Harry Reid 702-474-4041
United States Senator
500 East Charleston Boulevard
Las Vegas, Nevada 89104

Mr. Vic Rezendes
Birector, Energy Issues
Community and Economic Bevelopment Bivision
General Accounting Office Building
Room 1842
441 G St. , NW
Washington, B.C. 20548

The Honorable William V. Roth
Ranking Minority Member
Committee on Government Affairs
United States Senate
346 Birksen
Washington, B.C. 20510

Mr. Richard E. Sanderson
Birector, Office of Federal Activities
U.S. Environmental Protection Agency
Room 2119, Waterside Mall, A-104
401 M Street, SW
Washington, B.C. 20460

NAME/LOCATION PHONE/FAX

James A. Saric, Remedial Project Birector 312-886-0992
U.S. Environmental Protection Agency FAX 312-353-4788
Region V - 5HRE-8J
77 W. Jackson Blvd.
Chicago, Illinois 60604-3590

The Honorable Ban Schaefer
Ranking Minority Member
Subcommittee on Oversight and Investigations
Committee on Energy and Commerce
Member, U.S. House of Representatives
2322 Rayburn
Washington, B.C. 20515

The Honorable Philip R. Sharp
-------
Chairman, Subcommittee on Energy and Power
Committee on Energy and Commerce
Member, U.S. House of Representatives
331 Ford
Washington, B.C. 20515

The Honorable Floyd Spence
Ranking Minority Member
Committee on Armed Services
Member, U.S. House of Representatives
2120 Rayburn
Washington, B.C. 20515

The Honorable John M. Spratt
Chairman, Subcommittee on Military Application of
Nuclear Energy Panel
Committee on Armed Services
Member, U.S. House of Representatives
1536 Longworth
Washington, B.C. 20515

NAME/LOCATION PHONE/FAX

The Honorable Mike Synar
Chairman, Subcommittee on Environment, Energy, and Natural Resources
Committee on Government Operations
Member, U.S. House of Representatives
B371-B Rayburn
Washington, B.C. 20515

Mr. Charles Terrell
Environmental Specialist
Ecological Science Bivision
Soil Conservation Service
6159-S
P.O. Box 2890
Washington, B.C. 20013

The Honorable Strom Thurmond
Ranking Minority Member
Committee on Armed Services
United States Senate
232A Russell
Washington, B.C. 20510

The Honorable Barbara F. Vucanovich 702-255-6470
Member, U.S. House of Representatives
6900 Westcliff, Suite 509
Las Vegas, Nevada 89128

The Honorable Barbara F. Vucanovich
Member, U.S. House of Representatives
2202 Rayburn
Washington, B.C. 20515

The Honorable Malcolm Wallop
Ranking Minority Member
-------
Committee on Energy and Natural Resources
United States Senate
312 Dirksen
Washington, B.C. 20510

NAME/LOCATION PHONE/FAX

Pearl Young (5 Copies) 202-260-5076
Office of Federal Activities
U.S. Environmental Protection Agency
Room 2119, Waterside Mall, A-104
401 M Street, SW
Washington, B.C. 20460

NAME/LOCATION PHONE/FAX

The Honorable Louis W. Blessing Jr. 513-385-5302
Ohio House of Representatives
3672 Springdale Road
Cincinnati, Ohio 45251

Les Bradshaw 702-482-8134
Nye County Nuclear Waste Repository Project
Commmsioners Building
St. Patrick's Street
Tonopah, NV 89049

Richard Bole 513-367-2111
City of Harrison
300 George Street
Harrison, Ohio 45030

Lee Fisher 614-466-4320
Ohio Attorney General
30 East Broad Street
Columbus, Ohio 43266

The Honorable Michael A. Fox 513-896-1865
Ohio House of Representatives
State House
77 South High Street
Columbus, Ohio 43266

Guy Guckenberger 513-632-5797
Hamilton County Commissioners
138 East Court Street, Room 603
Cincinnati, Ohio 45202

Phil Hariis 513-285-6090
Ohio Environmental Protection Agency FAX 513-285-6404
401 East 5th Street
Bayton, Ohio 45402-2911

Laura Hegge 513-285-6357
Ohio Environmental Protection Agency
401 East Fifth Street
Bayton, Ohio 45402
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Steve James 614-848-6234
Ohio Department of Health
Box 118, Bureau of Radiological Health
Columbus, Ohio 43266

NAME/LOCATION PHONE/FAX

J. Kwasniewski 614-644-2322
Ohio Environmental Protection Agency
1800 WaterMark Drive
Columbus, Ohio 43266

The Honorable Barry Levy 513-422-2001
Ohio State Senate
2 North Main Street
Frost and Jacobs
Middletown, Ohio 45042

Irene Lewis 513-844-8020
Disaster Services Agency
141 Court St.
Butler County Courthouse
Hamilton, Ohio 45011

Paul J. Liebendorfer 702-687-4670
Bureau of Federal Facilities
Division of Environmental Protection
State of Nevada
333 W. Nye Lane
Carson City, NV 89710

Liore MacCarone 513-821-1092
Hamilton County Civil Defense
2377 Civic Center Drive
Cincinnati, Ohio 45231

Mr. John Marshall, Administrator 614-265-6306
Ohio Department of Natural Resources FAX 614-262-1143
Division of Wildlife
Attn: Environmental Section
1840 Belcher Drive
Columbus, Ohio 43224

The Honorable Robert J. Miller 702-687-5670
Governor of Nevada
State Capitol
Carson City, Nevada 89710

Ronald P. Miller 513-632-8461
Hamilton County Regional Planning
138 East Court Street, Room 802
Cincinnati, Ohio 45202

NAME/LOCATION PHONE/FAX

Graham E. Mitchell 513-777-0212
Ohio Environmental Protection Agency FAX 513-285-6249
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401 East 5th Street
Dayton, Ohio 45402-2911

Jerry Monahan 513-244-5843
Greater Cincinnati Building and Construction
1550 Chase Avenue
Cincinnati, Ohio 45223

Maud Naroll 702-687-4065
Nevada State Clearinghouse
Department of Administration
Capital Complex
123 West Nye Lane
Carson City, NV 89710

Mr. Gordon D. Proctor, Administrator 614-466-2307
Ohio Department of Transportation
Office of Planning and Environmental Services
25 South Front Street
Columbus, Ohio 43215

M. Proffitt 513-285-6073
Ohio Environmental Protection Agency FAX 513-285-6404
401 East 5th Street
Dayton, Ohio 45402-2911

Martha J. Raymond, Department Head 614-297-2470
Technical Review Services FAX 614-297-2546
Ohio Historic Preservation Office
Ohio Historical Center
1985 Velma Avenue
Columbus, Ohio 43211-2497

Mr. Tom Schneider, Fernald Project Manager 513-285-6055
Ohio Environmental Protection Agency FAX 513-285-6404
401 East 5th St.
Dayton, Ohio 45402-2911

NAME/LOCATION PHONE/FAX

Charles E. Shumann 513-651-9437
Hamilton County
1632 Central Parkway
Cincinnati, Ohio 45210

Sally Southard 513-887-3247
Butler County Commissioners
130 High Street
Hamilton, Ohio 45011

Peter Sturdevant
Hamilton County Department of Environmental Services 513-651-9437
Air Quality Management
1632 Central Parkway, Room 201
Cincinnati, Ohio 45201

The Honorable George V. Voinovich 614-466-3555
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Governor of Ohio
77 South High Street, 30th Floor
Columbus, Ohio 43266

Mr. Larry Weaver 614-466-0698
State/Federal Funds Coordinator
State Clearinghouse
Office of Budget and Management
30 East Broad Street, 34th Floor
Columbus, Ohio 43266-0411

The Honorable Cheryl Winker 513-574-2577
House of Representatives
5355 Boomer Road
Cincinnati, Ohio 45247

NAME/LOCATION PHONE/FAX

John Applegate 513-281-7160
University of Cincinnati
College of Law, Room 415
Cincinnati, Ohio 45221

Richard Arnold
P.O. Box 73
Pahrump, NV 89041

Daniel G. Baker 513-738-1234
Delta Steel Corporation
10860 Paddys Run Road, Box 39040
Harrison, Ohio 45239

Citizens Alert
P.O. Box 5339
Reno, Nevada 89513

Peggy Collins 513-868-9053
League of Women Voters of Hamilton/Fairfield Area
5299 Dee Alva Drive
Fairfield, Ohio 45014

Leroy E. Euvrard, Jr. J.D. 513-738-0245
Safety and Environmental Staff
2345 Joyce Lane
Okeana, Ohio 45053

Lisa Crawford
Fernald Residents for Environmental Safety and Health
10206 Crosby Road
Harrison, Ohio 45030

Sam Goodson 803-740-5334
Albright and Wilson Inc.
10818 Paddys Run Road, Box 39066
Cincinnati, Ohio 45239

Dee Irons 803-649-7963
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NUS Corporation
900 Trail Ridge Road
Aiken, SC 29803

NAME/LOCATION PHONE/FAX

Daryl G. Kimball, Research Analyst
Physicians for Social Responsibility
1000 16th Street, NW
Washington, B.C. 20006

Pan Kingfisher 918-458-4322
Native Americans for a Clean Environment FAX 918-458-0322
Box 1671
Tahlegua, Oklahoma 74465

Robin M. Madison
Ratheon Services Nevada
P.O. Box 95487
Las Vegas, NV 89193-5487

Patrick J. Malloy, Executive Director
Radioactive Waste Campaign
625 Broadway, 2nd Floor
New York, New York 10012

Dr. James Reisa 202-334-3060
National Academy of Sciences FAX 202-334-2752
2010 Constitution Avenue NW
Washington, D.C. 20418

William Rosse, Sr.
HC 61, Box 6240
Austin, NV 89310-9301

Robert M. Schwab 513-738-4825
FAT&LC
Box 126
Ross, Ohio 45061

Anthony Sears 513-738-8559
Morgan Township Trustees
1616 Bebb Park Lane
Okeana, Ohio 45053

Rev. Dr. Velma Shearer 513-836-9654
Church of the Brethren, District of Southern Ohio
124 Chesmut Street
Englewood, Ohio 45322

NAME/LOCATION PHONE/FAX

Donald H. Thiem 513-892-3740
Ross Township Trustees
3175 Hamilton Scipio Road
Hamilton, Ohio 45013
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William L. Vasconi, Chairman
Citizens Advisory Board for Nevada Test Site
6565 W. Atwood Ave.
Las Vegas, Nevada 89108

Gloria Walker
League of Women Voters of the Cincinnati Area
103 Wm. H. Taft Road
Cincinnati, Ohio 45219
702-295-3751
FAX 702-295-3616
513-281-8683
Dr. Gene E. Willeke
Miami University
Institute of Environmental Sciences
Oxford, Ohio 45056

NAME/LOCATION
513-529-5814
NAME/LOCATION
Ed and Agnes Ashbrook
9521 Haddington Ct.
Cincinnati, Ohio 45251-2365

Dennis Bechtel
319 Encima Ct.
Henderson, NV 89014
Lesley Cusik
483 Mahogany Road
Oliver Springs, TN 37840

Dirk and Vicky Dastillung
3088 Hamilton Scipio Road
Hamilton, Ohio 45013
Louis C. Bogar
2080 Smith Road
Hamilton, Ohio 45013
Pam Dunn
7781 New Haven Road
Harrison, Ohio 45030
Gerald L. Bradley
SW Region Water District
3640 Old Oxford Road
Hamilton, Ohio 45013

Christopher Brown
9457 S. Las Vegas Blvd. #93
Las Vegas, NV 89123

Harry Bryson
5728 Wooded Acres Drive
Knoxville, Tennessee 37921-3919

Curtis and Sandy Butterfield
4535 Morgan Ross Road
Hamilton, Ohio 45013

Jim Chandler
P.O. Box 64
Hamersville, Ohio 45130

Marvin and Doris Clawson
586 Charlberth Drive
Hamilton, Ohio 45013

Diane Cravotta
P.O. Box 91971
Henderson, NV 89009-1971
Kendall Garing
522 Azalea Drive
Rockville, Maryland 20850

Edwena Heitfield
9680 Howard Road
Harrison, Ohio 45030

James Henderson
6712 Reggie Circle
Las Vegas, NV 89107

Mr. Ron Kirk
Department of Energy
Oak Ridge Operating Office
200 Administration Drive
Oak Ridge, Tennessee 37830

Melvin and Jean Knollman
7513 Willey Road
Hamilton, Ohio 45013

Marilyn J. Littlepage
1851 Balzac Drive
Las Vegas, NV 89115

Ms. Julie Mason
Tetra Tech Co.
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Ken and Lisa Crawford
10206 Crosby Road
Harrison, Ohio 45030

NAME/LOCATION
4700 King Street
Suite 500
Alexandria, Virginia 22302
NAME/LOCATION
Lathia McDaniels
2396 Valley Drive
Las Vegas, NV 89108

Gerda McFarland
9035 Winton Road
Cincinnati, Ohio 45231

Bob and Betty McKay
2 New Haven Drive
Harrison, Ohio 45030

Maggie B. Merritt
63 Branch Hill Drive
Harrison, Ohio 45030

Donald and Kathleen Meyer
11785 Edgewood Road
Harrison, Ohio 45030

Richard Nocilla
823 Spyglass Lane
Las Vegas, NV 89107

Kathy Furlong
2209 Birch Drive
Hamilton, Ohio 45014

Norma J. Nungester
8574 Mount Hope Road
Harrison, Ohio 45030

Mary O'Brien
P.O. Box 8402
Pahrump, NV 89041

John B. Price
5474 Nottingham Place
Fairfield, Ohio 45014

E. Paul Richitt, Jr.
3575 W. Badura Ave.
Las Vegas, NV 89118
NAME/LOCATION
Valarie Rush
407 Sycamore, #2
Trenton, Ohio 45067

Carol A. Schroer
9886 Hamilton Cleves Road
Harrison, Ohio 45030

Spencer R. Seymour
2218 Park Avenue
Cincinnati, Ohio 45206

Steve and Peggy Shafer
8188 West Mill, Apt. 258
Cleves, Ohio 45002

Evelyne Shaver
9740 Baughman Road
Harrison, Ohio 45030

Edward B. Silberstein, M.D.
3530 Verga Lane
Cincinnati, Ohio 45237

Rosa Silver
PAI
1050 East Flamingo Road, Suite 367
Las Vegas, NV 89119

Connie Simkins
P.O. Box 333
Panaca, NV 89042

Lawrence Stebbins
3944 Silax Drive
Hamilton, Ohio 45013

Joanne S. Stockill
4625 Kay Place
Las Vegas, NV 89107

Angela Supe
3922 Patty Drive
Okeana, Ohio 45053
William L. Vasconi
6565 W. Atwood Ave.
Las Vegas, NV 89108
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J. E. Walther
3686 Cincinnati-Brookville Road
Hamilton, Ohio 45013

Jack and Roberta Warndorf
4441 Race Lane Road
Okeana, Ohio 45053

Edwa Yocum
9860 Hamilton Cleves Road
Harrison, Ohio 45030

Katherine L. Yuracko
5708 Stallion Ave.
Las Vegas, NV 89108

ATTACHMENT C.IV

PUBLIC MEETING TRANSCRIPT

TABLE OF CONTENTS

Page

Public Meeting (March 21, 1994), Harrison, Ohio C-IV-1-1

Nevada Test Site Community Advisory Board Meeting (May 11, 1994), Las Vegas, Nevada
-------
1

5 US DEPARTMENT OF ENERGY

6 PUBLIC MEETING

8 MONDAY, MARCH 21, 1994

9 THE PLANTATIONS, HARRISON, OHIO

24
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1 MR. STEGNER: Good evening. Thank

2 you for coming. My name is Gary Stegner. I work

3 at the Department of Energy at Fernald. Tonight

4 we're going to be discussing Operable Unit 4, which

5 are the silos, Silos 1 through 4 including the

6 basic five silos.

7 Briefly, very briefly, the way we're

8 going to set the evening up is, if you look at the

9 agendas on your chair, we'll start off with a

10 series of presentations which should last about a

11 total of about 45 minutes.

12 Following the presentations we'll

13 have an informal guestion and answer section. This

14 is informal as distinguished from the formal

15 comment period that will follow. During the

16 informal session, it will be a give and take with

17 the panel and any of the other experts who we might

18 have out there in the audience to answer your

19 guestions regarding Operable Unit 4. We do want to

20 keep focused as much as possible on Operable Unit

21 4.

22 Following the informal guestions and

23 answers, what we'll do is take a break for about 10

24 or 15 minutes. Then we'll come back, and then
-------
1 we'll have the formal comment period. The formal

2 comment period is for the record. You know, it is

3 something that will be included in our

4 Responsiveness Summary, and it will be included in

5 the Record of Decision for Operable Unit 4.

6 Before I introduce the panel tonight,

7 a few logistical announcements. People will

8 remind, I think everyone is registering at the door

9 as they come in. If you want to make a formal on

10 the record comment, please designate that when you

11 sign in. The way I will do that is, following the

12 break when we begin that, I will go through there

13 and find out the number of people who want to and I

14 will call them up.

15 Don't think that you have to come up

16 here to the microphone tonight to make your formal

17 comments because there are comment cards on your

18 chairs. Also you can give those to me after the

19 meeting. You can send them to Amy at the

20 Department of Energy at Fernald, and you can also

21 just write out your comments and send them to us at

22 the Department of Energy at Fernald. We ask that

23 you have those to us by April 20th, however.

24 I think there is ice water someplace
-------
1 in this room. Rest rooms are out the door there.

2 There's also a pop machine if you want to get

3 something to drink during the break. We encourage

4 you to take the handouts that we have scattered

5 throughout the room, if you want to find out more

6 about Operable Unit 4.

7 So let me get on with introducing our

8 panel tonight. We have Randi Allen, who is the

9 Operable Unit Four Manager for the Department of

10 Energy here tonight. Wilf Pickles, her counterpart

11 with FERMCO, the manager there. We have Ed

12 Skintik, Regulatory Compliance for the Department

13 of Energy. His counterpart, Eric Woods, FERMCO

14 reformatory programs; and also Dennis Nixon, the

15 Assistant Unit 4 Director. So without further ado,

16 I will turn it over to Randi Allen.

17 MS. ALLEN: We also have Eric Woods

18 who worke for FERMCO. All I'm going to do here

19 real guick in case there's anybody in the

20 audience that is not that familiar with Fernald,

21 I,m just going to introduce you to the operable

22 units, and then turn it over to Dennis Nixon. He's

23 going to go through some details on Operable Unite

24 4.
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1 Sure everybody has seen this before.

2 This is just to show you the location of the

3 Fernald. It's a 1,050 acre site located about 17

4 or 18 miles northwest of Cincinnati. What I'd like

5 to do here real quick is just run through the other

6 operable units to you, and then I'd like to present

7 a schedule. We're going to have a similar meeting

8 for all the other operable units in a little bit of

9 a later time scale here. I'll show that to you in

10 a minute.

11 Operable Unit 1, which you see in the

12 orange, is the waste pits, and Operable Unit 2 is

13 called other waste units. That's the flyash piles,

14 the south field, the sanitary field, and lime and

15 sludge fields. Operable 3, that's a bigger

16 operable unit. That's all the facilities located

17 on the site. Operable Unit 3, is obviously the

18 silos, one of the smaller units. And Operable Unit

19 5 is everything also not shown on the grid,

20 environmental media, the soils, and the ground

21 well.

22 Here's a schedule for the other

23 operable units. As you can see, in the yellow is

24 the period between like whenever you see the
-------
1 remedial investigation report, that's when the

2 documents are beginning to become available for

3 review by the public. Operable Unit 4 down there,

4 we're right now between the feasibility stage,

5 proposed plan. We've initiated preparation of a

6 Record of Decision.

7 Some places you see the feasibility

8 study, and shortly thereafter the US EPA, the DOE

9 headguarters, and the Ohio EPA will review and

10 comment on the document and approve the document.

11 It becomes available for the public to review, and

12 they'll have this type of evening for each one of

13 the other operable units.

14 This is the process we go through to

15 get in the file remediation. Actually, this is a

16 pretty simple version of it, if you can believe

17 it. Right now in Operable Unit 4 we are right here

18 in beginning preparation of the Record of

19 Decision. So we're getting ready in the near term

20 to issue the Record of Decision of Operable Unit

21 that gets submitted to the US EPA and Ohio EPA in

22 June of this year.

23 After that, once we have reached an

24 agreement on what that Record of Decision should
-------
1 say, the comments you provide on this proposed plan

2 are incorporated into that document. So once we

3 issue that Record of Decision, we will begin final

4 remediation.

5 At this time what I'd like to do is

6 introduce Dennis Nixon, and he is going to run

7 through the documents you guys have been asked to

8 review.

9 MR. NIXON: Good evening. What I'm

10 going to do, present this evening, is a brief

11 history of Operable Unit 4 and how we got to where

12 we're at today. As Randi said, Operable Unit 4 is

13 one of five operable units at Fernald. It's

14 located on the western portion of the site next to

15 Paddy's Run Creek. This is an areal shot of the

16 operable unit area.

17 There's a geographic area

18 encompassing the four waste storage silos. K-65

19 silos, which you'll see to the south, here Silos 1

20 and 2 contain the K-65 residues. Silo 3 is --

21 contains the cold metal oxide material. Silo 4 is

22 empty and was never used.

23 The operable unit also consists of a

24 radon treatment system and underground decant sump
-------
1 tank that was used in the process of filling the

2 silos, the surfaces soils, subsurface soils, and

3 the berm soils, as well as any perched water that

4 may be encountered during the final remediation.

5 The silos were constructed in 1951

6 and 1952 for use as interim storage vessels for

7 defensive program waste that was being produced at

8 that time at the Melloncrock Chemical Works in St.

9 Louis.

10 I have a group of shots on the

11 construction I'll just run through. This is a — I

12 believe the foundation being prepared for Silos 4,

13 3, 2, looking south. The silos were constructed --

14 Silos 1 and 2 were constructed in the winter

15 months, which caused some problems within the

16 construction, causing problems with shutting down

17 the concrete pours which resulted later in cold

18 joints, which when they stopped pouring the

19 concrete, which we'll show you in later pictures,

20 that later would form cracks in the sides of the

21 silos.

22 Silos 1 and 2 during the construction

23 phases, shot looking to the west during

24 construction. The silos were filled during up till
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1 1958. If you'll notice the cracks on the south

2 face where those cold joints in the construction

3 occurred. Essentially due to those cracks, there

4 later was an asphaltic cover. Here again the

5 cracks in the sides of the silos looking to the

6 north, Silo 1, 2, and 3.

7 In 1964 those cracks were sealed with

8 a Gunite material, and then an asphaltic sealant

9 was placed on that, and the first of two berms were

10 added. The berms were added not only for -- They

11 were mainly added for structural stability. They

12 were also there to provide sone shielding due to

13 the radiation that was given off by the silo

14 material. The decant sump tank, which was a buried

15 tank, this is the -- an accese way, a corrugated

16 pipe that was used to access that tank after the

17 berm was added.

18 And this is an areal shot of the

19 original berm. Again, the K-65 silo is here. In

20 1983 that berm, the original berm, had resided, and

21 we had another berm added in 1983 due to the

22 erosion problems. Furthermore, in 1987 these dome

23 cape were placed on the K-65 silos to enhance the

24 structural integrity of the dome itself. The foam
-------
1 was added to insulate the silos and to assist in

2 the radon problem, which we'll talk about a little

3 later.

4 Again, in 1991 — I'll talk about the

5 history, is the clay that was added. We had a

6 removal action in 1991. Due to the radon concerns,

7 the chronic radon emissions, as well as concerns of

8 the silos collapsing and releasing material, we

9 added a one-foot layer of bentonite clay to the

10 residues.

11 As I said, the material was added up

12 until 1958 In the silos. The majority of the

13 material, as I said, was processed at — the K-65

14 material was processed at the Melloncrock Chemical

15 Works in St. Louis. Essentially, they had a

16 problem in St. Louis with storage. So we

17 constructed the silos at Fernald for storage of

18 that material. It was shipped fron Melloncrock as

19 well as Lake Ontario Ordinance Works to the Fernald

20 site.

21 You can see here the incoming drums

22 that were received at the site. Those drums were

23 slurried in the drum handling building. They were

24 reslurried, pumped In the silo. That material was
-------
1 allowed to sit over night, essentially, and the

2 liquid was decanted off into the decant sump tank

3 that I spoke of earlier.

4 As well, some K-65 material was

5 processed at Fernald in our refinery. Those

6 raffinates were pumped in a liquid form through the

7 trench that you see here running east west to Silo

8 2.

9 The Silo 3 material was all processed

10 on site here in our refinery at Fernald. Those

11 raffinates were unlike the K-65 material, would

12 calcine at a very high temperature and would rot,

13 and would pneumatically convey through the same

14 trench to the pipe In Silo 3.

15 The K-65 material generally takes the

16 form of a wet clay material ranging from gray to

17 brown. It is defined as technically as 11E2

18 by-product material under the Atomic Energy Act,

19 which makes that an exception from the RECRA

20 regulations, even though we do consider RECRA as a

21 helpful and appropriate requirement.

22 The material in K-65 silos generally

23 the contaminates of concern are radium, thorium,

24 and lead-210. Due to that radium content, the
-------
1 residues give off a considerable amount of radon

2 gas, which again was the reason for the removal

3 action to add the one-foot layer of bentonite clay

4 in 1991.

5 There are elevated-concentrations in

6 the residues, the untreated residues, of barium and

7 lead. There are very low concentrations of PCB and

8 tributyl phosphate used that probably occurred

9 during the processing at the refinery or at the

10 Melloncrock Chemical Works.

11 Total volume of material, including

12 Silos 1 and 2, including the bentonite clay is

13 roughly 8,900 cubic yards. In your packets you

14 have tables from the remedial investigation, the

15 actual characteristics of the residues themselves.

16 I won't go over those tonight.

17 The Silo 3 material is called cold

18 metal oxides. As I said, those are a dry powdery

19 material like a talcum powder, again defined

20 technically as 11E2 by-product material, the much

21 lower concentrations of radium nuclides in the Silo

22 3 materials.

23 The predominant contaminates of

24 concern here are the thorium-230, uranium, and
-------
1 lead-210 again. The Silo 3 material also leaches

2 rare earth metals listed here. Little to no

3 organics in the Silo 3 material due to that high

4 temperature calcine process.

5 And here the total volume of Silo 3

6 material, approximately 5,000 cubic yards, for a

7 total residue volume of roughly 13,000 cubic yards

8 to be processed in our final remediation. Again, I

9 have the tables of the characteristics of that

10 waste.

11 In addition to the residues, Operable

12 Unit 4 will remediate surface soils, contaminated

13 surface soils, contaminated berm soils, the

14 subsurface soils below and surrounding the silos,

15 and again any perched water that is encountered

16 during the final remediation.

17 As Randi said, we are in the process

18 of a remedial investigation feasibility study. We

19 currently have completed our remedial

20 investigation. It is conditionally approved by the

21 US EPA. The feasibility study and the proposed

22 plan have been completed, and again are

23 conditionally approved by the US EPA.

24 We are at the phase that we are
-------
1 getting the public comments, public involvement in

2 our proposed plan, and responding to the comments.

3 We are making progress with our Record of Decision

4 based on this proposed plan. It's due to the

5 agency in June of this year. That will include a

6 Responsiveness Summary which will respond to the

7 guestions and comments that are raised tonight and

8 in other meetings or other discussions, formal

9 commments.

10 And then after that Record of

11 Decision, hopefully by October, November time frame

12 of this year, we'll have a Record of Decision.

13 We'll be moving forward into the remedial design

14 and remedial action phases of the project.

15 All of the points are important that

16 we make and go into detail with later. The

17 documents that have been prepared today are fully

18 integrated with the NEPA process and act as the

19 site's draft of the Environmntal Impact

20 Statement.

21 In the feasibility study, we

22 evaluated a full range of alternatives, you know,

23 alternatives that included on-site and off-site

24 disposal, various treatment options, and the DOE
-------
1 proposed alternative, preferred alternative, is as

2 follows:

3 Essentially, the major components of

4 that preferred alternative are to remove the

5 residues from the silos, stabilize those residues

6 by the use of vitrification and dispose of those --

7 thet vitrified waste off site at the Nevada test

8 site.

9 Again, we evaluated a full range of

10 alternatives, and those alternatives were evaluated

11 under the nine criteria which were provided by

12 CERCLA. We're currently involved with the

13 modfying criteria, which is to get the public

14 involved. Again, the major components, to remove,

15 treat, and dispose of the materials in the silos;

16 but in addition to that, we're going to be

17 demolishing. After the residues are recovered and

18 treated, we'll be demolishing and decontaminating

19 the silos themselves, the remediation facilities

20 reguired.

21 We'll be excavating any contaminated

22 soils, that's surface and subsurface soils, the

23 perched ground water. And then, of course, the

24 disposal of the soils and debris will be consistent
-------
1 with the Operable Unit 3 and Operable Unit 5

2 Records of Decision, respectively. They will not

3 be finally disposed of with this operable unit.

4 As for the cost of this action, the

5 cost ia roughly $90 million from start to finish,

6 which is made up of the capital cost for the

7 facility as well as various remediation costs and

8 operations and maintenance costs.

9 This is the schedule. Essentially,

10 we are at the end of the proposed plan period. We

11 are entering into the Record of Decision. We have

12 a draft Record Decision right now at the DOE

13 headguarters that's being reviewed. We have

14 initiated some work on the remedial design work

15 plan based on this proposed plan.

16 Following the Record of Decision, we

17 will go into full-blown remedial design, and then,

18 of course, remedial action will follow. The

19 construction you see here, the construction phase,

20 will be roughly through March of 1997.

21 We'll initiate the remedial

22 operations shortly thereafter, and the facilities

23 will operate roughly until the year 2,000. After

24 the operations are complete, this is the period in
-------
1 which we demolish and decontaminate the facilities

2 that were used to treat and stabilize the

3 materials.

4 There are a couple of key questions,

5 my last couple of slides here, that need to be

6 anewered. Why remove the silo waste at all? I

7 think everyone that's involved with this, this

8 project, will agree that the silo materials need to

9 be taken out of the silos and put into a safe

10 configuration.

11 The silos have guestionable

12 structural integrity. There is the potential,

13 always the potential, for a continued leakage from

14 the silos, proposes an unacceptable risk to both

15 the off-site residents as well as any future

16 trespassers for the site.

17 After they've been removed, why

18 vitrify these wastes? Vitrification is a very --

19 it's a proven technology, and due to our extensive

20 rehabilitative studies, we found it to be a very

21 good treatment technology for the K-65 silo

22 materials. The silo K-65 materials have high

23 silica contents which is very conducive to this

24 process.
-------
1 There is significant volume

2 reduction. There is up to a 60 percent reduction

3 when vitrifying the K-65 materials. We have

4 significant reduction of radon emanation rate.

5 Essentially, once the material has been vitrified,

6 it hes the radon flux of the common building

7 materials like bricks and wood.

8 It also reduces the leachability of

9 metals that are in the material. For example,

10 those metals we are concerned with listed here, the

11 untreated waste, the leaches in excess of the RECRA

12 maximum allowable concentration; after

13 vitrification all well below the regulatory

14 limits. Radon emanation rate, very high for the

15 untreated waste, and it is obviously a significant

16 reduction there.

17 That's all I have for you this

18 evening. I'd like to introduce Eric Woods, who's

19 going to talk in detail on the process in which we

20 integrated the CERCLA and NEPA in these documents.

21 MR. WOODS: Good evening. What I'd

22 like to do is provide a short presentation on

23 CERCLA/NEPA integration, basically focusing on

24 three thinge: a little bit about the history of
-------
1 NEPA compliance at the site, and then look at the

2 Operable Unit 4 feasibility study and proposed

3 plans specifically and kind of walk through how we

4 are integrating NEPA into these documents, and

5 then, lastly, provide a summary of the Operable

6 Unit 4 environmental impacts and the cumulative

7 environmental impacts.

8 So we're all on the same page with

9 respect to NEPA, NEPA is the National Environmental

10 Policy Act signed into law in January of 1970. The

11 goal of NEPA was to provide a national policy on

12 protection of the environment, and one of the

13 specific aspects of NEPA in order to accomplish

14 this goal is that it established a process by which

15 federal agencies, such as the Department of Energy,

16 will need to consider environmental impacts when

17 they made decisions.

18 This is formally known as the

19 Environmental Impact Statement Process, what we're

20 going through here for Operable Unit 4, and a very

21 important aspect of that is the public involvement

22 aspect.

23 The first Environmental Impact

24 Statement proposed at the Fernald site was a
-------
1 renovation EIS. When the site mission changed from

2 production to remediation, the need for this

3 document went away, and the Department of Energy

4 subesguently canceled the renovation EIS.

5 As I said, the mission was changing

6 at that point from production to remediation, and

7 there was still the need to address NEPA for the

8 clean-up activities that were being planned at that

9 time. Therefore, the Department of Energy issued a

10 second notice of intent in May of 1990. This was

11 followed by scoping meetings in June, and this

12 basically announced that it intended to prepare an

13 Environmental Impact Statement for the Operable

14 Unit 4 remedial activities.

15 This document was designed or was

16 planned to do a couple of things. Mainly, it was

17 to look at the environmental impacts of the

18 Operable Unit 4 alternatives, specifically, and

19 reach a decision for OU4 and OU4 only.

20 However, because it was the lead EIS

21 or the first of five integrated documents to be

22 prepared at the site, it was also to address

23 cumulative impacts, and we'll walk through the

24 document and I'll show where and how we've done
-------
1 that.

2 I'll mention that the remaining

3 operable units, 1, 2, 3, and 5, will also be

4 prepared as documents at a lower level, and we'll

5 make decisions for those operable units

6 specifically.

7 I think a key question is, why did we

8 integrate, why not do an individual EIS process and

9 an individual RI/FS process? The main reason is

10 there's a similarity between the two. The RI/FS

11 process under CERCLA, there's an awful lot of the

12 same things we need to do with the EIS under NEPA.

13 Primarily, NEPA evaluates the site, the

14 alternatives to reach an end goal, and it does

15 mention some of the criteria we look at. In the

16 end it identifies preferred alternatives. These

17 are similarities in the two.

18 There are some differences, primarily

19 in the way the alternatives are evaluated, and

20 where these differences occur is where we simply

21 utilize the CERCLA framework and infuse or

22 integrate NEPA into the documentation.

23 This does several things for us. It

24 avoids duplications, the duplications of preparing
-------
1 two separate documents. It also minimizes the

2 potential for inconsistencies, and it's consistent

3 with DOE policy.

4 Looking specifically at the Operable

5 Unit 4 documentation, I want to point out the

6 various parts of the document where NEPA has been

7 infused or integrated. The first place is right up

8 front in the Executive Summary in the introduction

9 in Chapter 1.

10 We provided a discussion of

11 CERCLA/NEPA or NEPA/CERCLA integration, basically

12 what role the various documents play, why we do

13 this, how the remaining operable units will

14 follow. This just gives an overview of the

15 process.

16 The next place where we have

17 integrated NEPA is in Chapter 4. This is really

18 the most important part of the document from the

19 NEPA perspective. This is where we identify

20 environmental impacts that we anticipate for the

21 alternatives that have been identified.

22 Basically, as you go through the

23 alternatives, there is a short-term effectiveness

24 discussion and a long-term effectiveness discussion
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1 for each alternative. Under short-term we provided

2 an analysis of the environmental impacts

3 anticipated during remedial activities. And then

4 in the long-term effectiveness section, we provided

5 an analysis of environmental impacts that are

6 anticipated after remedial activities are

7 complete.

8 When we evaluate environmental

9 impacts, these are some of the criteria we look

10 at. As you go through the document, you will see

11 short-term environmental impacts, just this is a

12 format of the evaluation you will see. Rather than

13 talk through these, I thought I would provide some

14 photographs to kind of illustrate what we're

15 talking about.

16 This slide illustrates several

17 things. This is Paddy's Run. Obviously, water

18 guality is related to Paddy's Run. Also the belton

19 king fisher and the various habitats of biotic

20 resources which evaluate wildlife, wildlife

21 habitat, any species that may be listed at the

22 state or federal level protected.

23 Also flood planes, there are flood

24 planes we must deal with along the Great Miami
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1 River. There's also flood planes along Paddy's

2 Run. Flood planes extend to various points on the

3 banks of Paddy's Run depending on what the

4 topography is like in that area.

5 Another example of biotic resources

6 is this overhead. This is along the eastern

7 portion of the site, and this basically shows a

8 typical field or pasture type habitat we have, and

9 as we went through the cumulative impact analysis

10 and for the purposes of that analysis looked at the

11 possibility of on-site disposal, this was typically

12 the kind of habitat that we identified being

13 disturbed.

14 Another important aspect is cultural

15 resources. Cultural resources could be historic or

16 prehistoric artifacts, such as projectiles or some

17 of the ceremonial pieces that are identified on

18 this overhead. They also could be structures such

19 as homes that this area is very rich in cultural

20 resources, and we have an active program to insure

21 that we don't impact these types of things.

22 This is another shot of the flood

23 plane area. This is along the Great Miami River.

24 You can see the site in the distance. It's upside
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1 down. The flood planes obviously extend in the

2 flat, cultivated fields adjacent to the Great Miami

3 River, and what we're concerned about when we look

4 at flood planes is basically changing elevations.

5 A flood, if it were to occur, either

6 a hundred-year flood or a 500-year flood, it's

7 typically accustom to proceeding a certain distance

8 from the river, in the case of Paddy's Run from the

9 stream. If we change elevations significantly, the

10 water can no longer go where it was accustomed to

11 going and will magnify down stream floods.

12 Kind of hand in hand with the flood

13 planes are wetlands. This is a typical wetland

14 that we have on site, basically this drainage ditch

15 with the cat tails. We have about 35 acres of

16 wetland on the Fernald site, and approximately 10

17 to 15 fall under this category of drainage ditch

18 wetlands. There's a larger area of forested

19 wetlands in the northern part of the site, which

20 are a little bit higher guality than this.

21 When we look at impacts in the

22 Operable Unit 4 document, both specific and

23 cumulative related to all of the operable units,

24 drainage ditch wetlands are primarily wetlands that
-------
1 could be impacted. Wetlands on site are shown in

2 red. This is a large area of forested wetlands I

3 was speaking about.

4 We're taking steps, as we did very

5 early on in the process, to avoid this wetland

6 area. However, if we cannot avoid this area, we're

7 developing a strategy to compensate for the loss of

8 wetlands. We're going to be negotiating that with

9 the Army Corps of Engineers and various other

10 agencies. So those are just some of the kinds of

11 things we look at as we go through our impact

12 analysis.

13 Back to the document itself, also in

14 Chapter 4, at the end of Chapter 4, we have several

15 short sections that we've added to comply with NEPA

16 guidelines. These are irreversible, irretrievable

17 commitment of resources and several others. So

18 that essentially takes care of the body of the

19 feasibility study.

20 As I said, this document is

21 functioning for the Environmental Impact Statement

22 at the site. So the other aspect of it is

23 cumulative aspects that occur in Appendix I in the

24 feasibility study. We've taken remedial
-------
1 alternatives, the latest information we had

2 available, and provided an analysis of the impacts

3 related to the overall remediation of the site.

4 Obviously, we're going to be

5 proceeding through the RI/FS process for the other

6 operable units. Decisions will be made for those

7 other operable units, and that -- the decisions

8 that are made at the very -- from the LRA's that

9 we've utilized for our evaluation in Appendix I.

10 If that happens, we'll update this analysis and

11 provide it for future feasibility studies for

12 submittance for other operable units.

13 Looking at some of the impacts we

14 anticipate for OU4 specifically, alternative, as

15 Dennis discussed, was removal, vitrification of the

16 contents of the silos, removal and on-property

17 disposal contingent upon decisions in OU3 and 5 for

18 storage.

19 Basically, there's an overall

20 beneficial impact for eliminating or controlling

21 the source or potential source of contamination of

22 the silo, contents in the silos. On the negative

23 side, the excavation of tho Operable Unit 4 area

24 and the potential excavation for on-site disposal
-------
1 facility will result in less than 15 acres of the

2 site being disturbed in the short term. Depending

3 on the decisions that are made in Operable Unit 3

4 and 4, a portion of these could be committed in the

5 long-term for disposal. Also potential for a small

6 area of wetlands to be disturbed as a result of the

7 excavation activities. Again, we're looking into

8 compensating for the loss of these wetlend areas.

9 And minor increases in traffic due to

10 goods and materials, fill material, being brought

11 on to the site. This is on the order of ten trips

12 per day for the life of the remedial activity. And

13 those we've identified as substantive. There are

14 others, some of the other categories are evaluated

15 and discussed in the document as well.

16 As far as cumulative impacts go,

17 again, an overall beneficial impact due to the

18 elimination of sources of contamination. Due to

19 the potential sources to the air, water, and soil,

20 again, we're looking at all five operable units

21 being remediated.

22 So we've got a larger area that will

23 be disturbed during that activity up to 250 acres.

24 And, again, the LRA's s that we use for this
-------
1 evaluation primarily looked at on-site disposal.

2 So this is somewhat of a worst case scenario.

3 Hand in hand with the disturbances at

4 the site, a portion of habitat, such as the field

5 habitat I showed in the overhead previously, and

6 some forested areas in the northern part of the

7 site would be disturbed.

8 We do have -- Probably the most

9 important impact we need to identify is, we do have

10 the potential to lose most of the wetland areas on

11 the site. We are trying to work with the various

12 crews to insure or to the extent possible avoid the

13 wetland areas. Wetlands that we do lose due to

14 excavation or commitment of land, we will begin to

15 compensate or mitigate the loss of those areas.

16 In the area of socioeconomics, which

17 looks at impacts from the action to the local or

18 area economy infrastructure such as public

19 services, we do expect a significant amount of

20 material to be purchased in the area.

21 And in addition, we've done a lot of

22 evaluation as to the level of work force at the

23 site, and we expect the level to stay fairly

24 consistent through the life of the remedial
-------
1 activities. Therefore, socioeconomics in the short

2 term should be primarily beneficial. And as we

3 complete remedial activities, the need for a lot of

4 the work force will decline, which could result in

5 minor socioeconomics after the activities are

6 complete.

7 That concludes my presentation, and

8 I'll turn it over to Randi Allen.

9 MS. ALLEN: I just have a couple

10 slides here. These are the last three slides in

11 your package, and I promise I'm not going to go

12 through all of those. Sitting up there looking out

13 at you guys, looks like not a moment too soon I'm

14 winding up this packet here.

15 This is really what we've gone

16 through in Operable Unit 4 so that we could relate

17 what we are intending to do with the residue to

18 advise you out there. Initially starts back when

19 we submitted the document to US EPA and Ohio EPA,

20 the document and the EIC.

21 Essentially, what we've gone through

22 here is beginning really in October, we have tried

23 to meet with the public to tell them what is in the

24 proposed plan and the feasibility study, and have
-------
1 gone through really risk assessment, ground water,

2 and different little round tables I guess.

3 And when we get down to the bottom of

4 this first slide, this is pretty much when we

5 started the distribution of this document. Because

6 it's an EIS the distribution of this document was

7 2,500 copies or something along that. This takes

8 us pretty much to where we are now. This is March

9 7th, this is just notifying this is an EIS

10 feasibility study.

11 The last sheet here will take us to

12 where we are now, to March 21st. And as I think

13 Dennis has told you, April 20th is the date that we

14 are asking for everybody's comments. You can give

15 us some comments this evening if you'd like to,

16 written or verbal comments. And I think the last

17 chapter in the proposed plan, there's — also you

18 can send it, there's the address for submitting

19 your comments to the US DOE, Ken or Gary, or you

20 can send them out to Jim Saric.

21 What we're going to do at that point

22 in time is prepere a responsiveness study. When we

23 submit our Record of Decision down here on June

24 10th to US EPA, that Responsiveness Summary will be
-------
1 part of that document. So that's your opportunity

2 to see how we responded to your comments.

3 This last one down here, there's been

4 quite a few questions on what kind of public

5 involvement do we have from this point on. Now,

6 they have revised the Community Relation Plan in

7 1986 and 1989. And it takes us pretty much up to

8 the Record of Decision point; is that riqht, Gary?

9 MR. NIXON: That's riqht.

10 MS. ALLEN: So what we need to do,

11 in the next three months I think the Public

12 Relations Department will be sendinq out some

13 questionnaires and folders to members of the

14 community to qet some communication, when we qet

15 into remedial desiqn what part do you want to play,

16 how involved do you want to be to, do you want to

17 continue to have round tables.

18 We need to qet some communication and

19 revise that plan. I think this is a pretty

20 standard format for all of the operable units once

21 they qet to the feasibility study point as we qo

22 throuqh the round tables and have a public

23 meetinq.

24 At this time what I would like to do is
-------
1 ask Jim Saric from US EPA and Tom Schneider from

2 the Ohio EPA if they'd like to make some comments.

3 MR. SARIC: I guess when I look at

4 the meeting we're having here tonight, the proposed

5 plan for Operable Unit 4 silos, I kind of sat back

6 and started thinking about some of the first times

7 I was involved in this project in 1987 for a few

8 months. And then I went and was working for EPA on

9 another Department of Energy proj ect and came back

10 several years ago in '91, and the K-65 silos were

11 an issue of a very heated debate. They were a very

12 strong public concern.

13 I think if it was the one symbol of

14 the Fernald site that was representative, it was

15 the K-65 silos, and a very significant source of

16 contamination, a very significant source of concern

17 for all of us involved.

18 And I think today we're really at a

19 key pivotal point, a crossroad, where DOE is

20 proposing a remedy, one which we've looked at and

21 reviewed several times as well as Ohio EPA. And

22 we've looked at various options, and we think we've

23 got one that's very reliable, a very good option

24 for handling this material.
-------
1 And, you know, we're hopefully going

2 to be able to move forward. We're encouraging you

3 to come forward with comments on this thing, and

4 then you'll have the Record of Decision coming in

5 in June which will basically begin finalizing this

6 decision. Obviously, if you look at some of the

7 earlier slides, there's still a lot more work to be

8 going on.

9 I mean, this is a decision on what

10 we're going to do, and now it's actually let's go

11 out and do it, remove the silo waste or whatever

12 the action. This will continue, and there's a lot

13 of work to be done, and I think the dates in 2,000

14 are, you know, ongoing as far as when activities

15 will be completed in 2,000 or 2,002.

16 So I guess, personally, I think we're

17 at a big crossroad here, and I guess it's important

18 really to understand what action is being taken,

19 and I encourage all your comments to give. If

20 you've got any guestions, please ask any of us,

21 myself or Tom Schneider, and we can go over those

22 things with you. Thanks.

23 MR. MITCHELL: At the last meeting I

24 showed a new table of organization for the new
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1 officers for the facility over the site, and Tom

2 Schneider has been selected as the Fernald

3 Coordinator, and this is his first meeting.

4 MR. SCHNEIDER: Well, I just want to

5 reiterate what Jim said. I think he said it very

6 clearly. We're at a very significant point in the

7 process. You know, we've all came a long way, and

8 you're all to be congratulated for having stuck it

9 out so long.

10 We're finally at the decision point.

11 We've spent all this time investigating this site,

12 now we're asking the decision. Now is not the time

13 to give up on your involvement, and now is probably

14 the time to make your comments count the most.

15 Your comments on this plan and the future proposed

16 plans is really where you have a chance to make a

17 substantial difference.

18 We along with US EPA participated in

19 the review of these documents and the proposed

20 remediation, but we're always open to your

21 suggestions and comments. So like I said, we look

22 forward to your cooments on this document. If you

23 have guestions, we'll be here to answer them.

24 In the future there will be probably
-------
1 a few more of us from Ohio EPA. We're hiring some

2 more staff, so hopefully that will be a little more

3 proactive to your needs and help you out as far as

4 information you might need. So like I said, feel

5 free to contact me outside of this at the office or

6 wherever. Thanks.

7 MR. STEGNER: Thank you. What we'll

8 do now is, we'll have an informal guestion and

9 answer session. It might be best if you use a

10 microphone back there. If you don't feel

11 comfortable, just stand up and shout it. We have a

12 recorder here tonight. Please just state your name

13 and the guestion, and we'll let the panel pick it

14 up. So whoever wants to be first, feel free.

15 MS. NUNGESTER: I'm Norma

16 Nungester. I'm a Fernald resident, and a member of

17 Fresh. I have a guestion of Dennis Nixon. He made

18 the statement that I don't agree with, and I

19 wondered if he could clarify for me. He said that

20 when you vitrify waste, it reduces radon emanation

21 to that of building materials. To my

22 understanding, when you vitrify radionuclides, that

23 they still are very, very hot.

24 MR. NIXON: That's correct. The
-------
1 concentrate, due that reduction, is the radon

2 generation from the treated waste itself that is

3 significantly reduce. The radon is actually held

4 up, and the surface area is significantly reduced.

5 Did you get every other word?

6 You're exactly right, that due to

7 that fact that there's a significant volume

8 reduction, you actually concentrate the

9 radionuclides, so you have a higher concentration

10 of say uraniun in a set volume, but the radon

11 itself is much less. The generation or the

12 emanation from the vitrified waste is much less

13 than in its natural form.

14 MS. NUNGESTER: Okay, thank you.

15 MS. YOCUM: Edwa Yocum, Fresh member

16 and a resident of the Fernald area. I was asking a

17 guestion, this concerns Subunit C2 on your

18 preferred alternative demolition removal on

19 property disposal. When you were talking about the

20 OU4 NEPA compliance with the substantive cumulative

21 impact up to 250 acres of surface disturbance, does

22 that mean that would be what would be part of where

23 the waste will be put?

24 MR. WOODS: Yeah. Again, we looked
-------
1 at an LRA and assumed on-site disposal.

2 MS. YOCUM: Okay.

3 MR. WOODS: And that acreage would

4 incur areas where waste would be disposed of.

5 MS. YOCUM: Okay. Then, you also

6 are talking about the loss of 220 acres of

7 habitat. Is that included in the 250 acres?

8 MR. WOODS: Yeah. That 250 would be

9 a total that would occur during the short term, in

10 other words, during excavation activities. Once

11 remediation is completed, we would look at

12 approximately 220 acres being permanently

13 committed, so yes, that's correct.

14 MS. YOCUM: Okay, all right, that's

15 what I wanted to know.

16 MS. NUNGESTER: Can you expand on

17 that permanently committed? I missed something.

18 Permanently committed for what, waste disposal

19 facility?

20 MR. WOODS: Yeah, correct.

21 MS. NUNGESTER: Not for the waste

22 itself but for the —

23 MR. WOODS: For the facilities that

24 would house the waste.
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1 MS. NUNGESTER: That's the inground

2 facility, the upgrade vault, as you so say?

3 MR. WOODS: Correct.

4 MS. NUNGESTER: Now can you give me

5 an explanation of what is in an upgrade vault?

6 MR. WOODS: The alternatives that we

7 used for the evaluation utilized the vault concept,

8 which would be a portion of the waste being

9 disposed of below grade, and, you know, basically a

10 portion above. There would be facilities that the

11 waste could be retrieved from, and what we used was

12 the calculation of the area.

13 MS. NUNGESTER: Disposal means

14 permanent?

15 MR. WOODS: Yes.

16 MS. NUNGESTER: But now you're

17 talking interim?

18 MR. WOODS: Well, what I'm saying is

19 the design of the facility wasn't as important as

20 the area that the facility could include. Designs

21 are going to be finalized as we go through the

22 remedial process.

23 MS. NUNGESTER: Well, this is

24 another thing, when you go through the RA and
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1 that's where the final decision and designs are

2 actually made —

3 MR. WOODS: Correct.

4 MS. NUNGESTER: — how can you come

5 out with a Record of Decision before you actually

6 know what the vault is going to look like and if it

7 is really going to do the job?

8 MR. WOODS: No, you cannot reach a

9 Record of Decision until, you know, we've gone

10 through the full analysis of what the vault will be

11 designed like and how it will work. What we did is

12 utilize the alternatives that were available at

13 that time for the purpose of the evaluation, which

14 is really the best we can do. We can't foresee.

15 MS. NUNGESTER: Okay as of today?

16 MR. WOODS: That's correct, that's

17 correct. As we go through the various operable

18 units and decisions are made as to the final design

19 of the vaults and changes are made to the area,

20 that may be required. We'll update tbe analysis

21 and provide it in the future integrated documents

22 for the other operable units.

23 MS. NUNGESTER: Okay. So then our

24 decisions of the -- So your alternatives for the
-------
1 Unit 4 can change by the time after arriving at a

2 decision?

3 MR. NIXON: We were specific with

4 the subunit wastes the Record of Decision. For

5 Operable Unit 4, specifically the Record of

6 Decision, the proposed plan in the future Record of

7 Decision will be that the Subunit C waste is -- you

8 remember us talking about being held in abeyance or

9 delayed operable units, the Subunit C waste will be

10 handled in accordance with the Records of Decisions

11 for Operable Unit 3 and Operable Unit 5,

12 respectively. Okay.

13 So as far as our Record of Decision,

14 essentially we carry it through the removal of the

15 soil, interim storage of that soil in accordance

16 with Removal Action 17, which is the management of

17 those soils, demolition of the structures and

18 storage of that debris in interim until OU3 comes

19 up with a final decision for the debris.

20 OU5 will have a final decision on how

21 the soils will be treated, and those all integrate

22 very well. When we start that remediation process,

23 when we have those soils excavated and stored, at

24 that time Operable Unit 3 and 5 Records Of
-------
1 Decisions will be in place, and we'll have very

2 good integration.

3 At that point we'll be able to

4 deliver -- Theoretically, we'll be able to take the

5 soils out and take those to a Operable Unit 5

6 facility for treatment. They'll be disposed of in

7 accordance with their Record of Decision, and that

8 may or may not be on-site disposal.

9 MS. NUNGESTER: Okay. You're

10 saying, you're taking the debris, the structure,

11 the eguipment, the surface soil, you're putting

12 them all in the underground vaults?

13 MR. NIXON: Operable Unit 4 is

14 delaying that decision. That's going to be

15 actually be stored in an interim fashion --

16 MS. NUNGESTER: Okay

17 MR. NIXON: -- until OU5 and OU3

18 have records of decision. Now, their Record of

19 Decision may very well be that we will treat soil

20 by washing it and disposing of that on site.

21 MS. NUNGESTER: Right, but it

22 doesn't say that, that it's going to be interim

23 until Unit 5 is considered.

24 MR. NIXON: The proposed plan does
-------
1 clearly state, as well as the Record of Decision

2 will clearly state those, that integration.

3 MS. NUNGESTER: It does?

4 MR. NIXON: Yes, it does.

5 MS. NUNGESTER: Okay. Well, I know

6 on the proposed plan booklet on page 43 talks about

7 that specific issue.

8 MR. NIXON: Right.

9 MS. NUNGESTER: If anybody has that

10 book, and they want to look at it, they can, but I

11 don't believe it says — It says something about

12 that it will be combined with 5, Unit 5, but it

13 does not say that would be interim disposal until

14 5.

15 MR. NIXON: Disposal, it is interim

16 storage.

17 NS. NUNGESTER: Or storage, but they

18 use "dispoeal" as the word throughout the whole --

19 MR. NIXON: In the proposed plan,

20 the proposed plan has, for Subunit C waste, it has

21 a selected or preferred alternative which is

22 on-site disposal identified, and the reason that's

23 in there is because on-site and off-site disposal

24 was so close we had to select the one for the sake
-------
1 evaluating the full alternative from start to

2 finish. Okay.

3 Later in the document it talks about

4 the integration effort that will occur with OU3 and

5 OU5, and puts — holds that decision in abeyance

6 for final disposal of those debris and soil until

7 OU3 and OU5 have their Records of Decision.

8 MS. ALLEN: The confusion could be

9 the fact sheet on page 12 states that the soil

10 debris will be disposed of on site.

11 MR. NIXON: There is an error in the

12 fact sheet on page 12, the last paragraph I

13 believe.

14 MS. NUNGESTER: Then, this shows

15 more of a reason why the public should have a

16 comment period before — after -- in between the

17 ROD's and even during the remedial, the RA, then,

18 to underatand it. Thank you.

19 MR. STEGNER: Other guestions?

20 UNIDENTIFIED SPEAKER: I have one,

21 and it goes to back to when you were talking about,

22 Randi about, the community and stake holders or

23 public or whatever we're called these days, plays a

24 part in this process. I'll echo what Edwa just
-------
1 said. We give our comments, then there's a Record

2 of Decision. You respond to our comments, and you

3 follow this thing down.

4 But what if we don't like your

5 responses, you know, I don't see another -- I guess

6 as a stakeholder, which is kind of an okay word

7 these days, I guess I have a little bit of a

8 problem with that because once I give you my

9 comments on this as of April 20th, I don't get to

10 say nothing else, and if you don't like what you

11 choose or I don't like the way you responded to my

12 comments, you know, how am I going to be able to

13 come beck and say I don't like this?

14 MS. ALLEN: Just like with any other

15 primary document, we submit them to US EPA, and

16 that same document also goes over to the PEIC, apd

17 I'm assuming that the Record of Decision will be

18 like any other document in that once it hits the

19 PEIC, you guys are invited and welcome to comment

20 on the docunent and provide comments over to Gary

21 and Ken.

22 UNIDENTIFIED SPEAKER: And they

23 would be considered as official comments? Because

24 as I read this thing here, it doesn't indicate that
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1 at all.

2 MS. ALLEN: It also doesn't in the

3 remedial investigation report, but if you can

4 remember --

5 UNIDENTIFIED SPEAKER: I guess what

6 we're asking for is that we need to be walked

7 through this process, you know. Once the Record of

8 Decision is made, we need to be talked to before

9 your remedial design stuff. We need to be involved

10 in that remedial design stuff.

11 Then we need to talk about the

12 remedial action stuff, and it's going to create a

13 lot of work for people, but we're afraid if we're

14 not walked through that procese that we're going to

15 end up at the end with an alternative that people

16 in this community are really going to be upset

17 with.

18 MS. ALLEN: I think that's where the

19 input on the edition that's coming out of the

20 public relations group is going to be critical

21 because it doesn't take us past the point we are

22 right now, and I think we need to get some kind of

23 idea of what kind of part you guys want to play in

24 that.
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1 MR. PICKLES: Really the FS and

2 proposed plans for Unit 5 is coming out, you do

3 have a comment period. I assume from your comments

4 about what we're doing in the — are you satisfied

5 with the issue; is that right?

6 UNIDENTIFIED SPEAKER: Well, I mean

7 some of us might be. I can't speak for everyone in

8 this room, but, you know, at the same time we're

9 going to walk through this process of designing how

10 we're going to do this, I want to know what's going

11 on and what's happening so I can verbally say I

12 don't like this or I like this or this isn't right

13 or whatever.

14 You know, I don't want to say, yeah,

15 yeah, I'm all for your alternative here, this

16 sounds great, let's do it, and then you don't talk

17 to me until the year 2,000, and I don't like what

18 you did.

19 You know, I think, you know, if we're

20 going to stick through this process as we've done

21 for ten years, and I guese we'll do it for the next

22 how many ever, we want to make sure that we're

23 making good and tough decisions as we move along

24 here so when we get done, we have a cohesive
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1 decision in this community that we can live with

2 what is left here.

3 MR. STEGNER: I think it's safe to

4 say that we'll be involving you throughout the

5 whole entire process, walking you through the

6 process, you and the Citizens Task Foree.

7 UNIDENTIFIED SPEAKER: We need to

8 see that as being a real life thing. Somewhere on

9 here it needs to be written in here we'll talk to

10 the public, we'll seek public input, we'll

11 whatever. That needs to be added in here somewhere

12 because we don't see that in here right now.

13 MS. ALLEN: Well, we almost have to

14 because I'm already getting asked guestions right

15 now that I can't answer until remedial design. As

16 far as long term during final remediation, I don't

17 have the answers right now. So I mean, this

18 process going to have to continue through final

19 clean-up because I just can't answer the guestions

20 right now.

21 UNIDENTIFIED SPEAKER: On February

22 1st the Ohio EPA issued a notice of deficiency and

23 closure. Were those deficiencies ever corrected?

24 MR. Nixon: Which closure plan?
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1 UNIDENTIFIED SPEAKER: On Unit 4,

2 the one you juat gave us an elaborate presentation

3 on.

4 MR. NIXON: I believe there might be

5 some confusion there. Can the State of Ohio clear

6 that up? RECRA Unit 4 Solid Waste Unit possibly,

7 it is not this operable unit.

8 UNIDENTIFIED SPEAKER: Not this

9 operable unit?

10 MR. SCHNEIDER: That's correct.

11 UNIDENTIFIED SPEAKER: So two

12 different hazardous waste units on this facility?

13 MR. SCHNEIDER: This ten's a

14 hazardous waste unit.

15 UNIDENTIFIED SPEAKER: Could we ask

16 them to stand when they speak?

17 MR. SCHNEIDER: We're saying

18 Operable Unit 4 is it not a hazardous operable

19 waste unit, not Operable Unit 4. I don't know what

20 exact letter you may have there, but we can talk

21 about it. I think it's probably a RECRA unit.

22 UNIDENTIFIED SPEAKER: It was issued

23 February 1st out of your office, 1994.

24 MR. SCHNIEDER: Must be a RECRA
-------
1 unit, then.

2 UNIDENTIFIED SPEAKER: Okay. I'll

3 discuss it with you.

4 UNIDENTIFIED SPEAKER: I'm Lou

5 Bogart. I'm a resident of Ross. I have some

6 technical questions. In looking at data tables for

7 Operable Unit 4, one of the things that strikes me

8 is that you always report uranium 254/236. Does

9 that mean there's U-236 there? If so, I don't

10 believe it because U-236 doesn't exist in nature.

11 Secondly, the ratio of U-234 to U-238

12 in many cases look very odd, odd in the sense that

13 in nature and in this ore and in the raffinate the

14 234, 238 ratio ought to be very close to unit. For

15 example, when in the table that you've given a

16 handout, the Silo 1 number looks pretty wrong. The

17 Silo 2 number is more acceptable.

18 And the reason I think that's

19 important is because you're going to focus the

20 clean-up levels on U-238. I don't guite know how

21 you're going to do that without doing some very

22 sophisticated isotopic analysis. But in any case

23 those numbers don't look right, and you see that in

24 many, many tables.
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1 On the inorganic chemicals, is there

2 somewhere in all the OU4 documentation a list of

3 all of the inorganic constituents? For example, I

4 note that in most of the recent documents you don't

5 list gold. Now you can. There is about, about

6 four times as much gold in this material as

7 silver.

8 Just as a side light for my own

9 amusement, I calculated this afternoon. There's

10 about $2.3 million worth of gold in those two

11 silos, and that may not be important, but what

12 other elements are not reported which may have some

13 impact on the processing of the material by

14 vitrification?

15 For example, there should be a fair

16 burden of rare earths, the whole lamprophyllite

17 series should be in these ores, and I don't see any

18 of that being reported. Anybody have an answer for

19 that one?

20 MR. NIXON: Well, you had about five

21 guestions, so I'll start in the beginning. One was

22 235 to 236, those are analyzed and reported the

23 same. You are correct. We don't feel there is any

24 uranium-236 in the residues. It's a good point.
-------
1 Whether the ratio between U-234 and U-238 is

2 correct, I do not have the answer to that, but we

3 can discuss that and get back with you within the

4 next couple of days.

5 MR. BOGART: How about a complete

6 list of —

7 MR. NIXON: Complete list, the

8 remedial investigation did do a complete list of

9 the organics, inorganics. Whether gold was

10 evaluated, I'm not sure. I'm looking at my team.

11 MR. BOGART: You were supplied gold

12 by TLCP.

13 MR. NIXON: But we also do a full

14 HSL, Hazardous Substance List, which gold would not

15 be part of. So I'm not sure whether gold was

16 particularly reported in the RI.

17 MR. BOGART: How about rare earths?

18 MR. NIXON: I couldn't answer that,

19 either. We've got a copy of the remedial

20 investigation here. Whether these fellows can

21 guickly find answers to those questions or again we

22 can get back with you.

23 Amy Engler I know is sitting out here

24 somewhere taking very good notes, and we'll respond
-------
1 to any of the questions which we don't have answers

2 to tonight. We've committed to have answers back

3 within 48 hours from this evening.

4 MR. BOGART: Well, I — not so much

5 for myself, but I think for the general public.

6 MR. NIXON: Any question that is

7 raised even in the informal conference will be

8 addressed in the responsiveness.

9 UNIDENTIFIED SPEAKER: Can we use

10 that gold as collateral, can we use that? You said

11 there's like $2 million worth of gold. Can we use

12 that as collateral somehow?

13 MR. BOGART: It's going to cost 90

14 million bucks, maybe we can make it 88 million

15 bucks. On page 21 or whatever this thing is

16 called, the proposed plan, the spiral-bound thing,

17 on page 12 about the middle of the page is an

18 initiation of a discussion about risk.

19 And this is the area that concerns me

20 the greatest, because although you point out

21 that -- And I presume in all cases you're talking

22 about fatal cancers because there are, of course,

23 nonfatal cancers also. And that's not terribly

24 clear in anything that's written.
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1 Risk from exposure, the radiation

2 naturally occurring in the environment is about 1

3 in 100 primarily from radon; however, incremental

4 risks targeted by the upper end of EPA range means

5 if all persons within a population of 10,000, 1

6 person might get cancer from the exposure, and

7 cancer is expected from all other causes. I think

8 the whole business of risk assessment needs to be

9 put into some kind of context.

10 If you look at the lateet NCRP

11 guidance, 115 and I guess 116, you can talk about

12 risk in terms of about 4 or 5 times 10 to the minus

13 10 and you do the hocus-pocus chemists like to do.

14 And that turns out the average resident from

15 natural radon, that risk becomes about one half

16 times 10 to the minus 2 and the range is 0 to 90

17 years old. And when 90 years old, I guess cancer

18 is the last thing I'm going to worry about.

19 But in any event, you make the

20 statement that the normal cancer risk is about 10

21 to the minus 2, and then you proceed to march down

22 the road of things that are 2 to 4 to 5 orders of

23 magnitude smaller, and it's never put in context.

24 And I think these documents need to discuss with
-------
1 are we paying for, and that becomes a real

2 problem. I don't know how many people feel

3 comfortable with a 10 to the minus 6 risk, and I'm

4 not real sure that that's a fatal cancer risk.

5 There is a problem with the

6 methodology of using the health effect summary

7 table slope factor thing as opposed to methodology

8 that's used by people who do the beer studies and

9 the NCRP studies because we're talking about vast

10 orders of magnitude differences.

11 Now, the last comment I guess, I'd

12 like to see something in these documents that more

13 clearly explains why the CERCLA process has elected

14 to use such abominably small risk estimates.

15 My last comment perhaps goes to EPA

16 back in 1986, was a bad year for me, EPA published

17 a notice of intent that they were going to

18 promulgate residual regulation standards. It is

19 now 1994, and, to the best of my knowledge,

20 residual radiation level standards have not been

21 promulgated.

22 In 1993 in a GAO report to Congress

23 somebody in EPA said that in March of 1994 they

24 were going to finally publish residual radiation
-------
1 standards, not publish them, but they would take

2 them to OMB, which would be the fist step in

3 getting them published -- well, not the first step,

4 but a key step in getting them published in the

5 Federal Register.

6 March 1994 is now. My concern is, is

7 there one part of EPA working on residual radiation

8 level standards which may very well impact on the

9 clean-up levels that are being talked about here

10 for the clean-up of OU4?

11 MR. NIXON: Was there any response?

12 MR. SARCA: Yeah, I can answer that

13 from my understanding. One of the people involved

14 from the EPA perepective that works with me, he's

15 been commenting that he's involved in working on

16 some of those standards. Will they directly impact

17 this investigation, I don't know. I don't think

18 so. Hearing some of the numbers, I think they may

19 even be moving towards the side of being egually as

20 conservative, could be more conservative.

21 I don't know what the final will come

22 out with. When they do come out of the numbers,

23 they'll go to budget and move forward from there.

24 I do know they are being worked on. One of
-------
1 the people from my office is doing that right now.

2 I don't know the exact state.

3 UNIDENTIFIED SPEAKER: If memory

4 serves, I think that the gold Lou was talking about

5 was contained in the pitch blend or whatever it was

6 that came over from Africa that the United States

7 bought and dumped into the K-65 silos. I heard or

8 read that souewhere. You might want to check that

9 out.

10 MR. NIXON: It is in the K-65

11 material, yes.

12 MR. BOGART: It all came from one

13 mine.

14 UNIDENTIFIED SPEAKER: The reason

15 they took that pitch was they wanted to strike

16 gold?

17 MR. BOGART: No, radium and gold.

18 UNIDENTIFIED SPEAKER: As far as I'm

19 concerned, it can be vitrified.

20 MR. BOGART: The guestion was, what

21 else is there?

22 UNIDENTIFIED SPEAKER: Okay. I just

23 have another guestion. When you said they were

24 filling the silos, especially 1 and 2, did they
-------
1 transport it through a pipe?

2 MR. PICKLES: Yes, ma'am.

3 UNIDENTIFIED SPEAKER: That's not

4 what I recall. If my memory serves me correctly,

5 some of that material may have been put in that

6 way, but I remember the workers saying at different

7 times that they also carted barrels out there from

8 the silos.

9 MR. NIXON: Most of the material in

10 Silos 1 and 2 were in a drum form that came from

11 Melloncrock Chemical Works in St. Louis. Those

12 drums were taken to the drum handling building

13 between Silos 2 and 3. The drums were dumped and

14 then mixed into a slurry with water and pumped into

15 the silo and then allowed to settle. The water was

16 decanted off into the decant sump tank, and then

17 that water was used to reslurry additional material

18 coming from off site.

19 The material -- The majority of the

20 material, that was processed here on site, because

21 we did process both at the Melloncrock Chemical

22 Works as well as some of the material being

23 processed here, K-65 asterial being processed at

24 the site in our Refinery Plant 2 and 3.
-------
1 That material as it was processed

2 from the production area at Fernald, it was

3 transported hydraulically in a slurry through that

4 underground trench, through the pipe back to Silo

5 2. But the majority of the material was in drum

6 form and reslurried at the silos.

7 UNIDENTIFIED SPEAKER: I think that

8 should have been mentioned in your report there,

9 you know. It says, from the way I read it,

10 everything went through that pipe and everything,

11 which it wasn't really.

12 MR. NIXON: I tried to talk to that

13 point in showing that one areal shot where you can

14 see all of the large numbers of drums that were

15 being stored by the silos. That is the incoming

16 material that was coming in from Melloncrock in St.

17 Louis and then reslurried at the site.

18 MR. STEGNER: Thank you. Let's take

19 our break now and reconvene for the formal comment

20 period.

21 (A brief recess was taken.)

22 (All panel members except Mr. Stegner stepped

23 down.)

24 MR. STEGNER: This is the beginning
-------
1 of the formal comment section where your comments

2 will be entered to the Responsiveness Summary in

3 the Record of Decision. We will do this as we have

4 some folks who have signed up to make commments.

5 You do not have to sign up to make comments. You

6 can have an open mike at the end. There's only

7 about four or five folks here that indicated they

8 wanted to make comments.

9 Again, you do not have to use this

10 forum to make the official comments. You can

11 submit comments on one of these cards and leave

12 then here at the and of the meeting or you can

13 submit comments to the Department of Energy at the

14 Public Affairs office. We also ask before you

15 leave, if you don't send, to fill out the

16 evaluation forms we have sitting on all of the

17 chairs.

18 The first person we have is Kevin

19 Sorrel. I guess can Kevin's not here.

20 UNIDENTIFIED SPEAKER: There's some

21 folks still out here in the hallway.

22 MR. STEGNER: You want to check out

23 there.

24 UNIDENTIFIED SPEAKER: Not there.
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1 MR. STEGNER: Is Lee Bolver still

2 here?

3 UNIDENTIFIED SPEAKER: He left.

4 MR. STEGNER: Bob, do you have

5 something to say?

6 UNIDENTIFIED SPEAKER: I'll turn it

7 in later.

8 MR. STEGNER: Bob Gessel — Godsel,

9 I'm sorry? Going very well so far. Tom Wagner,

10 Citizens Task Force? Okay. We have an open mike,

11 folks, if anyone wants to make a comment.

12 MS. NUNGESTER: You want my address,

13 too?

14 MR. STEGNER: Not necessary, as long

15 as we have your name.

16 MS. NUNGESTER: Norma Nungester,

17 Fernald resident and Fresh group. I have several

18 comments. First of all, I want to cover again what

19 was stated in the guestion and answer period. I

20 think between the draft ROD and the final ROD we

21 need a public comment official time, and you need

22 to formalize this. On down here below you say the

23 public involvement, public involvement, that means

24 nothing to us. You need to formalize that.
-------
1 And you also need more details on

2 your RD/RA work plan. We want to know more details

3 on transportation. We want to be notified when

4 you're transporting this stuff and talk about the

5 meterials that are actually in the K-65 when

6 they're vitrified and when you start to ship them

7 out to Nevada.

8 Also this stuff that stays on site,

9 I'd like to know how they will be monitored, and

10 for how long of a period they're going to be

11 monitored. I guess I just want to express that we

12 want a guarantee that real-time monitoring will be

13 used.

14 Also a suggestion, how about covering

15 those silos when you start working on them? I

16 think this is one of the most important things you

17 could do for the community. I think that's about

18 it. I'm trying to read ny notes that are chicken

19 scratch here.

20 Oh, one more thing. I'd like to be

21 diligent on referring large guantities of waste

22 from other sites. We don't want anything brought

23 in here from other plants to vitrify with our

24 material or to be put under the storage areas.
-------
1 Thank you.

2 MR. STEGNER: Thank you, Norma.

3 Edwa?

4 MS. YOCUM: Edwa Yocum. Some of

5 this will sound repetitious, but I'm asking for a

6 public comment period between the ROD's, the draft

7 and final; and we need an official public comment

8 period after the RA process. And also I'm asking

9 for a public comment period between the beginning

10 and completion of remediation. And then, too, when

11 dismantling the K-65 silos and also the 3 and 4,

12 I'd like to have a protective cover be used around

13 the silos.

14 And as far as I read in there, that

15 EPA would be reviewing the vault or the disposal

16 sites every five years, I'd like to know the

17 definition of "reviewing," and I would like

18 continuous monitoring and maintenance of on-site

19 disposal vaults or at least one time a year as long

20 as they're on site. And also, who would be paying

21 for this monitoring and maintenance? And this way

22 I recommend a trust fund for monitoring and

23 maintenance of the disposals.

24 MR. STEGNER: Thank you, Edwa. Open
-------
1 microphone still, folks. Thank you all very much.

2 - - -

3 MEETING CONCLUDED AT 8:45 P.M.

4 _ _ _

7
9

24
-------
1 CERTIFICATE

2 I, LISA CONLEY, RPR, the undersigned, a notary

3 public-court reporter, do hereby certify that at

4 the time and place stated herein, I recorded in

5 stenotypy and thereafter had transcribed with

6 computer-aided transcription the within (65),

7 sixty-five pages, and that the foregoing transcript

8 of proceedings is a complete and accurate report of

9 my said stenotypy notes.

13 MY COMMISSION EXPIRES: LISA CONLEY, RPR

14 JULY 28, 1994. NOTARY PUBLIC-STATE OF OHIO

24
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SUMMARY OF MEETING MINUTES
COMMUNITY ADVISORY BOARD FOR THE
NEVADA TEST SITE

DATE: May 11, 1994
TIME: 7:00 P.M. - 9:30 P.M.
PLACE: THE ALEXIS PARK RESORT
LAS VEGAS, NEVADA
SUBJECT: PROPOSED SHIPMENT OF FERNALD, OHIO LOW-LEVEL RADIOACTIVE WASTE TO THE NEVADA TEST SITE

SPEAKERS: Page
For the Government:

Jack Craig 9
Joe Fiore 7
Dennis Nixon 9
Layton O'Neill 13
David Rast 6

For the CAB Members:

William Vasconi, Chairperson 18
Dennis Bechtel 5
Chris Brown 8
Lathia McDaniels 7
Richard Nicolla 8
E. Paul Richitt, Jr. 11
Joanne Stockill 6
Katherine Yuracko 11

Ex Officio Members:

Joe Fiore 7
Paul Liebendorfer 7

For the Public:
Don Hendricks 12
Jerry Sieren 15
Michael Verrilli 15
John Walker 10

ATTENDEES:

DOE AFFILIATES:
Jack Craig, USDOE/FN
Leah Dever, DOE/NV
B. Dozier, REECO
J.E. Evered, FERMCO
Sharon Faurer, DOE/HQ
Joe Fiore, DOE/NV
Wendy A. Griffin, DOE/NV
Patricia Herrin, REECO
Warren Hooper, FERMCO
Steve Housen, FERMCO
Allene Kitchen, DOE
Joe Kitchen, DOE/NV
David Lojek, DOE/FN
-------
Darwin J. Morgan, DOE/NV
Dennis A. Nixon, FERMCO
Don Ofte, FERMCO
Layton O'Neill, DOE/NV
Brian Perkins, REECO
David Rast, DOE/FN
Myrle Rice, IT Corp.
Kevin Rohrer, IT Corp.
James Saric, USEPA/Region V
Bonnie Thompson, DOE/NV
Pam West-Thompson, RSN
Donaid Wruble, PAI
Runore Wycoff, DOE/NV
CAB MEMBERS:
Name
Address
Richard Arnold
Dennis Bechtel
Chris Brown
James Henderson
Marilyn Littlepage
Lathia McDaniels
Richard Nocilla
E. Paul Richitt, Jr.
Joanne Stockill
Bill Vasconi
(Chairperson)

Katherine Yuracko
2300 W. Bonanza Rd.
Las Vegas, NV 89106

319 Encima Ct.
Henderson, NV 89014

P.O. Box 1681
Las Vegas, NV 89125

6712 Reggie
Las Vegas, NV 89107

1851 Balzac Dr.
Las Vegas, NV 89115

2396 Valley Dr.
Las Vegas, NV 89108

823 Spyglass Ln.
Las Vegas, NV 89107

3575 W. Badura Ave.
Las Vegas, NV 89118

4625 Kay Place
Las Vegas, NV 89107

6565 West Atwood
Las Vegas, NV 89108

5708 Stallion Ave.
Las Vegas, NV 89108
EX-OFFICIO MEMBERS
Paul LiebendorFer
333 W. Nye Ln.
Carson City, NV 89710
-------
Joseph N. Fiore
P.O. Box 89193-8518
Las Vegas, NV 89193
PUBLIC CITIZENS:
Name
Address
George Blankenship
Jim Buchanan
Sydney Gordon
Don Hendricks
Rob Santa Maria
Tom Schneider
Gerald Sieren
Michael Verrilla
John B. Walker
P. I.C. 1820 Grant
Denver, CO 80203

2021 Girard #8E
Albuguergue, NM 87106

4295 E. Reno Ave.
Las Vegas. NV 89120

609 N. Crestline Dr.
Las Vegas, NV 89107

368 Pleasantview Dr.
Lancaster, NY 14086

40 South Main St.
Dayton, OH 45402

3439 Andalusia PI.
Las Vegas, NV

2985 Montessouri St.
Las Vegas, NV 89117

Capitol Complex
Carson City, NV 89701
REPORTED BY:
Wendy J. Pullium, PAI
Transcriber
CALL TO ORDER:
The meeting was called to order at 6:10 p.m.
The purpose of the evening's meeting was for two presentations. The first presentation was furnished by
representatives of the U.S. Department of Energy Fernald Field Office located in Cincinnati, Ohio. The
second presentation was presented by the Waste Management Division, U.S. Department of Energy, Nevada
Operations Office.

Each presentation was followed by a question and answer session from the NV/CAB and the public.

Joe Fiore announced that the state of Nevada had made a request in response to a draft Environmental Impact
Statement issued by Fernald which described the activities which result in waste being transported to the
Test Site, and the request involved extending the public comment period on that document for 60 days to give
the Community Advisory Board of the Nevada Test Site Programs (NV/CAB) an opportunity to understand the
situation better. In response to that, Fernald agreed to extend the comment period by 30 days. The original
closing date for comments was April 20th; it is now May 20th. This meeting was being held in time for
comments to be put together in the next nine days.

FERNALD'S PRESENTATION:
-------
Dave Rast from the Fernald Field Office gave a summary on the proposal to transport and dispose of low-level
radioactive waste at the Nevada Test Site's radioactive waste management site. The waste will be generated
in the cleanup and environmental restoration of the DOE's closed uranium production facility near Fernald,
Ohio. If the proposed and subseguent actions are implemented, approximately 300,000 cubic yards of
radioactive waste will be disposed of at the NTS. Disposal activities would cover a period of approximately
30 years. Copies of the slides presented are attached.

QUESTIONS AND ANSWERS:

At this time, each Board member introduced him/herself and then proceeded with their individual guestions
and/or comments.

DENNIS BECHTEL: First I would like to thank you for sharing information about the site. I had the
opportunity to visit Fernald several years ago as a member of the EMAC board. Could you possibly translate
your numbers, your 300,000 cubic yards and your annual figures in numbers of shipments, and what they might
mean?

DAVE RAST: We get approximately 18 cubic yards of waste on the average on a shipment. If I do the simple
math and just divide it by 20, that is 15,000.

DENNIS BECHTEL: So that's potentially what? Three thousand trips a year, and you are looking at FY96 here?
(No response given.)

JOANNE STOCKILL: What kind of shipments are you talking, rail or truck?

DAVE RAST: Truck. Currently the only mode of transportation we have off site is truck shipments. We have
been looking at rail shipments. Currently, the rail at Fernald is light gauge rail and cannot support heavy
shipments, and we have some local rail in the area that is in need of repair before I would attempt to effect
any shipments by rail.

JOANNE STOCKILL: Is that true of the 600,000, you are going to put in commercial sites?

DAVE RAST: Yes.

DENNIS BECHTEL: Follow up on the guestion I had. When you plan your shipping campaign, what sort of
coordination do you do with state and governments and particularly the state of Nevada? How do you handle
that?

DAVE RAST: Currently, we haven't done any coordination from Fernald in emergency preparedness. DOE
established a radiological response team and divides the contaminant into areas for response in a case of a
transportation emergency. We also effect training for our shippers. We also have a designated route for
which drivers are to transport shipments. They also have a designated call-in time; they have to report at
least once every 24 hours. Many of the trucks are being eguipped with satellite tracking eguipment. The
drivers also have all the emergency contact information in their transportation file within a packet and the
bill of lading transportation documents.

DENNIS BECHTEL: Where would those designated routes be in Nevada? Would they be interstates?

DAVE RAST: Interstates where possible. You can't get to the Nevada Test Site via interstates. They usually
come across 95 over 15, up 15 and back out 95.

DENNIS BECHTEL: So right through Las Vegas?

DAVE RAST: Yes, sir.

LATHIA MCDANIELS: Can you tell me what steps are implemented to insure that we don't accidently get mixed
low-level waste shipped to us?
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DAVE RASP: To insure that we don't get mixed waste transported to the Nevada Test Site, there is an
extensive characterization and certification program established by the Nevada Field Office. That
certification program is defined in their Waste Acceptance Criteria Document, NVO-325. We adhere to the
conditions established in that document.

We perform a review of our waste on a waste stream by waste stream basis. We also maintain control of
containers; maintain control of who has access to waste disposal facilities such as our dumpsters on site
have locks on them. Only designated personal have the ability to put trash into a dumpster, or to put any
kind of material into a waste container. We are implementing even tighter controls now on waste containers.

We do do sampling analysis of some materials, characterizing them under the RCRA regulations to check for
hazardous constituents, to make sure they are not a mixed waste. We maintain those characterization files at
the site. They have been reviewed by the representatives from the Nevada Field Office and also from the
Nevada Department of Environmental Protection on some of our waste streams.

LATHIA MCDANIELS: But there is no outside agency that has the hands-on ability to review while you are doing
it?

DAVE RAST: Before we are allowed to ship to Nevada Test Site, they review the characterization files for the
waste streams. Before that waste stream is approved for acceptance, they review it.

LATHIA MCDANIELS: When you say "they," who?

DAVE RAST: Nevada DOE field office.

JOE FIORE: We adhere to a very rigorous waste acceptance process. That includes formal submittal of
applications from waste generators. But to specifically answer your guestion, part of that process involves
oversight by the State of Nevada, Division of Environmental Protection. So that's the independent non-DOE
part of the thing.

PAUL LIEBENDORFER: I will say, we probably made a significant impact on all the waste that is shipped out
here from—not just Fernald but the other places as well--on the level of guality of the waste.

LATHIA MCDANIELS: Are you satisfied (Paul Liebendorfer) that we are not and we will not be getting any mixed
low-level waste?

PAUL LIEBENDORFER: Within the documents we have seen so far

LATHIA MCDANIELS: Outside of the documents; your personal feelings?

PAUL LIEBENDORFER: I think at this point in time, there has been nothing raised. Maybe I should take a step
back. There was a shipment that came in a couple years ago of thorium waste that we had great concerns about
because of what we perceived to be a lot of inadeguate documentation to support the position. We went around
for about eight or ten months on that.

I actually went back, and they did some resampling of some containers that were left there, and observed the
days worth of sampling and the evaluation, and insisted on additional information to be presented to be
included in the waste package to support their position. After conclusion of that particular round, we felt
that they, at that point in time, did have the ability to demonstrate that those documents coming back in,
that, thorium waste, were in fact, not a mixed waste. They have implemented a process that we don't look at
every waste stream. We are able to audit any waste stream we reguest.

Obviously, we cannot go to every site and look at every package, so we have got to the point where DOE
conducts an audit and we audit DOE.

RICHARD NOCILLA: I have been wondering if apart from the tradition of bringing your waste to the NTS, is
there another disposal site?
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DAVE RAST: We have disposed of waste at the Envirocare Facility in Utah and recently made some additional
shipments to a facility. Currently, under the current DOE regulations, the Nevada Test Site is the assigned
disposal site for Fernald. Now, we are working on petitions to get the exemptions to dispose of low-level
waste at commercial disposal sites.

CHRIS BROWN: What kind of half lives do the various radionuclides that you mentioned have?

DAVE RAST: The primary radionuclides that we have on site are uranium and thorium. I think the uranium is
ten million years and thorium is a billion.

CHRIS BROWN: And do you all make highly enriched or low enriched?

DAVE RAST: We only made low enriched uranium. We have some material that is for sale that is approximately
20-percent enrichment. We have limited guantities of that. Approximately, I think 50 pounds of the
20-percent enrichment material which is currently on the block for sale, and more than likely it will be
sold.

The highest enrichment we typically dealt with was 1.25 percent, which is about half a percent over normal.

CHRIS BROWN: The relation of this process of choosing the NTS and being designated to the PEIS process, I am
curious because it has up to six possible sites for low-level waste to be sent throughout the complex. I'm
wondering if Fernald would give consideration to a site more proximate to it through the PEIS process?

DENNIS NIXON: I believe he is referring to potential sites that could be constructed in close proximity to
the Fernald site, and we have essentially found that not to be implementable at this time and cost effective
for the small guantity of waste.

CHRIS BROWN: Three hundred thousand cubic yards is not a small amount.

DENNIS NIXON: The proposed action is only 13,000 cubic yards. The 300,000 is the total volume for the site.

CHRIS BROWN: Well, out of all the numbers you threw out at us, which 13,000 cubic yards?

DAVE RAST: Operable Unit 4 residues is the proposed action right now.

CHRIS BROWN: So, are you going to tier following EIS's on each of the operable units, and if so when will we
be seeing those?

DENNIS NIXON: This is the 13,000 for this action with Operable Unit 4, and we talked about reducing that to
6,000.

DAVE RAST: Each of the follow-up operable units has an accumulative effect. As you get to the decision
point in each of the other operable units, they will tier that effect into environmental assessment for each
of the operable units, and those will be coming out at the dates that you see the arrow pointed to at this
time.

CHRIS BROWN: So, if your presentation talks about the accumulative impact, the answer, we are only dealing
with 13,000, which really isn't relevant. We are dealing with the whole thing. These things are coming out
one after the other in the space of a year here, except for Operable Unit 3 which is going to take a few
more. We are basically talking about the whole volume, not just the 13,000.

JACK CRAIG: The document you have now is for Operable Unit 4. It is only making a decision on the 13,000
cubic yards. Like you said there will be follow-up documents that will also finalize the decision on the
other operable units.

If, through this process, all the leading alternatives are selected, you will get a chance to look at each
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one of those individually. And, those will add up to 300,000 if the leading alternatives are selected, but
you will get a chance to comment on each one of those as they come out. But this document you are looking at
now is only making a decision on the 13,000 cubic yards.

The other number that leads up to the 300,000, you will be able to comment on that later through the
submittal of the following-up documents.

JOHN WALKER: I haven't heard any discussion about the alternatives for on-site disposal. Even though it is
not the preferred alternative, it is an alternative that you did examine. Would you like to discuss those
alternatives? The alternatives for keeping it all at Fernald on site.

DENNIS NIXON: I think that what I'm addressing here is just the proposed action, which is again the 13,000
cubic yards which is Operable Unit 4. There are various reasons why. We evaluated a full range of options
and alternatives for both on-site and off-site disposal, various treatment options, etc. We chose the NTS
because it performed the best out of all the alternatives that we evaluated, and these are the reasons why
the NTS was rated better over on-site disposal. Also there are some real show stoppers when it comes to
on-site disposal with this waste whether it's hydrology which Dave has covered; the climate, we have a lot of
rainfall compared to what we would get in the desert here; the demographics of the area, there is a large
population in close proximity of the site; the land use scenario is an agricultural land use, so there is a
greater possibility of intrusion on the waste that was disposed of on site.

These things are resolved at the NTS. It is an arid climate; there is a very low population; there is very
low probability of future intrusion on the waste; it's probably not going to be farmed in the future; the
hydrology, geology, all that is very favorable to disposal of this waste at NTS.

JOHN WALKER: But there are some doable engineering systems where you can keep the waste on site a long
period of time; is that correct?

DENNIS NIXON: That is correct. However, it does not completely pass the threshold criteria which we look at
in the evaluation of the alternative. For one, it does not comply with all applicable, relevant, and
appropriate reguirements which are essentially the regulations that are applied to our site.

JOHN WALKER: I just want to make the point that there are alternatives to the preferred action that just
didn't seem discussed at all.

DENNIS NIXON: We fully evaluated on-site disposal. This is the list of alternatives we evaluated in the
Feasibility Study. For the Silo 1 and 2 material, or K-65 material, we have to evaluate no action, which
obviously is a good solution for this particular operable unit.

We evaluated on-property disposal with various treatments, stabilization options as well as off-site disposal
here and the NTS. We have not identified another off-site disposal facility that was available to this waste
stream.

For the Silo 3 contents, essentially the same alternatives were evaluated. Subunit C being the debris and
soils on other structures, etc., was review and evaluated and that will be disposed of on site most probably
assuming that the Operable Unit 5 waste is selected for on-site disposal.

KATHERINE YURACKO: Well, this is what I wanted to see, but now I want to know why are the only possibilities
on site in Nevada?

DENNIS NIXON: Well, these are the alternatives. We listed and reviewed and evaluated a lot more
alternatives than this, but not all alternatives passed the threshold criteria, which was to be protective
and to be able to comply with all the applicable, relevant, and appropriate reguirements such as disposal at
another commercial site. We cannot identify a commercial site such as the Envirocare Site. We cannot meet
their acceptance criteria.

DENNIS BECHTEL: How much does cost effectiveness enter into it?
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DENNIS NIXON: Well, I don't want to say it's low on the totem pole, but it is certainly less important than
the threshold criteria and being protective of the human health and the environment. It is also the most
cost-effective alternative.

PAUL RICHITT: With respect to the on site, what is the alternate plan used for Fernald Site after you finish
remediation?

DENNIS NIXON: We have a citizen's advisory board at Fernald that is determining that very issue. We have
not determined what the final land use for Fernald is.

PAUL RICHITT: Because you vitrify the waste, you reduce volume, you are going to stabilize it so it can't
migrate. You are going to bring it to the Test Site; the whole premise is to say the waste materials will be
held and stable. If that is the case depending on what you are going to put the Fernald Site to, you may
have the same benefit by leaving it on site and not have to worry about transportation where you may
introduce additional problems. So, is your basis for decision made before you have an alternate-use
determination on the Fernald Site?

DENNIS NIXON: We don't believe so. Again, on-site disposal does not pass the threshold criteria, and we
cannot meet all the applicable, relevant, and appropriate areas. We cannot insure that we--in the long term
over a thousand-year period—that we would not have intrusion due to the land use and the demographics of the
area.

JOANNE STOCKILL: Is there any assurance there would not be intrusion at the Nevada Test Site in a thousand
years?

DENNIS NIXON: No, there is not. However, it is less likely.

BILL VASCONI: Are there any guestions to be addressed from the audience?

DON HENDRICKS: Several months ago EPA took the position to DOE that the K-65 waste as well as some other
high-thorium waste should be classed as greater than Class C waste. If by definition, you take that at face
value, that means you should not dispose of those wastes in near-surface repositories. This doesn't guite
seem to go along with that.

I would also assume that because you have reduced the volume and you have upped the concentration, which
makes it even more significant.

DENNIS NIXON: That is true. The vitrification reducing the volume makes a more dense waste form. It does
concentrate the radionuclides. I would just say that this waste is not high-level waste. It is not
transuranic waste. It's categorized as lie (2) by-product material. Even though the EPA Region V has applied
40 CFR 191, which is the regulation which controls high-level and transuranic waste, that was felt to be that
our waste was enough like—due to the long-lived content and long lived alpha emitters — like the radium and
thorium and uranium series, that we should consider that in our decision for the waste stream, and which we
did in the document.

CHRIS BROWN: In terms of projected disposition at varies places, some on site some commercial and some NTS,
how does that work out in terms of radioactive hazardous materials, etc.

DENNIS NIXON: I think that all the waste that Dave spoke of was low-level radioactive waste.

DAVE RAST: All the waste that is projected in that is low-level radioactive.

CHRIS BROWN: The commercial stuff, is there any chance it will be sent to an incinerator?

DAVE RAST: Most of the material that we are looking at disposing of commercially is not amiable to
incineration. It's soils, it's a sludge material out of our waste pits: it will need some drying. Most of
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the drying technique that we are looking at is either a (unintelligible) drier or we found compaction and
super compaction is a much more effective drying technique than incineration. Incineration is very
expensive. Any kind of thermal treatment chews up massive amounts of energy, and you can run a 5,000-ton
press a lot more energy effectively than you can an incinerator.

JOANNE STOCKILL: I wanted to ask Joe, should this shipment go to the Test Site where would it be and how
would it be stored? Would it be in Area 5?

JOE FIORE: Yes. It would be treated as low-level waste as it is defined by our current DOE Orders, and the
bulk of it would go to Area 5 or Area 3 which is nearby.

KATHERINE YURACKO: I'm now confused as to what this stuff is we are talking about. Did you say this stuff
was regulated under the 40 CFR 191?

DAVE RAST: No. 40 CFR 191 was applied as a relevant and appropriate regulation to be considered. It is not
a high-level waste product. It is a by-product from a leaching operation. The US/EPA Region V felt that if
we wanted to dispose of that material on site, in our management of that material, we would have to follow
the 191 guidelines.

KATHERINE YURACKO: Knowing nothing more than EPA Region V, that sounds reasonable to me. How does the
facility you're talking about putting it in at the Test Site compare with a 40 CFR 191 facility?

JOE FIORE: We have done some performance assessments, Kathy, consistent with both 40 CFR 191 and the DOE
Order, and I think we have some preliminary results. I'm not certain I know them or I can explain them very
well. Layton, do you know what the preliminary results are?

LAYTON O'NEILL: Yes. They showed that the situation that we have will satisfy the 40 CFR 191, and we need
more data to affirm that.

JOE FIORE: Let me explain. The Order we are applying for our low-level waste disposal, the Order that we
must meet is that for low-level radioactive waste performance assessments described in a DOE Order, but that
is the prescriptive role to meet. The consideration of 40 CFR 191, I believe, is a more rigorous requirement
and I think we are trying to demonstrate that we also meet that, but it is not a requirement that we do meet
that for disposal of low-level waste.

KATHERINE YURACKO: But it sounds like the only reason it can't go is at Fernald is because they require that
they comply with 40 CFR 191, and so it is coming here because there is no requirement in Nevada to comply
with 40 CFR 191. Have I understood that right?

DENNIS NIXON: That is not entirely true. There is another regulation, an OAC (Ohio Administrative Code)
regulation, which would prohibit tne location of a disposal cell over a sole source aquifer, which we would
not comply with as well with this particular sighting of a disposal cell for this type of waste.

KATHERINE YURACKO: Let's say this is 40 CFR 191 waste. We have got 40 CFR 191 facilities all over this
country. Can't we put this in one of them?

DENNIS NIXON: I'm not familiar with the locations of those facilities.

KATHERINE YURACKO: Well, there is this kind of waste elsewhere; right? Isn't this similar to mill tailing
waste we have got all over the country?

DENNIS NIXON: No, I don't believe so.

KATHERINE YURACKO: It's originated under the same regulations.

DENNIS NIXON: Right.
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KATHERINE YURACKO: We have facilities constructed around this country under this regulation. But you are
saying that none of those can take this waste?

DENNIS NIXON: Right.

JOHN WALKER: I don't think there are any facilities under 191. I think WIPP is the only facility that they
are looking at for 191. I think 191 was thrown out or set aside on Yucca Mountain. They are trying to fix a
standard for Yucca Mountain, but 191 is only being applied to WIPP at this point, which is transuranic waste,
which is long-lived much like uranium.

KATHERINE YURACKO: Then WIPP is an alternative for this?

JOHN WALKER: No.

KATHERINE YURACKO: I am not getting what this waste is.

DENNIS NIXON: I think this is a very important issue that we have discussed hundreds of times over the last
two years. The reality of the matter is that this waste is not 40 CFR 191 waste even though the US/EPA
Region V has told us to consider it as relevant and appropriate. The DOE does not agree with that position
and has put forward a position paper that would identify that they do not concur with that position.
However, the ARARs (Applicable, Relevant and Appropriate Reguirements) that we are reguired to work on under
CERCLA, they are addressed by the Agency. We cannot negotiate those. Those are not subject to any kind of
negotiation. We do not consider this 191 waste. It is clearly not high level, it is clearly not
transuranic, which is the intent of that regulation.

The reason why it was applied to this waste is because it has greater than 100 nanocuries per gram of
long-lived alpha-emitting radionuclides like uranium, radium, and thorium series. Those are enough like what
is governed in 40 CFR 191 for Region V to make it relevant and appropriate in their minds.

MICHAEL VERRILLI: I have some guestions about containerization of the material. How is that done? Is the
material containerized there and then placed at the Test Site in the containers, or is it removed and then
placed in other containers? The current shipments.

DENNIS NIXON: It is all containerized at the Fernald Site. It is not removed from the container before it
is disposed.

MICHAEL VERRILLI: What kind of health hazards would those pose in the event of a breach of a container on a
public highway?

DENNIS NIXON: Not being a health physicist, I'm not going try to take a guess on the health hazards. Most
of the material we ship and most of the material that is transported to the Nevada Test Site has material
that has fixed contamination or it's a nonsmearable, nonreleasable contaminant.

MICHAEL VERRILLI: So it is a contaminant that you would have to have long exposure to be damaged?

DENNIS NIXON: Right. And uranium, itself, is not a high radiological risk.

MICHAEL VERRILLI: The disposal at the Test Site itself, is it buried, is it above ground?

DENNIS NIXON: It is shallow-land burial.

JERRY SIEREN: A private citizen. One of the major news services this morning reported, I think it was the
Review Journal, that the State of Ohio has become the leading candidate to host a commercial low-level
radioactive waste disposal site. And the reason they have become the leading candidate is because the state
of Michigan has been thrown out of the Midwest States Compact, because it refused to host the low-level
radioactive waste site, and Ohio is the next largest producer of low-level radioactive waste in that Compact.
A representative from the State of Ohio Environmental Protection Agency was guoted in the newspaper article,
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stating that the site would be located in Southern Ohio farm country due to lack of political clout in that
area.

That was just introductory. My question: Was this site that is being considered now be located in the state
of Ohio and presumably deemed acceptable for low-level rad waste, was it considered for the OU4 waste? And
if not, why not, and could it be considered for that rad waste?

DENNIS NIXON: We considered a regional disposal alternative. If you look at the OU4 documents, that was one
of the unsighted low-level waste disposal cells within 300 miles of Fernald and was evaluated as an option.
The current low-level waste repository for Ohio has gotten the honor to site within their state is part of
the Compacts' low-level waste disposal sites under the Low-Level Waste Policy Act. And just by virtue of
that Act and within the terms of that Act, DOE is prohibited from using those sites.

JERRY SIEREN: Is the site in Utah? Envirocare?

DENNIS NIXON: It's not a Compact site.

JERRY SIEREN: It does accept commercial low-level rad waste?

DENNIS NIXON: Yes, it does. But it's a private site.

A 10-minute break was called for after the Fernald segment and the group reconvened at 8:30 p.m.

WASTE MANAGEMENT DIVISION'S PRESENTATION:

Layton O'neill gave a slide presentation on the DOE Nevada Operations Office, Waste Management Division's
current low-level radioactive waste management program. Photographs of Nevada Test Site Area 5 and Area 3
waste disposal facilities and practices, and subsurface monitoring wells and holes, were shown and described.
Research results showing surface water does not seep below 20 feet down from the surface, and so does not
travel down to the 800-foot deep water table, were described.

QUESTIONS AND ANSWERS:

KATHERINE YURACKO: First of all, I have a lot of questions, and I frankly don't think we are going to get
through all of this tonight. I'd like to start off with one if I can. I heard that Ohio thinks this is
lie (2) material, and my comment earlier was DOE has lots of lie (2) material, has lots of lie(2) disposal
sites around the country. Now, Layton was kind enough to direct our attention to Chapter IV of 5820.2A which
addresses lle(2) material, and I'd like to read--I was skimming that—and in Chapter IV, Section 3a(l), it
states right here, "disposal sites should be identified and developed as needed in support of DOE remedial
actions, and will normally be located in the state in which the wastes were generated." So, I still don't
understand what's going on here.

LAYTON O'NEILL: Well, I will tell you what we did. When we started getting into this lie (2) waste proposals
to come to Nevada Test Site, we wrote a letter to Headquarters and said, provide us guidance because there is
not enough in the document on that Chapter. So we are waiting to hear from Headquarters on further guidance
on what they want us to do. That's all I can answer you. We don't have proper guidance from Headquarters on
what to do with that material.

KATHERINE YURACKO: I guess one of the things I am still hung up on is this notion that the only two
possibilities were on site and Nevada, and then it couldn't go on site because this was lie (2) material, and
so Nevada was the only alternative. But how about doing an evaluation of other lie (2) disposal sites?
lie (2) is CFR 192. There are a number of facilities in this country that are regulated under the 40 CFR 192
that are taking DOE material, and so I'm just confused on this.

DENNIS NIXON: I'm not sure which sites you are particularly referring to. We have identified no other sites
that could accept this material now. Not because it's 11 E2. Just being a low-level waste, it is not a mill
tailing.
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KATHERINE YURACKO: Well, that's what I'm confused about. I mean, I was told it's lie (2), and now you are
saying it's not really so, and it can't go into an lie (2) facility. Have you done an examination? There are
lots of those facilities. Let's take Grand Junction. Have you done an examination of putting this material
in the Grand Junction facility?

DENNIS NIXON: No, we have not. However, Dave can address those other disposal sites.

DAVE RAST: Most of the other sites and everything for UMTRA disposal are for native North American mill
tailings; and in particular, once you look at mill tailings that came off of those sites, and they were taken
out and used throughout the country verses the leachate from the K-65 materials. In that process there is a
higher concentration of radium in those products than we find within the UMTRA mill tailings. So, all the
performance assessments done for the UMTRA disposal sites are not driven to the levels of the material that
we have in the silos.

KATHERINE YURACKO: So this facility on the Nevada Test Site is more protective than a 40 CFR 192 facility?

DAVE RAST: Yes. Given the information of the performance of the cells that we have and we have looked at
the NTS, yes.

DENNIS BECHTEL: I do have a general guestion for Layton. How did you happen to pick the sites? It seems
like they are right on the boundary of the Test Site; Area 3 and Area 5, the low-level sites.

LAYTON O'NEILL: It was picked in 1953. It is fortuitous, according to my knowledge and information, about
what happened to the NTS. They searched around in the United States for a number of years to find a place to
test weapons, and they finally settled on the Nevada Test Site, and they said this is a good place to test
weapons.

I understand about five years ago, or maybe ten, they reinitiated that investigation, and went out again and
looked all over the United States to find out where the best place would be to test nuclear weapons, and they
ended up with the Nevada Test Site again. Now, we were fortuitous in picking the location we did, because,
it is a long ways to the ground table, and I think the early guys knew a little something about that. So, we
just bought into that. As I told you, we knew something about the depth to water from the other wells.

Area 5 is 800 feet to the water table. And there are a couple of studies that were done right near to us,
radiation migrations studies, that were done where we pumped water out of a well 100 feet from an original
detonation, and we pumped on it for 14 years. And the first thing we saw was at the end of two years of
continuous pumping day and night on that well, we saw tritium coming across, and we pumped on it again and
the tritium got to its maximum concentration at five years, and then it started to decay away again.

The people that studied the ground water at NTS say that it moves something like 11 feet a year, and that's
all it moves. We forced moving it by pumping down on it and keeping that pumping going for 14 years. So, it
is absolutely a good place, and it's very dry underneath us.

In the Area 3 area, the water table is at 1300 or 1500 feet below the surface of the land. So, we think
fortuitously they are both good locations, and we looked into that when we started Area 3. I told you we
picked an area where the detonation was at least 500 feet above the ground water table, and so we know we
have got 500 feet of basically unbothered soil beneath; if nothing else, it is probably compressed by the
weapons tests.

BILL VASCONI: Realizing the site characteristic studies and the fact that it is bound to be a better place
than along the Miami River back in Ohio, my guestion would be, you do have an ample supply of holes at the
Test Site to have your dumps, and I'm sure it can get shipped here. Is there any benefit to be derived from
the state of Nevada for bringing in the waste?

LAYTON O'NEILL: Well, I think that depends on who you talk to. For mixed waste, the state of Nevada was
gaining $20 a ton for the cement blocks we were putting in the ground. That's pretty good business for the
state of Nevada. They could also do that for other waste, I believe. They could charge a tariff on the DOE
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if they so chose to.

BILL VASCONI: Yes, accepting that it's a federal land and you are bringing in federal waste; is that not
true?

LAYTON O'NEILL: Yes, sir.

BILL VASCONI: So the benefits to be derived for Nevada would be negotiating for the waste in tonnage and/or
condition of; right?

LAYTON O'NEILL: I believe so, and we think that the waste is not going to get into the ground water table,
so we think they are not going to be harmed any.

JOHN WALKER: Just on the guestion of money and benefits, it seems to me that DOE receives the disposal funds
from its off-site generators. Isn't that the case that derives some of the waste management budget?

JOE FIORE: Yes. DOE takes out of the one pocket and puts it into another. We provide a budget for the
generator site and as we receive it, they pay us so much per cubic foot. So overall, the DOE, the disposal
of it, is funded by the Department.

LAYTON O'NEILL: Last year we had excess money and Reynolds Electrical and Engineering Company was forced to
return two million dollars; I think it was, to Headguarters, because we had more money than we were suppose
to spend. So it was returned to the Treasury.

JOE FIORE: And to the extent that those funds support workers at the Test Site and their jobs, that's the
extent of the benefit to the economy of the state.

JOHN WALKER: It's a federal activity, clearly not a state activity.

JOE FIORE: Correct.

JOANNE STOCKILL: Many years ago there were discussions about the state charging a fee for use of Nevada
roads and transportation. Has there been any recent discussions on that, for Nevada to gain some money from
shipments that are going to the Test Site?

PAUL LIEBENDORFER: I can speak to recently. I believe it is Nye County that has looked into some of those
situations. I would believe a separate tax to use the roads, within a road use, would be Department of
Transportation, typical to any trucking activity that went over it. I do know a couple of counties that are
actually looking at determining whether or not they could assess waste shipments that come back in to support
county emergency response activities. And I do know one of the counties is actually looking at that to
support their emergency response if something would happen on a road, but just a separate assessment that is
specific to low-level waste or hazardous waste or something else, I don't think. Any interstate transport
would have to be egual no matter what the material was.

LAYTON O'NEILL: I was involved, in my early days before I got into the waste management field, in the
training. My bosses went to the speak to the Governor, and it was at the time we had been asked by
Headguarters to start to receive off-site waste from the other locations in the United States. We made some
concessions to the state of Nevada, and we promised to train every patrolman in response to radiological
accidents and to provide them a radiation kit that was calibrated on a regular basis so they could depend on
it. We never did provide them with instruments, but we made a deal with the state emergency management group
to use civil defense instruments, and we calibrated them for about seven or ten years until the state asked
us to cease that program of calibrating.

We still are training highway patrolmen at this time. We still are training fire fighters in the state of
Nevada. We provided monitoring gear for the stop-stations for registering trucks coming in and out of the
state of Nevada, and we set them up with a monitoring device and an alarm that would detect radiation if the
truck had any that they weren't admitting or didn't know about. They were able to check and make sure they
-------
were within limits.

We were providing training for emergency medical people, and we are still doing that today underneath the
waste management program. I'm paying REECo a yearly amount to go out and do this training. And we have
trained most all of the fire fighters in the city of Las Vegas and all the cities that have fire departments;
we train a few of the volunteer fire departments. We are doing these programs today underneath the waste
management money.

JOE FIORE: I would just like to make a comment and maybe get an answer to a guestion to put this
transportation thing in perspective. We did some back-of-the-envelope calculations that said 15,000
shipments over 30 years. That's 500 shipments a year. How does that relate to what we receive now? Don't
we receive about 800 or a 1,000 a year today?

LAYTON O'NEILL: We are getting about three or four a week now. This isn't our heavy time now, because they
are just getting out of the snow up there. So I guess, a couple hundred a year.

KATHERINE YURACKO: I have three concerns on this. One, is that from what I can tell, this appears to be
inconsistent with the Departments' own policy on 11 e(2) material; two, I haven't been convinced that this is
the only place that this material can go; and three, I'm concerned that Nevada gets nothing for this.

PROPOSAL NO. 1

At this point Katherine Yuracko proposed that the Board reguest a 30-day extension (for comments on the Draft
EIS) in order to prepare an appropriate response, and in the meantime be provided with the Draft EIS and the
four volumes of supporting documentation.

1. Dennis Bechtel concurred and reguested that the Board ask for an extension.

2. Joe Fiore stated that this being the first procedural reguest that has been made by the Board, that he
would abide by the consensus of the Board.

3. Jim Henderson also felt there was not enough information at the present time to make comments.

4. Bill Vasconi inguired if the Board's reguest for an extension would be adhered to by Fernald. In
response, Jack Craig (a Fernald representative) said yes, they would.

5. DECISION: The Board voted on the proposal, and the proposal carried unanimously.

6. ACTION: Dennis Bechtel agreed to write a letter of reguest for a 30-day extension. The Board agreed
that each Board member would need a copy of the summary DEIS, and the Board as a whole would reguest one copy
of the four volumes of the supporting documentation therefrom.

7. The suggestion was made that the Feasibility Study and the EIS could be made available through Joe Fiore.
There were four copies of the proposed plan, or summary document made available at the meeting through
Fernald representatives. A reguest for any additional copies would need to go through Joe Fiore in order for
Fernald to send them.

PROPOSAL NO. 2

Katherine Yuracko proposed that at future briefings, the Board needs to receive the summary documents in
advance in order to review them before the presentation.

1. Bill Vasconi concurred with Kathy that the Board needed the summary information in advance.

2. ACTION: Joe Fiore recognized the need for the Board to be better informed in advance of any briefing or
presentation and agreed to get information to the Board in advance at future briefings.
-------
DISCUSSION ON THE CLASSIFICATION OF lie (2)

1. Richard Nicolla asked for direction from DOE on why the proposed Fernald waste is classed as lie(2)
waste.

2. It was determined that Fernald asked DOE/NV to identify the proposed waste as 11E2. In turn DOE/NV
requested Headquarters to qive them policy and call back on it, because it wasn't clear to DOE/NV what it
was.

3. Dennis Nixon made the point that in the DOE Orders, it refers to lie(2) material beinq received at NTS in
small quantities. The concern and question beinq can 6,000 cubic yards of the treated waste form be
considered a small quantity? Thus leavinq the question: What was the intent when "small quantities" was
written in the DOE Orders?

4. The question was raised that there are other disposal facilities in the United States that can receive
lie (2) material. Why can't this waste qo to these facilities?

5. ACTION: Joe Fiore aqreed to pursue the intent of the words "small quantities" as written in the DOE
Orders, but wanted to make sure everyone knew that it would take DOE lonqer than 30 days to qet that
answered.

6. ACTION: Fernald representatives aqreed to respond and answer the question on why the other disposal
facilities were not receivinq this waste.

ANNOUNCEMENTS

1. Bill Vasconi announced that there was another CAB north of Las Veqas (SNFCAB). The SNFCAB is a
cooperative aqreement between Nye County and Lincoln County and Esmeralda County. They have elected a
representative to attend and monitor this CAB's meetinqs for their benefit, and when appropriate this
tri-county CAB would be prepared to qive a presentation to this CAB on the qroup's activities.

2. Joe Fiore expressed his appreciation to the DOE and contractors representatives from Fernald for
respondinq promptly to this Board's request for a presentation.

3. Joe Fiore also brouqht to everyone's attention that the Fernald representatives supplied copies of a
public-information packaqe which has their charter and fact sheets for each member of the Nevada CAB to
review.

4. Dave Rast expressed the importance of follow-up in the formal documentation process in the comment
resolution. The written portion of the process is very important.

Meetinq adjourned at 9:50 p.m.
-------
APPENDIX D

ADMINISTRATIVE RECORD FILE INDEX

Index Number Document Number

U-006-101.27 DOE-750-92

U-006-101.28 KLX-1222

4412

U-006.101.29

U-006-101.30
U-006-104.1
U-006-104.2
U-006-104.4
U-006-104.10
U-006-105.1
U-006-105.2
U-006-105.3
U-006-105.4
WMCO:EC:90-0204
1776

DOE-1372-90
1777

DOE-23-91
2428
2450
695
786
3666
Document Title

THE ORIGIN OF K-65 MATERIAL
BLEEKER PUBLISHING

SUMMATION REPORT RECOVERY OF RADIUM FROM K-65 RESIDUE
VITROCORP
PRELIMINARY ASSESSMENT OF ALTERNATIVES FOR PROCESSING
AND DISPOSAL OF THE AFRIMENT RESIDUES

RESPONSE TO SPECIFIC REQUEST DURING HEARING BEFORE
SUBCOMMITTEE ON ENERGY RESEARCH AND DEVELOPMENT

PRMIT TO INSTALL/PERMIT TO OPERATE DETERMINATION ON
GLOVE BOX

PERMIT REQUIREMENTS FOR GLOVE BOX USE IN TREATABILITY
TESTING FOR K-65 SILO RESIDUES

RESPONSE TO OEPA STIPULATIONS FOR INSTALLATION AND
OPERATION OF THE GLOVE BOX FOR TREATABILITY TESTING

OEPA MAKES THE FOLLOWING STIPULATION REGARDING THE
INSTALLATION AND OPERATION OF THE GLOVE BOX

CALCULATION OF RADON EMISSION, DISPERSION,AND DOSIMETRY
COLORADO STATE UNIV
FROM K-65 STORAGE TANKS AT THE FEED MATERIALS
PRODUCTION CENTER

K-65 SILOS STUDY & EVALUATION REPORT
K-65 SILOS STUDY & EVALUATION CAMARGO REPORT APPENDIX A 02/01/1986
& B FEBRUARY 1986

K-65 SILOS STUDY & EVALUATION CAMARGO REPORT APPENDIX 02/01/1986
Document
Date
01/27/1992
02/12/1952
05/15/1981
07/22/1987
06/14/1990
07/16/1990
11/06/1991
09/27/1990
10/01/1985
02/25/1986
02/01/1986
02/01/1986
From
To
DOE
USAEC (DOE)
BATTELLE
DOE
DOE
METZENBAUM
WMCO
DOE-FMPC
DOE-FMPC
WMCO
DOE
OEPA
OEPA
DOE
WMCO
CAMARGO
DOE
CAMARGO
DOE
CAMARGO
# of Type of
Pages Documents
3 Letter
50 Report
59 Report
3 Letter
2 L

2 Letter
2 Letter
14 Letter
45 Report
500 Report
500 Report
-------
3667
C, D & E FEBRUARY 1986
Index Number Document Number

U-006-105.5
U-006-105.6
U-006-105.11
3703
U-006-105.7 DE-AC05-810R20722
167

U-006-105.8 DE-AC05-810R20722
168

U-006-105.9 DE-AC05-810R20722
169

U-006-105.10 FMPC/SUB-20A UC
555
2007
U-006-105.13 DOE-827-89
5619
U-006-105.14
U-006-105.15
U-006-105.16
5620
5621
Document Title

K-65 SILOS STUDY & EVALUATION CAMARGO REPORT APPENDIX F
1 OF 2 FEBRUARY 1986

K-65 SILOS STUDY & EVALUATION CAMARGO REPORT APPENDIX F
2 OF 2 FEBRUARY 1986

STUDY AND EVALUATION OF K-65 SILOS FOR THE FEED
MATERIALS PRODUCTION FACILITY AT FERNALD, OHIO

APPENDICES A THROUGH H: STUDY AND EVALUATION OF K-65
SILOS FOR THE FMPC

APPENDIX I: STUDY AND EVALUATION OF K-65 SILOS FOR THE
FEED MATERIALS PRODUCTION CENTER AT FERNALD, OH

A PROBABLISTIC RISK ASSESSMENT FOR THE K-65 SILOS AT
THE FMPC, REVISION 1

A PROBABLISTIC RISK ASSESSMENT FOR THE K-65 SILOS AT THE
FMPC NOVEMBER 1990

K-65 SILOS STRUCTURAL ANALYSIS REPORT
STUDY AND EVALUATION EFFECT OF INTERNAL ATTENUATION
LAYER ON K-65 SILOS VOLUME 1 DECEMBER 1988 (A CAMARGO
REPORT)

STUDY AND EVALUATION EFFECT OF INTERNAL ATTENUATION
LAYER ON K-65 SILOS VOLUME II DECEMBER 1988 (A
CAMARGO REPORT)

STUDY AND EVALUATION EFFECT OF INTERNAL ATTENUATION
LAYER ON K-65 SILOS VOLUME III DECEMBER 1988 (A
CAMARGO REPORT)
Document
Date
02/01/1986
02/01/1986
01/01/1990
01/01/1990
01/01/1990
10/01/990
11/01/1990
03/28/1989
03/28/1989
03/28/1989
03/28/1989
From
To
CAMARGO
DOE
CAMARGO
DOE
BNI
DOE-FMPC
BNI
BNI
DOE
UC
DOE-FMPC
UC
DOE-FMPC
DOE-FMPC
US EPA
DOE-FMPC
US EPA
DOE-FMPC
US EPA
DOE-FMPC
US EPA
# of
Pages
500
500
50
90
482
194
100
2
482
83
752
Type of
Documents
Report
Report
Report
Report
Report
Report
Report
Letter
REPORT
REPORT
REPORT
-------
Index Number

U-006-108.1

U-006-108.2

U-006-108.3

U-006-108.4

U-006-108.5

U-006-108.6

U-006-201.1

U-006-202.1

U-006-209.3

U-006-301.1

U-006-301.2

U-006-301.3
Document Number

NEPA DOC. 19
4476

NEPA DOC. 38
4477

NEPA DOC. 118
4478

NEPA DOC 373
4480

NEPA DOC 412
4482

NEPA DOC. 451
5843

DOE-697-92
2821
2822

ORNL/TM-12185
4180

PRE1256COV
91
394
1693
Document Title

K-65 SILO CLOSED CIRCUIT TELEVISION (CCTV) MONITORING
SYSTEM NEPA DOC. 19

K-65 SILO RADON MITIGATION AND DOME REINFORCEMENT NEPA
DOC NO. 38

K-65 AND METAL OXIDE RESIDUE SAMPLING DOC NO. 118
CATEGORICAL EXCLUSION DETERMINATION K-65 EMERGENCY
POWER SUPPLY NEPA DOC NO 373

CATEGORICAL EXCLUSION DETERMINATION OPERABLE UNIT 4
PILOT PLANT PHASE I NEPA DOC NO 412

OPERABLE UNIT 4 PILOT PLANT PHASE II NATIONAL
ENVIRONMENTAL POLICY ACT (NEPA) DOCUMENT NO. 451

ACTION MEMORANDUM: K-65 SILOS RADON TREATMENT SYSTEM
REMOVAL SITE EVALUATION K-65 SILOS RADON TREATMENT
SYSTEM

WASTE-SURFACE MAPPING OF THE FERNALD K-65 SILOS USING A
STRUCTURED LIGHT MEASUREMENT SYSTEM

SAMPLING AND ANALYSIS PLAN FOR STORAGE SILOS 1,2 AND 3
AT THE U.S. DEPARTMENT OF ENVERGY'S FMPC

IMPLEMENTATION PLAN FOR THE K-65 AND METAL OXIDE
RESIDUE SAMPLING PROJECT AT THE FMPC REV. 5

RI/FS WORK PLAN ADDENDUM: OPERABLE UNIT 4 K-65 AND
METAL OXIDES SILOS AND SUBSOILS SAMPLING AND ANALYSIS
PLAN (WITH TREATABILITY PLAN) JANUARY 1990
Document
Date
05/19/1987
09/14/1987
08/10/1988
03/03/1992
04/12/1993
06/23/1994
02/18/1992
01/01/1992
10/01/1992
04/01/1988
12/01/1988
From
To
DOE
DOE
DOE
DOE
DOE
DOE
DOE
DOE
DOE
DOE
DOE-FN
FERMCO
DOE
WEMCO
DOE
WEMCO
ORNL
DOE-FN
AS I
WEMCO
WMCO
DOE
# of Type of
Pages Documents
9 Report
18 Report
17 Report
3 Report
5 Report
5 LETTER/CATX
2 Letter
25 RSE
85 Report
215 Report
532 Report
01/17/1990
29
Addendum
-------
Index Number

U-006-301.4

U-006-301.5

U-006-301.6

U-006-301.7

U-006-301.8

U-006-301.9

U-006-301.10

U-006-301.11
U-006-301.13
Document Number

DOE-745-90
270
829

90L02298.HLW
276

DOE-1758-90
1276

DOE-277-91
1831

DOE-285-91
1995
1996
2430
U-006-301.12 DOE-1151-91
1374
1300
U-006-301.14 DOE-1802-91
1865
Document Title

TASK 9.33 K 65 SILO SAMPLING
SITE SPECIFIC HAZARD ASSESSMENT FOR BORINGS 2028 AND
2033 LOCATED IN THE K-65 CONTROL AREA MARCH 27, 1990

K-65 SILO RE-SAMPLING OPERATING PROCEDURES
K-65 SAMPLING PROJECT
K-65 SILOS SAMPLING AND ANALYSIS
REVISED K-65 SILO SUBSOILS SAMPLING AND ANALYSIS PLAN
RI/FS WORK PLAN ADDENDUM: K-65 SILO SUBSOILS SAMPLING
AND ANALYSIS PLAN NOVEMBER 13, 1990

RI/FS WORK PLAN ADDENDUM: K-65 SILO BERM VERTICAL
BORING SAMPLING AND ANALYSIS PLAN WITH SITE SPECIFIC
HEALTH AND SAFETY PLAN DECEMBER 1990

ADDITIONAL REVISIONS TO THE K-65 RESIUDE SAMPLING AND
ANALYSIS PLAN

RESIDUE SAMPLING FOR K-65 SILOS SAMPLING AND ANALYSIS
PLAN U.S. DEPARTMENT OF ENERGY FEED MATERIALS
PRODUCTION CENTER FERNALD, OHIO MAY 28, 1991

REVISIONS TO K-65 SILOS SUBSOILS SAMPLING AND ANALYSIS
PLAN
Document
Date

05/08/1990
03/27/1990

03/29/1990

08/24/1990

11/15/1990

11/16/1990

11/13/1990

12/01/1990
From
To

DOE
AS I

AS I
DOE-FMPC

DOE-FMPC
AS I

DOE-FSO
US EPA

DOE-FSO
EPAs

DOE
EPAs
# of Type of
Pages Documents

1 Letter
06/13/1991 DOE
EPAs

05/28/1991 DOE
EPAs
07/10/1991 DOE
EPAs
40
52
14
50
12
180
Report
Work Plan
Letter
Letter
Letter
Report
Addendum
Letter
Report
Letter
-------
Index Number

U-006-301.15

U-006-301.16
Document Number Document Title
1866

DOE-1882-91
1744
RI/FS WORK PLAN ADDENDUM K-65 SILO SUBSOILS AND PERCHED
GROUNDWATER SAMPLING AND ANALYSIS PLAN JUNE 27, 1991

REVISED SAMPLING AND ANALYSIS PLAN FOR THE K-65 SILOS
RESIDUE SAMPLING PROJECT
Document
Date

06/27/1991

07/25/1991
From
To

DOE
EPAs

DOE
EPAs
# of
Pages

30
Type of
Documents

ADDENDUM
Letter
U-006-301.17
U-006-301.18
1745

WEMCO:ER:92-191
3016
RESIDUE SAMPLING FOR K-65 SILOS SAMPLING AND ANALYSIS
PLAN JULY 15, 1991

K-65 SILOS DATA VALIDATION AND CHARACTERIZATION
07/15/1991
03/17/1992
DOE
EPAs

WEMCO
DOE
400
Report
Letter
U-006-301.19
DOE-244-91
5196
REVISED K-65 RESIDUE SAMPLING PROCEDURES
11/09/1990
DOE-FSO
US EPA
LETTER
U-006-301.20
5197
K-65 SILOS SAMPLING AND ANALYSIS PLAN ADDENDUM TO
THE FMPC RI/FS WORK PLAN
11/09/1990
DOE-FSO
US EPA
204
ADDENDUM
U-006-301.21
WMCO:R:AEC:90-0032
5345
OPERATIONAL SAFETY REQUIREMENTS FOR THE SAMPLING AND
ANALYSIS OF THE MATERIALS IN K-65 SILOS 1 AND 2
09/05/1990 DOE-FMPC
35
REPORT
U-006-301.22
DOE-1519-90
5816
K-65 SAMPLING PROCEDURES
07/25/1990
DOE-FN
EPAs
179
PROCEDURES
U-006-302.1
DOE-1315-90
1008
OPERABLE UNIT 4 SAMPLING RESULTS
06/29/1990 DOE
OEPA
17
Letter
U-006-302.2
344
TRANSMITTAL OF ANALYTICAL DATA
05/18/1990 ASI
DOE
173
Data
U-006-302.3
246
CERTIFICATE OF ANALYSIS - PROJECT NUMBER 482331 JOB
NUMBER 303317.24.05.20 - SILO MATERIAL
03/22/1990
IT
WMCO
33
Certificate
U-006-302.4
WEMCO:ER:92-191
3101
CHARACTERIZATION OF K-65 SILO CONTENTS
03/31/1992 WEMCO
DOE
Letter
-------
Index Number

U-006-303.1

U-006-303.2

U-006-303.3

U-006-303.4

U-006-303.5

U-006-303.6
Document Number

DOE-1892-91
1707
1718

DOE-017-92
2246
2247
2311
2506
Document Title

OPERABLE UNIT (OU) 4 TREATABILITY STUDY WORK PLAN
TREATABILITY STUDY WORK PLAN FOR OPERABLE UNIT 4 TASK 5
WORK PLAN JULY 1991

OPERABLE UNIT 4 TREATABILITY WORK PLAN
TREATABILITY STUDY WORK PLAN FOR OPERABLE UNIT 4
OCTOBER 1991

ADDENDUM TO OPERABLE UNIT 4 TREATABILITY STUDY WORK
PLAN OCTOBER 1991

OPERABLE UNIT 4 TREATABILITY STUDY WORK PLAN FOR THE
VITRIFICATION OF RESIDUES FROM SILOS 1, 2, AND 3 DRAFT
NOVEMBER 1991
Document
Date
07/23/1991
07/01/1991
10/03/1991
10/01/1991
11/01/1991
11/01/1991
From
To
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
# of
Pages
2
167
2
251
4
70
Type of
Documents
Letter
Work Plan
Letter
Report
Addendum
Work Plan
U-006-303.7
DOE-605-92
2470
REVISED OPERABLE UNIT 4 TREATABILITY STUDY WORK PLAN
FOR STABILIZATION AND CHEMICAL SEPERATION
01/02/1992 DOE
EPAs
Letter
U-006-303.8
2471
TREATABILITY STUDY WORK PLAN FOR OPERABLE UNIT 4
JANUARY 1992
01/01/1992 DOE
EPAs
250
Report
U-006-303.9
DOE-753-92
2711
REVISED OPERABLE UNIT 4 TREATABILITY WORK PLAN FOR
VITRIFICATION
01/28/1992 DOE
EPAs
Letter
U-006-303.10
2713
OPERABLE UNIT 4 TREATABILITY STUDY WORK PLAN FOR THE
VITRIFICATION OF RESIDUES FROM SILOS 1, 2, AND 3
JANUARY 1992
01/01/1992 DOE
EPAs
75
Work Plan
U-006-303.11 DOE-1017-92
2920
PROCEDURES FOR VITRIFICATION OF OPERABLE UNIT (OU) 4
WASTE
03/05/1992 DOE
EPAs
Letter
-------
Index Number

U-006-303.12

U-006-303.13
Document Number
Document Title
PROCEDURES FOR THE OPERABLE UNIT 4 TREATABILITY STUDY
2921 WORK PLAN FOR THE VITRIFICATION OF RESIDUES FROM SILOS
1, 2, AND 3

DOE-1174-92 REVISED OPERABLE UNIT 4 VITRIFICATION TREATABILITY
3003 STUDY WORK PLAN
Document From
Date To

03/05/1992 DOE
EPAs
03/24/1992 DOE
EPAs
# of
Pages

50
Type of
Documents

Work Plan
Letter
U-006-303.14
3006
OPERABLE UNIT 4 TREATABILITY STUDY WORK PLAN FOR THE
VITRIFICATION OF RESIDUES FROM SILOS 1, 2, AND 3 MARCH
1992
03/01/1992 DOE
EPAs
145
Work Plan
U-006-303.15 DOE-1352-92 DOCUMENT CHANGE REQUESTS (OCRS) FOR OPERABLE UNIT 4
3088 TREATABILITY WORK PLAN FOR STABILIZATION AND CHEMICAL
EXTRACTION
04/13/1992 DOE
EPAs
Letter
U-006-303.16
3161
OPERABLE UNIT 4 TREATABILITY STUDY WORK PLAN FOR THE
VITRIFICATION OF RESIDUES FROM SILOS 1, 2, AND 3
APPENDIX D PROCEDURES AND METHODS REVISED APRIL 1992
04/24/1992 DOE
EPAs
40
Work Plan
U-006-303.17 DOE-0069-93 DOCUMENT CHANGE REQUEST (OCR) FOR OPERABLE UNTI 4
3804 TREATABILITY WORK PLAN FOR STABILIZATION AND CHEMICAL
EXTRACTION
10/08/1992 DOE
EPAs
Letter
U-006-303.18 DOE-0156-93 DOCUMENT CHANGE REQUEST (OCR) FOR OPERABLE UNIT 1 AND
4098 OPERABLE UNIT 4 TREATABILITY STUDY WORK PLANS FOR
CEMENTATION (OU4)

U-006-303.19 DOE-118-91 REVISED PLAN FOR THE TREATABILITY SCREENING ACTIVITIES
2026 FOR OPERABLE UNIT 4
10/20/1992 DOE-FN
EPAs
10/22/1990 DOE-FSO
EPAs
Letter
Letter
U-006-303.20
U-006-303.21
2027
1433
TREATABILITY WORK PLAN (LABORATORY SCREENING) FOR SILOS 09/01/1990
1 AND 2 SEPTEMBER 1990

SITE SPECIFIC SAFETY PLAN FOR THE K-65 VERTCIAL BORING 03/01/1991
OPERATIONS
66
67
Report

Report
-------
Index Number

U-006-303.22
Document Number
5233
Document Title

OPERABLE UNIT 4 REMEDIAL ACTION SAFETY ASSESSMENT
REVISION 0 FEBRUARY 1993
Document
Date
From
To
02/01/1993 DOE-FN
# of
Pages

65
Type of
Documents

REPORT
U-006-303.23
DOE-1009-94
5212
OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY
WORK PLAN
02/25/1994 DOE-FN
EPAs
LETTER
U-006-303.24
U-006-303.25
WP-18-0007
5213

DOE-400-89
5564
OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY
WORK PLAN REVISION 0 FEBRUARY 1994

K-65 SILOS NEAR-TERM ACTIVITIES AND FINAL REMEDIATION
PLAN
02/25/1994 DOE-FN
EPAs

01/10/1989 DOE-ORO
OEPA
123
WORK PLAN
WORK PLAN
U-006-303.26
U-006-303.27
DOE-712-89
5618
DOE-1009-94
5850
K-65 SILOS INTERIM STABILIZATION - SAND FILL (K-65 SILO
PROJECT OUTLINE LAYER INSTALLATION) (WORK PLAN FOR THE
K-65 STORAGE SILOS INTERIM STABILIZATION PROJECT -
INSTALLATION OF SAND LAYER)

OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY
WORK PLAN
03/10/1989 DOE-FMPC
USEPA
02/25/1994
DOE-FN
EPAs
REPORT
LETTER
U-006-303.28
U-006-303.29
U-006-303.30
WP-18-0007

5845

DOE-1675-94
5836

5838
OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY 02/01/1994 USEPA
PLAN
WORK PLAN REVISION 0 FEBRUARY 1994 DOE-FN

OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY STUDY 05/11/1994 DOE-FN
WORK PLAN EPAs

OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY STUDY 05/11/1994 DOE-FN
WORK PLAN FEMP **DRAFT** MAY 1994 EPAs
100
156
TS WORK
LETTER
WORK PLAN
U-006-303.31
5832
OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY STUDY
PLAN
WORK PLAN **DRAFT FINAL** AUGUST 1994
08/04/1994
DOE-FN

EPAs
162 TS WORK
U-006-304.1
DOE-1763-90
1274
TRANSMITTAL OF THE REMEDIAL INVESTIGATION REPORT FOR
OPERABLE UNIT 4 - FMPC
08/20/1990
DOE-FN
DOE-HQ
Memorandum
-------
Index Number

U-006-304.2

U-006-304.3

U-006-304.4

U-006-304.5

U-006-304.6

U-006-304.7

U-006-304.8

U-006-304.9

U-006-304.10

U-006-304.11

U-006-304.12

U-006-304.13
Document Number

DOE-1774-90
1024

FMPC-0406-4
510

DOE-215-91
583

FMPC-0406-5
584

DOE-1261-93
4258

DOE-1688-93
4301
4290
4291
4292
4698
4699
4700
Document Title

REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4 TASK
6 REPORT AUGUST 1990

OPERABLE UNIT 4 - REMEDIAL INVESTIGATION (RI) REPORT
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4 TASK
6 REPORT OCTOBER 1990

EXPOSURE FACTORS USED IN THE REMEDIAL INVESTIGATION AND
BASELINE RISK ASSESSMENT FOR OPERABLE UNIT 4

OPERABLE UNIT 4 DRAFT REMEDIAL INVESTIGATION REPORT
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 1 OF 3 APRIL 1993 DRAFT

REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 2 OF 3 APRIL 1993 DRAFT

REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 3 OF 3 APRIL 1993 DRAFT

REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 1 OF 3 AUGUST 1993

REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 2 OF 3 AUGUST 1993

REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 3 OF 3 AUGUST 1993
Document
Date
08/24/1990
08/20/1990
11/06/1990
10/29/1990
03/05/1993
04/16/1993
04/16/1993
04/16/1993
04/16/1993
08/20/1993
08/20/1993
08/20/1993
From
To
DOE
EPAs
DOE
EPAs
DOE
US EPA
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE-FN
EPAs
DOE-FN
EPAs
DOE-FN
EPAs
# of
Pages
5
535
3
567
10
2
450
500
450
600
600
600
Type of
Documents
Letter
Report
Letter
Report
Letter
Letter
Report
Report
Report
Report
Report
Report
-------
Index Number

U-006-304.14

U-006-304.15
Document Number
Document Title
DOE-0238-94 OPERABLE UNIT 4 FINAL REMEDIATION INVESTIGATION
4946 REPORT/BASELINE RISK ASSESSMENT

REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
4947 FINAL VOLUME 1 OF 3 NOVEMBER 1993
Document
Date

11/02/1993

11/02/1993
From
To

DOE-FN
EPAs

DOE-FN
EPAs
# of
Pages
550
Type of
Documents

LETTER
REPORT
U-006-304.16
U-006-304.17
4948
4949
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
FINAL VOLUME 2 OF 3 NOVEMBER 1993

REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
FINAL VOLUME 3 OF 3 NOVEMBER 1993
11/02/1993
11/02/1993
DOE-FN
EPAs

DOE-FN
EPAs
550
550
REPORT
REPORT
U-006-304.18
DOE-1282-94 REVISIONS TO THE OPERABLE UNIT 4 REMEDIAL INVESTIGATION
5357 FINAL REPORT
03/18/1994
DOE-FN
EPAs
22
LETTER
U-006-304.19
DOE-1724-94

5625
OPERABLE UNIT 4 FINAL REMEDIAL INVESTIGATION REPORT
RESPONSES
05/20/1994
DOE-FN

FERMCO
19
U-006-305.1
2137
RI/FS WORK PLAN ADDENDUM TREATABILITY STUDY OPERABLE
UNIT 4 U.S. DOE FERNALD OH6 890 008 976
09/06/1990
US EPA
DOE-FN
Letter
U-006-305.2
U-006-305.3
2146
1925
RI/FS WORK PLAN ADDENDUM TREATABILITY STUDY OPERABLE
UNTI 4 U.S. DOE FERNALD

OU#4 RI DISAPPROVAL U.S. DOE - FERNALD OH6 890 008 976
09/07/1990
09/27/1990
US EPA
DOE

US EPA
DOE-FSO
Letter
Letter
U-006-305.4
2457
RI - OU #4 SAMPLING U.S. DOE - FERNALD OH6 890 008 976
10/18/1990
US EPA
DOE
Letter
U-006-305.5
1767
RI/RISK ASSESSMENT O.U. 4
10/02/1990
OEPA
DOE
Letter
U-006-305.6
2147
OU#4 - TREATABILITY STUDY U.S. DOE - FERNALD OH6 890
008 976
11/21/1990
US EPA
DOE-FSO
Letter
-------
Index Number

U-006-305.7

U-006-305.8

U-006-305.9

U-006-305.10

U-006-305.11

U-006-305.12

U-006-305.13

U-006-305.14

U-006-305.15

U-006-305.16

U-006-305.17

U-006-305.18
Document Number
Document Title
1172
2459
1817
1175
1176
1204
1205
2390
2159
2154
2340
NOTICE OF VIOLATION OU#4 RI/RISK ASSESSMENT U.S. DOE -
FERNALD OH6 890 008 976

OU#4 RI DISPOSAL U.S. DOE - FERNALD OH6 890 008 976
REVISED RI-RISK ASSESSMENT O.U. 4
OU#4 RI DISPUTE U.S. DOE - FERNALD OH6 890 008 976
OU#4 RI DISPUTE U.S. DOE - FERNALD OH6 890 008 976
DISPUTE OU #4 RI U.S. DOE - FERNALD OH6 890 008 976
OU#4 EPA RI DISPUTE U.S. DOE - FERNALD OH6 890 008 976
OU#4 EPA RI DISPUTE U.S. DOE - FERNALD OH6 890 006 976
OU#4 EPA RI DISPUTE U.S. DOE - FERNALD OH6 890 008 976
OHIO EPA COMMENTS CONCERNING: THE TREATABILITY STUDY
WORK PLAN FOR OPERABLE UNIT 4

DISAPPROVAL OF TREATABILITY STUDY WORK PLAN FOR OU#4
U.S. EPA COMMENTS ON TREATABILITY STUDY WORK PLAN FOR
ou4
Document
Date
12/07/1990
12/07/1990
12/07/1990
01/04/1991
01/04/1991
01/10/1991
01/25/1991
01/30/1991
02/22/1991
08/22/1991
09/03/1991
10/01/1991
From
To
US EPA
DOE-ORO
US EPA
DOE
OEPA
DOE
US EPA
DOE
US EPA
DOE
US EPA
DOE
US EPA
DOE
US EPA
DOE
US EPA
DOE
OEPA
DOE
US EPA
DOE-FSO
DOE-FSO
EPAs
# of
Pages
4
30
1
1
2
2
2
2
2
7
2
36
Type of
Documents
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Comment
Letter
Response
-------
Index Number

U-006-305.19

U-006-305.20

U-006-305.21
U-006-305.22
2589

U-006-305.23
U-006-305.24
U-006-305.25
U-006-305.26
U-006-305.27
U-006-305.28
U-006-305.29
U-006-305.30
Document Number Document Title

CONDITIONAL APPROVAL O.U. 4 TREATABILITY STUDY W.P.
2421
2844
2612
2738
2923
2966
3097
3264
3545
4211
4533
ADDENDUM AND REVISED TREATABILITY STUDY WORK PLAN FOR
OU #4

DISAPPROVAL OF THE OU #4 VITRIFICATION TREATABILITY
STUDY WORK PLAN

OHIO EPA COMMENTS ON OU4 VITRIFICATION TREATABILITY
STUDY WORK PLAN

APPROVAL O.U. 4 TREABILITY WORK PLAN
OHIO EPA COMMENTS OU4 VITRIFICATION TREATABILITY STUDY
WORK PLAN

DISAPPROVAL OF THE REVISED OU #4 VITRIFICATION
TREATABILITY STUDY WORK PLAN

CONDITIONAL APPROVAL OF THE SECOND REVISION OU #4
VITRIFICATION TREATABILITY STUDY WORK PLAN

OU4 VITRIFICATION STUDY CONDITIONAL APPROVAL
REVISED PROCEDURES FOR OU #4 VITRIFICATION TREATABILITY
STUDY

DOCUMENT CHANGE REQUEST FOR OU4 VITRIFICATION
TREATABILITY STUDY

OHIO EPA COMMENTS ON THE OU4 RI REPORT
Document
Date

11/01/1991

12/02/1991

12/24/1991
01/27/1992
03/15/1992

04/01/1992

05/14/1992

06/22/1992

03/05/1993

06/17/1993
From
To

OEPA
DOE

USEPA
DOE

OEPA
DOE

USEPA
DOE

OEPA
DOE

USEPA
DOE

USEPA
DOE-FN

OEPA
DOE
# of Type of
Pages Documents

1 Letter
Letter
Letter
Letter
Letter
Enclosure
Letter
Letter
Letter
Letter
Letter
26
Comment
-------
Index Number

U-006-305.31

U-006-305.32

U-006-305.33

U-006-305.34

U-006-305.35

U-006-305.36

U-006-305.37

U-006-305.38

U-006-305.39

U-006-305.40

U-006-305.41

U-006-305.42
Document Number
Document Title
4718
4752
4766
4808
4938
469
1049
1755
1277
2460
3345
1816
U.S DOE EXTENSION REQUEST FOR SUBMITTAL OF OU4 DRAFT
FINAL RI REPORT

DISAPPROVAL OF THE OU 4 REMEDIAL INVESTIGATION REPORT
COMMENTS
CONDITIONAL APPROVAL OF REVISED OPERABLE UNIT 4
REMEDIAL INVESTIGATION REPORT

CONDITIONAL APPROVAL OF THE OU 4 REMEDIAL INVESTIGATION
REPORT

OHIO EPA APPROVAL OF THE FINAL OU 4 RI REPORT
SILO SAMPLING U.S. DOE-FERNALD OH6 890 008 976
SILO SAMPLING U.S. DOE-FERNALD OH6 890 008 976
K-65 SAMPLING
K-65 SAMPLING OU#4 U.S. DOE-FERNALD OH6 890 008
976

OU#4 EXTERNAL SAMPLING U.S. DOE FERNALD OH6 890 008
976

FURTHER CLARIFICATION RELATIVE TO DISPOSAL OF THE K-65
RESIDUES AT THE FMPC

CONDITIONAL APPROVAL K-65 SIL VERTICAL BORING SAMPLING
PLAN
Document
Date
08/24/1993
06/23/1993

09/22/1993
10/06/1993

05/25/1989
05/25/1989
07/26/1990
08/15/1990
12/13/1990
01/10/1991
02/07/1991
From
To
USEPA
DOE-FN
USEPA
DOE-FN
OEPA
DOE-FN
USEPA
DOE-FN
OEPA
DOE-FN
OEPA
DOE
OEPA
DOE
OEPA
DOE
USEPA
DOE
USEPA
DOE
USEPA
USEPA
OEPA
DOE
# of
Pages
1
72

3
13
1
1
1
1
8
2
5
2
Type of
Documents
Letter

COMMENTS
COMMENTS
LETTER
Letter
Letter
Letter
Letter
Letter
Memo rand"
Letter
-------
Index Number

U-006-305.43

U-006-305.44
Document Number
Document Title
OU #4: K-65 SILO RESIDUE SAMPLING AND ANALYSIS PLAN
1743

APPROVAL OF K-65 SILO CONTENT SAMPLING PLAN
Document
Date

07/01/1991

09/10/1991
2121
From
To

US EPA
DOE

US EPA
DOE
# of
Pages
Type of
Documents

Letter
Letter
U-006-305.45
5051
CONDITIONAL APPROVAL OF THE OU 4 REMEDIAL INVESTIGATION
FINAL REPORT
01/06/1994
US EPA
DOE-FN
COMMENTS
U-006-305.46
5566
WASTE ANALYSIS FOR SILOS U.S. DOE-FERNALD OH6 890 008
976
02/01/1989
US EPA
DOE-FMPC
COMMENTS
U-006-305.47
5568
COMMENTS ON THE K-65 SILO SAND FILL PROJECT
05/19/1989
OEPA
DOE-FMPC
12
COMMENTS
U-006-305.48
5567
K-65 SAND PROJECT U.S. DOE-FERNALD OH6 890 008 976
05/22/1989
US EPA
DOE-FMPC
COMMENTS
U-006-305.49
5632
RISK ASSESSMENT COMMENTS ON CONDITIONALLY APPROVED OU 4
REMEDIAL INVESTIGATION FINAL REPORT
04/25/1994
US EPA
DOE-FN
COMMENTS
U-006-305.50
5833
OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY
WORK PLAN U.S. EPA COMMENTS
04/04/1919
US EPA
DOE-FN
13 COMMENTS/LET
U-006-305.51
U-006-305.52
5834
OPERABLE UNIT 4 PILOT PLANT TREATABILITY WP -COMMENTS
DOE FEMP MSL #531-0297
MSL#531-0297 OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY
5844 WORKPLAN OHIO EPA COMMENTS
05/16/1919

06/27/1994
OEPA
DOE-FN

OEPA
DOE-FN
COMMENTS
COMMENTS/LET
U-006-305.53 FINAL COMMENTS ON THE OU 4 REMEDIAL INVESTIGATION AND
5804 FEASIBILITY STUDY REPORTS
08/02/1994
US EPA
DOE-FN
COMMENTS
U-006-306.1
DOE-40-91
1924
OPERABLE UNIT 4 - REMEDIAL INVESTIGATION (RI) REPORT 10/26/1990
DOE
US EPA
Letter
-------
Index Number

U-006-306.2
585

U-006-306.3
U-006-306.4
U-006-306.5
U-006-306.6
U-006-306.7
U-006-306.8
U-006-306.9
U-006-306.10
U-006-306.11
U-006-306.12
Document Number
Document Title
Document
Date
From
To
DOE-336-91
1843

DOE-429-91
1835

DOE-452-91
948
DOE-463-91
984

DOE-499-91
1174

DOE-663-91
998
RESPONSE TO U.S. EPA & OEPA COMMENTS ON THE REMEDIAL
INVESTIGATION REPORT FOR OPERABLE UNIT 4

OPERABLE UNIT 4 - RI/FS SCHEDULE

OPERABLE UNIT 4 - FEASIBILITY STUDY (FS) REPORT
NOTICE OF DISPUTE - U.S. EPA DISAPPROVAL - OPERABLE
UNIT 4 REMEDIAL INVESTIGATION (RI) REPORT AND U.S. EPA
NOTICE OF VIOLATION (NOV)

PHASE I TREATIBILITY STUDY FOR OPERABLE UNIT 4
SUPPLEMENT TO NOTICE OF DISPUTE - OPERABLE UNIT 4
REMEDIAL INVESTIGATION (RI) REPORT

OPERABLE UNIT 4 - DISPUTE RESOULUTION
DOE-748-91 DISPUTE RESOLUTION - OPERABLE UNIT 4 REMEDIAL
1206 INVESTIGATION REPORT

DOE-537-91 DISPUTE RESOLUTION - OPERABLE UNIT 4 REMEDIAL
947 INVESTIGATION (RI) REPORT

RESPONSE TO COMMENTS TREATABILITY STUDY WORK PLAN FOR
2252 OPERABLE UNIT 4 JULY 1991 OCTOBER 1991

RESPONSES TO COMMENTS RECEIVED ON THE OPERABLE UNIT 4
2472 DRAFT TREATABILITY STUDY WORK PLAN DOCUMENT DATE -
OCTOBER 1991 JANUARY 1992
10/29/1990 DOE
EPAs

11/30/1990 DOE
EPAs
12/13/1990
DOE-FSO
US EPA
12/20/1990 DOE
US EPA
12/20/1990

12/26/1990

01/28/1991

02/13/1991

01/07/1991

10/01/1991

01/01/1992
DOE
US EPA

DOE
US EPA

DOE
EPAs

DOE
EPAs
# of
Pages

50
50
25
Type of
Documents

Report
Letter

Letter

Enclosure

Letter

Response

Response
-------
Index Number

U-006-306.13

U-006-306.14

U-006-306.15

U-006-306.16

U-006-306.17

U-006-306.18

U-006-306.19

U-006-306.20
Document Number
Document Title
2712
2883
3005
RESPONSE TO THE U.S. EPA COMMENTS OPERABLE UNIT 4
TREATABILITY STUDY WORK PLAN FOR THE VITRIFICATION OF
THE RESIDUES FROM SILOS 1, 2, AND 3

RESPONSE TO THE OEPA COMMENTS OPERABLE UNIT 4
TREATABILITY STUDY WORK PLAN FOR THE VITRIFICATION OF
THE RESIDUES FROM SILOS 1, 2, AND 3

RESPONSE TO THE OHIO EPA COMMENTS OPERABLE UNIT 4
TREATABILITY STUDY WORL PLAN FOR THE VITRIFICATION OF
THE RESIDUES FROM SILOS 1, 2, AND 3

RESPONSE TO THE U.S. EPA COMMENTS OPERABLE UNIT 4
TREATABILITY STUDY WORK PLAN FOR THE VITRIFICATION OF
THE RESIDUES FROM SILOS 1,2, AND 3
DOE-1434-92 REVISED PROCEDURES FOR OPERABLE UNIT 4 (OU 4)
3159 VITRIFICATION TREATABILITY STUDY

DOE-1773-92 RESPONSES TO THE OPERABLE UNIT (OU) 4 VITRIFICATION
3475 STUDY CONDITIONAL APPROVAL

DOE-2561-92 REVISED PROCEDURES FOR OPERABLE UNIT 4 VITRIFICATION
3693 TREATABILITY STUDY

DOE-2245-92 REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS) - USE
4097
OF BLAST FURNACE SLAG IN OPERABLE UNITS 1 AND 4
FORMULATIONS
U-006-306.21 DOE-2416-93 REQUEST FOR EXTENSION FOR RESUBMITTAL OF THE OPERABLE
4592 UNIT 4 REMEDIAL INVESTIGATION REPORT
Document From
Date To

DOE
EPAs
DOE
EPAs
03/24/1992 DOE
EPAs
03/24/1992 DOE
EPAs
# of Type of
Pages Documents
U-006-306.22
DOE-2594-93
4658
OPERABLE UNIT 4 REMEDIAL INVESTIGATION REPORT - DRAFT
COMMENT RESPONSE DOCUMENT
04/24/1992

05/27/1992

08/31/1992

07/29/1992

07/13/1993

07/29 1993
DOE
EPAs

DOE
OEPA

DOE
US EPA

DOE-FN
EPAs
DOE-FN
EPAs

DOE-FN
EPAs
16
142
Response
Response
Response
Response
Letter
Letter
Letter
Letter
Letter
Response
U-006-306.23 DOE-2789-93 OPERABLE UNIT 4 DRAFT FINAL REMEDIAL
4697 INVESTIGATION/BASELINE RISK ASSESSMENT REPORT
08/20/1993
DOE-FN
EPAs
52
Response
-------
Index Number

U-006-306.24
U-006-306.25
4945
U-006-306.26
Document Number

DOE-0182-94
4835
DOE-873-89
3358
Document Title

RESPONSES TO OPERABLE UNIT 4 REMEDIAL INVESTIGATION
REPORT ORIGINAL COMMENTS #12, #13 AND #19
RESPONSES TO USEPA AND OHIO EPA COMMENTS ON THE
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4,
AUGUST 1993

NOTIFICATION OF SAMPLING OF K-65 SILOS AT THE U.S. DOE
FMPC
Document
Date
From
To
10/28/1993 DOE-FN
EPAs

11/02/1993 DOE-FN
EPAs
04/06/1989 DOE
SOAPCA
# of
Pages
23
Type of
Documents

RESPONSES
RESPONSES
Letter
U-006-306.27
U-006-306.28
U-006-306.29
U-006-306.30
U-006-306.31
1997
DOE-1711-90
1275

DOE-1722-90
1805
2028

DOE-1937-90
1921
COMMENT RESPONSE TO U.S. EPA COMMENTS ON: THE RI/FS
WORK PLAN ADDENDUM: K-65 SILO EMBANKMENT AND SUBSOILS
SAMPLING AND ANALYSIS PLAN JULY 1990

K-65 SAMPLING PROCEDURES
INFORMATION SUBMITTAL UNDER PARAGRAPH XIII (B) OF THE
1990 CERCLA CONSENT AGREEMENT - GLOVE BOX TREATABILITY
TESTING

FMPC RI/FS REPORT OPERABLE UNIT 4 LABORATORY SCREENING
WORK PLAN

K-65 RESIDUE SAMPLING - RESOURCE TO U.S. EPA COMMENTS
ON SAMPLING PROCEDURES
07/01/1990 DOE
EPAs
08/10/1990 DOE
USEPA

08/14/1990 DOE
EPAs
09/01/1990
DOE
EPAs
11
09/19/1990 DOE
USEPA
Response
Letter
Letter
Comment
Letter
U-006-306.32
U-006-306.33
U-006-306.34
2426

DOE-60-91
1842

DOE-413-91
911
FMPC RI/FS PROJECT K-65 SILOS SAMPLING AND ANALYSIS
PLAN RESPONSE TO OEPA COMMENTS

K-65 SAMPLING
INFORMATION SUBMITTAL UNDER PARAGRAPH XIII (B) OF THE
1990 CONSENT AGREEMENT - ORGANIC EXTRACTION - K-65 SILO
RESIDUE SAMPLE ANALYSES
10/02/1990 DOE
OEPA
10/11/1990

12/11/1990
DOE
USEPA

DOE
EPAs
Response
Letter
Letter
-------
Index Number

U-006-306.35
Document Number
Document Title
DOE-579-91 K-65 SILOS BERM SAMPLING WORK PLAN
1836
Document
Date

01/14/1991
From
To

DOE
USEPA
# of Type of
Pages Documents

1 Letter
U-006-306.35
U-006-306.37
U-006-306.38
U-006-306.39
U-006-306.40
1157
RESPONSES TO OEPA COMMENTS ON THE K-65 SILO BERM
VERTICAL BORING SAMPLING PLAN
DOE-1803-91 K-65 CONTENTS RESAMPLING
1874

DOE-1886-91 K-65 SLANT BORING #2
1871

DOE-2195-91 COMPLETION OF OPERABLE UNIT 4 SAMPLING ACTIVITIES
2069
01/01/1991
07/10/1991
07/24/1991
09/10/1991
3344
REQUESTING A MEETING CONCERNING THE APPLICATION OF EPA 03/23/1992
STANDARDS FOR THE MANAGEMENT AND DISPOSAL OF HIGH-LEVEL
AND TRANSURANIC NUCLEAR WASTE
DOE
OEPA

DOE
EPAs

DOE-HQ
USEPA
Response
Letter
Letter
Letter
Letter
U-006-306.41
U-006-306.42
U-006-306.43
U-006-306.44
U-006-306.45
DOE-82-89
5338
K-65 AND METAL OXIDE SILO SAMPLING SCHEDULE
DOE-1364-89 STORAGE OF K-65 AND METAL OXIDE SAMPLE MATERIAL
5469

DOE-1806-91 CONFIRMATION OF VERBAL APPROVAL PROCEED ON CONTENT
5442 RESAMPLING
DOE-067-92
5350
OPERABLE UNIT 4 TREATABILITY WORK PLAN ADDENDUM
DOE-291-89 RESPONSES TO USEPA COMMENTS ON K-65 AND METAL OXIDE
5563 SILO SAMPLING PLAN
11/10/1988

08/30/1989

07/12/1991

10/08/1991

12/23/1988
DOE-FMPC
USEPA

DOE-FMPC
USEPA

DOE-FSO
EPAs

DOE-FN
EPAs

DOE-ORO
USEPA
11
LETTER
LETTER
LETTER
LETTER
RESPONSES
U-006-306.46 DOE-1308-89 RESPONSE TO U.S. AND OHIO EPA QUESTIONS ON K-65 SILO 07/14/1989 DOE-FMPC
5565 INTERIM REMEDIATION USEPA
33
RESPONSES
-------
Index Number

U-006-306.47

U-006-306.48

U-006-306.49

U-006-306.50

U-006-307.1

U-006-307.2

U-006-307.3

U-006-307.4

U-006-307.5

U-006-307.6

U-006-307.7
Document Number
Document Title
5734
5837
DOE-1837-94
5842

DOE-2187-94
5851
4635
4612
4637
4702
4703
4704
4705
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
RESPONSE TO COMMENTS AUGUST 12, 1993

TECHNICAL REVIEW COMMENTS ON OPERABLE UNIT 4 (OU4)
PILOT PLANT PHASE I TREATABILITY STUDY WORK PLAN,
REVISION 0 GENERAL COMMENTS

RESPONSES TO COMMENTS FROM THE OHIO EPA ON THE PHASE I
WORK PLAN FOR THE OPERABLE UNIT 4 PILOT PLANT

OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY STUDY
WORK PLAN

GEOLOGY OF CINCINNATI AND VICINITY 1916
RAINFALL AND RUNOFF IN THE MIAMI VALLEY STATE OF
OHIO MIAMI CONSERVANCY DISTRICT 1921

PROCESS ENGINEERING REPORT OPERATING MANUAL FOR K-65
STORAGE AREA FEED MATERIAL PRODUCTION CENTER,
FERNALD, OHIO

K-65 STORAGE TANK NO.l
K-65 STORAGE TANKS
LEASE OF FACILITIES TO AFRICAN METALS
LEASE OF K-65 TANK AREA
Document
Date
08/12/1993
05/11/1994
06/01/1994
08/04/1994

01/01/1921

From
To
DOE-FN
EPAs
DOE-FN
EPAs
DOE-FN
EPAs
DOE-FN
EPAs

CCC, INC.
USAEC
# of
Pages
150
12
10
18
217
235
50
Type of
Documents
RESPONSES
COMMENTS
RESPONSES
COMMENTS /LET
Report
Report
Report
11/25/1953 NLO
12/01/1953 USAEC
NLO

07/15/1958 USAEC
NLO

08/28/1958 USAEC
NLO
Memorandum
Letter
Letter
Letter
-------
Index Number

U-006-307.8
Document Number
Document Title
4611
RAINFALL FREQUENCY ATLAS OF THE UNITED STATES FOR
DURATIONS FROM 30 MINUTES TO 24 HOURS AND RETURN
PERIODS FROM 1 TO 100 YEARS TECHNICAL PAPER NO. 40
Document
Date
From
To
05/01/1961 US COMMERCE
# of
Pages

65
Type of
Documents

Report
U-006-307.9
U-006-307.10
U-006-307.11
4636
4613

BMI-2083
4681
SCOPING INVESTIGATION OF SHORT-TERM STORAGE COSTS FOR
AFRIMET RESIDUES - NFSS AND FMPC SEPTEMBER 29, 1980

SOIL SURVEY OF BUTLER COUNTY, OHIO
UC-11 PRELIMINARY ASSESSMENT OF ALTERNATIVES FOR PROCESSING
AND DISPOSAL OF THE AFRIMET RESIDUES FINAL REPORT
1981
09/29/1980 NLO
DOE-FN

01/01/1980 USAG
05/15/1981 BATELLE
DOE
49
259
64
Report

Report

Report
U-006-307.12
U-006-307.13
U-006-307.14
U-006-307.15
U-006-307.16
SOIL SURVEY OF HAMILTON COUNTY, OHIO
4614

FIRM FLOOD INSURANCE RATE MAP COUNTY OF HAMILTON
4610 OHIO

FEASIBILITY INVESTIGATION FOR CONTROL OF RADON EMISSION
4440 FROM THE K-65 SILOS

CONCEPTUAL DESIGN REPORT K-65 STORAGE SILO RADON
4441 MITIGATION AND DOME REINFORCEMENT STUDY

FMPC-2142 THE K-65 WASTE STORAGE SILOS AT THE FEED MATERIALS
4603 PRODUCTION CENTER SEPTEMBER 1988
08/01/1982 USAG
06/01/1982 FEMA
07/30/1987 WEMCO
DOE

05/13/1987 WEMCO
DOE

09/01/1988 WEMCO
DOE-ORO
286
100
51
12
Report

Map

Report

Report
U-006-307.17
U-006-307.18
4445
4770
SAMPLING AND RADIOLOGICAL ANALYSES OF SEDIMENT FROM
PADDY'S RUN AND THE STORM SEWER OUTFALL DITCH

TOPOGRAPHIC SURVEY AND GEOTECHNICAL INVESTIGATION
FMPC WATER POLLUTION CONTROL FERNALD, OHIO
09/07/1989 IT
AS I

10/05/1982 ATEC ASSOC.
NLO
75
Memorandum
REPORT
-------
Index Number

U-006-307.19

U-006-307.20

U-006-307.21

U-006-307.22

U-006-307.23

U-006-307.24

U-006-307.25

U-006-307.26

U-006-307.27
Document Number
Document Title
Document
Date
4942
4943
4944
5030
5031
5032
5033
5034
5035
EFFECT OF INCREASED PUMPING OF GROUND WATER IN THE
FAIRFIELD-NEW BALTIMORE AREA, OHIO - A PREDICITON BY
ANALOG-MODEL STUDY GEOLOGICAL SURVEY PROFESSIONAL
PAPER 605-C (ANDREW M. SPEIKER)

TREATMENT OF PITCHBLENDE RESIDUES FOR RECOVERY OF METAL
VALUES (JOHN E. LITZ)

WASTE WATER QUALITY REPORTS, NPDES PERMIT PARAMETERS
AND DATA SUMMARIES 1979 TO 1983
From
To

USGS
ECOREGIONS OF THE UNITED STATES
U.S. FOREST SERVICE 1976
BY ROBERT G. BAILEY
GLACIAL GEOLOGIC MAPPING IN HAMILTON COUNTY, OHIO
(REPORT OF PROGRESS ON THE FIRST PHASE) BY C. SCOTT
BROCKMAN SEPTEMBER 1986 OHIO DEPT. NATURAL
RESOURCES, DIV. GEOLOGICAL SURVEY

RADIOLOGICAL AND CHEMICAL BASELINE RISK ASSESSMENT
OPERABLE UNIIT 4 APRIL 2, 1990 PRELIMINARY
DRAFT

BEDROCK TOPOGRAPHY OF BUTLER COUNTY, OHIO BY JACK A.
LEOW JULY 1985 OHIO DEPT. NATURAL RESOURCES, DIV.
GEOLOGICAL SURVEY

GROUND-WATER HYDROLOGY AND GEOLOGY OF THE LOWER GREAT
MIAMI RIVER VALLEY, OHIO BY ANDREW M. SPIEKER
1968 U.S. GEOLOGICAL SURVEY PROFESSIONAL PAPER

FUTURE DEVELOPMENT OF THE GROUND-WATER RESOURCE IN THE
LOWER GREAT MIAMI RIVER VALLEY, OHIO - PROBLEMS AND
SOLUTIONS BY ANDREW M. SPIEKER 1968 U.S.
GEOLOGICAL SURVEY PROFESSIONAL PAPER 605-D
05/30/1974 HAZEN RESEARCH
COTTER CORP

NLO
01/01/1976
09/01/1986
04/02/1990 IT CORP
DOE-ORO
07/01/1985
01/01/1968
01/01/1968
# of
Pages

50
30
250
17
150
40

605-A

50
Type of
Documents

REPORT
REPORT
REPORTS
MAP
REPORT
REPORT
MAP
REPORT
REPORT
-------
Index Number

U-006-307.28

U-006-307.29

U-006-307.30

U-006-307.31
Document Number
Document Title
U-006-401.1
576

U-006-401.2
U-006-401.3
U-006-401.4
U-006-410.5
U-006-401.6
U-006-401.8
5036
5450
5451
5747
DOE-1265-90
337

DOE-1317-90
417
1746
1747

DOE-02-91
1670
5578
BEDROCK TOPOGRAPHY OF HAMILTON COUNTY, OHIO BY JOEL
VORMELEKER JULY 1985 OHIO DEPT. NATURAL
RESOURCES, DIV. GEOLOGICAL SURVEY

BEDROCK GEOLOGY OF THE CINCINNATI WEST QUADRANGLE AND
PART OF THE COVINGTON QUADRANGLE, HAMILTON COUNTY, OHIO
BY JOHN P. FORD 1974 OHIO DIV GEOLOGICAL

BEDROCK GEOLOGY OF HAMILTON COUNTY, OHIO BY M.
SWINFORD OHIO DIV GEOLOGICAL SURVEY (IN PREPARATION)

CHRONIC AND SUBCHRONIC, SYSTEMIC AND CARCINOGENIC, ORAL
AND INHALATION TOXICITY INFORMATION FOR 2-HEXANONE,
MAGNESIUM, TRIBUTYL PHOSPHATE, AND MIXED XYLENES. ORAL
AND DERMAL ABSORPTION FACTORS FOR MULTIPLE CHEMICALS.
(OU4, OU1 & OU2 RI REFERENCE)
ARAR IDENTIFICATION FOR OU4 FMPC RI/FS
POTENTIAL STATE ARARS FOR OPERABLE UNIT 4
DOE
APPLICABLE RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARS) FOR OPERABLE UNIT 4

ASSESSMENT OF IMPACTS OF ADDTIONAL ARAR, 40CFR191
AUGUST 14, 1990

ASSESSMENT OF IMPACTS OF ADDITIONAL ARAR, 40CFR191
AUGUST 24, 1990

POTENTIAL ARARS FOR OPERABLE UNIT 4 -REVISION 1
APPLICATION OF 40 CFR 191 TO OU #4
Document
Date

07/01/1985
01/01/1974

11/10/1992

07/21/1993
From
To
06/11/1990

06/27/1990

08/14/1990

08/24/1990

10/22/1990

04/25/1994
# of
Pages

1
22
DOLLARHIDE 106
VANLEEUWEN/EPA
04/30/1990 ASI
25
DOE
OEPA

DOE
USEPA
DOE
EPAs

USEPA
DOE-FN
64
70
25
83
Type of
Documents

MAP
REPORT
REPORT
REPORT
Letter

Letter

Report

Letter

LETTER
-------
Index Number

U-006-401.9

U-006-401.10

U-006-402.1

U-006-402.2

U-006-402.3

U-006-402.4

U-006-402.5

U-006-403.1

U-006-403.2

U-006-404.1

U-006-404.2

U-006-404.3
Document Number

DOE-1630-94
5570
5885

DOE-1166-90
336

FMPC-0412-4
299

FMPC-0412-5
1804

DOE-137-91
1846

FMPC-0412-6
560

FMPC-0413-2
416
1586

DOE-2954-93
4737
4738
4739
Document Title

APPLICATION OF 40 CFR 191 TO OPERABLE UNIT 4
APPLICABILITY OF 40 CFR PART 191 TO THE FEED MATERIALS
PRODUCTION CENTER (FMPC)

INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4
INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 12 REPORT MAY 1990

INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 12 REPORT AUGUST 1990

INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4 -
FINAL REPORT

INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 12 REPORT OCTOBER 1990

DETAILED ANALYSIS OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 13 PRESENTATION JUNE 1990

DETAILED ANALYSIS OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 13 PRESENTATION JULY 1990

OPERABLE UNIT 4 DRAFT FEASIBILITY STUDY REPORT/PROPOSED
PLAN

FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4
REMEDIAL INVESTIGATION AND FEASIBILITY STUDY VOLUME
1 OF 4 DRAFT SEPTEMBER 1993

FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4
REMEDIAL INVESTIGATION AND FEASIBILITY STUDY VOLUME
2 OF 4 DRAFT SEPTEMBER 1993
Document
Date
05/05/1994
07/10/1987
06/01/1990
05/01/1990
08/30/1990
10/29/1990
10/01/1990
06/01/1990
07/01/1990
09/08/1993
09/08/1993
From
To
DOE-FN
EPAs
DOE
US EPA
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
US EPA
DOE
EPAs
AS I
DOE

DOE-FN
EPAs
DOE-FN
# of
Pages
16
2
2
132
200
2
235
53
106
3
600
Type of
Documents
LETTER
LETTER
Letter
Report
Report
Letter
Report
Handout
Handout
Letter
Report
EPAs
09/08/1993 DOE-FN
EPAs
600
Report
-------
Index Number

U-006-404.4
Document Number
Document Title
4740
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4
REMEDIAL INVESTIGATION AND FEASIBILITY STUDY VOLUME
3 OF 4 DRAFT SEPTEMBER 1993
Document
Date
From
To
09/08/1993 DOE-FN
EPAs
# of Type of
Pages Documents
631
Report
U-006-404.5 FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 REMEDIAL
4741 INVESTIGATION AND FEASIBILITY STUDY VOLUME 4 OF 4 DRAFT
SEPTEMBER 1993

U-006-404.6 DOE-0383-94 REQUEST FOR EXTENSION ON SUBMITTAL OF THE OPERABLE UNIT
4924 4 DRAFT FINAL FEASIBILITY STUDY REPORT AND PROPOSED
PLAN
09/08/1993 DOE-FN
EPAs
11/22/1993 DOE-FN
EPAs
600
Report
LETTER
U-006-404.7 DOE-0636-94 OPERABLE UNIT 4 DRAFT FINAL FEASIBILITY STUDY
5037 REPORT/PROPOSED PLAN

U-006-404.8 DOE/EIS-0195D FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
5038 1 OF 4 DECEMBER 1993 DRAFT FINAL
12/21/1993
12/21/1993
DOE
EPAs

DOE
EPAs
700
LETTER
REPORT
U-006-404.9 DOE/EIS-0195D FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
5039 2 OF 4 DECEMBER 1993 DRAFT FINAL
12/21/1993
DOE
EPAs
700
REPORT
U-006-404.10
U-006-404.11
U-006-404.12
DOE/EIS-0195D FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
5040 3 OF 4 DECEMBER 1993 DRAFT FINAL

DOE/EIS-0195D FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
5041 4 OF 4 DECEMBER 1993 DRAFT FINAL

DOE-1008-94 OPERABLE UNIT 4 FINAL FEASIBILITY STUDY REPORT/PROPOSED
5204 PLAN
12/21/1993

12/21/1993

02/22/1994
DOE
OEPA

DOE
OEPA

DOE-FN
EPAs
700
700
REPORT
REPORT
LETTER
U-006-404.13 DOE/EIS-0195D FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
5205 1 OF 4 FINAL FEBRUARY 1994

U-006-404.14 DOE/EIS-0195D FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
5206 2 OF 4 FINAL FEBRUARY 1994
02/22/1994
02/22/1994
DOE-FN
EPAs

DOE-FN
EPAs
683
773
REPORT
REPORT
-------
Index Number
U-006-404
U-006-404
U-006-405
U-006-405
U-006-405
U-006-407
U-006-407
U-006-407
U-006-407
U-006-407
U-006-407
U-006-407
.15
.16
.1
.2
.3
.1
.2
.3
.4
.5
.6
.7
Document Number
DOE/EIS-0195D
5207
DOE/EIS-0195D
5208
DOE/EIS-0195D
4742
DOE/EIS-0195D
5042
DOE/EIS-0195D
5209

894
1928
2135
2136
1813
1173
Document Title
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
3 OF 4 FINAL FEBRUARY 1994
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
4 OF 4 FINAL FEBRUARY 1994
PROPOSED PLAN FOR OEPRABLE UNIT 4 DRAFT AUGUST 1993
PROPOSED PLAN FOR REMEDIA ACTIONS AT OPERABLE UNIT 4
DECEMBER 1993 DRAFT FINAL
PROPOSED PLAN FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4
FINAL FEBRUARY 1994
OU#4 ALTERNATIVES U.S. DOE FERNALD OH 6 890 008 976
893
OHIO EPA COMMENTS - OPERABLE UNIT 4 INITIAL SCREEENING
OF ALTERNATIVES REPORT
OU#4 - ALTERNATIVES U.S. DOE - FERNALD OH6 890 008 976
OU#4 DISPUTE RESOLUTION U.S. DOE FERNALD OH6 890 008
976
OU#4 ALT SCREENING DISPUTE RESOLUTION U.S. DOE
FERNALD OH6 890 008 976
OU#4 ALT SCREENING DISPUTE RESOLUTION U.S. DOE FERNALD
OH6 890 008 976
EXTENSION REQUEST OU #4 FS REPORT U.S. DOE FERNALD
OH6 890 008 976
Document
Date
02/22/1994
02.22.1994
09/08/1993
12/21/1993
02/22/1994
07/05/1990
07/06/1990
09/04/1990
10/03/1990
10/18/1990
10/31/1990
12/19/1990
From
To
DOE-FN
EPAs
DOE-FN
EPAs
DOE-FN
EPAs
DOE
OEPA
DOE-FN
EPAs
USEPA
DOE
OEPA
DOE
USEPA
DOE
USEPA
DOE
USEPA
DOE
USEPA
DOE
USEPA
DOE
# of Type of
Pages Documents
690 REPORT
815 REPORT
100 Work Plan
100 REPORT
105 REPORT
15 Letter
6 Letter
5 Letter
2 Letter
2 Letter
1 Letter
2 Letter
-------
Index Number

U-006-407.8

U-006-407.9

U-006-407.10

U-006-407.11

U-006-407.12

U-006-407.13

U-006-407.14

U-006-407.15

U-006-408.1

U-006-408.2

U-006-408.3

U-006-408.4
Document Number Document Title

OU #4 ARARS U.S. DOE - FERNALD OH6 890 008 976
1800
2962
4907
4909
4930
5121
5145
5532
1946
OPERABLE UNIT 34 ARARS
OHIO EPA COMMENTS ON THE OU 4 FEASIBILITY STUDY REPORT
AND PROPOSED PLAN

DISAPPROVAL OF THE O.U. 4 FEASIBILITY STUDY AND
PROPOSED PLAN

APPROVAL OF THE CLARIFICATION TO THE OU 4 FEASIBILITY
STUDY DOCUMENT CHANGE REQUEST

OHIO EPA COMMENTS ON THE REVISED O.U. 4 FS/PP
CONDITIONAL APPROVAL OF THE DRAFT FINAL OU 4
FEASIBILITY STUDY REPORT AND PROPOSED PLAN

APPROVAL OF THE FINAL OU 4 FEASIBILITY STUDY REPORT AND
PROPOSED PLAN (CONDITIONAL APPROVAL)

OPERABLE UNTI 4 INITIAL SCREENING OF ALTERNATIVES
COMMENT-RESPONSE DOCUMENT
DOE-1853-90 INFORMAL DISPUTE RESOLUTION MEETING
1927

DOE-1772-90 OPERABLE UNIT 4
1681
DOE-46-91
1672
OPERABLE UNIT 4 - DISPUTE RESOLUTION
Document From
Date To
01/21/1991 USEPA
DOE
'3/04/1992 USEPA
DOE
1/09/1993 OEPA
DOE-FN
709/1993 USEPA
DOE-FN
724/1993 USEPA
DOE-FN
724/1994 OEPA
DOE-FN
/09/1994 USEPA
DOE-FN
/09/1994 USEPA
DOE-FN
DOE
EPAs
707/1990 DOE
USEPA
724/1990 DOE
AS I
711/1990 DOE
USEPA
# of Type of
Pages Documents
4 Letter
2 Letter]
18 COMMENTS
66 COMMENTS
1 LETTER
18 COMMENTS
18 COMMENTS
6 COMMENTS
60 Report
2 Letter
1 Letter
3 Letter
-------
Index Number

U-006-408.5

U-006-408.6

U-006-408.7

U-006-408.8

U-006-408.9

U-006-408.10

U-006-408.11

U-006-408.12

U-006-408.13

U-006-408.14

U-006-408.15
Document Number
2339

DOE-208-91
1847

DOE-401-91
913

DOE-551-91
960

DOE-333-92
2507
5043

DOE-1944-92
3343
5210
DOE-1514-94
5478
DOE-1847-94
5629
5630
Document Title

OPERABLE UNIT 4 INITIAL SCREENING OF ALTERNATIVES
COMMENT - RESPONSE DOCUMENT

OPERABLE UNIT 4 - FEASIBILITY STUDY (FS) REPORT

OPERABLE UNIT 4 - PROPOSED PLAN
OPERABLE UNIT 4 - APPLICABLE OR RELEVANT AND
APPROPRAITE REQUIREMENTS (ARARS)

FEASIBILITY STUDY REPORT AND PROPOSED PLAN FOR OPERABLE
UNIT 4 RESPONSES TO COMMENTS DECEMBER 1993

OPERABLE UNIT (OU) ARARS
RESPONSES TO COMMENTS ON THE DRAFT FINAL FEASIBILITY
STUDY REPORT AND PROPOSED PLAN FOR OPERABLE UNIT 4
FEBRUARY 1994

OPERABLE UNIT 4 CONSENT AGREEMENT SCHEDULE - REQUEST
FOR EXTENSION OF THE FEASIBILITY STUDY/PROPOSED PLAN-
DRAFT ENVIRONMENTAL IMPACT STATEMENT PUBLIC REVIEW

RESPONSES TO COMMENTS - OPERABLE UNIT 4 FINAL
FEASIBILITY STUDY/PROPOSED PLAN/DRAFT ENVIRONMENTAL
IMPACT STATEMENT

FINAL FEASIBILITY STUDY REPORT AND PROPOSED PLAN FOR
OPERABLE UNIT 4 RESPONSE TO COMMENTS JUNE 1994
Document
Date

08/03/1990

11/06/1990

12/13/1990

01/10/1991

11/18/1991

12/21/1993

06/18/1992

02/22/1994
From
To

DOE
EPAs

DOE-FSO
US EPA

DOE
US EPA

DOE
EPAs

DOE
US EPA

DOE-FN
EPAs
# of Type of
Pages Documents
12
04/18/1994 DOE-FN
EPAs
06/03/1994 DOE-FN
EPAs
06/03/1994 DOE-FN
EPAs
100
118
16
Enclosure
Letter
Letter
Letter
Letter
RESPONSES
Letter
RESPONSES
LETTER
LETTER
RESPONSES
-------
Index Number

U-006-409.1
Document Number
4796
Document Title

OPERABLE UNIT 4 TREATIBILITY STUDY REPORT FOR THE
VITRIFICATION OF RESIDUES FROM SILOS 1, 2, AND 3
MAY 1993
Document
Date
From
To
05/01/1993 FERMCO
DOE-FN
# of
Pages

150
Type of
Documents

REPORT
U-006-409.2
5448
TREATIBILITY STUDY REPORT FOR OPERABLE UNIT 4 DRAFT
MARCH 31, 1993
03/31/1994 DOE-FN
500
REPORT
U-006-409.3
5498
TECH REPORT Y-87-1 CORPS OF ENGINEERS WETLANDS
DELINEATION MANUAL WETLANDS
RESEARCH PROGRAM TECHNICAL REPORT Y-87-1 FINAL REPORT
JANUARY 1987 BY ENVIRONMENTAL
01/02/1987 US ARMY
100
REPORT
U-006-409.4
5449
FEED MATERIALS PRODUCTION CENTER, NEAR FERNALD, OHIO
05/05/1987 OHIO HIS SOC
DOE-FMPC
LETTER
U-006-409.5
5309
DEPARTMENT OF ENERGY INTENT TO PREPARE A REMEDIAL
INVESTIGATION/FEASIBILITY STUDY - ENVIRONMENTAL IMPACT
STATEMENT FOR THE FIRST OF FIVE REMEDIAL ACTIONS AT THE
05/15/1990 DOE
NOTICE
U-006-409.6
DOE/NV/10630-20
5453
U.S. DEPARTMENT OF ENERGY NEVADA OPERATIONS OFFICE
ANNUAL SITE ENVIRONMENTAL REPORT - 1990 VOLUME 1
SEPTEMBER 1991
09/01/1991 DOE-NEVADA
200
REPORT
U-006-409.7 A PHASE I CULTURAL RESOURCES RECONNAISSANCE OF THE FEED
5497 MATERIALS PRODUCTION CENTER ALTERNATE WATER SUPPLY
SYSTEM, FERNALD, HAMILTON COUNTY, OHIO BY US ARMY

U-006-501.1 DOE-2185-94 OPERABLE UNIT 4 DRAFT RECORD OF DECISION/RESPONSIVENESS
5812 SUMMARY
09/01/1992 US ARMY
DOE-FN
08/05/1994 DOE-FN
EPAs
65
569
REPORT
REPORT
U-006-504.1
5902
APPROVAL OF THE DRAFT OU 4 RECORD OF DECISION
09/01/1994 USEPA
DOE-FN
LETTER
U-006-707.1 DOE-0245-94 OPERABLE UNIT 4 REMEDIAL INVESTIGATION/FEASIBILITY
4855 STUDY SCHEDULE
11/03/1993 DOE-FN
EPAs
LETTER
U-006-707.2
5073
U.S. EPA/OHIO EPA MAJOR COMMENT RESOLUTION MEETING ON
THE FEASIBILITY STUDY REPORT AND PROPOSED PLAN FOR
REMEDIAL ACTION AT OPERABLE UNIT 4
11/22/1993 DOE-FN/FERMCO
EPAs
MINUTES
-------
Index Number

U-006-708.1
Document Number

DOE-0854-94
5139
Document Title

COMMENCEMENT OF OPERABLE UNIT 4 REMEDIAL ACTIONS WITHIN
15 MONTHS AFTER RECEIPT OF UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY APPROVED RECORD OF DECISION
Document
Date
From
To
02/09/1994 DOE-FN
EPAs
# of
Pages

2
Type of
Documents

LETTER
U-006-710.1
5531
U.S. DOE REQUEST FOR EXTENSION ON THE OU #4 DRAFT
RECORD OF DECISION
04/29/1994 USEPA
DOE-FN
LETTER
U-006-710.2
DOE-1640-94
5515
OPERABLE UNIT 4 RECORD OF DECISION EXTENSION - FORMAL
AMENDED CONSENT AGREEMENT AMENDMENT
05/05 1994 DOE-FN
EPAs
LETTER
U-006-710.2
U-006-710.4
DOE-1734-94
5572
5633
OPERABLE UNIT 4 CONSENT AGREEMENT SCHEDULE - REQUEST
FOR EXTENSION OF THE FEASIBILITY STUDY/PROPOSED
PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT PUBLIC REVIEW
PERIOD AND THE SUBMITTAL OF THE DRAFT RECORD OF
DECISION TO THE USEPA

U.S. DOE REQUEST FOR SECOND EXTENSION OF THE OU #4
DRAFT RECORD OF DECISION
05/19/1994 DOE-FN
EPAs
05/26/1994 USEPA
DOE-FN
LETTER
NOTICE
U-006-710.5
DOE-1860-94
5646
OPERABLE UNIT 4 RECORD OF DECISION EXTENSION - FORMAL
AMENDED CONSENT AGREEMENT AMENDMENT
06/13/1994 DOE-FN
LETTER
U-006-710.6
U-006-1003.1
5791
308
U.S. DOE OU #4 DRAFT RECORD OF DECISION EXTENSION
AMENDMENT

THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW
OF THE INITIAL SCREENING OF ALTERNATIVES FOR OEPRABLE
UNIT 4 (SILOS 1,2,3,& 4) AT THE DOE'S FMPC AT FERNALD,
OHIO
07/25/1994 USEPA
DOE-FN

06/04/1990 DOE
PUBLIC
LETTER
NOA
U-006-1003.2
U-006-1003.8
326
C:OP:93-484
4293
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW
OF THE INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE
UNIT 4 (SILOS 1,2,3,4) AT THE DOE FMPC AT FERNALD, OHIO

APPROVAL OF NOTICE OF AVAILABILITY (NOA) FOR OPERABLE
UNIT 4 REMEDIAL INVESTIGATION REPORT
05/30/1990 DOE
PUBLIC
04/16/1993 FERMCO
DOE
NOA
-------
Index Number Document Number

U-006-1003.9
4294
U-006-1003.10 C:OP:93-484
4959
U-006-1003.11
4960
U-006-1003.12 C:P:93-1343
4963
U-006-1003.13
4964
U-006-1003.14 C:ENV:94-0006
5183
Document Title

THE USDOE ANNOUNCES THE AVAAILABILITY FOR THE PUBLIC REVIEW
AND COMMENT OF THE ADMINISTRATIVE RECORD FILE FOR THE
OPERABLE UNIT 4 REMEDIAL INVESTIGATION REPORT AT THE
DOE FEMP AT FERNALD, OHIO
Document
Date
APPROVAL OF NOTICE OF AVAILABILITY (NOA)
UNIT 4 REMEDIAL INVESTIGATION REPORT
FOR OPERABLE
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW
AND COMMENT OF THE ADMINISTRATIVE RECORD FILE FOR THE
OPERABLE UNIT 4 REMEDIAL INVESTIGATION REPORT AT THE
DOE FEMP, FERNALD, OHIO

APPROVAL FOR NOTICE OF AVAILABILITY (NOA) FOR THE
OPERABLE UNIT 4 DRAFT FEASIBILITY STUDY REPORT AND
DRAFT PROPOSED PLAN

THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC
INSPECTION OF THE DRAFT FEASIBILITY STUDY REPORT AND
DRAFT PROPOSED PLAN FOR OPERABLE UNIT 4 AT THE DOE
FEMP, FERNALD, OHIO

APPROVAL FOR NOTICE OF AVAILABILITY (NOA) OF THE
OPERABLE UNIT 4 FEASIBILITY STUDY REPORT/PROPOSED PLAN
- DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR FORMAL
PUBLIC COMMENT
From
To
04/19/1993 DOE
PUBLIC
04/16/1993 FERMCO
DOE

04/06/1993 DOE
PUBLIC
09/13/1993 FERMCO
DOE
09/13/1993 DOE
PUBLIC
02/23/1994 FERMCO
DOE-FN
# of Type of
Pages Documents
1
NOA
LETTER
NOA
LETTER
NOA
LETTER
U-006-1003.15
5184
U-006-1003.16 C:ENV:94-0016
5483
U-006-1003.17
5484
THE USDOE AT THE FEMP, FERNALD, OHIO, ANNOUNCES THE
AVAILABILITY OF THE OPERABLE UNIT 4 FEASIBILITY STUDY
REPORT/PROPOSED PLAN - DRAFT ENVIRONMENTAL IMPACT
STATEMENT FOR FORMAL PUBLIC COMMENT

APPROVAL FOR NOTICE OF AVAILABILITY (NOA) FOR EXTENDING
THE PUBLIC COMMENT PERIOD FOR OPERABLE UNIT 4
FESIBILITY STUDY/PROPOSED PLAN - DRAFT ENVIRONMENTAL

THE USDOE FEMP ANNOUNCES THE EXTENSION OF THE PUBLIC
REVIEW AND COMMENT PERIOD ON THE OPERABLE UNIT 4
FEASIBILITY STUDY REPORT/PROPOSED PLAN-DRAFT
03/02/1994 DOE-FN
PUBLIC
04/19/1994 FERMCO
DOE-FN
04/19/1994 DOE-FN
PUBLIC
NOA
LETTER
NOA
-------
Index Number Document Number

U-006-1003.18 C:ENV:94-0020
5581
Document Title

APPROVAL FOR NOTICE OF AVAILABILITY (NOA) FOR EXTENDING
THE PUBLIC COMMENT PERIOD FOR THE OPERABLE UNIT 4
FEASIBILITY STUDY/PROPOSED PLAN - DRAFT ENVIRONMENTAL
IMPACT STATEMENT
Document
Date
From
To
05/18/1994 FERMCO
DOE-FN
# of
Pages

1
Type of
Documents

LETTER
U-006-1003.19
5582
THE USDOE FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
ANNOUNCES THE EXTENSION OF THE PUBLIC REVIEW AND
COMMENT PERIOD ON THE OPERABLE UNIT 4 FEASIBILITY STUDY
PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT
05/18/1994 DOE-FN
PUBLIC
NOA
U-006-1003.20
C:ENV:94-0032
5828
APPROVAL FOR NOTICE OF AVAILABILITY (NOA) FOR DRAFT
RECORD OF DECISION FOR REMEDIAL ACTIONS AT OPERABLE
UNIT 4
06/27/1994 FERMCO
DOE-FN
LETTER
U-006-1003.21
5829
THE UNITED STATES DEPARTMENT OF ENERGY ANNOUNCES THE
AVAILABILITY FOR PUBLIC INSPECTION THE PROPOSED DRAFT
RECORD OF DECISION FOR REMEDIAL ACTION AT OPERABLE UNIT
4 AT THE FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
08/17/1994 DOE-FN
PUBLIC
NOA
U-006-1004.2
5369
U.S. DEPARTMENT OF ENERGY PUBLIC MEETING MARCH 21,
1994
03/21/1994
DOE-FN
PUBLIC
65
TRANSCRIPT
U-006-1005.1
5417
PUBLIC HEARING AND FORMAL COMMENT SESSION ON THE
PROPOSED PLAN FOR OPERABLE UNIT 4
03/14/1994
DOE-FN
PUBLIC
NOTICE
U-006-1005.2
U-006-1005.3
U-006-1006.1
5418
5419
5189
AGENDA, OVERHEADS AND HANDOUTS FROM THE PUBLIC HEARING
OF THE OPERABLE UNIT 4 PROPOSED PLAN MARCH 21, 1994

PUBLIC HEARING SIGN-IN SHEETS FROM THE OPERABLE UNIT 4
FEASIBILITY STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL
IMPACT STATEMENT HELD MARCH 21, 1994

FACT SHEET FOR THE PROPOSED PLAN FOR REMEDIAL ACTIONS
AT OPERABLE UNIT 4 SILOS 1-4 FEBRUARY 1994
03/21/1994
03/21/1994
DOE-FN
PUBLIC

DOE-FN
02/18/1994 DOE-FN
PUBLIC
65
42
16
HANDOUTS
ROSTER
FACT SHEET
-------
Index Number

R-008-101.1

R-008-101.2

R-008-101.3

R-008-101.4

R-008-101.5

R-008-101.6

R-008-101.7

R-008-101.8

R-008-101.9

R-008-101.10

R-008-101.11

R-008-101.12
Document Number Document Title

K-65 AREA WEEKLY REPORT MAY 23, 1991
2226
1292
1298
1369
1564
1620
1741
1906
1896
2059
1931
K-65 AREA WEEKLY REPORT MAY 30, 1991

K-65 AREA WEEKLY REPORT JUNE 6, 1991

K-65 AREA WEEKLY REPORT JUNE 14, 1991

K-65 AREA WEEKLY REPORT JUNE 21, 1991

K-65 WEEKLY REPORT JUNE 28, 1991
DOE-1765-91 K-65 WEEKLY REPORT JULY 5, 1991
1867
K-65 WEEKLY REPORT JULY 19, 1991

K-65 WEEKLY REPORT JULY 26, 1991

K-65 WEEKLY REPORT AUGUST 2, 1991

K-65 WEEKLY REPORT AUGUST 9, 1991

K-65 WEEKLY REPORT AUGUST 16, 1991
Document
Date
05/23/1991
05/31/1991
06/06/1991
06/14/1991
06/21/1991
06/28/1991
07/05/1991
07/19/1991
07/26/1991
08/02/1991
08/09/1991
08/16/1991
From
To
DOE
EPAs
DOE
USEPA
DOE
USEPA
DOE
USEPA
DOE
USEPA
DOE
USEPA
DOE
USEPA
DOE
USEPA
DOE
USEPA
DOE
EPAs
DOE
EPAs
DOE
EPAs
# of
Pages
23
4
4
4
7
12
2
10
4
4
4
3
Type of
Documents
Report
Report
Report
Report
Report
Report
Letter
Report
Report
Report
Report
Report
-------
Index Number

R-008-101.13

R-008-101.14

R-008-101.15

R-008-101.16

R-008-101.17

R-008-101.18

R-008-101.19

R-008-101.20

R-008-101.21

R-008-101.22

R-008-101.23

R-008-101.24
Document Number Document Title

K-65 WEEKLY REPORT AUGUST 22, 1991
1999
2061
2236
2237
2209
2238
2239
2314
2359
2372
2402
2509
K-65 WEEKLY REPORT AUGUST 30, 1991

K-65 WEEKLY REPORT SEPTEMBER 13, 1991

K-65 WEEKLY REPORT SEPTEMBER 20, 1991

K-65 WEEKLY REPORT FOR SEPTEMBER 27, 1991

K-65 WEEKLY REPORT OCTOBER 4, 1991

K-65 WEEKLY REPORT OCTOBER 11, 1991

K-65 WEEKLY REPORT OCTOBER 18, 1991

K-65 WEEKLY REPORT OCTOBER 25, 1991

K-65 WEEKLY REPORT NOVEMBER 1, 1991

K-65 WEEKLY REPORT NOVEMBER 8, 1991

K-65 WEEKLY REPORT NOVEMBER 15, 1991
Document
Date
08/22/1991
08/30/1991
09/13/1991
09/20/1991
09/27/1991
10/04/1991
10/11/1991
10/18/1991
10/25/1991
11/01/1991
11/08/1991
11/15/1991
From
To
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
EPAs
# of
Pages
3
4
4
4
7
4
4
6
4
4
4
4
Type of
Documents
Report
Report
Report
Report
Report
Report
Report
Report
Report
Report
Report
Report
-------
Index Number

R-008-101.25

R-008-101.26

R-008-101.27

R-008-101.28

R-008-105.1

R-008-106.1

R-008-106.2

R-008-106.3

R-008-106.4

R-008-106.5

R-008-108.1

R-008-201.1
Document Number Document Title

K-65 WEEKLY REPORT NOVEMBER 22, 1991
2516
2521
5347
5348
1432

DOE-745-92
2703

DOE-1015-92
3030

DOE-1382-92
3184

DOE-1742-92
3290

DOE-2022-92
3512
K-65 WEEKLY REPORT NOVEMBER 29, 1991

K-65 WEEKLY REPORT JULY 12, 1991

K-65 WEEKLY REPORT SEPTEMBER 6, 1991
Document
Date

11/22/1991
11/29/1991
07/12/1991
09/06/1991
REVIEW OF THE K-65 SILOS STUDIES FOR THE FMPC APRIL 1, 04/01/1991
1991

SILOS 1 AND 2 REMOVAL ACTION BENTONITE EFFECTIVENESS 01/27/1992
ENVIRONMENTAL MONITORING PLAN

REVISED SILO 1 AND 2 REMOVAL ACTION BENTONITE 03/17/1992
EFFECTIVENESS ENVIRONMENTAL MONITORING PLAN

SILOS 1 & 2 REMOVAL ACTION BENTONITE EFFECTIVENESS 04/16/1992
ENVIRONMENTAL MONITORING PLAN

BENTONITE EFFECTIVENESS MODEL RESULT FOR JANUARY 05/22/1991
THROUGHT APRIL, 1992

BENTONITE EFFECTIVENESS MODEL RESULT FOR MAY 1992 06/30/1992
NEPA DOC 278 EVALUATION OF STRUCTURAL STABILITY OF THE K-65 SILOS AT 10/30/1989
4479 FERNALD NEPA DOC 278
DOE-1060-90
3047
REMOVAL SITE EVALUATION K-65 SILOS
05/21/1990
From
To

DOE
EPAs

SANDIA NL
DOE

DOE
EPAs

EPA
DOE

DOE-FMPC
DOE-HQ

DOE-FO
WMCO
# of
Pages
27
Type of
Documents

Report
Report
REPORT
REPORT
Report
Letter
Letter
Letter
Letter
Letter
Report
Letter
-------
Index Number

R-008-201.2

R-008-202.1

R-008-203.1

R-008-203.2

R-008-203.3

R-008-203.4

R-008-203.5

R-008-204.1

R-008-204.2

R-008-204.3

R-008-204.4

R-008-204.5
Document Number

DOE-159-91
1683
294
444

DOE-1537-90
1244
443
3270
3271
DOE-566-90
266

PM&A-PM4-91-406
5349
5444

DOE-213-91
2336
1875
Document Title

REMOVAL ACTION MEMORANDUM: SILOS 1 & 2 REMOVAL ACTION

REMOVAL SITE EVALUATION K-65 SILOS
A BASELINE RISK ASSESSMENT FOR THE K065 SILOS USING EPA
METHODOLOGY FOR APPLICABILITY TO THE EE/CA MAY 11, 1990

TRANSMITTAL OF THE K-65 SILOS EE/CA - CONSENT AGREEMENT
DELIVERABLE

ENGINEERING EVALUATION/CPST ANALYSIS (EE/CA) K-65 SILOS
REMOVAL ACTION AT THE FMPC JULY 1990

ENGINEERING EVALUATION/COST ANALYSIS - ENVIRONMENTAL
ASSESSMENT FOR THE K-65 SILOS REMOVAL ACTION, FEMP

FINDING OF NO SIGNIFICANT IMPACT ENGINEERING
EVALUATION/COST ANALYSIS - ENVIRONMENTAL ASSESSMENT
K-65 SILOS REMOVAL ACTION FERNALD ENVIRONMENTAL

REVISED K-65 WORK PLAN
RISK MANAGEMENT PLAN FOR OPERABLE UNIT 4 SILOS 1 & 2
(K-65) REMOVAL ACTION

SILOS 1 AND 2 OPERATIONAL SAFETY REQUIREMENTS REVISION
NO. 4 NOVEMBER 1991

K-65 SILOS REMOVAL ACTION WORK PLAN
SILOS 1 AND 2 (K-65 SILOS) REMOVAL ACTION WORK PLAN
NOVEMBER 1990
Document
Date
10/29/1990
05/21/1990
05/11/1990
07/31/1990
07/31/1990
11/14/1991
11/14/1991
From
To
DOE-FSO
WMCO
DOE-FMPC
WMCO
UC
DOE-FMPC
DOE-FMPC
EPAs
BNI
DOE
DOE
DUFFY
DOE
# of Type of
Pages Documents
2 Letter
5 RSE
132 Report
2 Letter
135 Report
2 Letter
9 Report
03/13/1990 DOE-ORO
DOE-FMPC

09/11/1991 WEMCO
DOE

11/01/1991 PARSONS
DOE-FN

11/02/1991 DOE-FMPC
EPAs

11/01/1990
19
25
25
Work Plan
REPORT
REPORT
Letter
Report
-------
Index Number

R-008-204.7

R-008-204.8

R-008-204.9

R-008-204.10

R-008-204.11

R-008-205.10

R-008-205.18
R-008-206.3
Document Number

DOE-1512-91
1561
1562

DOE-0650-93
4009
4010

DOE-0021-94
4777

WMCO:EMT:90-869
1006

WEMCO:ER:92-158
3015
R-008-205.20 DCR65A
4452
2830
R-008-206.5 DOE-2349-92
3601

R-008-206.6 C:OP:93-1284
4749
Document Title

REMOTE SURFACE MAPPING TECHNOLOGY SUPPORT DEMONSTRATION
ON FERNALD SILO 4

FERNALD SILO #4 REMOTE SURFACE MAPPING TECHNOLOGY
SUPPORT DEMONSTRATION WORK PLAN MAY 1991

BENTONITE EFFECTIVENESS EVALUATION FOR OPERABLE UNIT 4
AT THE FERNALD ENVIRONMENTAL MANAGEMENT PROJECT

K-65 SILO REMOVAL ACTION - BENTONITE EFFECTIVENESS
EVALUATION DECEMBER 17, 1992

OPERABLE UNIT 4 SILO 2 CAMERA INSTALLATION/BENTONITE
INSPECTION WORK PLAN

APPROVAL FOR RUST FORCE ACCOUNT TO COMPLETE THE SILOS 1
AND 2 REMOVAL ACTION

TIGER TEAM COMMITMENT NO. TT:89:0243 (TTA#611) -
INTERIM STABILIZATION (FFCA) AND COMPLETE
CHARACTERIZATION REQUIRED (K-65 SILOS)

K-65 SILO VERTICAL BORING SAMPLING AND ANALYSIS PLAN
RI/FS WORK PLAN ADDENDUM MARCH 1991

CHARACTERISTICS OF FENRALD'S K-65 RESIDUE BEFORE,
DURING AND AFTER VITRIFICATION FEBRUARY 1991

RESULTS OF GRAB SAMPLES AND CONTINOUS PYLON MONITORS
FOR SILOS 1 AND 2

K-65 SILOS - HEADSPACE RADON CONCENTRATION
Document
Date
06/21/1991
05/01/1991
12/17/1992
12/17/1992
10/05/1993
12/18/1990
03/17/1992
From
To
DOE-FSO
EPAs
DOE
EPAs
DOE-FN
EPAs
DOE-FN
EPAs
DOE-FN
EPAs
WMCO
DOE
WEMCO
DOE
# of
Pages
2
49
2
200
10
3
2
Type of
Documents
Letter
WORK PLAN
Letter
Report
WORK PLAN
Letter
Letter
03/01/1991
02/01/1991
08/17/1992
DOE
EPAs
50
09/09/1993 FERMCO
DOE-FN
Addendum
Report
Letter
LETTER
R-008-207.1
3329
COMMENTS ON K-65 INTERIM STABILIZATION PROJECT
10/09/1987 OEPA
DOE
Letter
-------
Index Number

R-008-207.2

R-008-207.7

R-008-207.8

R-008-207.9

R-008-207.11

R-008-207.12

R-008-207.13

R-008-207.16

R-008-207.19

R-008-207.21

R-008-207.22

R-008-207.23
Document Number
Document Title
3440
2456
547
1711
1879
919
1794
2804
2453
2903
3168
4129
USEPA REVIEW OF K-65 SILOS INTERIM STABILIZATION
PROJECT

OU#4 - REMOVAL #4 K-65 BORINGS U.S. DOE FERNALD OH6
890 008 976

EE/CA K-65 REMOVAL #4 U.S. DOE-FERNALD OH6 890 008
976

K-65 EE/CA
EE/CA K-65 REMOVAL #4 U.S. DOE-FERNALD OH6 890 008
976

REMOVAL #4 WORK PLAN U.S. DOE-FERNALD OH6 890 008
976

CONDITIONAL APPROVAL OF K-65 REMOVAL WORK PLAN
BACKGROUND INFORMATION ON HOW TARGET RADON
CONCETRATION WAS DERIVED

APPROVAL - REMOTE SURFACE MAPPING TECHONLOGY SUPPORT
DEMONSTRATION ON FERNALD SILO 4 WORK PLAN

DISAPPROVAL OF THE SILO 1 AND 2 REMOVAL ACTION
BENTONITE EFFECTIVENESS ENVIRONMENTAL MONITORING PLAN

APPROVAL OF THE REVISED SILO 1 AND 2 REMOVAL ACTION
BENTONITE EFFECTIVENESS ENVIRONMENTAL MONITORING PLAN

DISAPPROVAL OF THE BENTONITE EFFECTIVENESS EVALUATION
FOR OU4
Document
Date
10/19/1987
08/27/1990
09/04/1990
09/05/1990
10/18/1990
11/30/1991
12/05/1990
01/29/1992
07/25/1991
12/19/1992
04/21/1992
02/12/1993
From
To
US EPA
DOE
US EPA
DOE
US EPA
DOE
OEPA
DOE
US EPA
DOE
US EPA
DOE
OEPA
DOE
US EPA
DOE
OEPA
DOE
US EPA
DOE
US EPA
DOE
US EPA
DOE-FN
# of
Pages
3
3
3
2
2
2
1
2
1
1
1
25
Type of
Documents
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Comment
-------
Index Number

R-008-207.24

R-008-208.5

R-008-208.7

R-008-208.9

R-008-208.11

R-008-208.12

R-008-208.14
Document Number
Document Title
R-008-208.17
R-008-208.18
R-008-208.21
4931
557
APPROVAL OF THE CAMERA INSTALLATION/BENTONITE
INSPECTION WORK PLAN

K-65 REMOVAL ACTION ENGINEERING EVALUATION/COST
ANALYSIS RESPONSIVENESS SUMMARY
DOE-1904-90 EXTENSION OF PUBLIC COMMENT PERIOD FOR THE K-65 EE/CA
1680

DOE-1870-90 K-65 SILOS REMOVAL ACTION
1732
Document
Date

11/24/1993
10/17/1990
09/11/1990
09/27/1990
DOE-19-91
1908

DOE-35-91
1933

DOE-131-91
1932
K-65 SILOS REMOVAL ACTION - INFORMAL DISPUTE RESOLUTION 10/04/1990

K-65 ACTION REMOVAL - STATEMENT OF DISPUTE 10/11/1990
K-65 REMOVAL ACTION
R-008-208.15 DOE-557-91 RESPONSE TO OHIO EPA COMMENTS ON THE SILOS 1 AND 2
10/22/1990
01/11/1991
5346
1910
1911
REMOVAL ACTION WORK PLAN

RESPONSE TO U.S. EPA COMMENTS

RESPONSE TO OHIO EPA COMMENTS
DOE-1023-91 K-65 SILOS WORKING GROUP STATUS REPORT
2182
03/28/1991
R-008-208.22 DOE-1186-91 MAJOR POINTS AND ISSUES RESULTING FROM THE APRIL 10, 04/22/1991
2979
1991 MEETING
From # of Type of
To Pages Documents

USEPA 1 LETTER
DOE-FN

DOE 14 Response
EPAs

DOE 2 Letter
EPAs

DOE 2 Letter
USEPA

DOE 3 Letter
USEPA

DOE-FMPC 31 RESPONSES
OEPA

DOE 4 Response
USEPA

DOE 12 Response
OEPA

DOE 1 Letter
K-65 SR. COMMITTEE

DOE 7 Letter
EPAs
-------
Index Number

R-008-208.23

R-008-208.25

R-008-208.29

R-008-209.1

R-008-209.2

R-008-1002.1

R-008-1003.1

R-008-1003.2

R-008-1004.1
Document Number

DOE-1344-91
1502

DOE-1359-91
1287

DOE-1508-91
1366

DOE-382-92
2515

DOE-871-88
4374
5528
5905
447
305
4068
Document Title

K-65 REMOVALACTION ADVISORY COMMITTEE

MAJOR POINTS OF DISCUSSION

K-65 TABLETOP EXERCISE
DELAY OF THE INITIATION OF THE INSTALLATION OF THE
BENTONITE IN SILOS 1 AND 2

COMPLETION REPORT FOR THE EXTERIOR FOAM
APPLICATION/RADON TREATMENT SYSTEM OPERATION OF THE
K-65 INTERIM STABILIZATION PROJECT - FEED MATERIALS
PRODUCTION CENTER

DRAFT FINAL REPORT FOR THE SILOS 1 & 2 (K-65) REMOVAL 05/17/1994
ACTION MAY 1994

ADDENDUM TO THE RI/FS COMMUNITY RELATIONS PLAN FOR
REMOVAL ACTION NO.4 SILOS 1 AND 2 AUGUST 1990

THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW 08/01/1990
OF THE ENGINEERING EVALUATION/COST ANALYSIS FOR THE
K-65 SILOS (SILOS 1 AND 2) REMOVAL ACTION AT THE DOE
FMPC AT FERNALD, OHIO

THE USDOE ANNOUNCES THE AVAILABILITY OF THE
ADMINISTRATIVE RECORD FILE FOR THE K-65 SILOS (SILOS 1
AND 2) REMOVAL ACTION AT THE DOE'S FMPC AT FERNALD,
OHIO

K-65 SILOS REMOVAL ACTION COMMUNITY WORKSHOP AND SITE 08/16/1991
SPECIFIC PLAN PRESENTATION AUGUST 16, 1990
Document
Date
05/15/1991
05/17/1991
06/11/1991
11/20/1991
05/23/1988
05/17/1994
08/01/1990
08/01/1990
05/07/1990
From
To
DOE
US EPA
DOE
EPAs
DOE
EPAs
DOE
EPAs
DOE
US EPA
DOE-FN
EPAs
DOE-FN
EPAs
DOE
PUBLIC
DOE
PUBLIC
# of Type of
Pages Documents
2 Letter
10 Letter
4 Letter
2 Letter
50 Report
146 REPORT
5 ADDENDUM
2 NOA
1 NOA
DOE-FN
150
Transcript
-------
Index Number

R-014-108.1
Document Number

NEPA DOC 312
4461
Document Title

CATEGORICAL EXCLUSION DETERMINATION K-65 DECANT SUMP
TANK REMOVAL ACTION NEPA DOC. NO. 312
Document
Date

12/21/90
From
To

DOE
DOE
# of Type of
Pages Documents

4 Report
R-014-201.1
R-014-202.1
R-014-204.1
R-014-204.2
R-014-204.3
DOE-1784-90
901

WMCO:EMT:90-539
485
539

DOE-76-91
2187
546
REMOVAL ACTION MEMORANDUM: K-65 DECANT SUMP TANK
REMOVAL SITE EVALUATION K-65 DECANT SUMP TANK WATER
K-65 DECANT SUMP TANK REMOVAL ACTION WORK PLAN FMPC
DRAFT

K-65 DECANT SUMP TANK REMOVAL ACTION WORK PLAN
K-65 DECANT SUMP TANK REMOVAL ACTION WORK PLAN FMPC
SEPTEMBER 1990
08/23/1990

08/17/1990

09/01/1990

10/17/1990

09/01/1990
DOE
WMCO

WMCO
DOE

WMCO
DOE-ORO

DOE
EPAs

DOE
EPAs
45
49
Letter
RSE
Work Plan
Letter
Work Plan
R-014-204.4
R-014-204.5
R-014-207.1
905
5441
1994
K-65 DECANT SUMP TANK REMOVAL ACTION WORK PLAN FMPC
DECEMBER 1990

K-65 DECANT SUMP TANK REMOVAL ACTION RISK MANAGEMENT
PLAN MARCH 1991

REMOVAL #5 K-65 DECANT TANK U.S. DOE-FERNALD OH6
890 008 976
12/01/1990
03/01/1991
11/13/1990
DOE
EPAs

WEMCO
DOE-FN

US EPA
DOE
71
Work Plan
WORK PLAN
Letter
R-014-207.2
R-014-207.3
R-014-207.4
1789
1139
1989
COMMENTS K-65 DECANT SUMP TANK REMOVAL W.P.
REMOVAL #5 - DECANT SUMP TANK U.S. DOE FERNALD
OH6 890 008 976

CONDITIONAL APPROVAL K-65 DECANT SUMP REMOVAL WORK PLAN
11/19/1990
01/10/1991
01/11/1991
OEPA
DOE

US EPA
DOE

OEPA
DOE
Letter
Letter
Letter
-------
Index Number

R-014-207.5

R-014-207.6
Document Number Document Title

K-65 DECANT SUMP REMOVAL
1098
3763
U.S. EPA COMMENTS ON REMOVAL ACTION 5: K-65 DECANT SUMP
TANK FINAL REPORT
Document
Date

04/01/1991

09/25/1992
From
To

OEPA
DOE

US EPA
DOE
# of Type of
Pages Documents

1 Letter
Letter
R-014-207.7
R-014-207.8
3787
4024
OHIO EPA COMMENTS ON THE OU 4 - DECANT SUMP TANK
REMOVAL ACTION FINAL REPORT

APPROVAL OF THE OU4 DECANT SUMP TANK FINAL REPORT
10/01/1992
12/14/1992
OEPA
DOE

OEPA
DOE-FN
Letter
Letter
R-014-207.9
4019
REMOVAL ACTION 5: K-65 DECANT SUMP TANK FINAL REPORT
RESPONSE TO COMMENTS
12/29/1992
US EPA
DOE-FN
Response
R-014-208.1
1140
WMCO TECHNICAL RECOMMENDATIONS FOR THE RESPONSE TO U.S.
EPA MODIFICATIONS OF THE K-65 DECANT SUMP TANK REMOVAL
ACTION WORK PLAN
WMCO
DOE
Enclosure
R-014-208.2
DOE-867-91
1142
K-65 DECANT SUMP TANK REMOVAL ACTION
03/01/1991 DOE
US EPA
Letter
R-014-208.3
R-014-208.4
R-014-208.5
R-014-208.6
R-014-209.1
903
904
1990

DOE-0343-93
3895
3611
RESPONSE TO THE U.S. EPA COMMENTS K-65 DECANT SUMP TANK
REMOVAL ACTION WORK PLAN

RESPONSE TO OHIO EPA COMMENTS K-65 DECANT SUMP TANK
REMOVAL ACTION WORK PLAN

THE RESPONSE TO OHIO EPA GENERAL COMMENTS ON THE K-65
DECANT SUMP TANK REMOVAL ACTION WORK PLAN

RESPONSES TO COMMENTS ON THE OPERABLE UNIT (OU) 4
DECANT SUMP TANK FINAL REPORT

FINAL REPORT K-65 DECANT SUMP TANK REMOVAL ACTION
AUGUST 1992
12/11/1990
12/11/1990 DOE
11/19/1992
08/01/1992 DOE
EPAs
DOE
US EPA
DOE
OEPA
DOE
OEPA
DOE
EPAs
DOE
8
2
2
30
40
Response
Response
Response
Response
Report
-------
Index Number

R-014-209.2

R-014-209.3

R-014-401.1

R-014-1002.1

R-014-1003.1
Document Number Document Title

DOE-1282-93 DECANT SUMP TANK FINAL REPORT
4148
4149
1141
5906
1766
REVISED FINAL REPORT K-65 DECANT SUMP REMOVAL ACTION
FEBRUARY 1993

POTENTIAL ARARS K-65 DECANT SUMP TANK REMOVAL ACTION
ADDENDUM B TO THE RI/FS COMMUNITY RELATIONS PLAN FOR
REMOVAL ACTION NO. 5 K-65 DECANT SUMP TANK AUGUST
1991

THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW
OF THE ADMINISTRATIVE FILE FOR THE K-65 DECANT
SUMP TANK REMOVAL ACTION AT THE DOE FEMP, FERNALD, OHIO
Document
Date
03/05/1993
02/01/1993

08/01/1991

From
To
DOE-FN
EPAs
DOE-FN
EPAs
DOE
EPAs
DOE-FN
EPAs
DOE
PUBLIC
# of
Pages
2
30
5
5
1
Type of
Document:
Letter
Report
Report
ADDENDl
NOA
-------
Index Number

R-025-104.1

R-025-108.1

R-025-108.2

R-025-201.1

R-025-201.2

R-025-201.3

R-025-202.1

R-025-204.1

R-025-204.2

R-025-206.1

R-025-209.1

R-025-209.2
Document Number

DOE-65-91
5443

NEPA DOC. 369
4462

NEPA DOC 386
4481

DOE-105-91
2244

DOE-515-91
2676

DOE-523-92
2538
2245

WEMCO:P:91-957
2677

WEMCO:P:92-008
2780

DOE-016-92
2211

WEMCO:EVP:92-014
2682

DOE-1215-93
4143
Document Title

PERMIT TO OPERATE FOR FMPC SILO NO.3
CATEGORICAL EXCLUSION DETERMINATION SILO 3 REMOVAL
ACTION NEPA DOCUMENT 369

CATEGORICAL EXCLUSION DETERMINATION SILO 3 BEST
MANAGEMENT PRACTICES (BMP) WEATHERPROOFING NEPA DOC 386

ACTION MEMORANDUM: SILO 3
ACTION MEMORANDUM: SILO 3 REMOVAL ACTION
SILO 3 REMOVAL ACTION
REMOVAL SITE EVALUATION SILO 3
SILO 3 REMOVAL ACTION SCOPE OF WORK
SILO 3 BEST MANAGEMENT PRACTICE WORK PLAN
CHAIN-OF-CUSTODY FOR SILO 3 MATERIAL
SILO 3 REMOVAL ACTION
SILO 3 EXPEDITED REMOVAL ACTION FINAL REPORT
Document
Date
10/19/1990
03/03/1992
07/02/1992
10/03/1991
12/13/1991
12/19/1991
09/01/1991
12/17/1991
01/06/1992
10/04/1991
01/23/1992
02/24/1993
From
To
DOE-FMPC
OEPA
DOE-FN
DOE-HQ
DOE-FN
DOE-HQ
DOE
WEMCO
DOE
WEMCO
DOE
EPAs
DOE
WEMCO
WEMCO
DOE
WEMCO
DOE
DOE
US EPA
WEMCO
DOE
DOE-FN
EPAs
#
P,
8
5
4
2
2
2
50
4
16
2
1
2
# of Type of
Pages Documents

LETTER
Report

Report

Letter

RSE

Letter

Work Plan

Letter

Letter
-------
Index Number

R-025-209.3

R-025-1003.1

R-025-1003.2
Document Number
4144

WEMCO:EM(AR):91-087
2678
2679
Document Title

FINAL REPORT SILO 3 REMOVAL ACTION SEPTEMBER 1993
APPROVAL OF NOTICE OF AVAILABILITY
EXPEDITED REMOVAL ACTION
(NOA) FOR THE SILO 3
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW
OF THE ADMINISTRATIVE RECORD FILE FOR THE SILO 3
EXPEDITED REMOVAL ACTION AT THE DOE FMPC, FERNALD, OHIO
Document
Date
02/01/1993
01/09/1992

From
To
DOE-FN
EPAs
WEMCO
DOE
DOE
PUBLIC
# of
Pages
40
1
1
Type of
Documents
Report
Letter
NOA
-------
Index Number Document Number Title
Document From
Date To
# of Pages
Document Type
U-006-105 .
U-006-105 .
U-006-105 .
U-006-105 .
U-006-105 .
U-006-302 .
U-006-302 .
U-006-302 .
U-006-302 .
5975
5976
5977
5978
5979
5999
6000
6001
6002
FINAL DESIGN REPORT RADON MITIGATION & DOME REINFORCEMENT PROJECT
EVALUATION OF WMCO FOAM ALTERNATIVES
QUALITATIVE FEASIBILITY STUDY OF ALTERNATIVES FOR INTERIM REMEDIATION
OF K-65 SILOS
QUANTITATIVE ANALYSIS REPORT OF ALTERNATIVES FOR INTERIM REMEDIATION
OF K-65 SILOS
THE ADAPTABILITY OF VITRIFICATION TECHNOLOGY TO K-65 RESIDUE MATERIAL
INDEX OF CHEMICAL DATA PACKAGES - OPERABLE UNIT 4 - AUGUST, 1994
08/20/87 IT CORP.
DOE-FN
04/06/88 IT CORP.
DOE-FN
06/17/88 TI CORP.
DOE-FN
07/01/88
337
144
27
188
05/25/89 PAC. NW LABS 7
DOE-FN
08/31/94 FERMCO
FERMCO
24
INDEX OF REFERENCED CHECMICAL ANALYTICAL DATA PACKAGES - OPERABLE UNIT 08/31/94 FERMCO
4 - AUGUST 1994 FERMCO
INDEX OF RADIOLOGICAL ANALYTICAL DATA PACKAGES - OPERABLE UNIT 4 -
AUGUST 1994
INDEX OF REFERENCED RADIOLOGICAL ANALYTICAL DATA PACKAGES - OPERABLE
UNIT 4 -AUGUST 1994
08/31/94 FERMCO
FERMCO
08/31/94 FERMCO
FERMCO
REPORT
REPORT
REPORT
REPORT
REPORT
DATA
DATA
DATA
DATA
U-006-302 .
6003
INDEX OF FIELD FORMS - OPERABLE UNIT 4 - AUGUST 1994
08/31/94 FERMCO
FERMCO
DATA
-------
Index Number Document Number
Title
Document
Date
From
To
# of Pages
Document Type
U-006-303 .
U-006-305 .
U-006-408 .
U-006-408 .
5980

5981

DOE-2378,79,80-94

5982

5983
SITE SPECIFIC SAFETY PLAN FOR THE K-65 LOW-ANGLE BORING OPERATIONS 03/06/91
MARCH 6, 1991
HAMILTON COUNTY COMMENTS - OU 4 PHASE II PILOT PLANT TRT STUDY WP 09/08/94
TRANSMITTAL OF RESPONSIVENESS SUMMARY FOR THE OPERABLE UNIT 4 09/09/94
FEASIBILITY STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT
SEPTEMBER 1994

RESPONSIVENESS SUMMARY FOR THE OPERABLE UNIT 4 FEASIBILITY 09/09/94
STUDY/PROPOSED PLAN - DRAFT ENVIRONMENTAL IMPACT STATEMENT - SEPTEMBER
1994
IT 65
DOE-FN
OEPA
DOE-FN
DOE-FN 3
STAKEHOLDER
DOE-FN 352
EPA/STAKEHOLDER
REPORT
COMMENTS
LETTER
RESPONSE
U-006-504 .
U-006-505 .
U-006-505 .
OU4 RECORD OF DECISION - COMMENTS
09/12/94
5984

DOE-2389-94

5985

DOE-0034-95

6056
EXTENSION REQUEST FOR THE SUBMITTAL OF THE FINAL OPERABLE UNIT 4 FINAL 09/14/94
RECORD OF DECISION
TRANSMITTAL OF RESPONSES TO THE UNITED STATES ENVIRONMENTAL PROTECTION 10/11/94
AGENCY AND THE OHIO ENVIRONMENTAL PROTECTION AGENCY COMMENTS ON THE
CONDITIONALLY APPROVED DRAFT RECORD OF DECISION FOR OPERABLE UNIT 4
OEPA
DOE-FN
DOE-FN
US EPA
DOE-FN
EPAS
COMMENTS
LETTER
LETTER
U-006-505 .
U-006-1003.
6057

C:ENV:94-0047

5986
PROPOSED DRAFT RECORD OF DECISION FOR REMEDIAL ACTIONS AT OPERABLE
UNIT 4 RESPONSE TO COMMENTS - OCTOBER 1994
10/11/94
APPROVAL FOR NOTICE OF AVAILABILITY (NOA) OF THE RESPPONSIVENESS 09/13/94
SUMMARY FOR THE OPERABLE UNIT 4 FEASIBILITY STUDY/PROPOSED PLAN-DRAFT
ENVIRONMENTAL IMPACT STATEMENT
DOE-FN
EPAS
FERMCO
DOE-FN
15
RESPONSES
LETTER
U-006-1003.
5987
THE UNITED STATES DEPARTMENT OF ENERGY ANNOUNCES THE AVAILABILITY FOR 09/14/94 DOE-FN
PUBLIC INSPECTION OF THE RESPONSIVENESS SUMMARY FOR THE OPERABLE UNIT PUBLIC
4 FEASIBILITY STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT
NOA
-------
Index Number Document Number
Title
Document From
Date To
# of Pages
Document Type
U-006-1005.
OVERHEADS PRESENTED AT THE MAY 11, CAB MEETING IN NEVADA - (CITIZEN'S
ADVISORY BOARD)
05/11/94 DOE-FN
CAB
48
OVERHEADS
5988
-------
APPENDIX E
STATE OF OHIO CONCURRENCE
TABLE D.3-5 (Continued)
Pathway Parameters

Inhalalion of Volatiles Released from

IR (m3/hr)

ET (hr/d)

EF (d/yr)

ED (yr)

BW (kg)

AT-Noncancer (d)f

AT-Cancer (d)g

Incidental Ingestion of Soil/Sediment

IR (g/hr)

FI (unitless)

EF (d/yr)

ED (yr)

BW (kg)

AT-Noncancer (d)f

AT-Cancer (d)g

See footnotes at end of table.
Trespassing
Child
Age 6-18
ihold Water
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.1
0.25
52
12
43
4380
25550
Expanded
Trespasser
Child
Age 6-18
Uses
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.1
0.1
110
12
43
4380
25550
Expanded RME CT On-Property On-Property
Trespasser On-Property Resident Resident
Adult Farmer Farmer Child
18-50 Age 1-70 Age 1-70 Age 1-6

N/A 0.63 0.63 0.63
N/A 0.25h 0.17h 0.33h
N/A 350d 275b 350d
N/A 70 9e 6
N/A 70 70 15
N/A 25550 3285 2190
N/A 25550 25550 25550
0.1 0.18 0.122 0.2
0.05 1 1 1
40 350d 275b 350d
32 70 9e 6
70 70 70 15
11680 25550 3285 2190
25550 25550 25550 25550
0.25h

350d

70
-------
Pathway Parameters

Dermal Contact While Bathing

SA (m2)

PC (cm/hr)

ET (hr/d)

EF (d/yr)

ED (yr)

BW (kg)

AT-Noncancer (d)f

AT-Cancer (d)g

Dermal Contact With Soil/Sediment

SA (m2)

DA (cm/m2)

ABS

EF (d/yr)

ED (yr)

BW (kg)

AT-Noncancer (d)f

AT-Cancer (d)g

See footnotes at end of table.
Trespassing
Child
Age 6-18
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.41
1
CSV
52
12
43
4180
25550
Expanded
Trespasser
Child
Age 6-18
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.41
1
CSV
110
12
43
4180
25550
Expanded
Trespasser
Adult
18-50
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.57
1
CSV
40
32
70
11680
25550
RME
On-Property
Farmer
Age 1-70
2.3h
CSV
0.25h
350d
70
70
25550
25550
0.57
CSV
CSV
350d
70
70
25550
25550
CT On-Property
Resident
Farmer
Age 1-70
2.3h
CSV
0.17h
275b
9e
70
3285
25550
0.5
CSV
CSV
275b
9e
70
3285
25550
On-Property
Resident
Child
Age 1-6
0.8h
CSV
0.33h
350d
6
15
2190
25550
0.2
CSV
CSV
350d
6
15
2190
25550
-------
Pathway Parameters

Inhalation of Dusts, Volatiles, and Radon

DR (mrem/hr)

ET Indoors (hr/d)

ET Outdoors (hr/d)

EF (d/yr)

ED (yr)

BW (kg)

Ingestion of Vegetables and Fruit

IR (g/d)

FI (unitless)

EF (d/yr)

ED (yr)

BW (kg)

AT-Noncancer (d)f

AT-Cancer (d)g

Ingestion of Meat

IR (g/d)

FI (unitless)

EF (d/yr)
ED (yr)
Trespassing
Child
Age 6-18
CSV
N/A
4
52
12
43
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Expanded
Trespasser
Child
Age 6-18
CSV
N/A
2
110
12
43
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Expanded
Trespasser
Adult
18-50
CSV
N/A
1
40
32
70
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
RME CT On-Property
On-Property Resident
Farmer Farmer
Age 1-70 Age 1-70
CSV CSV
18.3 19.8
5.7 4.2
350 275
70 9
70 70
122 78b
1 1
350d 275b
70 9e
70 70
25550 3285
25550 25550
75 50b
1 1
350d 275b
70 9e
On-Property
Resident
Child
Age 1-6
CSV
22
2
350
6
15
101.51
1
350d
6
15
2190
25550
29
1
350d
6
N/A
-------
Pathway Parameters

BW (kg)

AT-Noncnacer (d)f

AT-Cancer (d)g

Ingestion of Milk

IR (L/d)

FI (unitless)

EF (d/yr)

ED (yr)

BW (kg)

AT-Noncancer(d)f

AT-Cancer(d)g
Trespassing
Child
Age 6-18
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Expanded
Trespasser
Child
Age 6-18
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Expanded
Trespasser
Adult
18-50
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
RME
On-Property
Farmer
Age 1-70
70
25550
25550
0.3
1
350d
70
70
25550
25550
CT On-Property
Resident
Farmer
Age 1-70
70
3285
25550
0.2b
1
275b
9e
70
3285
25550
On-Property
Resident
Child
Age 1-6
15
2190
25550
0.9
1
350d
6
15
2190
25550
a Parameter values obtained from Final RI Report for Operable Unit 4 (November 1993), Table D.3-12.
b Special guidance from EPA Region V.
c Drinking water consumption rate of 1.4 L/day from NRC (Nuclear Regulatory Commission), 1977, U.S. Nuclear Regulatory Commission) Regu (National Council on Radiation Protection)
Report No. 76.
d Guidance from EPA (1991a), OSWER Directive: 9285.7-01B.
e Guidance from EPA (1991b), Interim Final, OSWER Directive: 9285.6-03.
f Calculated as the product of ED (years) x 365 days/year.
g Averaging time for carcinogens calculated as the product of 70 years x 365 days/year.
h EPA (1992a), "Dermal Exposure Assessment: Principles and Applications, EPA/600/8-91/011B.
i Guidance from EPA (1989), Interim Final, p. 6-36.
See footnotes at end of table.
-------
OhioEPA
State of Ohio Environmental Protection Agency

Southwest District Office
40 South Main Street
Dayton, Ohio 45402-2086
513) 285-6357
George V. Voinovich
FAX (513) 285-6404
Governor

February 11, 1994

Mr. Jack R. Craig
Project Manager
U.S. DOE - FEMP
Post Office Box 398705
Cincinnati, Ohio 45239-8705

Dear Mr. Craig:

The purpose of this letter is to conditionally approve the revised O.U.4 FS/PP based on comment responses and
conference calls that have occurred during the past several weeks. Conditional approval is given until we
see the negotiated changes in the final document.

If you have any guestions, please contact Tom Schneider or me.

Sincerely,

Graham E. Mitchell
Project Manager

GEM:nys

cc: Jenifer Kwasniewski, DERR
Tom Schneider, DERR
Mike Proffitt, DDAGW
Jim Saric, U.S. EPA
Ken Alkema, FERMCO
Lisa August, GeoTrans
Jean Michael, PRC
Robert Owen, ODH
-------