Superfund Record of Decision Feed Materials Production Center USDOE Operable Unit 2 Fernald, OH


                                    EPA/ROD/R05-95/289
                                    1995
EPA Superfund
     Record of Decision:
     FEED MATERIALS PRODUCTION CENTER (USDOE)
     EPA ID: OH6890008976
     OU02
     FERNALD, OH
     06/08/1995

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Text:

                                 FINAL

                           RECORD OF DECISION

                        FOR REMEDIAL ACTIONS AT

                            OPERABLE UNIT 2

                FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
                             FERNALD, OHIO


                             MAY 15, 1995

                        U.S.  DEPARTMENT OF ENERGY



                                 TABLE OF CONTENTS

Table of Contents 	    i

List of Table 	   iv

List of Figures 	    v

List of Acronyms 	   vi

Declaration 	   D-l

Decision Summary

1.0    Site Name,  Location, and Description 	   1-1

2 . 0    Site History and Enf orcment Activities 	   2-1

       2 .1   History of Operation Unit 2 	   2-3

       2 . 2   Operation Unitt 2 CERCLA Actions 	   2-4

3.0    Highlights of Community Participation 	   3-1

4.0    Scope and Role of the Operable Unit 	   4-1

5.0    Summary of Site Characteristics 	   5-1

       5 .1   Summary of Nature and Extent of Contamination 	   5-1

       5.2   Pathways of Contaminant Migration 	   5-6

6. 0   Summary of Site Risks 	   6-1

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     6.1    Overview of the Baseline Risk Assesment 	   6-1

            6.1.1   Identification of Contaminants of Concern 	   6-2

            6.1.2   Exposure Assesment for the Base Risk Assesment 	   6-3

                    6.1.2.1   Current Land Use With Access Controls 	   6-3

                                  TABLE OF CONTENTS
                                    (Continued)

                    6.1.2.2   Current Land Use Without Access Controls 	   6-3

                    6.1.2.3   Future Land Use With Federal Ownership 	   6-4

                    6.1.2.4   Future Land Use With Private Ownership 	   6-4

                    6.1.2.5   Exposure Point Concentrations 	   6-4

                    6.1.2.6   Exposure Assesment Parameters 	   6-10

            6.1.3   Toxivity Assessment 	   6-10

            6.1.4   Risk Characterization 	   6-22

     6.2    Uncertainties 	   6-26

     6.3    Baseline Ecological Risk Assesment 	   6-27

     6.4    Conclusion 	   6-29


7.0     Description of Remedial Alternatives 	   7-1

        7.1   Alternative 1:   No Action 	   7-1

        7.2   Alternative 2:   Consolidation and Capping 	   7-1

        7.3   Alternative 3:   Excavation and Off-Site Disposal 	   7-3

        7.4   Alternative 6:   Excavation and On-Site Disposal with Off-Site
              Disposal of Fraction Exceeding Waste Acceptance Criteria 	   7-4

        7.5   Major ARARs for Operable Unit 2 	   7-6

              7.5.1  No Action Alternative 	   7-10

              7.5.2  Chemical-Specific ARARs/TBCs 	   7-10

              7.5.3  Action-Specifc ARARs/TBCs 	   7-10

              7.5.4  Location-Specific ARARs/TBCs 	   7-10

8.0     Summary of the Comparative Analysis of Alternatives 	   8-1

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        8 .1   Comparative Analysis of Alternatives 	   8-2

              8.1.1  Overall Protection of Human Health and the Environment 	   8-2

              8.1.2  Compliance with ARARs 	   8-4

              8.1.3  Long-Term Effectiveness and Permanence 	   8-5

              8.1.4  Reduction of Toxicity,  Mobility,  or Volume Through Treatment....   8-7

              8.1.5  Short-Term Effectiveness	   8-7

              8.1.6  Implementability 	   8-8


                                  TABLE OF CONTENTS
                                    (Continued)

              8.1.7  Cost 	   8-10

              8.1.8  State Acceptance 	   8-10

              8.1.9  Community Acceptance 	   8-11

9.0     Selected Remedy 	   9-1

        9.1   Key Components 	   9-1

        9.2   Cleanup Levels 	   9-3

10.0    Statutory Determinations 	   10-1

        10.1  Protection of Human Health and the Environment 	   10-1

        10 . 2  Compliance with ARARs 	   10-2

              10.2.1  Chemical-Specifc ARARs/TBCs 	   10-2

              10.2.2  Action-Specffic ARARs/TBCs 	   10-3


              10.2.3  Lotion-Specific ARARs/TBCs 	   10-4

        10.3  Cost Effectiveness 	   10-9

        10.4  Utilization of Permanent Solution and Alternative Treatment Technologies or
              Resources Recovery Technologies to the Maximum Extent Practicable	   10-9

       10.5   Preference of Treatment as a Principal Element	   10-10

       10.6   Irreversible and Irretrievable Commitment of Resources	   10-10

       11. 0   Documentation of Significant Changes	   11-1

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References

Appendix A

                                           LIST OF TABLES

Table                                                                                       Page

5-1     Operable Unit 2 Summary of Contaminant Concentrations	  5-2

6-1     Operable Unit 2 Contaminants of Concern	  6-6

6-2     Principal Exposure Parameters for Selected Operable Unit 2 Baseline
        Risk Assessment Receptors	  6-11

6-3     Dermal Reference Doses and Cancer Slope Factors for Contaminants
        of Contra Chemical Carcinogens	  6-14

6-4     Oral and Inhalation Cancer Slope Factors for Contaminants of Concern
        Radiological and Chemical Carcinogens	  6-16

6-5     Contaminants of Concern Reference Doses for Noncarcinogenic Chemicals	  6-20

6-6     Current Land Use Scenarios Carcinogenic Risk and Hazard Index 	  6-23

6-7     Future Land Use With Federal Ownership Scenario Carcinogenic Risk
        and Hazard Index	  6-24

6-8     Future Land Use With Private Ownership Scenario Carcinogenic Risk and
        Hazard Index	  6-25

8-1     Summary of Comparative Analysis of Remedial Alternative Operable Unit 2	  8-3

8-2     Summary of Long-Term and Short-Term Environmental Impacts	  8-6

9-1     Summary of Operable Unit 2 Primary Soil Cleanup Levels for the Selected
        Alternative	  9-4

9-2     Summary of Operable Unit 2 Secondary Soft Cleanup Levels for the Selected
        Alternative	  9-6

10-1    Compliance with Operable Unit 2 Chemical-Specfic ARARs - Alternative 6	 10-3

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                                          LIST OF FIGURES





Figures                                                                                     Page





1-1     FEMP Facility Location Map	  1-2





2-1     FEMP Site Map	  2-5





6-1     General Conceptual Site Model/Operable Unit 2	  6-5





7-1     Site Plan Potentity Acceptable Region for Operable Unit 2 On-Site Disposal	  7-7





7-2     Typical Detail Composite Cap and Liner	  7-8

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ALARA






ARAR






AT SDR






AWWT






CERCLA






CFR






COG






CPC






CT






DOE






EA






ECAO






EPA






FCTF






FEMP






FFCA






FMPC






FONSI






FS






FS/PP-EA






HE AST






HI






HQ






ILCR






IRIS






LOAEL
  ACRONYMS AND ABBREVIATONS





as low as reasonable achievable





applicable or relevant and appropriate requirement





Agency for Toxic Substances and Disease Registry





Advanced Wastewater Treatment





Comprehensive Environmental Response, Compensation, and Liability Act





Code of Federal Regulations





contaminant of concern





constituent of potential concern





central tendency





United States Department of Energy





Environmental Assessment





Environmental Criteria and Assesment Office





United States Environmental Protection Agency





Fernald Citizen Task Force





Fernald Environmental Management Proj ect





Federal Facility Compliance Agreement





Feed Materials Production Center





Finding of No Significant Impact





Feasibility Study





Feasibility Study/Proposed Plan - Environmental Assessment





Health Effects Assessment Summary Tables





hazard index





hazard quotient





incremental lifetime carter risk





Integrated Risk Information System





lowest observed adverse effect level

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MCL                      maximum contaminant level

MCLG                     maximum contaminant level goal

MUSLE                    Modified Universal Soil Loss Equation

NCP                      National Oil and Hazardous Substances Polution Contingency Plan
                         (commonly known as the National Contingency Plan)

NEPA                     National Environmental Policy Act of 1970

NOAEL                    no observed adverse effect level

O&M                      operations and maintenance

OAC                      Ohio Administrative Code

ODAST                    one-dimensional analytical solute transport

OEPA                     Ohio Environmental Protection Agency

ORC                      Ohio Revised Code

PAH                      polynuclear aromatic hydrocarbon

PEIC                     Public Environmental Information Center

PRG                      preliminary remediation goal

PRL                      preliminary remediation level

RCRA                     Resource Conservation and Recovery Act

RfD                      reference dose

RI                       Remedial Investigation

RI/FS                    Remedial Investigation/Feasibility Study

RME                      reasonable maximum exposure

ROD                      Record of Decision

RSE                      removal site evaluation

SARA                     Superfund Amendment and Reauthorization Act of 1986

S.R.                      state route

SWIFT                    Sandia Waste Isolation Flow and Transport

TBC                      To Be Considered

UCL                      upper confidence limit

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U.S.C                    Unitted State Code

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UNITS OF MEASUREMENT





g                         gram





kg                        kilogram





L                         liter





m3                        cubic meters





• g                        microgram





mg                        milligram





mrem                      millirem





ppm                       parts per million





pCi                       picoCurie

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                                    DECLARATION

SITE NAME AND LOCATION
U.S. Department of Energy  (DOE)
Fernald Environmental Managemere Project  (FEMP) - Operable Unit 2
Fernald, Hamilton Country, Ohio

STATEMENT OF BASIS AND PURPOSE
This decision document present the selected remedial action for Operable Unit 2 at the U.S.
Department of Energy FEMP site in Fernald, Ohio.  This remedial action was chosen 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, the National Oil and Hazardous Substance Polution Contingency Plan (NCP).

The decision presented herein for the remedial action is based on information available in the
Administrative Record for Operable Unit 2 maintained in accordance with CERCLA.  This Record
was made available for public review and comment.  This decision is also based on the issues
raised at the public meeting held on November 8, 1994 and the comments received during the
public comment period following the issuance of the Feasibility Study/Proposed
Plan-Environmental Assessment  (FS/SP-EA) .  In making this decision DOE and the U.S.
Environmental Protection Agency (EPA) have considered all comments received during the public
comment period on the FS/PP-EA.

The State of Ohio concurs with the selected remedy.

ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from Operable Unit 2, if not addressed by
implementing the response action this Record of Decision, may present a current or
potential threat to public health welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY
Operate Unit 2 consists of thee Solid Waste Landfill, the North and South Lime Sludge Ponds, the
South Field, the Inactive and Active Flyash Piles, and berms, liners, and soils within the
Operable Unit 2 boundaries.  Soils outside the Operable Unit 2 bounders and all groundwater will
be remediated under the Operable Unit 5 Record of Decision.

Operable Unit 2 is the third of five operable units to begin remediation at the FEMP.  Remedial
actions for each operable unit will be coordinated to achieve overall risk reduction for the
site.

The selected remedy for Operable Unit 2 includes excavation of all material with contaminants of
concern above the established cleanup levels, material processing for size reduction and
moisture control if reguired, on-site disposal in an engineered disposal facility with a
composite cap and linear system, and off-site disposal of a small fraction of the excavated
material that exceeds the waste acceptance criteria of the on-site disposal facility.  A maximum
waste acceptance criteria of 346 picoCuries per gram (pCi/g) of uranium-238, or 1,030 parts per
million (ppm) total uranium, has been developed for the on-site disposal facility.  It is
estimated that 314,700 cubic yards of Operable Unit 2 material will meet the waste acceptance
criteria and be disposal in the on-site disposal facility. DOE will not dispose of any off-site
waste in this on-site disposal facility.  It is estimated that up to 3,100 cubic yards of
material will not meet the waste acceptance criteria for on-site disposal.  This is
approximately one percent of the total amount of waste material that will be excavated.  This
material will packaged and shipped top an off-site disposal facility.  Soils containing lead
from the Firing Range (approximately 300 cubic yards) will also not be disposed of in the

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on-site disposal facility. This material will be treated before being sent off site for
disposal.

The location of the on-site disposal facility is subject to review and approval by EPA during
the remedial design phase. The geology of the disposal facility location, in combination with
engineering controls, will be protective of human health and the environment, based on
evaluation of a series of soil borings made in the proposed area.

This alternative will include continued federal ownership of the site with access restrictions
(fencing) and groundwater monitoring as institutional controls at the on-site disposal facility
and the subunits.

The principal threats posed by Operable Unit 2 are addressed by this alternative through the
removal of the contamination sources and containment in an engineered disposal facility.

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 (or justifies a CERCLA waiver), and is cost effective. The selected remedy utilizes
permanent solutions and alternative treatment technologies to the maximum extent practicable.
An EPA waiver is reguired from Ohio Solid Waste Disposal Regulations to allow waste disposal
over a high-yield sole-source aguifer. The waiver is granted pursuant to CERCLA § 121(d)(4)(D)
which allows a waiver of an applicable or relevant and appropriate reguirement (ARAR) if "the
remedial action selected will attain a standard of performance that is eguivalent to that
reguired under the otherwise applicable standard, reguirement, criteria, or limitation, through
the use of another method of approach." The justification for this waiver is provided in the
Decision summary of this Record of Decision and is supported by the Administrative Record for
Operable Unit 2.

Because this remedy will result in contaminants remaining on site in an engineered disposal
facility, a review will be conducted no less often than every five years after the initiation of
remedial action to ensure that the remedy continues to provide adeguate protection of human
health and the environment [CERCLA §121(c)].

Regional Administrator Date
U. S. Environmental Protection Agency, Region 5

J. Phil Hamrie Date
Manager, Ohio Field Office
U. S. Department of Energy

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1.0 SITE NAME, LOCATION, AND DESCRIPTION

The Fernald Environmental Management Project (FEMP) is located on a 1,050-acre site in a rural
agricultural are about 18 miles northwest of downtown Cincinnati, Ohio. The site is near the
village of Fernald, New Baltimore, New Haven, Ross, and Shandon Ohio, and located west and
south of Ohio State Routes (S.R.) 128 and 126, respectively (See Figure 1-1). The street
address of the FEMP is: 7400 Willey Road, Fernald, Ohio 45030.

The FEMP is a government-owned, contractor-operated federal facility that produced high-purity
uranium metal products for the U.S. Departmennt of Energy (DOE) and its predecessor agencies
during the period 1951 to 1989. Thorium was also processed, but on a smaller scale, and is
still stored on site. A portion of the thorium has been shipped off site for dispose. During
production, the site was known as the Feed Materials Production Center (FMPC). Uranium
processing operations at the FEMP were limited to a fenced, 136-acre tract known as the
Production Area. The remaining FEMP site consists of waste storage and disposal areas and
forest and pasture lands, a portion of which is leased for livestock grazing.

Most facilities structures rest on a relatively flat plain about 580 feet above mean sea level.
The elevation slopes slightly toward Paddys Run, a small intermittent stream on be west side of
be site.

Natural drainage at the FEMP generally flows from east to west, with the exception of the
extreme northeast corner, which drains east toward the Great Miami River.
The western portion of the FEMP property lies within the north-south corridor of the 100- and
500-year flood of Paddys Run. On-site surface waters are confined to Paddys Run and its unnamed
tributaries and total approximatdy 8.9 acres. Results from a site-wide wetlands delineation
indicate a total of 35.9 acres of freshwater wetlands on the site. The Great Miami Aguifer is
the principal aguifer within the FEMP study area and has been designated as a sole-source
aguifer under the provision of the Safe Drinking Water Act. The Great Miami Aguifer is the
primary source of water for local residences and business. To protect public health, DOE
provides bottled water for those whose private wells have been impacted by contamination of the
Great Miami Aguifer from be

The land adjacent to the FEMP is primarily devoted to open land uses such as agriculture and
recreation. There is some commercial activity adjacent to the site such as a panel truss
company and several nursery suppliers. However, the majority of commercial activity is
generally located in the village of Ross, approximately 2 miles northeast of the facility, and
along S.R. 128 just south of Ross. Industrial usage is concentrated in the areas south of the
FEMP, along Paddys Run Road, in Fernald, and in a small industrial park on S.R. 128 between
Willey Road and New Haven Road.

Open acreage on the FEMP is currently being leased for liverstock grazing, but there are no
areas within the FEMP boundaries considered to be prime farmland under Farmland Protection Act
of 1981.

Concentrations of residential units are situated northeast of the FEMP in Ross and southeast of
the FEMP in a trailer park adjacent to the intersection of Willey Road and S.R. 128. Other
residences are scattered around the area, generally in association with farmsteads. An
estimated 23,000 residents live within a 5-mile radius of the FEMP.

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES

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The Fernald site was constructed in the early 1950s to produce high-grade uranium metal for use
in plutonium production in government reactors at Richland, Washington, and Aiken, South
Carolina.

The FMPC was constructed on an accelerated schedule by the Atomic Energy Commission with the
aid of the U.S. Army Corps of Engineers. The location was selected in 1950 and site preparation
and construction began in May 1951. Operation began later in 1951 upon completion of the Pilot
Plant, the site's first operational facility. Construction of the main facilities continued for
three years and full-scale operation began in May 1954.

During production, large guantities of liguid and solid waste materials were generated. Prior
to 1984, solid and slurried materials from uranium processing were stored or disposed of in the
on-site. Waste Storage Area. This area, located west of the former Production Area, includes
six low-level radioactive waste storage pits; a burn pit; a clearwell; two earthen-bermeds,
concrete silos containing K-65 residues; one concrete silo containing cold metal oxides; and one
unused concrete silo. Wastes from the non-process site operations were disposed of in the lime
sludge ponds and a solid waste landfill (also located in the Waste Storage Area.) Areas to the
southwest of the former Production Area were used to dispose of earthen materials, construction
rubble, boiler plant flyash and bottom ash, and other waste.

In March 1985, U.S. Environmental Protection Agency (EPA) issued a Notice of Noncompliance to
DOE identifying potential environmental impacts associated with the FEMP's past and ongoing
operations. Between April 1985 and July 1986, conferences were held between DOE and EPA
representatives to discuss the major issues and to identify steps to achieve and maintain
environmental compliance. Out of these meerting, a Federal Facility Comppliance Agreement
(FFCA) was jointly signed by DOE and EPA on July 18, 1986. A major component of this agreement
was initiation of the Remedial Investigation/Feasibility Study (RI/FS). Additionally, in 1988,
DOE entered into a Consent Decree with the State of Ohio that provided for the management of
water pollution and hazardous wastes. This agreement was modified in 1993 by the Stipulated
Amendment to the Consent Decree.

Production activities were stopped in 1989, and the production mission of the facility was
formally ended in 1991. The FMPC was included on the National Priorities List in 1989.
Subseguently, the site was renamed the FEMP to reflect the change in mission. Cleanup of the
FEMP is being conducted under 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, under 40 Code of Federal Regulations (CFR) Part 300, the
National Oil and Hazardous Substances Pollution Contingency Plan (known as the National
Contingency Plan, or NCP).

The RI/FS Work Plan (DOE 1988b) identified 39 site areas for investigation. To promote a more
structure and expeditious cleanup of the FEMP, the 39 areas and related environmental issues
were partitioned into five study areas called operable units. The division into operable units
became a condition of the April 1990 Consent Agreement between EPA and DOE. This agreement was
revised in September 1991 to adress additional environmental issues and revise the CERCLA
schedules.

The revised Consent Agreement is referred to as the 1991 Amended Consent Agreement. The 1991
Amended Consent Agreement was modified on April 9, 1993 by an agreement between EPA and
DOE resolving a dispute concerning EPA's denial of DOE's reguest for an extension of time to
submit Operable Unit 2 documents. This modified agreement established new schedules extending
the submittal dates of sthe Operable Unit 2 Remedial Investigation (RI) Report, Feasibility
Study/Proposed Plan-Enironmental Assessment (FS/PP-EA) , and drafts Record of Decision (ROD) and
also accelerated the Operable Unit 1, Operable Unit 3, and Operable Unit 5 draft ROD submission

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dates by 30 days each. Seperate RI/FS documentation and RODs are being issued for each of the
five operable units at the FEMP. A description of the FEMP operable units is listed below:

Operable Unit 1: Waste Pit Area
! Waste Pits 1 through 6 and the liners and berms
! Clearwell
! Burn Pit
! Berms and liners within the operable unit boundary

Operable Unit 2: Other Waste Units
! Solid Waste Landfill
! North and South Lime Sludge Ponds
! Inactive Flyash Pile
! South Field
! Active Flyash Pile
! Berm, liners, and soils within the operable unit boundary

Operable Unit 3: Former Production Area
! Production area production associated facilities and eguipment
! All structures, eguipment, utilities, tanks, and drums
! Scrap Metal Piles
! K-65 Transfer Line
! Effluent lines
! Wastes (solid waste, waste product, and thorium)
! Wastewater Treatment Facilities
! Fire Training Facilities
! Feedstocks
! Coal pile

Operable Unit 4: Silos 1 through 4
! K-65 Silos (Silos 1 and 2)
! Metal oxide silo (Silo 3)
! Empty silo (Silo 4)
! Decant sump system and buried K-65 Transfer Trench
! Berms and soil within the operable unit boundary

Operable Unit 5: Environmental Media
! Soils not included in previous operable unit definitions
! Flora and fauna
! Surface water and sediments
! Groundwater

Following the issuance sof sthe ROD for the last of the five operable units, the Amended Consent
Agreement provides for a Comprehensive Site-Wide Operable Unit (Operable Unit 6). If needed,
Operable Unit 6 will be created to perform a final assessment from a site-wide perspective to
ensure that ongoing or planned remedial actions identified int he RODs for the five operable
units will provide a comprehensive remedy for the FEMP site which is protective of human health
and the environment. It it is determined that the remedial actions specified in the RODs for
Operable Units 1 through 5 are not protective from a site-wide perspective, a Feasibility Study
(FS) would be initiated.

The ROD for the Comprehensive Site-Wide Operable Unit would be issued following the ROD for
the last of the other five operable units.

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2.1 HISTORY OF OPERABLE UNITS 2

As indicated above, Operable Unit 2 consists of five site areas and their associated berms,
liners, and soils.

! The Solid Waste Landfill was reportedly used for the disposal of cafeteria waste
rubbish, and other types of waste from the nonprocess areas and on-site
construction/demolition activities.

! The North and South Lime Sludge Ponds contain waste from the FEMP water treatment
plant operations, coal pile storm water runoff, and boiler plant blowdown. The
South Lime Sludge Pond is inactive and overgrown with grasses and shrubs, while the
North Lime Sludge Pond is currently in use.

! The Inactive Flyash Pile was used for the disposal of ash from the boiler plant and
other nonprocess waste and building rubble such as concrete, gravel, asphalt,
masonry, and steel rebar.

! The South Field was reportedly used as a burial site for FEMP nonprocess waste such
as flyash, on-site construction/demolition rubble, and soils that may have contained
low levels of radioactive. A slope at the southwest border of the South Field was
used as the backstop for the FEMP security firing range for 35 years. Lead
ammunition used during target practice was embedded in this slope.

! The Active Flyash Pile was the disposal area for flyash and bottom ash from the
FEMP boiler plant.

The operational histories of the Lime Sludge Ponds and Active Flyash Pile are well understood,
but the operational histories of the Solid Waste Landfill, Inactive Flyash Pile, and South Field
are vague and not well documented. The location of each submit is shown in Figure 2-1.

2.2 OPERABLE UNIT 2 CERCLA ACTIONS

Operable Unit 2 conducted two phases of a CERCLA remedial investigation. Field investigation
activities conducted from 1988 through 1992 are referred to collectively as the Phase I Field
Investigation. Additional field investigations carried out in 1993 are called the Phase II
Field Investigation. Each phase encompassed all affected media (surface water, sediment,
surface soil, subsurface soil, and groundwater) and collected samples from all five subunits in
Operable Unit 2.

In Addition to the field investigations conducted under CERCLA, a removal site evaluation (RSE)
and several removal actions were conducted in the Operable Unit 2 areas. A RSE was performed to
assess lead contamination in the South Field Firing Range and to determine whether the nature
and extent of lead contamination warranted a removal action. In January and February 1992,
vertical borings were completed in the western embarkment of the South Field. It was determined
from the sampling results that a removal action was not necessary for the lead contamination of
the South Field Firing Range.

The Inative Flyash Pile/South Field Disposal Area Control Removal (Removal Action No. 8)
consisted of the installation of ropes, fences, and warning signs around the perimeter of these
waste areas to control access. Phase I of the activities, which included fencing and roping
the areas to be controlled, was completed in December 1991. Phase II, which included a
radiological survey of the area, was completed in June 1992.

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The Active Flyash Pile Control Removal Action  (Removal Action No. 10) was completed as a time-
critical removal action to mitigate the wind and water erosion of the Active Flyash Pile.  This
was accomplished by regarding the pile, installing a silt trap and wind barrier, and applying a
crusting agent to the surface of the pile.  Implementation of this removal action was completed
in June 1992.

Periodic routine inspections of the Active Flyash Pile and necessary maintenance of the erosion
control measures are ongoing.

The Paddys Run Erosion Control Removal Action  (Removal Action No. 29) was implemented in
Paddys Run to provide bank stabilization adjacent to the Inactive Flyash Pile.  Continued
erosion of the bank could have undermined the western slope of the Inactive Flyash Pile and
resulted in a discharge of contamination into Paddys Run.  The bank was protected by installing
riprap stone to cover the exposed soil face adjacent to Paddys Run.  This time-critical removal
action was completed in September 1993.  Periodic routine inspections of the riprap stone and
necessary maintenance of the erosion control measures are ongoing.

The South Field and Inactive Flyash Pile Seepage Control Removal Action  (Removal Action No. 30)
is anticipated to be implemented in April 1995.  This time-critical removal action will collect
contaminated surface water that is currently seeping into the drainage ditches and migrating
directing to Paddys Run or to the Great Miami Aguifer.  The Action Memorandum  (Craig 1994) was
issued in October 1994 and the Work Plan  (DOE 1995b) was submitted to EPA and the Ohio
Environmental Protection Agency (OEPA) in January 1995.

                          3.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION

DOE's formal community relations program for the Fernald site, which began in 1985, focused on
opening the lines of communication with members of the public residing near the FEMP site.  A

variety of forums were used to provide information to the community, including a periodic
newsletter, regular community meetings, and availability sessions.  Other activites included
site tours, open houses, a speakers bureau, community assessments, and the development of fact
sheets.

Several reading rooms, which were later consolidated into one facility locked near the FEMP
site, were opened to house information about all aspects of the RI/FS process.  In 1990, DOE
established an Administrative Record for the site.  The local Administrative Record is located
at the Public Environmental Information Center  (PEIC) at 10845 Hamilton-Cleves Highway,
Harrison, Ohio 45030; a copy of the Administrative Record is also maintained a the offices of
EPA Region V in Chicago, Illinois.
In November 1993 DOE implemented a pubic involvement program at the FEMP site which aimed at
involving community members and other interested parties in decision making at the FEMP site.
This public involvement program (which operaes today) consists of three elements:  (1) public
information activities, (2) management involvement, and  (3) person-to-person communication.  As
a result of this public involvement Program and the community relations activities reguired
under CERCLA, DOE provided the public with opportunities to comment on decisions relying to the
remediation of Operable Unit 2.

The RI Rport and the FS/PP-EA were made available to the public on February 18, 1994 and
April 29, 1994, respectively.  Notices of availability for inspection of both documents were
published in May 1994 in the Harrison Press, the Hamilton Journal, and The Cincinnati Enguirer.
A workshop was held on May 10, 1994 to present the results of the RI and to answer guestions

-------
from the public.

A general overview of the Operable Unit 2 subunits was provided, the nature and extent of
contamination in the soils and groundwater were illustrated using solid block modeling, and the
results of the Operable Unit 2 Baseline Risk Assessment were presented.  Another public workshop
was held on June 28, 1994 to discuss the FS/PP-EA that had recently been submitted to EPA and
OEPA.  The purpose of this informational meeting was to discuss the alternatives considered for
remediation of Operable Unit 2 and explain how the preferred remedial alternative was
identified.

The workshop also emphasized ways the public could become involved in the decision-making
process for Operable Unit 2.

On September 13, 1994, OEPA sponsored a public workshop on the possibility of establishing a
disposal facility on the FEMP property as a component of remedial actions.  The purpose of this
meeting was to discuss the waiver from an applicable or relevant and appropriate reguirements
(ARAR)  that was reguested from EPA in the Operable Unit 2 FS/PP-EA to allow disposal of FEMP
low-level remediation waste on FEMP property.  This waiver was necessary becuase Ohio Solid
Waste Disposal Regulations prohibit placement of a new solid waste disposal facility over a
high-yield sole-source aguifer (see Section 7.5.4 for more information on the waiver).  On
October 25, 1994, DOE held a public workshop to discuss any comments and concerns of
implementing an on-site disposal facility.

In postcards were mailed reminding stakeholders of the October 25, 1994 workshop
(discussed above), the upcoming public comment period, and the November 8, 1994 formal public
meeting.  A notice of availability announcing the openning of the formal public comment period
(scheduled to end on November 25, 1994) for the FS/PP-EA was published on October 26, 1994.  On
November 3, 1994 OEPA held an availability session for members of the public to discuss the
Operable Unit 2 Proposed Plan.  A formal public meeting was then held on November 8, 1994.  At
this meeting, representative from DOE, EPA, and OEPA answered answered guestions about the
preferred remedial alternative and other alternatives under consideration for Operable Unit 2.
The first part of the meeting consisted of a brief presentation and the opportunity for
guestions and answers.  The second part of the meeting was dedicated to receiving formal
comments from the public on the Operable Unit 2 Proposed Plan.  OEPA sponsored a second meeting
with the elected officials of Ross, Crosby, and Morgan townships to discuss the Operable Unit 2
Proposed Plan and waiver on November 30, 1994.

In response to a November 21, 1994 reguest from the public for more time to review the remedial
alternatives, the comment period was extended to December 30, 1994.  A notice appeared in the
Harrison Press, Hamilton Journal, and The Cincinnati Enguirer announcing this extension in
addition to the mailing of informational postcards.  On December 19, 1994, DOE attended the
monthly Crosby Township Trustee meeting to give a briefing on the Operable Unit 2 preferred
remedial alternative.  A second extension was granted pursuant to stakeholder reguest dated
December 30, 1994 which extended the puplic comment period to January 20, 1995.  A notice
appeared in the Hamilton Journal and The Cincinnati Enguirer on January 6, 1995 notifying
stakeholders of the second extension and informational postcards were again mailed.  DOE met
with the Ross Township Trustees on January 5, 1995 to again discuss the Operable Unit 2
Preferred remedial alternative.

Responses to comments received during the public comment period and at the public meeting are
included in the Responsive Summary, which is part of this ROD.  This ROD presents the selected
remedial action for Operable Unit 2 at the FEMP site in Ferdnald, Ohio chosen in accordance with
CERCLA  (as amended by SARA) and,  to the extent practicable, the NCP.  The information that the
Operable Unit 2 decision is based upon can be found in the Administrative Record.  After

-------
signature of the ROD by EPA, if the remedial action differs significantly from the remedy
selected in the ROD with respect to scope, performance, or cost, DOE would either:

1) Publish an explanation of significant differences (significant in this context is
when a remedial action difference does not fundamentally alter the remedy selected in
the ROD with respect to scope performance, or cost) which would be made available to
the public in the Administrative Record (along with publication in a major local
newspaper of general circulation); or

2) Proposed an amendment to the ROD (significant in this context is when remedial action
difference fundamentally alters the basic features of the selected remedy). To amend
the ROD, DOE would issue a notice of availability and brief description of the
proposed amendment in a major local newspaper of general circulation, make the
proposed amendment to the ROD and information supporting the decision available for
public comment, and provide a reasonable opportunity to comment, not less than 30
calendar days.
In the event of a ROD modification, DOE will notify stakeholders and provide an opportunity to
voice guestions and concerns. A workshop would be offered if the modification is an
"explanation of significant differences." In the case of a ROD amendment, a workshop could
provides if there was significant interest from the public in having both a formal public
meeting and an informational workshop.

4.0 SCOPE AND ROLE OF THE OPERABLE UNIT

As discussed in Section 2.0, the Fernald site has been divided into five operable units to
organized the evaluation and selection of appropriate remedial actions. The existing site
strategy for cleanup is the remediation of each individual operable unit with coordination among
the operable units with respect to treatment, disposition options, and land use. The proposed
remedial action for Operable Unit 2 represent a significant portion of the remedial action for
the site as a whole. The schedule for submittal of Draft RODs to the EPA for each operable unit
is as follows:

! Operable Unit 4: June 10, 1994 (signed by EPA on December 7, 1994)
! Operable Unit 1: November 6, 1994 (signed by EPA on March 1, 1995)
! Operable Unit 2: February 4, 1995
! Operable Unit 5: July 3, 1995
! Operable Unit 3: April 2, 1997

Remedial actions for each operable unit will be coordinated to achieve overall risk reduction
for the FEMP. The final remedial actions for Operable Unit 2 will be coordinated with other
remediation at the FEMP and will constitute the overall remediation of the FEMP when combined
with the other operable unit remedial and removal actions. The removal actions that were taken
by Operable Unit 2 are detailed in Section 2.2.

The primary focus of remedial action for Operable Unit 2 is the permanent disposition of the
contaminated materials, including waste and soil, from each of the five subunits. The purpose
of the remedial action is to prevent unacceptable urrent or future exposure to the contaminated
materials of Operable Unit 2 and to mitigate the threat of continued release of hazardous
substances into the environment.

It is DOE's policy to intergrate the reguirements of the National Environmental Policy Act of
1970 (NEPA) into the procedural documentation reguirements of CERCLA whenever practicable. It

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is not DOE's intent to make a determination concerning the applicability of NEPA to CERCLA
activities. Consistent with DOE's Policy, the Operable Unit 2 FS/PP was written at the level of
an Environmental Assessment (EA) thus it is a FS/PP-EA. However, pursuant tot the Revised
Secretarial Policy on NEPA, issued June 13, 1994, a Finding of No Significant Impact (FONSI)
will not be prepared. It was decided that the term "EA" would remain on the document to avoid
confusion among stakeholders.

5.0 SUMMARY OF SITE CHARACTERISTICS

Several investigation studies were conducted to determine the characteristics of the
contamination sources and the nature and extent of contamination within Operable Unit 2. These
investigations focused on the following areas and media:

! surface and subsurface materials within each of the subunit boundaries and
immediately surrounding the subunits;
surface water sediment within each of the subunit boundaries; and
perched groundwater and Great Miami Aquifer groundwater potentially impacted by
Operable Unit 2.

5.1 SUMMARY OF NATURE AND EXTENT OF CONTAMINATION

The nature and extent of radiological and chemical constituents within Operable Unit 2 are based
on data collected during Phase I and Phase II of the RI field investigation activities. Data
generated prior to RI field activities, namely the Environmental Survey (DOE 1987 and 1988a) and
the Characterization Investigation Study (Weston 1978), were used to define data objectives for
the RI and for supplementary data. Additional information on the nature and extent of
contamination in Operable Unit 2 is provided in Section 4.0 of the Operable Unit 2 RI Report.

Table 5-1 summarizes the detected concentrations of contaminants of concern (COCs) in each of
the subunits. The dashes in the table indicate that the contaminant is not a COG for that
media/subunit.

COCs were determined in the Operable Unit 2 Baseline Risk Assessment. The process of
determining COCs is explained in Section 6.1.1 of this document and Table 6-1 provides a
complete listing of COCs for Operable Unit 2. The 5-1 includes all COCs for both the private
ownership and federal ownership scenarios. Additional information on the development of COCs is
provided in Section 6.0 of this document.

Solid Waste Landfill

Trenching and boring activities in the Solid Waste Landfill have determined that cafeteria,
laboratory, construction/maintenance, and manufacturing wastes were disposed in the landfill.
The depth of waste is generally 10 feet with a maximum depth of 15 feet in the southeastern
corner of the landfill.

Twenty-three COCs have been identified for the Solid Waste Landfill. These COCs consist of 13
radionuclides, 4 metals, and 6 organic compounds. The extent of COCs in the Solid Waste
Landfill

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                                                                                 TABLE 5-1
                                                         OPERABLE  UNIT  2  SUMMARY OF CONTAMINANT CONCENTRATIONSa
  Contaminant of Concern  (COG)
Solid Waste Landfill
    min.      max.
                                                                 Lime  Sludge  Ponds
Inactive Flyash Pile
   min.          max.
Active Flyash Pile
  min.        max.
                                                                                 SURFACE SOIL
 Cesium-137 (pCi/g
 Neptunium-237 (pCi/g)
 Plutonium-238 (pCi/g)
 Radium-226 (pCi/g)
 Radium-228 (pCi/g)
 Strontium-90 (pCi/g)
 Technetium-99 (pCi/g)
 Thorium-228  (pCi/g)
 Thorium-230  (pCi/g)
 Thorium-232  (pCi/g).
 Uranium-234  (pCi/g)
 Uranium-235/236  (pCi/g)
 Uranium-238  (pCi/g)
 Uranium-total (mg/kg)
 Antimonyc  (mg/kg)
 Arsenic (mg/kg)
 Beryllium  (mg/kg)
 Leadd (mg/kg)
 Aroclor-1254 (ug/kg)
 Aroclor-1260 (ug/kg)
 Benzo(a)anthracene  (ug/kg)
 Benzo(a)pyrene  (ug/kg)
 Benzo(b)fluoranthene  (ug/kg)
 Benzo(k)fluoranthene  (ug/kg)
b
0.0457
0.0191
0.915
0.721
0.527
-
0.482
0.939
0.601
1.43
0.0764
2.34
-
3.8
4.4
0.46
-
-
-
55
59
64
-
-
3.11
0.9024
2.26
2.99
1.44
-
2.33
9.61
2.5
48.9
3.33
63.8
-
27.3
8.3
0.97
-
-
-
880
760
710
-
0.064 0.89
- -
_ _
0.205 3.48 0.523
0.709 2.92 0.415
- -
- -
0.082 2.91 0.79
0.373 44.8
0.037 2.75 0.841
- -
_ _
0.856 84
2.45 244
- -
1.9
- -
_ _
- -
_ _
- -
_ _
- -
_ _
0.089
0.056
-
2.7 0.874
2.62 0.917
0.16
0.42
2.71 0.658
0.117
2.33 0.19
2.73
0.149
2.87
1.86
-
33.2 4.6
0.49
13.7
89
38
44
51
46
49
0.836
0.483
-
30.8
3.88
1
142
4.41
13.8
3.99
16.3
0.887
16.6
50.6
-
9.3
1.9
46
89
52
5500
9400
6200
7300
0.0721 0.919
0.057 0.3
-
1.3 4.61
1.01 3.17
-
-
0.805 3.81
-
0.931 3.74
-
-
-
-
-
10.4 14.5
1.5 6.4
-
-
-
-
-
-
-
See footnotes at end of table

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Contaminant of Concern  (COG)
Dibenzo(a,h)anthracene  (ug/kg)
Dieldrin  (ug/kg)

Indeno(1,2,3-cd)pyrene  (ug/kg)
Solid Waste Landfill
    min.      max.
     56
     46
              200
              480
                TABLE 5-1
                (continued)

Lime Sludge Ponds      Inactive Flyash Pile
  min.       max.         min.         max.

   SURFACE SOIL  (continued)

                          2200         2200
South Field
min.    max.
                                                                               43      1900
                                                                               9.7      9.7
                                                                                                                                      Active Flyash Pile
                                                                               45
                                                                                      6000
                                                                           SEDIMENT
Radium-226  (pCi/g)
Uranium-total  (mg/kg)

Aresnic  (mg/kg)
Radium-226  (pCi/L)
Strontium-90  (pCi/L)
Uranium-234  (pCi/L)
Uranium-235/236  (pCi/L)
Uranium-238  (pCi/L)
Uranium-total  (ug/L)
    14.7      22.6
                                                                 GROUNDWATER (Great Miami Aquifer)
                                                                               1.57
                                                                                       2.96
                                                                                                    0.637
                                                                                                    10.9
                                                                                                                 1.32
                                                                                                                 10.9
-
-
0.17
0.05
0.16
0.375
-
-
4.74
0.277
3.69
9.15
-
-
1.1
0.076
0.579
1.63
-
-
1.41
0.16
1.94
4
-
-
2.5
0.15
2.6
5.62
-
-
7.73
0.698
8.0
29.4
-
-
0.83
0.22
0.76
1.67
-
-
662
31.7
707
2070
0.264
BDLe,f
0.682
0.666
0.338
2.0
1.19
BDL
104
4.7
119
462
                                                                     PERCHED GROUNDWATER
Neptunium-90  (pCi/L)
Strontium-90  (pCi/L)
Technetium-99  (pCi/L)
Uranium-234  (pCi/L)
Uranium-235/236  (pCi/L)
Uranium-238  (pCi/L)
Uranium-total  (ug/L)
Carbazole  (ug/L)
-
-
BDLf
1.1
0.208
0.67
2
BDLf
-
-
BDL
12
0.432
15.2
55.8
BDL
0.149
3.45
BDLf
0.5
0.076
0.3
1
-
0.399
3.45
BDL
11.02
0.7
11.81
58
-

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                                                                               TABLE 5-1
                                                                              (continued)
a Air and Great Miami River surface water COCs are not included in this table because no samples were taken; the COCs for these media were determined
 through fate and transport modeling.
b_ = not a COG for that media/subunit
c Antimony is a subsurface soil COG for the Solid Waste Landfill based on the future homebuilder exposure scenario.
d Lead is a COG for the Firing Range only, not the entire South Field area.
e BDL = below detection limit
f Although this contaminant was not detected,  it is a COG for perched groundwater or groundwater because fate and transport modeling predicted that the
  contaminant would migrate from the soil to the perched groundwater or Great Miami Aguiger in the future.

-------
is distributed throughout the surface and subsurface fill material with the maximum
concentrations in the southeastern corner of the landfill. COCs were also detected in the
glacial till beneath the landfill and in the perched groundwater near the southeast corner of
the subunit. While uranium was detected above background in the Great Miami Aguifer, the
concentrations were similar in upgradient and downgradient wells indicating that there is not a
significant impact on the Great Miami Aguifer from the Solid Waste Landfill. The number of COCs
detected in the surface water, sediment, and perched groundwater are fewer than those detected
in the surface and subsurface soils.

Lime Sludge Ponds

Field investigations of the Lime Sludge Ponds indicate that the sludge within the subunit is
homogeneous. While radionuclides are present in the sludge, sampling in the berm soils and
glacial till beneath the ponds has determined that the soils have higher concentrations of most
constituents than the sludge. Elevated concentrations of uranium and thorium were detected in
downgradient perched groundwater wells, but samples collected from the K-65 Slurry Line Trench
(outside of Operable Unit 2 boundaries) detected elevated radiosotope activities. The perched
groundwater contamination may be due to both the Lime Sludge Ponds and the K-65 Slurry Line
Trench.

Thirteen COCs have been identified for the Lime Sludge Ponds. These COCs consist of twelve
radionuclides and one metal. The extent of COCs in the Line Sludge Ponds is limited mostly to
the berm soils surrounding the ponds. The COCs were also detected in the perched groundwater
downgradient of the subunit. No impact from the Lime Sludge Ponds has been observed on the
Great Miami Aguifer.

Inactive Flyash Pile

Field investigations of the Inactive Flyash Pile indicate that waste other than flyash was
disposed of in the subunit. Sludge, clay-tile drain pipe, wood, nails wire, construction
debris, and small amounts or organic waste were found in addition to flyash. The flyash
generally had lower concentrations of contaminants than the other material. A portion of the
identified waste materials appear to be resting on or near the interface between the flyash and
the native glacial overburden. The surface soils on the Inactive Flyash Pile also had elevated
levels of radionuclides.

The occurrence of uranium contamination in the perched groundwater beneath the Inactive Flyash
Pile appears to be related to waste materials buried within or near this subunit. The perched
groundwater appears to discharge through seeps into the Paddys Run drainage channel or directly
into the Great Miami Aguifer through region where the glacal overburden has been eroded. This
is believed to be thee most significant mechanism to transport uranium contamination from
Operable Unit 2 into the Great Miami Aguifer. Uranium contamination in the Great Miami Aguifer
was not detected upgradient or from the northern part of the subunit. Uranium contamination was
detected in two wells downgradient from the central part of the subunit. This suggest that a
source of uranium contamination to the Great Miami Aguifer exists beneath the central part of
the Inactive Flyash Pile.

Eleven COCs have been identified for the Inactive Flyash Pile. These COCs consist of eight
radionuclides, two metals, and one organic compound. The extent of COCs in the Inactive Flyash
Pile covers most of the surface soils, subsurface soils, surface water, sediment, and perched
water sampled within the subunit. Radionuclides appear to be connected to non-flyash waste such
as sludge, wood, and construction debris, whereas organic appear to be intermixed with the
flyash, possibly from dust control spraying. Uranium is the only COG detected in the Great
Miami Aguifer downgradient of the subunit.

-------
South Field

Feild investigations indicate that dumping of different types of material took place in the
South Field, making the are heterogenous. Test trenches uncovered a range of waste materials
including concrete, steel pipe, sheet steel, wood, and clay tile. The results of wipe samples
taken from the materials indicate that they represent a potential source for the leaching of
radionuclides to groundwater.

Twenty-six COCs have been identified for the South Field. Thee COCs consist of 13 radionuclide,
4 metals, and 9 organic compound. The ement of COCs in the South Field covers most of the
surface and subsurface softs, surface water, sedimem, perched groundwater, and groundwater
sampled within the subunit. Radionuclides and organic were detected in higher concentrations in
the northern portion of the South Field. The COCs were also detected in the perched groundwater
beneath the subunit and in the Great Miami Aquifer downgradient of the subunit.

Active Flyash Pile

It has been determined from field observation and historical documentation that the Active
Flyash Pile contains only flyash. Interviews with former processing personnel indicated that
organic compounds could have been sprayed on the flyash to reduce fugitive emissions of
particulates.

Fourteen COCs have been identified for the Active Flyash Pile. These COCs consist of 11
radionuclides and 3 metals. The extent of COCs in the Active Flyash Pile covers most of the
surface softs, subsurface soils, and sediment within the subunit. Uranium is the only COG
detected in the Great Miami Aguifer downgradient of the subunit.

5.2 PATHWAYS OF CONTAMINANT MIGRATION

This section summarizes the results of the evaluation of constituent migration from Operable
Unit 2.

The potential routes of contaminant migration have been determined to be surface water,
groundwater, and air.

! Surface Water

Dispersion of contaminants transported to Paddys Run Creek via surface water
runoff from the Operable Unit 2 area, for both surface water and sediments
Discharges of water from Paddys Run to both the Great Miami River and Great
Miami Aguifer

! Groundwater

Groundwater transport of contaminants from Operble Unit 2 is considered to be
the most significant pathway for the migration of wastes from Operable Unit 2.
The Great Miami Aguifer, which is designated as a sole-source aguifer,
underlies the Operable Unit 2 subunits.
Leachate migration from the subunits.
Vadose zone transport vertically downward to the Great Miami Aguifer
Transport of contaminants through groundwater
Infiltration of contaminated surface water from Paddys Run to the aguifer

! Air

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                 Dispersion of radionuclides  (e.g., uranium, thorium, and technetium)
                 Dispersion of a variety of inorganic costituents
                 Dispersion of organic consituents

 The routes of exposure to human receptors will be outlined in Section 6.0, Summary of Site
Risks.

                                   6.0   SUMMARY OF SITE RISKS

The potential risk from Operable Unit 2 subunits, current and future, has been calculated in the
Operable Unit 2 RI (DOE 1995a) as the Baseline Risk Assessment.  The assessment was based on the
nature and extent of the contaminants found in the Operable Unit 2 during field investigations.
Computer modeling was performed to predict the fate and transport of constituents of potential
concern over a 1,000-year period.  The Operable Unit 2 Baseline Risk Assessment is summarized in
this section.  For more in-depth information on the methodology and results of the fate and
transport computer modeling and the methodology and details of the Baseline Risk Assessment,
refer to Appendies A and B of the RI Report for Operable Unit 2.

6.1  OVERVIEW OF THE BASELINE RISK ASSESSMENT

A baseline risk assessment was conducted using EPA Risk assessment methodology to provide an
evaluation of the potential threat (both current and future) to human health and the environment
caused by constituent releases from Operable Unit 2 in the absence of any remedial action (the
"no action" alternative).   The assessment provides the basis for determining whether remedial
action is necessary.   To support his determination for Operable Unit 2, the risk for each
subunit was quantified separately.  The primary objectives of the Baseline Risk Assessment are
to:   (1) determine those constituents that posed a significant risk to receptors; (2) perform an
exposure assessment to determine the pathways and media of concern;  (3) determine toxicity
levels of constituents in relevant media within the boundaries of Operable Unit 2 (e.g., air,
soil, water);  (4) determine the magnitude of expected impact or threat and its liklihood.

The chemical and radiological constituents present within the Operable Unit 2 subunits present
potential risks to human and environmental receptors.  Two types of human health effects can
result from exposures to radionuclides and chemicals:  (1) carcinogenic (e.g., lung cancer
caused by inhalation of radon) and (2) noncarcinogenic (e.g., nephritis of the kidney caused by
ingestion of uranium).  To limit the likelihood of someone developing cancer from exposure to
contamination at a CERCLA site, the EPA has established an acceptable range of incremental
lifetime cancer risk (ILCR).   This range is from 1x10-4 to 1x10-6.  Cancer risk is defined as
the incremental probability of an individual developing cancer over a lifetime as a result of
exposure to a potential carcinogen.  The ILCR of 1x10-6 is referred to as the "point of
departure" and provides a referrence for the risk estimates presented in the Operable Unit 2
Baseline Risk Assessment.

To put the ILCR acceptable range in the context of the background cancer rate, it is estimated
that about one in three American will develop cancer during their lifetime from all causes,  and
that the risk from exposure to naturally-occurring radiation in the environment is about 1x10-2,
primarily from randon.  Thus, the EPA acceptable range for CERCLA cleanup sites is a very small
percentage of the normal cancer risk expected in the general United States population from
everyday exposures and other causes.   For example, the ILCR targeted by the upper end of EPA's
range (i.e., 1x10-4)  means that if all persons in a population of 10,000 were assumed to be
repeatedly exposed to a site's contaminants, one person might develop cancer as a result of thos
exposures, in addition to the departure (1x10-6), one person in a population of 1,000,000 might
develop cancer in addition to the approximately 330,000 cancer cases expected from all other
causes.

-------
EPA has developed a measure for noncancerous hazards from chemicals that is called a "hazard
quotient" (HQ). The HQ is determined by comparing the amount of a specific chemical to which
someone might be exposed at a site with the dose that the scientific community consider safe or
acceptable for that chemical. An HQ of greater than 1.0 indicates that the exposure level
exceeds the protective level for the chemical. Exposures to more than one chemical can result
in multiple HQs.

The sum of these HQs eguals the hazard index (HI). If the HI exceeds 1.0, an adverse health
effect might result from the estimated exposure. Because he hazards are additive, 0.2 is the
hazard point of reference for the results presented in the Operable Unit 2 Baseline Risk
Assessment.

For someone to be at risk from a chemical hazard, the individual must be exposed to the waste at
the site. The help determine if there is a need to undertake cleanup at a CERCLA site, the EPA
evaluates the risk an individual site poses, assuming that no additional engineering controls
were installed to prevent the migration of contaminants from the subunits. By this approach,
the primary hazards can be identified, and it an be determined whether someone who might enter
the site or who uses the site in the future could be at risk. This is referred to as a baseline
risk assessment.

6.1.1 Identification of Contaminants of Concern

The Operable Unit 2 RI Report identified the constituents of potential concern (CPCs) present
within each subunit's media. CPCs include those constituents which are present at levels above
background concentrations and at levels that exceed EPA-approved screening criteria. The
screening criteria used is 1x10-7 (ten times lower than the ILCR point of departure of 1x10-6)
and a HI of 0.1 (one tenth of the HI level that indicates hazard from a chemical). Modeling is
used to predict constituent movement from source areas to receptor locations through various
media (e.g., groundwater or air).

The Operable Unit 2 Baseline Risk Assessment evaluated constituents and exposure pathways to
determine their potential current and future impacts on human health. Constituents which
resulted in risks to a receptor of greater than 1x10-6 or which yielded a HI greater than 0.2
were designated as COCs. COCs for Operable Unit 2 are presented by subunit and media in Table
6-1 for both the private ownership and federal ownership scanerios. The COCs under the federal
ownership scenario are marked with an asterisk. Section 6.0 and Appendix B of the Operable Unit
2 RI Report present a more detailed discussion of the COCs for each subunit.

6.1.2 Exposure Assessment for the Baseline Risk Assessment

The exposure assessment was developed to depict what may happen in and around the FEMP site if
no further remedial actions are taken. Exposure scanerios were used to determined the need for
additional cleanup activities at the site.

The baseline exposure scenarios are used to identify the sources of contamination and the
potential routes to humans by presenting the exposure pathways for each land use scenario. The
exposure scenarios evaluated include: (1) current land use with access controls: (2) current
land use without access controls; (3) future land use with federal ownership; and (4) future
land use with private ownership. These exposure scenarios were carried through the
decision-making process for this operable unit to develop the maximum and minimum cleanup goals,
with the understanding that the final goals would fall within this range. Figure 6-1 provides a
visual description of the receptors, media, and pathways considered in the baseline risk
assessment.

-------
6.1.2.1   Current Land Use With Access Controls

The scenario was evaluated for current conditions assuming that DOE maintains the FEMP site as
it exists with access controls.  The following receptors were evaluated for this scenario:   (1)
trespassing youth;  (2) on-property groundskeeper;  (3) off-property resident farmers  (adult and
child); and (4) Great Miami River users.

6.1.2.2   Current Land Use Without Access Controls

A second current land-use scenario assumes that access to the FEMP site is no longer controlled
and cattle are assumed to graze on the site.  In addition to the receptors for current land use
without access controls, an additional receptor for this scenario was the user of meat and milk
products from livestock grazing on the site.

6.1.2.3   Future Land Use With Federal Ownership

The scenario was evaluated for future land use assuming that the federal government maintains
ownership of the FEMP site and that access controls remain in effect.  The receptors evaluated
under this scenario included:  (1) expanded trespasser (one who makes repeated unauthorized
entry to and wanders freely over the site);  (2) off-property resident farmers  (adult and child);
and (3) Great Miami River users.

6.1.2.4   Future Land Use With Private Ownership

This second future land-use scenario assumes that the FEMP site is no longer owned by the
federal government, that all access controls are discontinued, and that the site changes to
agricultural use. For this scenario, the following receptors were evaluated:   (1) reasonable
maximum exposure  (RME) on-property resident farmer  (adult and child);  (2) central tendency  (CT)
on-property resident farmer  (adult); (3) homebuilder; and  (4) perched groundwater user.  The RME
on-property resident farmer receptor includes more conservative exposure conditions than the CT
on-property resident farmer, which represents typical conditions.

6.1.2.5   Exposure Point Concentrations

The exposure point concentration is the concentration of a constituent in an environmental
medium that may be contracted by a real or hypothetical receptor.  It is used in combination
with other exposure parameters in intake eguations to guantify that actual intake [in
milligrams/kilograms-day (mg/kg-day) for chemical and pCi for radionuclides] that a receptor may
receive via specific pathway (e.g., soil, groundwater, etc.) and route of exposure  (e.g.,
ingestion, inhalation, and dermal contact).

Exposure point concentrations for Operable Unit 2 were determined in different ways, depending
on whether exposures were assumed to be current or future and depending on the environmental
medium of interest.  To be consistent with the concept of the RME scenario reguired by EPA, an
estimate of the highest exposure that can reasonably by expected to occur reguires a reasonable
maximum estimate of the concentration of each contaminant in each exposure medium.  Except for
soil,  exposure source term concentrations for all media were modeled.  Because of the
uncertainty

-------
                                                        TABLE 6-1
                                       OPERABLE UNIT 2 CONTAMINANTS OF CONCERN
 Solid Waste Landfill
  Lime Sludge Ponds
   Inactive Flyash Pile

  Surface Soil
     South Field
 Active Flyash Pile
Neptunium-237
Radium-226*
Radium-228*
Strontium-90
Thorium-228*
Thorium-230
Thorium-232*
Plutonium-238
Uranium-234
Uranium-235/236
Uranium-238*
Antimony
Arsenic
Beryllium
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Cesium-137
Radium-226*
Radium-228*
Thorium-228*
Thorium-230
Thorium-232*
Uranium-238*
Uranium-total*
Radium-226*
Radium-228*
Thorium-228*
Thorium-232*
Arsenic*
Dibenzo(a,h)anthracene
Cesium-137
Neptunium-237
Radium-226*
Radium-228*
Strontium-90
Technetium-99
Thorium-228*
Thorium-230*
Thorium-232*
Uranium-234
Uranium-235/236
Uranium-238
Uranium-total
Arsenic
Berylium
Lead**
Aroclor-1254
Aroclor-1260*
Benzo(a)anthracene
Benzo(a)pyrene*
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene*
Dieldrin
Indeno(1,2,3-cd)pyrene*
Cesium-137
Neptinium-237*
Radium-226*
Radium-228*
Thorium-228*
Thorium-232*
Arsenic*
Beryllium

-------
            No COCs
        Uranium-total*
See footnotes at end of table.
      Solid Waste Landfill
                                   No COCs
                                   No COCs
                                TABLE 6-1
                               (Continued)

                                Surface Water

                                 No COCs

                               Sediment


                                 No COCs
                                                                                          No COCs
                                Radium-226*
       Lime Sludge Ponds         Inactive Flyash Pile

                     Groundwater (Great Miami Aquifer)
 Uranium-234
 Uranium-235/236
 Uranium-238
 Uranium-total
Uranium-234
Uranium-235/236
Uranium-238
Uranium-total
Uranium-234*
Uranium-235/236-*
Uranium-238*
Uranium-total*
                                                        Perched Groundwater
                                     South Field
Uranium-234*
Uranium-235/236*
Uranium-238*
Uranium-total*
                                                                                                                             No COCs
                             Radium-226*

                              Arsenic*
                           FEMP-OU02-6 FINAL
                             Active Flyash Pile
  Radium-226
  Strontuim-90
  Uranium-234*
  Uranium-235/236*
Uranium-238*
  Uranium-total*
 Technetium-99
 Carbazole
 Uranium-234
 Uranium-235/236
 Uranium-238
 Uranium-total
Neptunium-237
Strontium-90
Technetium-99
Uranium-234
Uranium-235/236
Uranium-238
  No COCs
                                No COCs
                                                                No COCs
                             Uranium-total

-------
                                                             TABLE 6-1
                                                             (Continued)

                                                 Impact on Air  (Gaseous Emissions)

 Radon-222                     No COCs                  Radon-222                    Radon-222*                   Radon-222

                                                Great Miami River Surface Water

                                                                                    Radium-226*
    No COCs                    No COCs                    No COCs                                                  No COCs
                                                                                    Technetium-99*

This table includes COCs to be considered under both the private ownership and the fedral ownership scenarios.

* COCs marked with an asterisk are for the federal ownership scenario.

• Lead is a COG for the Firing Range only, not the entire South Field area.

Source:  Table 2-1, Operabler Unit 2 FS Report.

-------
associated with any estimate sof exposure point concentrations for soil, the 95 percent upper
confidence limit (UCL) on the calculated mean for either a normal or lognormal distribution is
the recommended statistic (concentration value) to be constructed from measured contaminant
concentration data and used in risk assessments (EPA 1992a).   Derivation of the 95 percent UCL
for each environmental medium is described in detail in Appendix B, Section B.2.0, of the
Operable Unit 2 RI Report.

Exposure Point Concentration for Soil

Exposure point concentrations for direct contact surface soil exposure pathways, under both
current and future land use assumptions, and the 95 percent UCLs determined from surface soil
data using the process described in the FEMP guidelines for determining CPCs and Appendix B,
Section B.2.0, of the Operable Unit 2 RI Report.

Exposure Point Concentration for Groundwater

Current exposures to groundwater at the FEMP will be addressd as part of the Operable Unit 5 RI.
Exposure to potential future concentrations of constituents in groundwater from contaminated
material in each operable unit are addressed during each operable unit baseline risk assessment.
Future exposure point concentrations for groundwater were determined from the results of
groundwater transport modeling, as described in detail in Section 5.0 and Appendix A of the
Operable Unit 2 RI Report.

Because the South Field and Inactive Flyash Pile form one contiguous area, source terms from
these two subunits were combined for assessment of exposures to constituents migrating in
groundwater from the South Field and Inactive Flyash Pile.  For an assessment of exposures to
contaminants migrating from the Active Flyash Pile, Solid Waste Landfill, and Lime Sludge Ponds,
independent source terms were derived.

Soils CPCs for each subunit (Inactive Flyash Pile and South Field combined)  were subjected to
leachate estimations as described in Section 5.4.2.1 of the Operable Unit 2 RI Report.  CPCs
determined to be present in leachate above screening criteria (derived from EPA Region III ILCR
of 1.0 x 10-7 and a HI of 0.1)  were then modeled in the vadose zone [using one-demensional
analytical solute transport (ODAST)]  using the methodology outlined in Section 5.4.2.2 of the
Operable Unit 2 RI Report.  Leachate concentrations are modeled through the vadoze zone to the
regional aguifer to yield the calculated future concentrations in the aguifer directly
underlying the waste area.

Concentrations of CPCs determined to be present at this interface at levels above an ILCR of
1x10-7 and a HI of 0.1 were then selected as groundwater CPCs; their concentrations were
estimated at sepcific locations (on-subunit, on-property, and off-property).

Off-property concenstrations of constituents in groundwater were calculated using the regional
aguifer model, Sandia Waste Isolation Flow and Transport  (SWIFT) III (Geotrans 1987).  The
maximum calculated concentrations in the aguifer underlying the Active Flyash Pile, South Field
and Inactive Flyash Pile Area  (combined),  Solid Waste Landfill,  and Lime Sludge Ponds were used
to estimate on-subunit exposures.   The maximum claculation concentrations on-property and at the
fenceline were used for exposure point concentrations for on-property and off-property future
groundwater exposures.  Details of the model and parameters used tos calculate future CPC
concentrations in the Great Miami Aguifer are presented in Section 5.0 of the Operable Unit 2 RI
Report.  The locations of calculated maximum off-property concentrations of contaminants
transported from the waste areas of Operable Unit 2 by groundwater are also shown in Section 5.0
of the Operable Unit 2 RI Report.

-------
Exposure Point Concentrations for Surface Water and Sediment

Like groundwater, exposures to current concentrations in surface water and sediment, if present,
outside the boundaries of Operable Unit 2 waste areas, are to be addressed in the Operable Unit
5 Baseline Risk Assessment. CPC exposure point concentrations for current exposures to surface
water and sediment within each subunit were estimated using fate and transport modeling. For
future exposures to surface water on the subunit. The Modified Universal Soil Loss Eguation
(MUSLE), a commonly used soil loading model (EPA 1988), was used to determine if soil runoff
would contribute significantly to constituent concentrations on the subunit and conseguently in
the Great Miami River. The input for this model is the 95 percent UCL surface soil
concentrations. The model and modeling results are presented in Section 5.0 and Appendix A of
the Operable Unit 2 RI Report.

Exposure Point Concentrations for Air

Operable Unit 2 airborne concentrations of constituents from the individual waste aras were
modeled for both current and future conditions at on-subunit, on-property, and off-property
locations. The model assumed mass loading (fugitive dust emissions) of surface soil to the air
from each waste area and subseguent transport and dispersion of contaminants. The model and
parameters for air dispersion are described in Section 5.0 of the Operable Unit 2 RI Report.
The initial source term for air modeling is the 95 percent UCL soil concentration. The results
of air modeling provide the highest annual average air concentrations and deposition rates at
each of the specified locations (on-subunit, on-property, off-property). This allows for
calculation of exposures to constituents being released to air and exposures resulting from
ingestion of vegetation on which air particulates are deposited.

6.1.2.6 Exposure Assessment Parameters

The eguations and parameter values used in estimating intake are provided in Section B.2.2 of
Appendix B of the Operable Uni 2 RI Report. Attachment III of Appendix B of the RI Report
presents the calculated intakes by subunit for each current and assumed future receptor, media,
and pathway. The trespassing youth has the lowest exposure freguency and duration of all of the
current and assumed future land use receptors. The trespassing youth is assumed to be exposed
52 days a year for 12 years. In contrast, the on-site RME farmer has the maximum exposure
duration and freguency. The on-site RME farmer is assumed to be exposed to on-site contaminants
24 hours a day, 350 days a year for 70 years. All other receptors have exposure durations and
freguencies somewhere between the trespassing youth and the on-site RME farmer to evaluate a
range of possible exposures. Table 6-2 lists the principal exposure parameters for a range of
receptors.

6.1.3 Toxicity Assessment

Chemical Carcinogens

The toxicity information considered in the assessment of potential carcinogenic risks includes
(1) a weight-of-evidence classification and (2) a slope factor. The weight-of-evidence
classification gualitatively describes the likelihood that a chemical is a human carcinogen and
is based on an evaluation of available data from human an animal studies. A chemical may be
placed by EPA in one of three groups in EPA' s classification system to indicate its potential
for carcinogenic effects Group A, a human carcinogen, Group Bl, or B2, a probable human
carcinogens because of a lack of data are placed by EPA in Group D, and those for which there is
evidence of noncarcinogenicity in humans are placed by EPA in Group E.

-------
                                               TABLE 6-2

                        PRINCIPAL EXPOSURE PARAMETERS FOR SELECTED OPERABLE UNIT  2
                                    BASELINE RISK ASSESSMENT RECEPTORS
 Parameter
                                       Expanded
                                       Trespasser
                                       (Youth)
On-Property
RME Farmer
Off-Property
  Farmer
                                              All Pathways
 Exposure Frequency (days/year)
 Exposure Duration (years)
 Body Weight (kg)
 Inhalation Rates (m3\hour)
 Exposure Time (hours\day)
 Ingestion Rate (Liter/day)
 Fraction Ingested
 Ingestion Rate (mg/day)
 Fraction Ingested
Ingestion Rate (mg/day)
Fraction Ingested
110
12
43
Inhalation of Particulates
0.83
2
Ingestion of Drinking Water
NAa
NA
Ingestion of Soil
100
0.125
Ingestion of Sediment
100
0.063
350
70
70

0.83
5.7

2
1

180
1

NA
NA
350
70
70

0.83
5.7

2
1

NA
NA

NA
NA

-------
   Parameter
  Exposure Time Indoors (hours/day)
  Exposure Time Outdoors (hours/day)
  Shielding Ratio Indoors
  Shielding Ratio Outdoors
  Ingestion Rate (kg/day)
  Fraction Ingested

See footnote at end of table
       TABLE 6-2
      (Continued)
 Expanded                            On-Property
 Trespasser                          RME Farmer
 (Youth)

 External Radiation Exposure

   NA                                   18.3
    2                                    5.7
   NA                                    0.5
    0                                     0

 Ingestion of Homegrown Fruits

   NA                                   0.142
   NA                                     0.3
                                       Ingestion of Homegrown Vegetables
                                                                                               Off-Property
                                                                                                 Farmer
                     NA
                     NA
                     NA
                     NA
                    0.142
                     0.3
 Ingestion Rate (kg/day)
 Fraction Ingested
 Ingestion Rate (kg/day)
 Fraction Ingested
 Ingestion Rate (Liter/day)
 Fraction Ingested
   NA
   NA

Ingestion of Home-Produced Meats

   NA
   NA

  Ingestion of Milk

   NA
   NA

  Ingestion of Surface Water
 Ingestion Rate (mg/L or pCi\L)            0.035
 Exposure Time (hours)                       1
 aNA = not applicable
 Source:  Tables B.2-4A and B.2-4B, Operable Unit 2 RI Report.
0.201
 0.40
0.101
 0.50
 0.40
 0.75
                                         NA
                                         NA
0.201
0.40
0.101
0.75
0.40
0.75
                    NA
                    NA

-------
The cancer slope factor is the toxicity value used to qualitatively express the carcinogenic risk
of cancer-causing constituents. It is defined as the upper-bound estimate of the probability of
cancer incidence per unit dose average over a lifetime. Slope factors are derived from studies
of carcinogenicity on humans and/or laboratory animals and are typically calculated for
compounds in Groups A, Bl, and B2. Slope factors are specific to a chemical and route of
exposure and expressed in units of (mg/kg-day)-1 for both oral and inhalation routes. The
induction of cancer by dermal absorption is evaluated using oral slope factors. Inhalation
cancer toxicity values are usually expressed as inhalation unit risks in units of reciprocal
micrograms/cubic meter (ug/m3), I/* g/m3 .

The primary sources of these toxicity values are EPA's Intergrated Risk Information System
(IRIS) (EPA 1993a) and the guartely updated Health Effects Assessment Summary Tables (HEAST) EPA
1993b). Other EPA sources of cancer slope factors were also consulted when available. The
dermal cancer slope factors for COG chemical carcinogens are listed in Table 6-3. The oral
inhalation cancer slope factors for COG chemical carcinogens are listed in Table 6-4.

Radiocarcinogens

Carcinogenicity is the limiting deleterious effect at the levels of radiation dose encountered
within Operable Unit 2 and has been used as the sole basis for assessing the radiation-related
human health risks of a site contaminated with radionuclides (EPA 1989a).

The risk relationship between radiation dose and health effects is relatively well characterized
for high doses (i.e., >10 rad). Hence, risk estimates are strictly applicable only to large
populations exposed to high levels of radiation. Lower levels of exposure may constitute a
health risk, but a direct cause and effect relationship is difficult to establish because a
particular effect in a specific individual can be produced by many different processess. For
low doses, health effects are presumed to occur but can only be estimated statistically.
Therefore, the risk of cancer incidence from exposure to low levels of ionizing radiation must
be extrapolated from incidence data at higher doses.

Under CERCLA methodology, the EPA assumes a unit intake of, or external exposure to, a
radionuclide over a lifetime. The annual dose equivalent from the radionuclide to each
organ in each year of life is calculated. The average excess number of all types of
radiation-induced fatal cancers that occur in a year is then estimated for the corresponding
dose equivalents received during that year and relevant preceding years. The excess number of
radiation-induced fatal cancers is derived from epidemiological data extrapolation from high
radiation doses to low doses, and

-------
                                                            TABLE  6-3

                                      DERMAL REFERENCE DOSES AND CANCER  SLOPE  FACTORS  FOR
                                                   CONTAMINANTS OF CONCERN
                                                   CHEMICAL CARCINOGENS
          Chemical
             Gastrointestinal  Absorption
                      Fraction
                                     Dermal Reference Dose
                                         (mg/kg-day)
                          Dermal Slope Factor
                                (mg/kg-day) -1
                                                           INORGANICS
Arsenic
Beryllium
Cadmium

Lead
Manganese

Molybdenum
Nickel
Selenium
Thallium
Uranium-Totaid
(food)
(water)

(food)
(water)
0.95g
O.Olg
O.OSa

 Nai
O.OSa

0.38a
O.Olc
0.8a
 la
O.OSc
2,
5,
5,
2,

4,
1.
1.
2,
4,
7,
.85
.00
.00
.50

.20
.50
.90
.00
.00
.00
X
X
X
X
ND
X
X
X
X
X
X
10-4
15-5
10-5
10-5

10-3
10-4
10-3
10-3
10-3
10-3
                                                                                                         x 100
                                                                                     1.50  x 10-4
                                 NDb
                                 ND
                                 ND
                                 ND
                                 ND
                                 ND
                                 ND
                                 ND
                                 ND
                                 ND
                                 ND
                                                         VOLATILES
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Carbazole
Dibenzo(a,h)anthracene
Dibenzofuran
Indeno(1,2,3-cd)pyrene
2-Methylnaphalene
                        0.43a
                        0.43a
                        0.43a
                        0.43a
                        0.43a
                          9
                        0.43a
                         NAi
                        0.43a
                        l.Of
 0
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
 ND
 ND
 ND
 ND
 ND
0.02
 ND
 ND
 ND
 ND
See footnotes at end of table

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

Gastrointestinal Absorption Dermal Reference Dose Dermal Slope Factor
Chemical Fraction (mg/kg-day) (mg/kg-day)-1

SEMIVOLATILES (Continued)

Phenanthrene 0.9e ND ND
Tributyl phosphate 0.9e 4.50 x 10-3 ND

PESTICIDE/PCBS

Dioxins/furans 0.5h ND 3.00 x 10-5
aSee the Toxicity Profile for this chemical in Attachment B.II of the Operable Unit 2 RI Report.
bND = No data availabe.
cEPA 1989a, "Risk Assessment Guidance for Superfund, Volume, Human Health Evaluation Manual (Part A)",
EPA/540/1-89/002, pp. A-2 to A-3.
dThe carcinogenicity of uranium is due to its radioactive rather than chemical toxicity; its cancer potency due to
penetrating external radiation is presented in Table B.2-11 of the Operable Unit 2 RI Report.
eSee Section B.2.5.2 of the Operable Unit 2 RI Report.
fJones, T.D. and B.A. Owen, 1989, "Health Risk from Mixtures of Radionuclides and Chemicals in Drinking
Water, Oak Ridge National Laboratory, Oak Ridge, Tennessee, ORML-6533.
gDollarhide 1993, Memorandum from Environmental Criteria and Assessment Office (ECAO) to EPA Region V,
7/21/93, Including Attachments 1-6.
hATSDR (Agency for Toxic Substances and Disease Registry) 1990, "Toxicological Profile for 2,3,7,8-
Tetrachlorodibenzo-p-dioxin," Draft for Puplic Comment, U.S. Public Health Service, Atlanta, Georgia.
iNA - Not appllicable.
Source: Table B.2-12, Operable Unit RI Report.

-------
                                                            TABLE 6-4

                                  ORAL AND INHALATION CANCER SLOPE FACTORS FOR CONTAMINANTS OF CONCERN
                                               RADIOLOGICAL AND CHEMICAL CARCINOGENS
   Parameter
   Cesium-137+ld
   Neptunium-237+ld
   Lead-210+2d
   Plutonium-238

   Plutonium-239/240
   Radium

   Radium-226+8d
   Radium-228+ld
   Ruthenium-106
   Strontium-90+ld
   Technetium-99
   Thorium-228+7d
   Thorium-230
   Thorium-232+10d
   Thoriuum-total
   Uranium-234
   Uranium-235
   Uranim-235/236
   Uranium-238+2d
   Uranium-totale
   Antimony
   Arsenic
Barium
Oral
Cancer Slope
Factor
(mg/kg-day) -1
2,
2,
6,
2,
2,
3,
7,
1.
9,
3,
1.
5,
1.
1.
.8
.2
.6
.2
.3
.8
.8
.0
.5
.6
.3
.5
.3
.7
x
x
X
X
X
X
X
X
X
X
X
X
X
X
10-11
10-10
10-10
10-10
10-10
10-11
10-10
10-10
10-12
10-11
10-12
10-11
10-11
10-10
ND
1.
1.
1.
2,



.6
.6
.6
.8



X
X
X
X


1
10-11
10-11
10-11
10-11
ND
ND
.7 x 10+oh
Inhalation Cancer
 Slope Factora
  (mg/kg-day) -1
                                                         RADIOLOGICAL
                                                         INORGANICS
   1.9 x 10-11
   2.9 x 10-8
   4.0 x 10-9
   3.9 x 10-8

   3.8 x 10-8
   1.2 x 10-9
   7.0 x 10
   6.9 x 10
   4.4 x 10
         9
         10
         10
6.2 x 10-11
         12
   7.
       x 10-
       x 10-
   2.9 x 10-E
   1.1
   2.6
       x 10
       ND
       x 10-
           -7
                                           ND
   2.5 x 10-E
   2.5 x 10-E
   5.2 x 10-E
        ND
        ND
     1.5 x 10+1
     ND
                                                                                                         Oral
                                                                                                                 Tumor Site

                                                                                                                         Inhalation
NDn
ND
ND
Neoplasms /Lung
tumors
ND
Bone/Cancer/
Paranasal Sinus
ND
ND
ND
ND
ND
ND
ND
ND
ND
Bone Sarcoma
ND
ND
ND
ND
ND
Lung
ND
ND
ND
ND

ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Respir,
                                                                       Cancer
                                                                   Classification
                                                                                                       ND
                                                                        ND
                                                             :y System    A
                                                      ND                 ND
                                                                                                                                                             Source
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
 b
b,c
b,g
   See footnotes at end of table.

-------
                                                         TABLE 6-4
                                                         (Continued)
Parameter
 Beryllium
 Cadmium
 Lead (Inorganic)
 Nickel
 Selenium
 Thallium
 1,1,2-Trichlorotrifluoromethane
 1,2-Diethylbenzene
 1,4-Dioxane
 2-Methylnapthalene
 4-Methylphenol(o-cresol)
 Benzo(a)anthracene
 Benzo(a)pyrene
 Benzo(b)fluoranthene
 Benzo(g,h,i)perylene
 Benzo(k)fluoranthene
 Bis(2-Ethyexyl)phthalate
 Carbazole
 Dibenzo(a,h)anthracene
 Indeno(1,2,3-cy)pyrene
 Phenanthrene
 Tributyl phosphate
See footnotes at end of table.
Oral Cancer Slope
     Factor
 (mg/kg-day)-1
   4.3 x 10+0
       ND
       ND
       ND
       ND
       NDi
       ND
       ND
   1.1 x 10-2
    7
    7
                         Inhalation Cancer
                          Slope Factora
                           (mg/kg-day)-1
                                                  INORGANICS  (Continued)
                               8
   ND
   ND
7.3 x 10-1
  3 x 10+0
7.3 x 10-1
   ND
7.3 x 10-2
1.4 x 10-2
2.0 x 10-2
7.3 x 10+0
  3 x 10-1
   ND
   ND
                                                      VOLATILES
                             4 x 10+0
                           6.3 x 10+0
                               ND
                           8.4 X 10-1
                               ND
                               ND
                               ND
                               ND
                               ND
                                                    SEMIVOLATILES
    ND
    ND
6.1 x 10-1
6.1 x 10-0
6.1 x 10-1
    ND
6.1 x 10-2
    ND
    ND
6.1 x 10+1
    x 10-1
    ND
    ND
                               6.1
                                                                                                      Oral
                                                                                                              Tumor  Site

                                                                                                                       Inhalation
                                                                        Cancer
                                                                    Classification
                                  Total Tumors
                                       ND
                                       ND
                                       ND
                                  Liver, Lung
                                       ND
                                       ND
                                       ND
                                      Nasal
                                    cavity/Liver
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
Lung
:espiratory System
ND
:espiratory System
ND
ND
ND
ND
ND
ND
ND
Pulmonary adenomas
Total tumors
Lung
ND
ND
ND
ND
ND
ND
ND
B2
A
B2
A
B2
D
ND
ND
B2
ND
C
B2
B2
B2
D
B2
ND
ND
ND
ND
ND
                                                                                                                                                          Source
                                                b
                                              b,c
                                                b
                                              b,g
                                                b
                                                b
 ND
  b
d,f
  j
  j
  j
  j
  j
 ND
 ND
  j
  j
  j

-------
Parameter
                                                            TABLE 6-4
                                                            (Continued)
Oral Cancer Slope
     Factor
 (mg/kg-day)-1
Inhalation Cancer
 Slope Factora
  (mg/kg-day)-1
                                                                                                      Oral
                                                     PESTICIDES/PCBs
                                                                                                              Tumor Site

                                                                                                                      Inhalation
                                         Cancer
                                     Classification
                                                                                                                                                         Source
Aroclor-1254
Aroclor-1260
Dieldrin
Heptachlorodibenzofuranj
Heptachlorodibenzo-p-dioxinj
Octaclorodibenzo-p-dioxinj
Tetrachlorodibenzofuranj
   7.70 x 10+0
   7.70 x 10+0
   1.60 x 10+1
   1.5 x 10+4
   1.5 x 10+4
   1.50 x 10+2
   1.5 x 10+3
     ND
     ND
 1.60 x 10+1
 1.5 x 10+4
 1.5 x 10+4
 1.50 x 10+2
 1.5 x 10+3
   Liver
   Liver
Liver/Lung
     ND
     ND
     ND
     ND
ND
ND
ND
ND
ND
ND
ND
B2
B2
B2
ND
ND
ND
ND
 1
 1
 k
ND
ND
ND
ND
aWhere only a unit risk for inhalation is available, the cancer slope factor by derive by assuming a 70 kg adult inhales 20m3 of air/day.
bEPA IRIS database
CThe HEAST  (1992) presented an inhalation slope factor of 50  (mg/day)-l, based on absorbed dose  (absorption factor of 0.3).  A risk of 15  (mg/g-day)-1 based
on ambient dose is the value used in this risk assessment.
dEPA, HEAST, Annual FY-1991
eNo data presented for chemically induced carcinogenicity - radiocacinogenicity of uranium isotpes are discussed individually.
fslope factors for benzo(a)pyrene used for B2 PAHs.
gEPA, HEAST, Annual FY 1992.
hDerived from the proposed inoganic arsenic ingestion unit risk [5x 10-5  (ug/L)-!].  "The uncertainties associated with ingested inorganic arsenic  such as that
estimates dcould be revised downward as much as an order of magnitude, relative to the risk estimates associated with most other carcinogens"  (EPA  1993) .
iNot classified or not classifiable as to human carcinogenicity.
jFor polychlorinated dibenzo-p-deioxzin and polychlorinated dibenxofurans, the 2, 3, 7, 8-TCDD toxicity equivalents will be calculated using the appropriate
l-TESFS/89  (1989 EPA Interim)  Toxicity Equivalent Factor  (EPA 1989c).
eEPA IRIS database 1994, May 1994.
1EPA IRIS database 1994, September 1991
mEPA HEAST 1993
nND - No data available
Source:  Table B.2.8, Operable Unit 2 RI Report.

-------
hypothetical models for projecting risk through a lifetime. The relationship between cancer
incidence and exposure to radioactive materials is guantified by using mathmatical extrapolation
models, which estimate the largest possible linear slope (within the 95 percent UCL) at low
extrapolated doses consistent with the data. Because EPA is concerned with assessing cancer
incidence, each radionuclide slope factor has been calculated by dividing the excess fatal
cancer risk for that radionuclide by the mortality-to-incidence risk ration (EPA 1989a) for the
types of cancer induced by that radionuclide. This "radiocarciniogenicity slope factor" thus is
characterized as the "maximum likelihood estimate of the age-averaged lifetime total excess
cancer risk per unit intake or exposure" (EPA 1993b). That is, the true risk to humans,
although not identifiable, is not likely to exceed this upperbound estimate; it may, in fact, be
lower. The COG radiocarcinogenic oral and inhalation cancer slope factors are listed in Table
6-4.

Noncarcinogens

The potential for noncarcinogenic health effects resulting from exposure to chemical
contaminants is assessed by comparing an exposure estimate (intake) to a reference doese (RfD).
The RfD is expressed in units of mg/kg-day and represents a daily intake of contituent per
kilogram of body weight that is not sufficient to cause the threshold effect of concern for the
constituent.

A RfD is specific to the chemical, the route of exposure, and exposure duration. To derive a
RfD, the EPA reviews all relevant human and animal studies for each compound and selects the
study (or studies) pertinent to the derivation of the specific RfD. Each study is evaluated to
determine the no-observed-adverse-effect level (NOAEL) or, if data are inadeguate for such a
determination, the lowest-observed-adverse-effect level (LOAEL). The NOAEL corresponds to the
dose, in mg/kg-day, that can be administered over a lifetime without inducing observable adverse
effects. The LOAEL corresponds to the lowest daily dose, in mg/kg-day, that can be administered
over a lifetime that induces an observable adverse effect. The toxic effect characterized by
the LOAEL is referred to as the "critical effect". To derived a RfD, the NOAEL (or LOEAL) is
divided by uncertainty factors to ensure that the RfD will be protective of human health.
Separate RfDs are needed for ingestion and inhalation pathways. The primary source of values
for RfDs are the IRIS and the HEAST compiled and maintained by the EPA (EPA 1993a, 1993b).
Other EPA sources of RfD values were also consulted, when available. The COG reference doses
for noncarcinogenic chemicals are listed in Table 6-5. Dermal reference doses for
noncarcinogenic chemical effects were listed in Table 6-3.

-------
                                                     Chronic Inhalation
                                                       Reference  Dosea
                                                         (mg/kg-day)
   Effect of Concern
Oral
                        Inhalation
                                          Oral
Uncertainty Factor
    Inhalation       Source
                                                                                      RADIOLOGICAL
Uranium-total
                                                           NDb
                                                                                    ND
                                                                                                                                                     ND
                                                                                                                                                                    ND
                                                                                                                                                                                   ND
                                                                                       INORGANICS
Antimony
                                                           ND
                                                                                    ND
                                                                                                                                  Nasal Cavity
                                                                                                                                  Rhinitis
                                                                                                     Keratosis;
                                                                                                     hyperpigmentation
Barium
Beryllium
Cadmium (food)
Cadmium (water)
Cyanide
Lead (Inorganic)
Manganese (oral & food)
Selenium
Thallium
7.
5.
1.
5.
2 .

1.
5.
7.
.0 x
.0 x
. 0 x
.0 x
.0 x
NDd
.4 x
. 0 x
.0 x
10-2
10-3
1-5
10-4
10-2

10-1
10-3
10-5
1.43 x 10-4
ND
ND
ND
ND
ND
1.1 x 10-4a
ND
ND
5.0 x 10-4
ND
ND
ND
ND
ND
4 .0 x 10-4
ND
ND
Increased Blood pressure
None observed
Renal damaged
Renal damaged
Weight loss, thyroid
effect, myelin degradation
CNSh effects
No effects
Selenosis
Increased SCOT and serum
Fetotoxicity
ND
Cancer
Cancer
ND
CNS effects
ND
ND
ND
3
100
10
10
100
ND
1
3
3000
lOOi
ND
ND
ND
ND
ND
ND
ND
ND
                                                                                                     LDH levels;  alopecia
                                                                                      VOLATILES
                                                           ND
                                                                                    ND
                                                                                                     Survival/Histopathology
                                                                                                                                     ND
                                                                                                                                                                    ND

-------
                                                                                      TABLE 6-5
                                                                                     (Continued)
Parameter




4-Methylphenol(p-cresol)


Bis(2-Ethylhexyl)phthalate

Tributyl phosphate



Deildrin
                                                     Chronic Inhalation
                                                       Reference Dosea
                                                         (mg/kg-day)
NDe


ND

ND
                                                 Effect of Concern
                                              Oral                  Inhalation
    SEMIVOLATILES

ND


ND

ND

 PESTICIDES/PCBS

ND                Liver  lesions
                                                                                      Oral
ND

ND
                                                                           Uncertainty Factor
                                                                             Inhalation      Source
                                                                                                          ND
aEPA IRIS database  1993,  July 1993.

bND = No data available.

CEPA, HEAST, Annual  FY-1992.

dThe EPA RfD Work Group  considers it inappropriate to develop a RfD  for  inorganic lead (1985).
fEPA IRIS database  1993,  February 1993.

gEPA IRIS database  1994,  May 1994.

hCNS = Central nervous  system

Source:  Table B.2-7, Operate Unit  2 RI  Report.

-------
6.1.4 Risk Characterization

The risk characterization was performed for over 30 CPCs in 10 different media for each of the
five Operable Unit 2 subunits. This characterization assumed that no additional engineering
controls were installed to prevent the migration of contaminants from the subunits. The summary
of results for the COCs in each media and subunit is provided to Section 6.0 of the Operable
Unit 2 RI Report.

Table 6-6 summarizes the total risks and hazards posed to receptors for both current land-use
scenarios. The maximally exposed receptor for current land-use scenarios for each of the five
subunits is the on-property groundskeeper, which had carcinogenic risks on the order of 1x10-4.
These risks were dominated by external radiation from thorium-228, thorium-232, radium-226, and
radium-228 in soil. The His of systematic toxic effects from each subunit to the groundskeeper
were below 1.0. The His for the trespassing youth were below 1.0 for the Lime Sludge Ponds,
Inactive Flyash Pile, and Active Flyash Pile, but were above 1.0 for the Solid Waste Landfill
and the South Field. Calculated risks to the off-property resident farmers (adult and child)
approached a range on the other of 1x10-7 and 1x10-9; total His for both the adult and child
were well below 1.0.

Table 6-7 summarizes the risks and hazards posed to the receptors evaluated under the future
land use with federal ownership scenario. The maximally exposed receptors under this scenario
for each of the five subunits is the expanded trespasser and the off-property resident farmer.
The expanded trespasser had a carcinogenic risk on the order of 1x10-4 to 1x10-5. Major
contributors to this risk include external radiation from thorium-228, thorium-232, radium-226,
and radium-228. The His from each subunit to the expanded trespasser were below 1.0.
Calculated risks to the off-property resident farmer approached a range on the order of 1x10-5
and 1x10-8. Both off-property resident farmer receptors (adult and child) and His that exceeded
1.0 from two subunits (Inactive Flyash Pile and South Field) due to ingestion of total uranium
in groundwater.

Tabel 6-8 summarizes the risks and hazards posed to the receptors evaluated under the future
land use with the private ownership scenario. The maximally exposed receptor associated with
each of the five subunits under this scenario is the RME on-property resident farmer, with
carcinogenic risks on the order of 1x10-3 to 1x10-5. The risks were primarily due to external
radiation from radium-226, radium-228, thorium-228, and thorium-223 and from the ingestion of
produce irrigated with groundwater contaminated with uranium. Total His from two subunits
(Inactive Flyash Pile and

-------
                                                                                                                         TABLE  6-6
                                                                                    CURRENT LAND USE  SCENARIOS
                                                                                CARCINOGENIC RISK AND HAZARD  INDEX
Subunit
Solid Waste
Landfill

Lime Sludge
Ponds

Inactive
Flyash Pile

South Field

Active
Flyash Pile

Trespassing
Risk Typea Youth
Carcinogenic 1.5 x 10-5

Noncarcinogenic 8.6
Carcinogenic 1.1 x 10-5

Noncarcinogenic 2.1 x 10-1
Carcinogenic 1.5 x 10-5

Noncarcinogenic 1.0 x 10-1
Carcinogenic 1.0 x 10-4
Noncarcinogenic 53
Carcinogenic 2.6 x 10-5

Noncarcinogenic 3.6 x 10-2
On-Property
Groundskeeper
3.4 x 10-5

4 .3 x
4.5 x

1.3 x
5.0 x

2.0 x
2.2 x
NDb
8.0 x

5.9 x

10-3
10-5

10-1
10-5

10-2
10-4

10-5

10-2
Off-Property
Resident
Farmer
6.0 x 10-5

1.8 x 10-6
1.5 x 10-7

2.0 x 10-5
6.1 x 10-7

5.5 x 10-2
6.4 x 10-7
2.0 x 10-5
4 .7 x 10-7

6.2 x 10-4
Off-Property
Resident
Child
2.7 x 10-8

6.4 x 10-6
1.4 x 10-8

9.3 x 10-5
7.9 x 10-8

2.0 x 10-4
2.4 x 10-7
7.2 x 10-5
6.6 x 10-8

2.1 x 10-3
Great Miami Great Miami
Use of River River
Meat and Recreational Recreational
Milk User User
9.0 x 10-9 2.8 x 10-10 4.2 x 10-9

5.8 x 10-7 1.1 x 10-7 2.2 x 10-6
1.4 X 10-6 NAc NA

4.3 x 10-4 NA NA
1.1 x 10-7 8.4 x 10-9 3.0 x 10-9

1.4 x 10-5 1.9 x 10-6 4.2 x 10-6
4.5 x 10-6 4.2 x 10-6 6.3 x 10-8
3.0 x 10-5 8.0 x 10-7 2.5 x 10-6
4.7 x 10-7 1.4 x 10-9 7.7 x 10-9

3.7 x 10-3 6.1 x 10-3 2.1 x 10-5
Great Miami
River
Agricultural
User
6.5 x 10-7

1.1 x 10-4
NA

NA
5.3 x 10-9

3.6 x 10-5
4.4 x 10-6
4 .0 x 10-5
3.5 x 10-9

6.7 x 10-6
aThe carcinogenic risk value is the  incremental  lifetime cancer risk (ILCR) and the noncarcinogenic value  is  the  hazard index (HI).

bND = not determined because toxicity  data  not available.

cNA = the indicated land use is not  applicable to the subunit.

Source:  Tabel 7-1, Operable Unit  2  RI  Report.

-------
                                                          TABLE 6-7
                                       FUTURE  LAND USE WITH FEDERAL OWNERSHIP SCENARIO
                                              CARCINOGENIC RISK AND HAZARD INDEX
                                                                                 Off-Property  Resident
Subunit                         Risk  Typea                  Expanded Trespasser           Farmer

Soil Waste Landfill
Carcinogenic
Noncarcinogenic
Carcinogenic
Noncarcinogenic
Carinogenic
Carcinogenic
Noncarcinogenic
Carcinogenic
Carcinogenic
Noncarcinogenic
2. 0x10-5
2.7x10-1
2.4x10-5
2.2x10-1
3.0x10-5
1.4x10-4
8. 0x10-2
4. 9x10-5
4 2x10 2
8.7x10-5
1.2x10-1
6.7x10-8
1. 8x10-6
1.7x10-7
2. 0x10-5
7.5x10-5
1 2
8.7x10-5
1. 1
1. 1x10-5
1. 1x10-4
3.7
3.5x10-9
6. 4x10-6
1. 6x10-8
9.3x10-5
4.0x10-6
2 5
4.2x10-6
3.1
7.2x10-7
7 9x10 1
NCb
NC
Inactive Flyash Pile



South Field



Active Flyash Pile



Operable Unit 2-Wide



aThe carconogenic risk value  is  the  Incremental Lifetime Cancer Risk (ILCR) and the noncarcinogenic  value  is  the Hazard Index (HI).

bNC - Not calculated.

Source:   Tabel 7-1, Operable  Unit  2  RI  Report.

-------
                                                                                               TABLE  6-8

Waste Subunit
Solid Waste
Landfill

Lime Sludge Ponds

Inactive Flyash
Pile

South Field

Active Flyash Pile

Operble Unit 2-
Wide


Risk Typea
Carcinogenic
Noncarcinogenic
Carcinogenic
Noncarcinogenic
Carcinogenic
Noncarcinogenic
Carcinogenic
Noncarcinogenic
Carcinogenic
Noncarcinogenic
Carcinogenic
Noncarcinogenic
On-Property
Farmer
( RME ) b
2. 8x10-3
2. 9x10-1
1.3x10-5
1.7x10-3
1.5x10-3
22
3.4x10-2
23
8.4x10-5
9. 9x10-1
3.3x10-2
23
On-Property
Resident
Farmer ( CT ) c
2.0x10-4
1.2x10-1
9.3x10-7
7.3x10-4
8.6x10-5
9. 8
2.0x10-3
11
4 .8x10-6
4 .5x10-1
NCf
NC
On-Property
Resident
Child
6.4x10-4
1. 0
1.2x10-6
7. 9x10-3
7.7x10-5
65
9.2x10-5
63
5.7x10-6
2.8
NC
NC
Home
Builder
9.0x10-6
4 .8x10-1
NAe
NA
NA
NA
1.1x10-5
5.4x10-1
NA
NA
NC
NC
Perched
Groundwater
User
2. 8x10-3
NDd
7.7x10-5
3.1x10-3
NA
NA
NA
NA
NA
NA
NC
NC
Great Miami
River
Recreational
User
2. 8x10-10
1. 1x10-7
NA
NA
8.4x10-9
1. 9x10-6
4 .2x10-8
2.5x10-6
1.4x10-9
6. 1x10-6
NC
NC
Great Miami
River
Residential
User
4 .2x10-9
2.2x10-6
NA
NA
3.0x10-9
4 .2x10-6
6.3x10-8
1.4x10-4
7.7x10-9
1.5x10-5
NC
NC
Great Miami
River
Agricultural
User
6.5x10-7
1. 1x10-4
NA
NA
5.4x10-10
3.6x10-5
4 .2x10-6
4.0x10-5
3.5x10-9
6.7x10-6
NC
NC
aThe carcinogenic risk value is the  Incremental  Lifetime Cancer Risk (ILCR)  and the noncarcinogenic value is the  Hazard  Index (HI).





bRME - Reasonable Maximum Exposure





cCT - Central Tendency





dND - Not determined because toxicity  data  not  available.





eNA - The indicated receptor is not  applicable  to  the waste subunit.





fNC - Not calculated





Source:  Table 7-1, Operable Unit 2  RI  Report.

-------
South Field) exceeded 1.0 for the on-property resident farmer (adult and child) (RME and CT) due
mostly to ingestion of total uranium in groundwater.

6.2 UNCERTAINTIES

Sources of uncertainty in the Operable Unit 2 Baseline Risk Assessment are discussed in
Section B.4.3 of the Operable Unit 2 RI Report. Generally, uncertainty arises wherever
imperfect information or understanding exist. In risk assessment, this typically is mitigated
by making conservative assumptions for individual parameters. Significant uncertainty results
for those particular pathways that reguired fate and transport modeling to support the
assessment of exposure and, therefore, for the homegrown produce and beef and milk pathways.
Such uncertainty was generated for the air and groundwater pathways of exposure. The high
uncertainty must be recognized in the interpretation of risk from these media. Certain exposure
pathways for a particular medium also tend to have higher or lower uncertainty depending on
their assumptions. For example, incidental ingestion of soils by residents tends to have
significantly less uncertainty than ingestion of fruits and vegetables, and meat and milk raised
on contaminated soils. To assess these indirect exposure pathways, assumptions must be made
regarding contaminant uptake from soil to plant and plant to livestock that are not reguired for
the soil ingestion pathway. These assumptions contribute significant uncertainty to risk
estimates for these pathways.

The greatest uncertainty in the Operable Unit 2 Baseline Risk Assessment is associated with the
assumptions made to estimate exposure point concentrations in groundwater, air, fruit and
vegetables, and milk and beer for the assumed future receptors. These receptors include the
on-property resident farmer and child and the off-property resident farmer and child. For the
on-property RME farmer and home builder, the highest uncertainty is associated with the assumed
future land use and potential exposure pathways. This receptor scenario was included in
response to guidance, but the liklihood of occurrence within Operable Unit 2 is unknown.
Uncertainty associated with the off-property resident farmer and child is primarily the result
of surface water, groundwater, and air modeling used to support those scenarios. The modeling
assumptions were conservative and therefore resulted in conservative estimates for the exposure
point concentrations.

Taken together, the uncertainties identified with site data, exposure parameters, fate and
transport modeling, toxicity assessment, and risk characterization are judge to be high (i.e.,
there is the potential to overestimate risk by two or more orders of magnitude)

6.3 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, was to
estimate the potential and future baseline risks of FEMP contaminants to ecological receptors.

The EPA and DOE agreed in the Amended Consent Agreement (September 1991) that the Site-Wide
Ecological Risk Assessment would be performed as part of the RI for Operable Unit 5. However, a
gualitative evaluation of risks was performed for the Operable Unit 2 remedial action. Residual
contaminant concentrations projected to remain following the implementation of the selected
remedy were compared to benchmark values from Operable Unit 5 identified as being protective of
ecological receptors. Concentrations were below benchmark values, indicating no adverse impact.

The Site-Wide Ecological Risk Assessment in the Operable Unit 5 RI Report guantitatively
assesses 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.

-------
This section summarizes the results of the Site-Wide Ecological Risk Assessment from the
Operable Unit 5 RI Report.

The ecological receptors potentially exposed to FEMP contaminats include all organisms,
exclusive of humans and domestic animals. The ecological risk assessment focused on a group of
indicator species selected to present a variety of exposure pathways and trophic positions.
Territorial vegetation was represented by a generic plant specis. Terrestrial wildlife species
to be evaluated were selected based on species abundance on the FEMP site, trophic level
position, and habit reguirements. The species evaluated were the white-tailed deer (Odocoileus
virginiaunus), white-footed mouse (Peromyscus leucopus), raccoon (Prycon 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 or 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 primarilydue to nonradiactive 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 NOAELs 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 1.0 only for arsenic, lead, molybdenum, and silver. These
chemical 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
to radionuclides. If perfect transfer or biomagnification of uranium occsurs (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 fall below the range likely to result in harmfull effecsts.
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 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
aquatic organisms would ensure that there were no deleterious effects from radiation on the
population. The most affected organisms would be aguatic plants, receiving as total dose from
internal and external exposure of about 140 rad/day. The total dose to fish is minimally over
the limit, at 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 were 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 sewer outfall ditch; and silver 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 aguatic communities do not
indicate any affects consistent with contaminant impact 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 suggest 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 95
percent UCLs 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 radionuclies 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 sil inorganic chemical concenstrations 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.

6.4 CONCLUSION

The results of the Operable Unit 2 Baselsine Risk Assessment demonstrate ther current and future
risks and hazards from the Operable Unit 2 subunits will exceed the EPA acceptable carcinogenic
risk range of 1x10-4 to 1x10-6 and the acceptable noncarcinogenic hazard limit of 1.0.
Therefore, actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this ROD, may present a current or
potential threat to public health, welfare, or the environment.
7.0 DESCRIPTION OF ALTERNATIVES

This section identifies and provides a description of each of the remedial action alternatives
studied in the detailed analysis phase of the Operable Unit 2 FS. Remedial alternatives for

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Operable Unit 2 were developed by examining available technologies for cleanup that were
potentially applicable to the contaminated materials within the subunits. The FS initially
evaluated eight remedial alternatives against three general criteria effectiveness,
implementability, and cost. Based on this screening, the four alternative discussed in this
section were selected for detailed analysis; the alternatives retain the original numbering.
For more in-depth information on remedial alternatives, refer to the Operable Unit 2 FS Report.
Information on the environmental impacts associated with each alternative can be found in Table
8-2.

7.1 Alternative 1: No Action

The no action alternative is retained throughout the FS process as reguired by the NCP [40 CFR
§300.43(e) (6)]. This alternative provides a baseline against which other alternatives can be
evaluated. Under this alternative, no remedial action world be taken and the material would be
left "as is," without the implementation of any containment, removal, treatment, or other
mitigating actions. This alternative would not reduce the toxicity, mobility, or volume of
contamination at the action. In addition, this alternative woild not provide monitoring of soil
or groundwater, nor world it provide access restrictions to limit exposure to the waste
material.

7.2 Alternative 2: Consolidation and Capping

Alternative 2 includes consolidation of material within or near each of the subunits. A
composite cap is then constructed over the waste materials.

At the Solid Waste Landfill, material along the south side of the landfill world be removed to
allow placement of a proper foundation for the capping system adjacent to the railroad track.
Also, material close to a sand layer in the southeast corner of the landfill would be excavated
and world be replaced by clean to to halt the migration of contaminants into the sand layer.
Material in the northeast corner of the landfill would be consolidated toward the center of the
subunit to simplify the design geometry and construction of the cap.

At the North Lime Sludge Pond, free-standing water would be pumped to the Advance Wastewater
Treatment (AWWT) facility for treatment and discharge to the Great Miami River. This would not
be necessary for the South Lime Sludge Pond. The top 3 feet of lime sludge in both ponds would
then be stabilized in place by mixing with flyash and/or cement to support the cap. The
existing K-65 Slurry Line Trench, located south of the Lime Sludge Ponds, would be removed in
conjunction with the consolidation activities. The trench and piping material would be moved to
the staging/material preparation area processed for size reduction, and placed within the limits
of the consolidation area.

The slurry line trench, which holds electrical conduits and utility lines that are still
utilized at the site, would be reconstructed in the area south of the consolidation area. The
activity would be done to allow placement of a proper foundation for the capping system.

At the Inactive Flyash Pile, South Field, and Active Flyash Pile waste material with COCs above
the cleanup levels that is directly over the Great Miami River Aguifer or that is in an area
where there is limited natural soil protection the aguifer (less than 16 feet) would be
excavated. This material would be moved to the northeast area of the South Field where the
depth of natural soil is at least 16 feet thick. All existing waste material within the
floodplain (portions of the Inactive Flyash Pile and South Field) would be excavated and
consolidated in the northeast portion of the South Field. Prior to the actual excavation and
movement of this material, the area in the northeast of the South Field would be graded,
compacted, and covered with a drainage layer of gravel.

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Soil containing lead from the Firing Range, which is assumed to be mixed waste, would be
excavated, treated, packaged, and transported to an off-site facility for disposal. The
guantity of soils reguiring off-site disposal is estimated at 300 cubic yards. Firing Range
material surrounding the area with bullets that is not found to be hazardous after testing would
be managed with the other South Field material.

Sands under the Inactive Flyash Pile/South Field area serve as a lateral pathway by which
perched groundwater and leachate from the consolidated waste may enter the Great Miami Aguifer.
During the excavation and consolidation of the materials at the Inactive Flyash Pile, South
Field, and Active Flyash Pile, a subsurface drain would be constructed along the southwestern
and southeastern sides of the consolidation area to collect groundwater from the perched aguifer
underlying the area and to collect drainage from the gravel layer constructed prior to placement
of the consolidated material.

The subsurface drain would discharge by gravity into a pumping station. Collected leachate/
groundwater would be pumped to the AWWT facility for treatment and discharge to the Great Miami
River. Construction water in the subunit areas would be collected, as reguired, to maintain a
dry excavation and transferred to the AWWT facility for the treatment and discharge to the Great
Miami River.

Following the completion of consolidation activities at each subunit, excavated areas would be
backfilled, as necessary, with clean material and the entire consolidation area at each subunit
would be graded to blend withs the surrounding topography. The consolidation operation for the
subunits would be coordinated with the remedial actions associated with Operable Units 1, 2, 3,
and 5.
This alternative would include federal ownership of the FEMP with access restrictions (fencing)
and groundwater monitoring as institutional controls at each of the consolidated areas.

! Years to implement: 4.25 ! Present worth cost: $69.9 million

! Residual risk: 1.2 x 10-6 ! Quantity of waste

! Residual hazard: 1.3 x 10-1 to be handled: 251,400 cubic yards

7.3 Alternative 3: Excavation and Off-Site Disposal

Alternative 3 includes excavation of all materials with COG concentrations above the cleanup
levels, material processing for size reduction asnd moisture control (if reguired), and off-site
disposal.

At the North Lime Sludge Pond, free-standing water would be pumped to the AWWT facility for
treatment and discharge to the Great Miami River. The lime sludge from both ponds would then be
excavated and dried, as necessary, to meet the waste acceptance criteria for sthe off-site
disposal facility.

Debris (e.g., concrete, drum, steel, pallets, etc.) from all subunits would be visually
segregated, moved to the staging/material preparation area, processed for size reduction if
reguired, placed in containers, and shipped to an off-site disposal facility. Soil and other
wastes (i.e., flyash and lime sludge) would be placed directly in containers suitable for
shipment by rail or truck and transported to an off-site disposal facility. An off-site

-------
disposal facility has not yet been chosen, however Envirocare in Clive, Utah was used as a
representative off-site disposal facility for purposes of the cost estimate.

Soil containing lead from the Firing Range, which is assumed to be mixed waste, would be
excavated, treated, packaged, and transported to an off-site facility for disposal. The
guantity of soils reguiring off-site disposal is estimated to be 300 cubic yards. Firing Range
material surrounding the area with bullets that is not found to ber hazardous after testing
would be managed with the other South Field material.

Excavation would be completed to the reguired depth established by computer modeling to remove
material with COG concentrations above the cleanup levels. Upon reaching this predetermined
depth, verification sampling and testing would be completed to confirm that all material with
COG concentrations above their respective cleanup levels has been removed. If the results of
the verification sampling would be performed until acceptable test results are obtained. The
remaining soil would either be graded to blend in with the surrounding toprography, or utilized
for on-going construction activities at the FEMP. Excavation operations would be coordinated
with the remedial actions associated with Operable Unit 1, 3, 4, and 5.

Construction water in he subunit areas would be collected, as reguired, to maintain a dry
excavation, and transferred to the AWWT facility for treatment and discharge to the Great Miami
River.

This alternative would include federal ownership of the FEMP with access restrictions (fencing)
and groundwater monitoring as institutional controls at each subunit.

! Years to implement: 4.25 ! Present worth cost: $212.8 million

! Residual risk: 2.5 x 10-6 ! Quantity of waste

! Residual hazard: 2.0 x 10-2 to be handled: 314,700 cubic yards
7.4 Alternative 6: Excavation on On-site Disposal with Off-Site Disposal of Fraction
Exceeding Waste Acceptance Criteria

Alternative 6 includes excavation of all soils with COCs above the cleanup levels, material
processing for size reduction and moisture control if reguired, on-site disposal in an
engineered disposal facility, and off-site disposal of a small fraction of the excavated
material that exceeds the maximum waste acceptance criteria of the on-site disposal facility.
The maximum waste acceptance criteria is 346 pCi/g of uranium-238, or 1,030 ppm of total
uranium. Appendix E.2 of the operable Unit 2 FS Report present the details of how this waste
acceptance criteria was determined.

At the North Lime Sludge Pond, free-standing water would be pumped to the AWWT facility for
treatment and discharge to the Great Miami River. This would not be necessary for the South
Lime Sludge Pond. The lime sludge from both ponds would then be excavated and dried, as
necessary, before on-site disposal.

Debris (e.g., concrete, drums, steel, pallets, etc.) from all subunits would be visually
segregated, moved to the staging/material preparation area, processed for size reduction if
reguired, and placed in the on-site disposal facility. The remaining contaminated materials
from the subunits would be excavated, as described below, and placed in the on-site disposal
facility.

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It is estimated that up to 3,100 cubic yards of material from Operable Unit 2 would not meet the
waste acceptance criteria for on-site disposal. This approximately one percent of the total
amount of waste material that would be excavated. This material would be packaged in containers
suitable for shipment by rail or truck and transported to an off-site disposal facility. An
off-site disposal facility has not been chosen, however, Envirocare in Clive, Utah was used as a
representative off-site disposal facility for purposes of the cost estimate.

Soil containing lead from the Firing Range, which is assumed to be mixed, would be
excavated, treated, packaged, and transported to an off-site facility for disposal. The
guantity of soils reguiring disposal is estimated to be 300 cubic yards. Firing Range material
surrounding the area with bullets that is not fund to be hazardous after testing would be
managed with the other South Field material.

Excavation would be completed to the reguired depth established by computer modeling to remove
materials with COG concentrations above the cleanup levels. Upon reaching this predetermined
depth, verification sampling and testing would be completed to confirm that all material with
COG concentrations above their respective cleanup levels had been removed. If the results of
the verification sampling/testing indicate that contamination above cleanup levels remains, then
additional excavation and verification sampling would be performed until acceptable test results
are obtained.

The remaining soil would wither be graded to blend in with the surrounding topography, or
utilized for on-going construction activities at the FEMP. The excavation/disposal operation
for the Operable Unit 2 subunit would be coordinated with the remedial operations associated
with Operable Unit 3 and Operable Unit 5. Long-term monitoring would be performed at each
subunit to monitor groundwater and surface water to ensure that any material with concentrations
below cleanup levels that is left in place causes no adverse effects.

Figure 7-1 depicts the limits of the potentially acceptable region for the location of the
on-site disposal facility. The geology of the disposal facility location identified in the
figure in combination with the engineering controls will be protective of human health and the
environment, based on a series of soil boring made in the area. However, the disposal facility
location is subject to review and approval during the remedial design phase. DOE intends to
construct only one disposal facility at the FEMP.

Therefore, would on-site disposal be selected for other Fernald operable units, the disposal
facility capacity and location could be adjusted accordingly during the remedial design process.
Figure 7-2 depicts a cross-section of the proposed cap and liner system for the on-site disposal
facility.
Construction water in the subunit areas and from the on-site disposal facility construction
location would be collected, as reguired, to maintain a dry excavation, and transferred to the
AWWT facility for treatment and discharge to the Great Miami River.

This alternative would include federal ownership of the FEMP with access restrictions (fencing)
and groundwater monitoring as institutional controls at the subunits and on-site disposal
facility. Cap maintenance would also be performed at the on-site disposal facility.

! Years to implement: 4.25 ! Present worth cost: $105.9 million

! Residual risk: 2.5 x 10-6 ! Quantity of waste

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Residual hazard: 2.0 x 10-2 to be handled: 314,700 cubic yards
7.5 MAJOR ARARS FOR OPERABLE UNIT 2

CERCLA §121(d)(2) directs that for wastes left on site, remedial actions must comply with
federal and state environmental laws that are legally applicable or are relevant and appropriate
under the circumstances of the release or potential release. According to CERCLA §121 (e) (2), no
federal, state, or local permits are reguired for the portion of any removal or remedial action
conducted entirely on site. Off-site actions must comply with all reguirements that are
applicable, including permit reguirements. This section discusses the ARARs for Operable Unit
2. The list of major ARARs is attached to this Record of Decision as Appendix A.

ARARs are defined as follows:

! Applicable reguirements are cleanup standards of control, and other substantive
environmental protection reguirments, criteria, or limitations promulgated under
federal or state law that specifically address a hazardous substances, pullutant,
contaminant, remedial action, location, or other circumstance at a CERCLA site.

! Relevant and appropriate reguirements are cleanup standards, standards of control,
and other substantive environmental protection reguirements, criteria, or limitations
promulgated under federal and state law that, while not "applicable" to a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance at
a CERCLA site, address problems or situations sufficiently similar to thos encountered
at the CERLA site that their use is well suited to the particular site.

! To Be Considered (TBC) criteria is a catergory that includes non-promulgated
criteria, advisories, and guidance issued by federal or state government that are not
legally binding and do not have the status of potential ARARs. However, pertinent
TBCs will be considered along with the ARARs in determining the necessary level of
cleanup or technology reguirements.

EPA has identified three categories of ARARs:

! Chemical-specific ARARs are usually health- or risk-based numerical values or
methodologies used to determine acceptable concentrations of chemicals that may be
found in or discharged to the environment [e.g., maximum contaminant level (MCLs) that
establish safe levels in drinking water].

! Action-specific ARARs are usually technology- or activity-based reguirements or
limitations on actions or conditions involving special substances.
! Location-specific ARARs restrict actions or contaminant concentrations in certain
environmentally sensitive areas. Examples of areas regulated under various federal
laws include floodplains, wetlands, and locations where endangered species of
historically significant cultural resources are present.

Sources of Operable Unit 2 ARARs are federal and state laws, regulations, and guidance and DOE

-------
Orders that address the site specific circumstances in Operable Unit 2.

7.5.1 No Action Alternative

There are no major ARARs for the no action alternative. A no-action decision can only be made
when no remedial action is necessary because the site is already protective of human health and
the environment.

7.5.2 Chemical-Specific ARARs/TBCs

All Operable Unit 2 remedial alternatives must meet the chemical-specific ARARs associated with
potential releases to air, surface water, groundwater, and penetrating radiation. These ARARs
include federal and any more stringent state non-zero maximum contaminant level goals (MCLGs)
and MCLs for drinking water; the Ohio Water Quality Criteria for surface water; EPA limits for
radionuclide air emissions; National Ambient Air Quality Standards and the Ohio Air Toxic Policy
for air pollution; and DOE dose limits for exposure to radioactivity.

7.5.3 Actio-Specific ARARs/TBCs

Alternatives proposing that remediation waste remain on site would have a number of
action-specific reguirements that must be met. These reguirements would depend on type of
disposal (i.e., consolidation/containment or at an engineered on-site disposal facility) and
classification of the remediation waste. The reguirements include EPA regulations and DOE
Orders governing the management and disposal of low-level radioactive waste/residual radioactive
material and OEPA regulations for the disposal of solid wastes. Specific layers of the cap and
liner systems of the disposal facility and the duration of protection are specified in the
action-specific reguirements. If different regulatory types of remedialion waste are disposed
of together in a facility, the most stringent technical reguirements would be met.

7.5.4 Location-Specific ARARs/TBCs

Along with the action-specific reguirements for waste dispose, there are a number of
location-specific ARARs. The protection of endangered species, cultural resources, floodplains,
and wetlands is reguired by federal and state regulation. Part of the Inactive Flyash Pile and
South Field are located in a 100- and 500-year floodplain area but the remedial alternative will
not adversely impact this floodplain. A small area of wetlands is located north of the Solid
Waste Landfill. During remediation contaminated sediments may be removed from the area, thus
impacting the wetland.

Wetlands in other areas of the site may also be impacted by construction and operation of the
on-site disposal facility. This action will be performed in accordance with the Clean Water Act
(Section 404 and applicable regulations) and a DOE NEPA assessment [10 CFR §1022] was performed
to minimize impact to floodplains and wetlands.

The most significant issue influencing the location-specific ARARs is the determination by EPA
Region V (53 Federal Register 25670) that the buried valley aguifer system of the Great
Miami/Little Miami Rivers of southwestern Ohio (Great Miami Aguifer) is a sole or principal
source of drinking water and that contamination of this aguifer would create a significant
hazard to the public health.

The determination was effective July 8, 1988. The Federal Safe Drinking Water Act reguires all
federally-funded projects to undergo a review to ensure that the project will not adversely
impact a sole source of drinking water.

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OEPA has established solid waste siting criteria that prohibit locating a new solid waste
landfill over a sole-source aguifer [Ohio Administative Code (OAC) 3745-27-07(H)(2)(c)]. OEPA
has also established that a new solid wrote disposal facility may not be located above an
unconsolidated aguifer capable of sustaining a yield of 100 gallon per minute for a 24 hour
period (AOC 3745-27-07 (H)(2)(d)]. The Great Miami Aguifer gualified as both a sole-source
aguifer and a 100-gallon-per minute-yield aguifer.

Ohio Revised Code (ORC) 3734.02(G) allows exemptions to reguirements identified in the
regulations for obtaining a permit or license. These exemptions must be based on a
determination that the exemption would be unlikely to adversly affect public health or safety or
the environment.

OEPA has established two specific policies [GD0202.101 and GD0202.102] that identify conditions
that would be acceptable to allow an exemption to the two cited rules. While these policies
state that several hours will be considered in evaluating an exemption, the specific factore
identified indicate that the protection of human health and the environment should be provided
solely by the existing hydrogeologic conditions. This has been reaffirmed by OEPA in several
meetings.

The primary hydrogeologic standards established by these policies the:

! Significant thickness of low permeable material between the disposal facility and th
the aguifer

! Lack of inter-connection between the sole-source aguifer and any significant zones
of saturation

! Significant amount of sediment [soil] between the disposal facility and the
high-yield aguifer to prevent leachate from migrating to the high-yield aguifer
during the life of the landfill and the post-closure care period. The post-closure
care period for a solid waste landfill is a minimum of 30 years [OAC 3745-27-14 (A) ] .

It has been determined, based on existing hydrogeologic information, that the existing
hydrogeologic conditions a thee FEMP do not fully meet the conditions. This is based on the
posibility that some granular soils thee interebedded the till and the need in protect the
aguifer for significantly longer than 30 years [at least for 200 years; an ARAR under 40 CFR
192] .

The existing geologic information is based on borings within the boundaries of the on-site area
determine in exhibit the best hydrogeologic conditions. The current definition for the on-site
the with the best hydrogeologic conditions is where 12 feet or more of gray clay would exist
between the before of a proposed engineered disposal facility and the aguifer. A pre-design
investigation has been initiated to establish the best location for a disposal facility in this
identified area. The objective is to locate the disposal facility footprint where there is the
greatest amount of gray clay and the least amount of interbedded granular material. The
pre-design investigation will also obtain site-specific field information to verify the modeling
parameters that demonstrated the protection of human health and the envronment (i.e., protection
of the acguifer).

Based on the pre-design investigations, DOE will determine what additional engineering controls
beyond these reguired by me OEPA solid waste landfill regulations are necessary to protect the
aguifer. The resulting combination of hydrogeologic conditions and engineering controls will
provide protection of human health and the environment.

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This combination meets the criteria for an EPA waiver of the identified OEPA ARARs based on an
equivalent standard of performance. The preamble to the NCP [55 Federal Register 8748] directs
that for a CERCLA waiver of ARARs based on the equivalent standard of performance, the following
factors need to be considered: degree of protection level of performance, reliabilities into
the future, and the time required for results.

EPA further directs that the purpose of thee waiver is for the use of alternative but equivalent
technologies, methods or approached and that a comparison based on risk is only pertained where
the original standard is risk based. ORC 3734.02(G) and the supporting policies can be
interpreted to be based on a combination of method (i.e., performance) and risk. Therefore, a
discussion addressing the equivalency of the selected alternative to the OEPA standards based on
performance and risk will be provided in Section 10.2.3.

A feasible location for the on-site disposal facility and the necessary engineering controls to
meet the equivalent standard of performance to protect human health and the high-yield
sole-source aquifer are addressed in Section 5.0 of the Operable Unit 2 FS Report. The specific
design of the engineering controls and location of the disposal facility would be finalize
during the remedial design process.
8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVE

Section 8.0 profiles the basis for evaluating the relative performance of the alternatives with
respect to the nine EPA evaluation criteria, noting how the preferred alternative compares to
the other alternatives under consideration. The following are the EPA evluation criteria:

1. Overall Protection of Human Health and Environment addressed whether or not a
remedy provides adequate protection and describes how risks posed through each
pathway are eliminated, reduced, or controlled through treatment enginering
controls or institutional controls.

2. Compliance with ARARs addressed whether or not a remedy will meet all of the
applicable or relevant and appropriate requirements of other Federal and State
environmental status and/or provide grounds for provoking a waiver.

3. Long-Term Effectiveness and Permanence refers to the magnitude of residual risk
and the ability of a remedy to maintain reliable protection of human health and
the environment over time once cleanup goals have been met.

4. Reduction of Toxicity, Mobility, or Volume Through Treatment is the anticipated
performance of the treatment technologies that may be employed in a remedy.

5. Short-Term Effectiveness refers to the speed with which the remedy achieves
protection, as well as the remedy's potential to create adverse impacts on human
health and the environment that may result during the construction and
implementation period.

6. Implementability is the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement the
chosen solution.

7. Cost includes capital and operation and maintenance costs.

8. State Acceptance indicates whether, based on its renew of the RI/FS and Proposed

-------
Plan, the State concurs with, oppose, or has no comment on the preferred remedial
alternative.

9. Community Acceptance will be asssessed in the ROD following a renew of the public
comments received on the RI/FS report and the Proposed Plan.

The nine criteria are categorized into three groups: threshold criteria, primary balancing
criteria, and modifying criteria. The first two criteria, overall protection of human health
and the environment and compliance with ARARs, are the threshold criteria that must be satisfied
in order for an alternative to be eligible for section as the preferred remedial alternative.
Criteria three through seven are the primary balancing criteria that are used to weigh major
trade-offs among alternatives. State and community acceptance are the modifying criteria that
are taken into account after public comment is received on the Proposed Plan.
8.1 COMPARATIVE ANALYSIS OF ALTERNATIVES

The following section summarizes the information presented in Section 6.0 of the Operable Unit 2
FS Report for Operable Unit 2, and relies upon the detailed analysis of alternatives presented
in Section 5.0 of the same report.

The following are the remedial alternatives that underwent detailed analysis (the preferred
remedial alternative is underlined):

Alternative 1 No Action
Alternative 2 Consolidation and Capping
Alternative 3 Excavation and Off-Site Disposal
Alternative 6 Excavation and On-Site Disposal with Off-Site Disposal of Fraction
Exceeding Waste Acceptance Criteria

Table 8-1 provides a summarized comparative analysis of alternatives for Oparable Unit 2.

8.1.1 Overall Protection of Human Health and the Environment

Alternative 1, No Action, would not be protective of human health and the environment because no
remedial activities would be conducted. The Baseline Risk Assessment for Operable Unit 2
concludes that, without remediation Operable Unit 2 presents potentially unacceptable risks to
human health and the environment.

The remaining alternatives, collectivey referred to as "action alternatives", would provide
long-term protectiveness. For Alternative 3, Excavation and Off-Site Disposal, protectiveness
would be obtained by remove of the contaminated materials to cleanup levels. The material would
then be transported to an off-site disposal facility.

Alternative 6, Excavation and On-Site Disposal with Off-Site Disposal of Fraction Exceeding
Waste Acceptance Criteria, would provide protectiveness by the removal of the contaminated
material to cleanup levels. Protectiveness would be maintained through disposal of the removed
material in an engineered on-site dispose facility. The facility would utilize engineering
design to prelude human

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                                                                                           TABLE 8-1
                                                                                         SUMMARY OF  COMPARATIVE  ANALYSIS  OF REMEDIAL ALTERNATIVES
                                                                                          OPERABLE UNIT 2
                                                Threshold Criteria
                                                                                                                              Primary Balancing Criteria
    Alternative

 1 - No Action
      Overall Protection
       of Human Health
     and the Environment

Not protective
                                                                                          Effective, with
                                                                                          concerns over
                                                                                          permanance
                                                                                          because of inability
                                                                                          to monitor leaks
                                                                                        Mininalal treatment
                                                                                         (Firing Range soil)  so
                                                                                        no significant effect
                                                                                        on toxicity, mobility
                                                                                        or volume
                                                                          Implementability

                                                                          None
                                                                                                                                                                                             Present
                                                                                                                                                                                             Worth
                                                                                                                                                                                               Cost
                                                                                                                                                                                         ($millions)
                                                                                          Highly effective
                                                                                          and permanent
     Excavation and
     On-Site
     Disposal with
     Off-Site
     Disposal of
     Fraction
     Exceeding Waste
     Acceptance
     Criteria
                          Protective
                                Reguires  EPA  waiver  from
                                OEPA  prohibition  on  siting a
                                disposal  facility above  a high-
                                yield sole-source aguifer;
                                waiver is based on achieving a
                                standard  of eguivalent
                                performance;  complies  with
                                all other ARARs
Effective and
permanent
                                                                                        Minimal treatment
                                                                                         (Firing Range soil)  sc
                                                                                        no significant effect
                                                                                        on toxicity, mobility
                                                                                        or volume
Minimal treatment
(Firing Range soil)  so
no net effect on
toxicity, mobility or
volume
Effective -
moderate risk to
workers,
minimal risk to
volume
Reliable
technology;
administratively
possible to
implement, but
may be time
consuming to
obtain necessary
permits and
approvals

Reliable
technology;
administratively
implementable
community
Source:

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and ecological contact with the contaminated material. The facility would also be designed so
that it would not pose unacceptable impacts to the Great Miami Aguifer.

Alternative 2, Consolidation and Capping, would provide protection by consolidation the
contaminated material in these areas, capping this material, and installing a subsurface
drainage system in the South Field area. Thee measures would eliminate direct contact, reduce
exposure to an acceptable level, and migitate the potential migration of contaminants to the
Great Miami Aguifer.

This alternative would not be protective of the on-property resident farmer. Therefore,
continued federal ownership with access restriction would be reguired. Assessing the
effectiveness of the containment systems is only possible by monitoring the groundwater around
the consolidation areas.

This uncertainty would be minimized by regular inspection and maintenance of the capping
systems.

8.1.2 Compliance with ARARs

Except for alterative 1, each of the Operable Unit 2 remedial alternative would either comply
with the chemical-, action-, and location-specific ARARs, or meet the reguirements for an ARAR
waiver from the EPA. ARARs are not pertinent to Alternative 1, the No Action alternative, since
no remediation activities would occur.

Alternative 6, On-Site Disposal with Off-Site Disposal of Fraction Exceeding Waste Acceptance
Criteria, would meet the location-specific ARARs with an ARAR waiver of one reguirement. To
protect human health and the environment, OEPA regulations have established that new solid waste
disposal facilities should not be contructed over a sole source aguifer or aguifers that yield
greater than 100 gallons per minute. Because the Great Miami Aguifer that underlies the FEMP is
a sole-source aguifer and yields more than 100 gallons per minute, a waiver was reguested to
locate an on-site solid waste disposal facility on the FEMP. EPA allow waivers to ARARs if a
standard of eguivalent performance is attained. In this case, a waiver is justified because the
combination of the existing hydrogeology at the proposed location and the engineering controls
of the disposal facilities would be eguivalent to the hydrogeology criteria established by OEPA
for an exemption to the prohibition of siting a new solid waste disposal facility over a
high-yield sole-source aguifer.

Additional information on the waiver is provided in Section 7.5.4 and 10.2.3.
8.1.3 Long-Term Effectiveness and Permanence

Alternative 1, No Action, would not provide long-term effectiveness since no remedial activities
would occur. The Operable Unit 2 Baseline Risk Assessment concludes that without remediation,
Operable Unit 2 presents unacceptable risks to human health and the environment.

Alternative 3, Excavation and Off-Site Disposal, would provide the most effective long-term
protection of human health and the environment since contaminated material would be excavated
and disposed of at an approved off-site disposal facility.

Alternative 6, Excavation and On-Site Disposal with Off-Site Disposal of Fraction Exceeding
Waste Acceptance Criteria, would include disposal of contaminated material at an on-site,
engineered disposal facility. This disposal facility would restrict access to the contaminated
material and mitigate the potential for exposure. The disposal facility, unite capping the

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waste, would be able to collect leachate that may migrate from the waste by the liner/leachate
collection system, and monitor leaks before they reach the groundwater. The liner system would
provide additional protectiveness against future impact to the Great Miami Aquifer. In
addition, by combining all remediation waste into one disposal location, Alternative 6 also
allows increased flexibility in land use option, a reduced buffer area, and centralized
operations and maintenance. The long-term effectiveness of the facility would be ensured by
federal ownership with access restriction.

Alternative 2, Consolidation and Capping, would entail consolidation of contaminated material to
provide protection of the Great Miami Aguifer and to facilitate contruction of the capping
system. A capping system would be installed which will restrict access to the contaminated
material and mitigate the potential for exposure. A subsurface drainage system would be
constructed in the South Field area to provide extra protection to the Great Miami Aguifer.
However, none of the systems would include a composite liner with leachate collection and leak
detection layers. Continued protectiveness of the cap system would reguire long-term
maintenance of the facility and groundwater monitoring around the subunits. Federal ownership
of those areas with access restriction would be reguired to maintain the long-term effectiveness
of the remedy.

Table 8-2 summarizes the long-term impacts on the environment from the Operable Unit 2 remedial
alternatives.

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                                                                                                  TABLE  8-2

                                                             SUMMARY OF LONG-TERM AND SHORT-TERM  ENVIRONMENTAL IMPACTS FOR OPERABLE UNIT 2

                                                              Long Term


                                                                                                                       Alternative 1

                                                                                                                    No impact
Water Quality   Continued migra-
and Hydrology   tion contam-
                inants to surface
                and groundwater

Air Quality
                                         No impact
                                         No impact
                Potential  release  to     Loss  of 2  ac
                ecological  receptors     managed grassland,
                                         13.8  as introduced
                                         grassland/leased
                                         pasture and old
                                         field,  6,4  ac early/
                                         mid-successional
                                         and riparian wood-
                                         lands , c 10  ac pine
                                         plantation, and 0 . 2
                                         ac  wetlands habit
Wetland and
Floodplain
                No impact
                                        No  impact
                                                                     No impact
                                                                                           No impact
                                                                                                                    No impact
No impact

Loss of 13.8 ac
introduced
grassland/ leased
pasture and old
field 6,4, ac
early/mid-
succession al and
riparian
woodlands , and
0.2 ac wetlands
habitat
Potential loss of 0.2
0.2 ac wetlands;
no f loodplain
impact

No impact

Loss of 49 ac
introduced
receptors
pasture and old
field 8,3 ac
early/mid-
succession al and
riparian
woodlands , and
0 . 65 ac wetlands
habitat
Potential loss of
0 . 65 ac wetlands ;
no floodplain
impact

Potential release
to ambient air
Potential release
to ecological









Potential release
to wetlands and
floodplain


Fugitive dust
emissions
Habitats
disturbed









Potential for
runoff and
limited excava-
tion in wetlands
and floodplain
Fugitive dust
emissions
Habitats
disturbed









Potential for
runoff and
limited excava-
tion in wetlands
floodplain
                                                                                                                                                                    Minor  traffic  in-
                                                                                                                                                                                              Minor traffic in-
aac = acre
bCommitment of acreage is  at the  FEMP  unless  otherwise indicated.  Note that 1.0 acre = 0.4 hectares  (ha)
cImpacts to woodlands and  wetlands  from potential on-site borrow activities are not included.
dMost of the consolidated  metropolitan statistical area (CMSA)  revenue increase would occure during the  performance of the alternative (i.e., 51 months) with minimal  increase
during operation and maintenance  activities  (if reguired).
Source:   Table 5-14, Operable Unit  2  FS  Report.

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8.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment

Alternative 1, No Action, does not include treatment and would not result in a reduction of
toxicity, mobility, or volume.

However, each action alternative would include treatment of construction water at the AWWT
facility prior to monitoring and discharge to the Great Miami River. These alternative would
also include treatment of lead contaminated mixed waste and transport to an off-site disposfl
facility. Alternative 2, Consolidation and Capping, would include treatment of perched
groundwater collected in the subsurface drain from the South Field area.

Alternative 3, Excavation and Off-Site Disposal, and Alternative 6, Excavation and On-Site
Disposal with Off-Site Disposal of Fraction Exceeding Waste Acceptance Criteria, would include
crushing/shredding and dewatering/drying of selected contaminated material. For Operable Unit
2, these treatments would have an insignificant change in the total volume for disposal, no
change in the toxcicity, and little or no change in the mobility of contaminants. The need for
additional treatment to meet an off-site disposal facility's waste acceptance criteria is not
anticipated.

In total, the reduction of toxicity, mobility, or volume through treatment is considered
eguivalent for all action alternatives, because the amount of material being treated is minimal.
New treatment technologies will continue to be evaluated; if one is developed in the future that
may significantly reduce the volume, toxicity, or mobility of Operable Unit 2 remedition waste,
it will be considered for use at the FEMP site. Engineering studies will be performed on the
geochemical barriers and brick making technologies during the Remedial Design process. These
studies would be completed in a phased approach to determine (1) the effectiveness of the two
technologies, and (2) the need for additional studies. DOE would proceed with further studies
of if it is determined that the technologies are cost effective and reduce contaminant toxicity,
mobility, or volume.

8.1.5 Short-Term Effectiveness

Alternative 1, No Action, would be highly effective relative to short-term risks since there
would be no remedial activities. Therefore, there would be no additional short-term risk to
workers or the community around the FEMP site.

For Alternative 2, Consolidation and Capping, contaminated material would only be excavated to
remove it from direct contact with the Great Miami Aquifer and to facilitate placement of the
capping system at each subunit. This alternative would reset in minimal risk to site workers
and the public because much of the material remains in place at the subunits.

Alternative 6, the preferred remedial alternative, would involve removal of contaminated
material and disposal in an on-site engineered disposal facility During excavation activities
and placement of the material in the disposal facility, there would be potential exposure to the
remediation workers. This exposure potential would be managed in accordance with a Health and
Safety Plan and, therefore, is considered acceptable. Potential risks to the on-site
non-remedialon workers and to the off-site general public would be managed through application
of appropriate administrative and engineering controls, and are therefore considered minimal.

Alternatwe 3, Excavation and Off-Site Disposal, would involve removal and disposal of
contaminated/material at an off-site disposal facility. This alternative would entail
excavation and off-site transport of contaminated material. This would reset in increased
exposure to on-site workers during hanging (drying, crushing/shredding, packaging, and loading)
and the off-site public during transportation. These exposure potentials would be managed in

-------
accordance with a Health and Safety Plan, applicable transportation requirement, and applicable
appropriate administrative and engineering controls, and are, therefore, considered acceptable.

Alternative 1 would provide the best short-term effectiveness since no remedial activities would
occur.

Alternative 2 would provide slightly better short-term effectiveness than Alternative 6 became
less contaminated material is excavated, and small amounts of contaminated material is treated
and transported off-site for disposal in both alternatives. Alternative 3 would procide the
least short-term effectiveness because of the potential to expose the community to contaminated
material during transportation to an off-site disposal facility.

Table 8-2 summarizes the short-term impacts on the environment from the Operable Unit 2 remedial
alternatives.

8.1.6 Implementability

There would be no implementation required for Alternative 1 because no remedial activities would
be involved. For the remaining "action alternatives", removal and treatment of perched
groundwater at the AWWT facility would be both technically and administratively implementable.

Alternative 2, Consolidation and Capping, would be the most implementable of the action
alternatives. Consolidation of the materials would be relatively simple and the capping system
at each subunit would be readily contructable. A minimum amount of material (lead-contaminate,
soil from the Firing Range) would require off-site disposal, so no issues are anticipated that
would affect the administrative feasibility of this action.

Alternative 6, Excavation and On-Site Dispose with Off-Site Disposal of Fraction Exceeding Waste
Acceptance Criteria, the preferred alternative, would require a CERCLA ARAR waiver from the
EPA to construct an on-site disposal facility over a high-yield sole-source aquifer. The
combination of existing hydrogeology and engineering controls of the on-site disposal facility
is equivalent to the hydrogeologic requirements established by OEPA for an exemption to the
prohibition of siting a new solid waste disposal facility over a high-yield sole-source aquifer.
Therefore, this alternative would be administratively implementable, since the dispose facility
would meet the criteria for an EPA CERCLA ARAR waiver of the OEPA siting criteria based upon
achieving a standard of equivalent performance. If the fraction of remediation waste above the
waste acceptance criteria is sent to a commercial off-site disposal facility, an exemption is
anticipated to be needed from the DOE Order 5820.2A requirement that waste must go to a DOE
facility for disposal.

Alternative 3, Excavation and Off-Site Disposal, would not require the construction of caps or a
disposal facility at the FEMP, nut would require a significant quantity of contaminated material
to be disposed off-site. The off-site disposal would be subject to various local, state, and
federal requirement and would require coordination with jurisdictional agencies. Therefore,
this alternative would be administratively possible to implement, but may be time consuming.
Issues associated with transportation and public acceptance could arise. If the remediation
waste is sent to a commercial off-site disposal facility, an exemption is anticipated to be
needed from the DOE Order 5820.2A requirement that waste must go to a DOE facilities for
disposal.

Alternative 2 would be the most implementable of the "action alternatives" because reliable
technology would be used and no issues are anticipated with the administrative implementability.
Alternative 6 is considered more implementable than Alternative 3 because an EPA CERCLA ARAR
waiver from OEPA siting requirements has been discussed with the appropriate agencies and

-------
indications are that a waiver is possible, whereas transportation and public acceptance (alluded
to during the Operable Unit 4 and Operable Unit 1 public comment periods) of the transport of
contaminated material to the off-site facility affects severals states and regulatory agencies.

8.1.7 Cost

Alternative 1 would be the least costly since there would be no remedial actives. Of the
remaining alternative, Alternative 2 is the next least costly at $69,644,000 followed by
Alternative 6 at $105,950,000, with Alternative 3 as the most expense at $212,795,000 (all costs
presented as net present worth). It is important to note that for an unbiased comparison of
alternative with varying construction schedule and monitoring and maintenance cost, the cost
estimates were prepared on a net present worth basis which is basically the amount of money that
would have to be invested today, taking into consideration inflation and discount rates, to
completely pay for all construction costs for an alternative, including 30 years of monitoring
and maintenance costs following remedition.

Based on assumptions concerning field operations, the construction duration of each alternative
falls within a narrow range (i.e., plus or minus 4 months). It was, therefore, assumed that the
construction duration for each of the alternatives was the same.

8.1.8 State Acceptance

The State of Ohio has reguested that DOE agree to certain stipulations as conditions for
obtaining State concurrence on the Operable Unit 2 remedial alternative. These stipulations
are:

! No off-site waste shall be disposal of in the proposed engineered disposal facility or
any other facility on the FEMP site.
! The disposal facilitu waste acceptance criteria for uranium-238 shall be set at a
maximum of 360 pCi/g with the flexibility to be lowered based upon other operable unit
decisions and volume.
No characteristic hazardous waste shall be disposed of in the facility.
DOE shall use excavation and waste management technigues which will prevent the
dilution of waste concentrations to meet the waste acceptable criteria.

Thee issues have been addressed in the Responsiveness Summary which is part of this ROD.

The State of Nevada (i.e., Division of Environmental Quality) and State of Utah (i.e.,
Department of Environmental Quality) concur with the balanced approach being employed for the
remediation of Operable unit 2. The balanced approach to waste management is when the small
volumes of highly contaminated material from the site are sent off-site for disposal while the
larger volumes of material with lower concentrations are safely managed on site. Both states
conveyed that by taking this balanced approach, their support for waste disposal facility in
their own states receiving out-of-state waste would continue.

8.1.9 Community Acceptance

No member of the local public, including the Fernald Citizens Task Force (FCTF), prefers
contaminated materials from Fernald to be disposed of on the FEMP site. Some members of the
local community expressed absolute non-acceptance of the selected remedy. They believe for
various reasons (e.g., geology, population density, personal preference) that the implementation
of an on-site disposal facility is unacceptable. However, other stakeholders understand the
necessity of taking a balanced approach is cleanup. Those stakeholders expressed a similar
position, as is paraphrased from the FCTF March 11, 1995 recommendation:

-------
It is necessary to take a balanced approch to cleanup because if the decision was made to
send all Fernald waste and contaminated materials off site, Fernald would face the likelihood
of reprisals from other states resulting in not being any to send any waste off site. By
managing the Fernald materials fairly and effectively, DOE will be in a more eguitable
position to prevent a decision to send outside waste to Fernald.

In addition, as a result of current and foreseable budget conditions, a decision to send waste
off-site would greatly delay cleanup and may prevent any progress at all. An on-site disposal
facility is thus more viable under the current budget and political constraints. Hence, the on-
site disposal facility is the guickest way to protect the aguifer and overall environment in the
long-term, and any failure of the disposal facility would not present any immediate or
significant threat to human health and the environment. Those stakeholders also recognize
that any on-site disposal facility will be built for long-term performance using the best
design, technology, and enginering controls available (including an adeguate buffer zone and
continued federal ownership of any property containing the disposal facility, that it will be
continually monitored, and that the federal government will have adeguate procedures in place to
identify and correct any failures to the disposal facility.
Stakeholders in Nevada expressed their support for the proposed balanced approach for the

remediation of Operable Unit 2. They believe that all sites must bear the burden of sharing in
the resolution of these problems to ensure that they are not simply passed on to over location.
They also feel that it is important that possible health and safety risks to the public be
minimized by reducing the volume of waste transported off the FEMP site.

9.0 SELECTED REMEDY

Based upon consideration of the regurements of CERCLA, the detailed analysis of the alternatives
using the nine criteria and public comment; DOE and EPA have determined that Alternative 6 is
the most appropriate remedy for Operable Unit 2 at the FEMP.

Alternative 6 will be protective of the federal ownership scenario through excavation of all
waste materials and soils with COCs above the cleanup levels (presented in Section 9.2),
material processing for size reduction and moisture control if reguired, on-site disposal in an
engineered disposal facility, off-site disposal of a small fraction of the excavated material
that exceeds the waste acceptance criteria of the on-site disposal facility, and continued
federal ownership of the FEMP. The key components of the selected remedy are summarized below.

9.1 KEY COMPONENTS

The selected remedy consist of the following key components:

! Construction of the engineered on-site disposal facility. The on-site disposal
facility will be located within the limits of the potential acceptable region
shown on Figure 7-1 and will have at least a 300-foot buffer tone between the
waste and the property boundary.

The on-site disposal facility will be constructed with a composite liner of soil
and geosynthetics. The excavated material will be placed on the liner system.
The composite cap of soil and geosynthetic will be constructed above the waste and
tied-in with the liner system. Constuction will also include associated site
would and installation of monitoring wells. The composite liner and cap will be
as shown on Figure 7-2, or eguivalent. The design of the disposal facility is

-------
subject to review and approval during remedial design based on additional
investigation and the design process.

 Excavation at  the  Operable  Unit  2  subunits  to the  reguired depth established by
the RI and FS Reports to remove materials with COG concentrations above the
cleanup levels (see Section 9.2).  Excavation will be performed in such a way as
to minimize possible dilution of waste and the concept of ALKRA will be documented
in the Remedial Action Work Plan and implemented during construction.

 Verification sampling and testing  in the excavated area  to confirm that  material
with COG concentration above the cleanup levels has been removed.  If the results
of the verification sampling and testing indicate that contamination above cleanup
levels remains, then additional excavation and verification sampling and testing
will be performed until acceptable results the obtained.

 Segregation of debris (e.g.,  concrete,  steel,  pallets, etc.)  from Operable  Unit 2
subunits and processing for size reduction,  if reguired,  before disposal in the
on-site disposal.

 Collection and treatment  of the  construction  water from  the Operable Unit  2
subunits and disposal facility construction areas.

 Establishment  of maximum  waste acceptance criteria for the on-site disposal of
Operable Unit 2 materials.  Operable Unit 2  material with concentration at or
below 346 pCi/g of uranium-238 or 1,030 ppm of total uranium will be accepted at
the on-site disposal facility.
 Transportation and on-site  transportation of  excavated material  with a
concentration a or below 346 pCi/g of uranium-238, or 1,030 ppm of total uranium.

 Transportation and off-site trasposal  of approximately 3,100  cubic yards  of
material with a concentration of uranium-238 above 346 pCi/g,  or of total uranium
above 1,030 ppm.

 Excavation,  treatment,  and  off-site  disposal  of approximately 300  cubic yads  of
lead-containing soft from the South Field Firing Range that will be handed as
mixed waste.

 Restoration of Operable Unit 2  subunits  after excavation and  verification
sampling and testing.  Restoration of the Operable Unit 2 subunits will include
grading of the subunits to blend with the surrounding topography, seeding,
seeding, and the installation of monitoring wells.

 Institutional  controls  such as  access  retrictions (fencing) and  groundwater
monitoring a the Operable Unit 2 subunits and on-site diposal facility.
Monitoring will continue for at least 30 years following closure of the on-site
disposal facility.  Continued federal ownership of the FEMP is also a key
component of the selected remedy.

 Maintenance of the Operable Unit 2 subunits after restoration and  maintenance of
the on-site disposal facility, including the capping system and leachate
collection system. Because this remedy will result in contaminants remaining on
site in an engineered disposal facility,  a review will be conducted no less often

-------
than every five years after the initiation of remedial action with accordance with
CERCLA §121(c) to ensure that the remedy continue to provide adequate protection
of human health and the environment. This renew will continue until determined
that it is no longer needed to maintain protectiveness of the disposal facility.

The net present worth cost for the selected remedy based on a construction duration of 51 months
and 30 years for operation and maintenance (O&M) after remediation is $105.9 million. This net
present worth cost includes $85.9 million for construction and $20.0 million for O&M after
remediation.

These cost estimates the based on conservative estimates of waste volume. The on-site disposal
facility will be constructed in phase to accommodate only that waste which generated.

Figure 7-1 depicts the proposed feasible location of the on-site disposal facility. Based on a
series of soil borings made in the area, the geology of the disposal facility location
identified in the figure in combination with the engineering controls will be protective of
human health and the environment.

However, the disposal facility location is subject to review and approval during the remedial
design phase. DOE intends to construct only one disposal faculty at the FEMP. Should on-site
disposal be selected for other FEMP operable units, the disposal facility capacity and
configuration would be adjusted accordingly during the remedial design process to accommodate
other FEMP operable unit remediation wastes (that meet the established waste acceptance
criteria). DOE will not dispose of any off-site waste in this on-site disposal facility.

9.2 CLEANUP LEVELS

The goals for protecting human health and the environment depend on the contaminated media and
the exposure pathways. The exposure pathways are dependent on the future land use designated
for the FEMP site. The two land-use scenarios considered in the FS are continuing federal
ownership of the FEMP (with restricted access) and the site being used by a farmer with no use
limitations. These scenarios represent two extremes of land use; future land use may be similar
to either one of these scenarios or may fail between these two scenarios. Corresponding soil
cleanup levels have been determined to meet the acceptable risk range (1 x 10-4 to 1 x 10-6 and
a HI = 0.2). If found to be necessary, the Operable Unit 5 ROD will modify the Operable Unit 2
cleanup levels downward to ensue protectiveness of human health and the environment.

The cleanup levels for the selected alternative were developed to protect the expanded
trespasser under a future land-use scenario of continued federal ownership. A multi-step
process was followed to develop the Operable Unit 2 cleanup levels, which were called
Preliminary Remediation Levels (PRLs) in the FS/PP. The first step of the process was to
develop risk-based Preliminary Remediation Goals (PRCs), which are cleanup levels based on
results of the Baseline Risk Assessment that are protective of human health. Risk-based PRGs
were then modified based on a number of factors including access controls, such as fencing to
keep intruders out, and proposed engineering controls.

The Operable Unit 2 cleanup levels have been divided into primary and secondary cleanup levels,
which are presented in Table 9-1 and Table 9-2, respectively. The COCs for the primary cleanup
levels contribute over 90 percent of the risk from Operable Unit 2 and over 99 percent of the
volumes

-------
                                                            TABLE 9-1

                                           OPERABLE UNIT 2 PRIMARY SOIL CLEANUP LEVELS
                                                    FOR THE SELECTED ALTERNATIVE
Contaminant of Concern  (COG)
Units
             Backgrounda    Cleanup Levelb

                 ALL SUBUNITS
Basis for Cleanup Level
Radium-226
Radium-228
Thorium-228
Thorium-232
Uranium-234g
Uranium-235/236g
Uranium-238
Uranium-Total
Uranium-234g
Uranium-235/236g
Uranium-238
Uranium-Total
pCi/g
pCi/g
pCi/g
pCi/g
1.42
1.25
1.43
1.36
1.8
2.0
1.8
1.5
                                                      SOLID WASTE LANDFILL
pCi/g
pCi/g
pCi/g
mg/kg
1.04
0.15
1.22
3.4
62.9
63.1
12. 9d
38.6
                                                        LIME SLUDGE POND
pCi/g
pCi/g
pCi/g
mg/kg
1.04
0.15
1.22
3.4
196
195
45.3d
136
                                                   10-6 ILCRc
                                                   10-6 ILCR
                                                   10-6 ILCR
                                                   10-6 ILCR
                                                   10-6 ILCR
                                                   10-6 ILCR
                                                    ARARe,f
                                                     ARARf
                                                   10-6 ILCR
                                                   10-6 ILCR
                                                     ARARf
                                                     ARARf
                                   INACTIVE FLYASH PILE  (WASTE/SOIL OVER THE GREAT MIAMI AQUIFER)
Arsernic
Uranium-234g
Uranium-235/236g
Uranium-438g
Uranium-Totalg
mg/kg
pCi/g
pCi/g
pCi/g
mg/kg
8.2
1.04
0.15
1.12
3.4
16.9
8.68
7.79
6.12
24.8
                                                   10-6 ILCR
                                                   10-6 ILCR
                                                   10-6 ILCR
                                                   10-6 ILCR
                                                     ARARf

-------
Contaminant of Concern  (COG)
Units
    TABLE 9-1
   (Continued)

Backgrounda
                             Cleanup  Levelb
                  Basis for Cleanup Level
                             INACTIVE FLYASH PILE  (WASTE/SOIL LOCATED OVER > 16 FEET NATURAL SOIL)
Arsenic
Uranium-434g
Uranium-235/236g
Uranium-238g
Urraniurn-Totalg
       ing/kg
       pCi/g
       pCi/g
       pCi/g
       ing/kg
         8.2
         1.04
         0.15
         1.12
         3.4
  16.9
  4.24
  3.35
  3.22
  24.8
10-6 ILCR
10-6 ILCR
10-6 ILCR
10-6 ILCR
  ARARf
                              SOUTH FIELD  (WASTE/SOIL LOCATED OVER THE GREAT MIAMI AQUIFER)
Leadh
Thorium-230g
Uranium-234g
Uranium-235/236g
Uranium-238g
Uranium-Totalg

See footnotes at end of table.
       ing/kg
       pCi/g
       pCi/g
       pCi/g
       pCi/g
       ing/kg
                                                          26.4
            97
            04
          0.15
          1.12
          3.4
  400
  6.97
  8.68
  7.79
  6.12
  24.8
  ARARi
  ARARj
10-6 ILCR
10-6 ILCR
10-6 ILCR
  ARARf
                         SOUTH FIELD  (WASTE/SOIL LOCATED OVER > 16 FEET NATURAL SOIL)
Thorium-230g
Uranium-234g
Uranium-235/236g
Uranium-238g
Uranium-Totalg
pCi/g           1.97
pCi/g           1.04
pCi/g           0.15
pCi/g           1.12
mg/kg           3.4
                       6.97
                       4.24
                       3.35
                       3.22
                           ARARj
                         10-6 ILCR
                         10-6 ILCR
                         10-6 ILCR
                           ARARf
                                               ACTIVE FLYASH PILE
Arsenic
Uranium-234g
Uranium-235/236g
Uranium-238g
Uranium-Totalg
mg/kg
pCi/g
pCi/g
pCi/g
mg/kg
    8.2
    1.04
    0.15
    1.12
    3.4
16.9
8.64
7.75
6.12
 28
    10-6 ILCR
    10-6 ILCR
    10-6 ILCR
    10-6 ILCR
      ARARf

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aBackground value from Operable Unit 2 RI Report, Table 4-1A, surface concentrations.
bThe cleanup level is the lowest value of the 10-6 ILCR, 0.2 Harzard Index, or ARAR standard.
cILCR = incremental lifetime cancer risk.  In the case of radionuclide, the cleaaup level is the concentration
responsible for the incremental risk plus the background concentration.
dThis value determined by calculating the uranium-238 concentration in uranium-total.
eARAR = applicable or relevant and appropriate reguirement
fBased on the proposed MCL for uranium (56 Federal Register 33050).
gCleanup revel due to off-property resident farmer receptor
hThe lead cleanup level applies to the Firing Range only, not the entire South Find area.
iBased on the EPA "Revised Interim Soft Lead Guidance for CERCLA Sites and RCRA Corrective Action
Facilities  (OSWER Directlye 9355.4-1-12).
JBased on DOE Order 5400.5, Chapter IV (4)(a)(2).

Source:  Table 2-23, Operable Unit 2 FS Report.

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                             OPERABLE UNIT 2 SECONDARY  SOIL  CLEANUP LEVELS
                                     FOR THE SELECTED ALTERNATIVE

Contaminant of Concern  (COC)         Units       Backgrounda      Cleanup  Levelb

                     SOUTH FIELD (WASTE/SOIL LOCATED OVER  THE  GREAT MIAMI AQUIFER)
Aroclor-1260c
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthenec
Benzo(k)fluoranthene
Dibenzo(a,h)anthracenec
Dieldrin
Indeno(l,2,3-cd)pyrenee
Phenanthrene
Technetium-99
Thorium-230c
   2 5
 0.455
 0.777
 0.513
 0.603
 0.157
0.00957
 0.496
 0.19
  71
 6. 97
                       SOUTH FIELD (WASTE/SOIL LOCATED  OVER  >  16 FEET NATURAL SOIL)
Aroclor-1260c
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(a)fluoranthenec
Benzo(a)fluoranthene
Dibenzo(a,h)anthracenec
Dieldrin
Indeno(l,2,3-cd)pyrenee
Phenanthrene
Technetium-99
Thorium-230c
10-6 ILCRd
  ARARe, f
   ARARf
   ARARf
   ARARf
   ARARf
   ARARf
   ARARf
   ARARf
10-6 ILCR
   ARARg
                        10-6  ILCR
                          ARARf
                          ARARf
                          ARARf
                          ARARf
                          ARARf
                          ARARf
                          ARARf
                          ARARf
                        10-6  ILCR
                          ARARg
                                          ACTIVE FLYASH  PILE

aBackground value  from Operable unit 2 RI Report, Table 4-1A,  surface concentration.
bThe cleanup level  is  the  lowest value of the 10-6 ILCR,  0.2  Hazard Index, or ARAR standard.
CCleanup level due  to  off-property resident farmer receptor.
dILCR = incremental lifetime cancer risk.  In the case  of radionuclides,  the cleanup level is  the  contentration
responsible for  the incremental risk plus the background concentration.
eARAR = applicable  or  relevant and appropriate requirement
fBased on the Ohio  Water Quality Standard  (OAC 3745-107)
gBased on DOE Order 5400.5,  Chapter IV (4)(a)(2).

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to be excavated under the selected alternative. The COCs for the secondary cleanup levels pose
risks that are dose to the 10-6 point of departure and contribute a small percentage to the
overall risk from Operable unit 2. Based on existing analyical results from the RI and the
volume calculations from the FS, secondary cleanup levels will most likely be achieved by
remediation to the primary levels, however, will be confirmed through post-remediation sampling.

10.0 STATUTORY DETERMINATIONS

In accordance with the statutory reguirements of Section 121 of CERCLA, as amended, remedial
action taken pursuant to Section 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 solution 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 s
substances, pollutants, or contaminants.

In addition, CERCLA §121(c) 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 action for Operable Unit 2 satisfies these 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 removing the sources of contamination and disposing of the excavated material in
an engineered on-site disposal facility and a fraction of material at an off-site disposal
facility. The on-site disposal facility will utilize engineering design features to prevent
human and ecological contact with the contaminated material. The facility will also be designed
so that based on current EPA standards and modeling/risk assessment methodologies, it will not
pose unacceptable impacts to the Great Miami Aguifer. Baseline cancer risks from current
conditions exceed the 10-6 to 10-6 acceptable risk range established by EPA in the NCP. Under
the future land use scenario of commued federal ownership, the residual cancer risk associated
with Operate unit 2 will be reduced to 2.5 x 10-6 which is within the acceptable target risk
range. Non-carcinogenic hazards will be reduced to 2.0 x 10-2 which is less than the EPA
standard of 1.0.

10.2 COMPLIANCE WITH ARARs

Compliance with the chemical-, action-, and location-specific ARARs is discussed below.
Detailed discussion of the principal ARARs and TBCs is presented in Section 7.5. The complete
list of applicable reguirements, relevant and appropriate reguirements, and TBCs is presented in
Appendix A.

10.2.1 Chemical-Specific ARARs/TBCs

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Alternative 6 will comply with the chemical-specific ARARs/TBCs discussed in Section 7.5.2 and
identified in Table A-l of Appendix A. ARARs associated with penetrating radiation and
potential releases of contaminants to air, surface water, and groundwater will be met through
the removal of all contaminated material above cleanup levels from Operable Unit 2. Most of
this material will be disposed at an on-site disposal facility. Operable Unit 2 remediation
waste that does not meet the on-site waste acceptance criteria will be sent to an approved
off-site disposal facility.

The engineering controls and institutional actions described earlier for the on-site disposal
facility were established for the protection of human health and will ensure that the
groundwater MCLs and non-zero MCLGs will be met at the boundary of the disposal facility and at
each Operable Unit 2 subunit. Ohio Water Quality Standards will be met at both Paddys Run and
the Great Miami River.

Air emission and radon protection standards will also be met above the on-site disposal facility
and each subunits.

Although ARARs are not pertinent to the no action alternative, the FS compared the fate and
transport modeling results for the No Action Alternative (Alternative 1) to the
chemical-specific ARARs in order to establish a baseline against which the "action alternatives"
could be compared to demonstrate compliance. The South Find was the only subunit that would
exceed the surface water ARARs for the No Action Alternative. Under Alternative 6, the selected
remedial alternative, the concentration of dieldrin and polynuclear aromatic hydrocarbons (PAHs)
at Paddys Run will be egual to the ARAR standards of 7.6 x 10-4 microgram/liter (•xg/L) and
0.31 (• g/L, respectively. The concentrations at the Great Miami River will be 9.8 x 10-7 • g/L
for dieldrin (below the 7.6 x 10-4 • g/L standard) and 4.1 x 10-4 • g/L for PAHs below the 0.31
• g/L standard). Thee concentrations are for the expanded trespasser scenario, which will have
higher soil cleanup levels than the on-property resident farmer scenario. Therefore, since the
expanded trespasser scenario will meet the ARAR standards, the on-property farmer scenario will
meet them also.

Table 10-1 illustrates that on-site disposal also brings Operable Unit 2 into compliance with
the proposed groundwater MCL for uranium, which would not be met under the No Action
Alternative.

The maximum groundwater concentration is presented in the table (underneath subunit); therefore,
the points of compliance, which are at the boundaries of the subunit and the on-site disposal
facility, will also comply with the proposed uranium MCL. Treated construction water will meet
the Ohio Water Quality Standards found in Table A-l of Appendix A.

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                                              TABLE 10-1

                      COMPLIANCE WITH OPERABLE UNIT 2 CHEMICAL-SPECIFIG ARARs

                                             ALTERNATIVE 6
                            MAXIMUM CROSS-MEDIA GROUNDWATER CONCENTRATIONSa
COG



Total
Uranium
ARAR
Standard


20 «g/L

Point of
Compliance

Under Subunit

FEMP Fenceline
Solid
Waste
Landfill
18 • g/L

0.7 «g/L
Lime
Sludge
Ponds
3.2 «g/L

0.1 «g/L
Inactive Flyash
Pile/South
Field
18.4 • g/L

2.2 'g/L
Active
Flyash Pile

10.7 • g/L

1.5 'g/L
On-Site
Disposal
Facility
20 • g/L

2.1 «g/L
a These concentrations are for the expanded trespasser scenario, which will have higher soil cleanup levels  than  the  on-
property resident farmer.  Therefore, since the expanded trespasser scenario will meet the ARAR standards, the on-property
resident farmer scenario will meet them also.  The groundwater modeling procedures and the results are presented  in detail  in
the FS Report, Appendix D.
b Proposed MCL (56 Federal Register 33050)

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10.2.2 Action-Specific ARARs/TBCs

Alternative 6 will meet the principal action-specific ARARs/TBCs discussed in Section 7.5.3 and
listed in Tables A-2, A-3, and A-4 of Appendix A. Because Operable Unit 2 includes both
low-level radioactive waste/residual radioactive material and solid waste, design and
construction of the on-site disposal facility will meet the more stringent reguirements for the
disposal of low-level radioactive waste/residual radioactive material. EPA states in 40 CFR
§192.02(a) that the disposal facility must be designed to be effective for up to 1,000 years, to
the extent reasonable achievable, and in any case. for at least 200 years. DOE Order 5820.2A
reguires compliance with performance objectives for low-level radioactive waste dosposal sites,
including protection of public health and safety, protection of the public and the environment
from releases of radioactivity, and protection of groundwater resources. DOE Order 5400.5
reguires that the As Low As Reasonably Achievable (ALARA) policy to minimize radiation exposure
be adopted during design and construction.

The on-site disposal facility will also meet the less stringent OEPA technical reguirements for
the disposal of solid waste. These reguirements include specifications for the design and
construction of a liner and cap system for the on-site disposal facility. Material with
contaminant levels that are below the cleanup levels will be left in place.

Material from the South Field Firing Range is assumed is be mixed waste and will be treated and
shaped to an off-site disposal facility that is approved to accept mixed waste. Firing Range
material that is hazardous waste must comply with the storage, packaging, and transportation
reguirements of the Resource, Conservation, and Recovery Act (RCRA), including the manifest
system, while it is being prepared and shipped from the FEMP. Packaging and transportation of
the Firing Range wastes will also be reguired to meet DOE regurements for the transport of
hazardous materials.

Firing Range material that is not a hazardous waste, but contains COCs above the clearup levels,
will be disposed of on-site with the rest of the South Field low-level radioactive
waste/residual radioactive material.

10.2.3 Location-Specific ARARs/FBCs

Alternative 6 will not meet all the location-specific ARARs/TBCs discussed in Section 7.5.4 or
in Table A-5 of Appendix A. Because the on-site disposal facility will contain solid waste in
addition to low-level radiative waste/residual radioactive material, the following OEPA siting
criteria from the Ohio Solid Waste Disposal Regulations are pertinent ARARs. OAC 3745-27-07 and
-20 list the following areas where a solid waste disposal facility may not be located:

! in surface and subsurface areas surrounding a pubic water supply well through
which contaminants may move toward and may reach the public water supply well
within a period of five years;

! above an aguifer declared by the Federal government under the Safe Drinking Water
Act to be a sole source aguifer;

! above an unconsolidated aguifer capable of sustaining a yield of 100 gallons per
minute for a 24-hour period to an existing or future water supply well located
within 1,000 feet of the limits of soils waste placement;

! in a regulatory floodplain;

! within 1,000 feet of an existing water supply well or developed spring;

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! within 300 feet of the facility's property line;

! within 1,000 feet of an existing residence whose owner has not conscented in
writing to the location of the facility;

! within 200 feet of a stream, lake, or wetland;

! the isolation distance between the uppermost aguifer system and the bottom of the
recompacted soil liner of the disposal facility cannot be less than 15 feet of in
situ or added geologic material.

The proposed feasible location of the on-site disposal facility is on the eastern side of the
FEMP which is not in a floodplain; near a stream, lake, or wetland; within 1,000 feet of an
existing water supply well or developed spring; near enough to an existing public water supply
well so that contaminants may reach the wall within a period of 5 years. The facility will not
be placed within 300 feet of the FEMP property line or within 1,000 feet of an existing
residential house. The isolation distance between the uppermost aguifer system and the bottom
of the recompacted soil liner well be greater than 15 feet.

The remaining two siting criteria (bullets two and three) cannot be met because of the FEMP's
location over a sole-source aguifer that is capable of sustaininng a yield of 100 gallons per
minute for a 24-hour period. OEPA has established two specific policy (GD202.101 and GD202.102)
that identify condition that would be acceptable to allow an exemption to the siting criteria.
While these policies state that several factors will be considered in evluating an exemption,
the specific factors identified indicate that the protection of human health and the environment
shoed be provided study by the existing hydrogeologic conditions. This has been reaffirmed by
OEPA in several meetings.

The primary hydrogeologic standards established by these policies the:

! Significant thickness of low permeable material between the disposal facility and
the aguifer

! Lack of inter-action between the sole-source aguifer and any significant zones of
saturation

It has been determined, based on existing hydrogeologic information, that the existing
hydrogeologic condition at the FEMP do not fully meet the conditions. This is based on the
possibility that some granular soils are interbedded in the till and the need to protect the
aguifer for significantly longer than 30 years (at least for 200 years; an ARAR under 40 CFR
192) .

Because the aguifer underlies the entire site, a waiver was reguested to locate an on-site
disposal facility on the FEMP. The waiver reguest was based on the ability of the selected
remedial action, through the use of another method or approach, to attain a standard of
performance that is eguivalent to that reguired by the ARARs. The criteria in determining a
CERCLA ARAR waiver based on an eguivalent standard of performance [40 CFR 300.430
(f) (1) (ii) (c) (4)] are: degree of protection, level of performance, reliability into the future,

-------
and time required for results. Additional information on the OEPA requirements is presented m
Section 7.5.4.

The preamble to the NCP states that the purpose of this waiver is for the the of alternative but
equivalent technoloqies and comparison based on risk is only permitted where the oriqinal
standard is risk-based. The Ohio exemption guidance, with its focus on qeoloqical conditions,
is for the most part analoqous to a technology standard but also appears to be, with respect to
level of performance, risk and technology based. Therefore the following analysis of the CERCLA
waiver criteria uses a technology-based comparison, except for level of performance, which is a
risk-based comparison.

The circumstances of the selected alterative are considered equivalent to the OEPA requirments
and thereby warrant the granting of a CERCLA ARAR waiver. The basis for equivalency is
identified for each of the identified criteria:

Degree of protection:

! OEPA Standard

The justification to allow a solid waste landfill over a high-yield sole-source aquifer is that
the existing hydrogeology with provide adequate protection to the high-yield sole source
aquifer from the effective of a release of leachate and thereby protect the aquifer from
contamination. The approach spelled out by the pertinent policies is to prevent leachate
from reaching the aquifer during the active life of the landfill and the post closure period of
30 years. The active life of the disposal facility for Operable Unit 2 waste is estimated to be
4.25 years. It should be noted that if future operable unit decisions direct disposal of other
waste in the on-site disposal facility, the maximum active life could be approximately 20 years.

! Equivalent Standard

The combination of engineering control and existing hydrogeology proposed in this alternative
will provide the same degree of protection to the aquifer as the hydrogeologic conditions
described in the OEPA policy alone. Modeling with the combined controls shows that the leachate
will not reach the aquifer during the active life of the landfill and a post closure period of
thirty years.

It should be noted that the modeling performed in the Operable Unit 2 FS Report (Appendix D.I)
was performed for 1000 years and assumed that the liner system and man-made materials (e.g.,
leachate collection, leak detection, and synthetic liners) of the disposal facility would fail.
This modeling showed that with the enhanced cap to reduce infiltration and the exiting
hydrogelogy, leachate that may eventually reach the aquifer would not came the costituent
concentration in the aquifer to exceed the promulgated and proposed MCLs.

Level of performance (method based):

! OEPA Standard

Significant thickness of low permeable material between the disposal facility and the aquifer

! Equivalent Standard

Modeling has shown that the combination of 12 feet of gray clay with a minimum kd of 3.1 and a
maximum waste acceptance criteria of 346 pCi/g of uranium-238, or 1,030 ppm total uranium, will
not exceed the proposed MCL for total uranium a the boundary of the disposal facility or a

-------
concentration level based on the 10-6 ILCR at the boundary of the FEMP. Only the layers in the
engineered cap and the gray clay and unsaturated Great Miami Aguifer hydrogeologic layers were
used in this modeling. The liner system and brown clay will increase the protection of the
aguifer.

! OEPA Standard

Lack of inter-connection between the sole source aguifer and any significant zones of
saturation

! Eguivalent Standard

Any inter-connection will be minimized by:

1) locating the disposal facility in an area with the greatest thickness of gray clay
and the least occurrence of interbedded granular material; and

2) providing an increase in the engineered controls to compensate for any reduction of
protection due to interbedded granular material; and/or
3) providing engineering control of lateral movement of water in an area of
interbedded granular material by removal the granular material affecting the
geologic protection of the for or by preventing the movement of water from the
areas to the aguifer.

! OEPA Standard

Significant amount of sediment [soil] must exist between the disposal facility aand the high-
yield aguifer to prevent leachate from migrating to the high andd aguifer during the life of
the landfill and the post-closure care period: The post-closure care period for a solid waste
landfill is a minimum of 30 years [OAC 3745-27-14 (A) ] .

! Eguivalent Standard

At a minimum, a total of four additional layers will be added to the standard solid waste cap
and liner [OAC 3745-27-08 (C)]. These layers are a sand filter, biotic barrier and bentonite
composite layers in the cap to reduce infiltration aand to protect the intergrity of the cap. A
leak detection layer will be provide in the liner to monitor the integrity of the containment
system and to provide early warning to allow corrective action prior to any adverse impact to
the aguifer. These additional engineering controls together with the natural hydrogeology will
prevent leachate from reaching the aguifer during the post-closure care period.

Level of performance (risk based):

! OEPA Standard

ORC 3734.02(G) allows exemptions of OEPA regulations if an alternative is unlikely to
adversely affect the pubic health or safety or the environment. The pertinent policies mirror
this reguirement using an approach which reguires existing hydrogeologic conditions to provide
this protection.

OEPA does not propose a specific definition for the protection of human health and the
environment. However, OAC 3745-27-10 (F) (7) (a)-(d), which specifies solid waste landfill

-------
operating requirements, sets forth concentration levels for constituents detected in the
groundwater for which a corrective action is required.  This standard provides an appropriate
framework for risk analysis in this case became the waiver concerns the establishment of a
solid waste disposal unit.  These levels the concentrations that the a a statistically
significant level to be:

            protective of human health and the environment; and

            the promulgated MCL; or

            background concentration for contituents that do not have a promulagted MCL; or

            the alternative groundwater protection standard for a known or suspected carcinogen,
            concentration levels that represent a cumulative excess upper-bound lifetime cancer
            risk to an individual within the 1 x 10-4 to 1 x 10-6 range.

 !         Equivalent  Standard

This same definition has been used as a threshold criteria in evaluating alternatives in the
CERCIA decision making process making the FEMP and specifically in the Operable Unit 2 FS with
the addition that constituents in groundwater should not be higher than the proposed MCLs.   This
alternative meets this threshold criteria.

Protection of human health has been determined through the risk assessment process based on
contaminant transport modeling and the NCP acceptable ILCR range of 1x10-4 and 1x10-6 and in
compliance with promulaged and proposed MCLs.


Reliability into the future:

The combination of hydrogeologic and engineering controls  (including additional controls
beyond the requirements for a solid waste disposal facility) provides increased reliability into
the future because of the following:

              !    The biotic barrier in the  cap  will  prevent burrowing animals  or  vegetative
                 roots from compromising the integrity of the cap and thereby increasing the
                 infiltration.

              !    Leak detection monitoring  will provide  an early warning of  any problem in
                 leachate containment and allow corrective measures to be undertaken prior to
                 adverse impact to the aquifer.

Time required for results:

Construction of a disposal facility-with additional engineering control will not take
significantly longer than the time required for a disposal facility which strictly meets the
Ohio Solid Waste Disposal Regulations.
A CERCLA ARAR waiver of the OEPA prohibition of siting a disposal factory over a high-yield
sole-source aquifer is justified based on an equivalent standard of performance [40 CFR 300.430
(f)(1)(ii)(C)]  to the OEPA policies allowing an exemption to the siting requirements.  This
waiver is applicable only to Operable Unit 2 on-site remediation waste.  If on-site disposal is
chosen as the selected remedy for other FEMP operable units, separate waivers from this Ohio

-------
requirement would be necessary.

The disposal facility location and design with be subject to review and approval during the
remedial design phase. DOE intends to construct only one disposal facility at the FEMP.
Therefore, should on-site disposal be selected for other Fernald operable units, the disposal
facility capacity and location would be adjusted accordingly during the remedial design process.

There is a 0.2 acre area of wetlands located to the north of the Solid Waste Landfill that will
be adversely impacted during the removal of contaminated material. Operable Unit 2 will comply
with the substantive permitting requirement for impacts to wetlands under the Clean Water Act
(33 CFR §§ 323-330) . Compensatory initiation for wetlands impacted by Operable Unit 2 actives
will be determined using 404 (b) (1) [33 United States Code (U.S.C.) §1344(b) (1) ] guidelines of
the Clean Water Act in consultation with the U.S. Army Corp of Engineers, EPA, and OEPA. The
Inactive Flyash Pile and a portion of the South and the located in the 100-year floodplain of
Paddys Run.

Under this alternative, no adverse impacts to the floodplain are expired.

10.3 COST EFFECTIVENESS

The selected remedy is cost-effective because it has been determined to provide overall
effectiveness proportional to its cost, the net present worth value being $105.09 million. The
estimated cost of on-site disposal is $36.3 million more than consolidation and capping and will
provide greater long-term effectiveness and permanence than consolidation and capping through
the use of an engineered disposal facility with liners and leachate detection and collection
devices. While the selected remedy effectively reduces the hazards posed by all the
contaminants of concern in Operable Unit 2, its cost is about one half of the cost of excavation
and off-site disposal of contaminated material.

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

EPA and the State of Ohio have determined that the selected remedy for Operable Unit 2
represents the maximum extent to which permanent solutions and treatment technologies can be
utilized in a cost-effective manner for Operable Unit 2. Of those alternatives that the
protective of human health and the environment and comply with ARARs, 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, also considering State and community
acceptance.

Which the selected remedy does not offer as high a degree of long-term effectiveness and
permanence as the off-site disposal alternative, it will significantly reduce the risks from the
contaminated material through excavation and placement in an engineered on-site disposal
facility. By combining all the remediation waste into one disposal location, it can be managed
more effectively over the long-term.

The selected remedy also allows increased flexibility in land use options, a reduced the of
buffer area, and centralized operations and maintenance.

The selected remedy does not provide a significant reduction of toxicity, mobility, or volume
through treatment. Treatment of leachate and intruction water will take place at the on-site
AWWT facility and land-contaminated mixed waste from the South andd Firing Range will be treated

-------
before being transported to an on-site disposal facility. Except for the no action alternative,
each alternative includes the same amount of treatment.

The selected remedy provides adequate short-term effectiveness and is readily implementable.
Because the majority of the waste material will remain on site during remediation, there is very
little opportunity for public exposure to the contaminants. The exposure potential to
remediation workers will be managed in accordance with a health and safety plan and is,
therefore, considered acceptable.

The on-site disposal alternative is considered to provide more short-term effectiveness and is
more implementable than off-site disposal, but slightly less implementable than consolidation
and containment. The selected remedy costs slightly more than consolidation and containment and
is half the cost of off-site disposal.

The major tradeoffs that provide the basis for the selection of on-site disposal with off-site
disposal of the fraction exceeding the waste acceptance criteria the long-form effectiveness and
cost. The selected remedy provides the most reliable method of managing and monitoring the
disposal of Operable Unit 2 contaminated material for the least cost. For this reason,
Altarnative 6 is determined to be the most appropriate remedy for the contaminated material from
Operable Unit 2.

10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT

The selected remedy does not satisfy the statutory preference for theatment as a principle
element.

The NCP states in 40 CFR §300.430(a) (iii) (A) and (B) that "EPA expects to use treatment to
address the principal threats posed by a site" and "to use engineering controls, such as
containment, for waste that poses a relatively low long-term threat." Operable Unit 2 waste the
considered in pose a low long-term threat in all subunits except a portion of the waste in the
Inactive Flyash Pile and South Field. This waste is considered a principal threat due to the
placement of the waste and the vulnerable hydrogeology (sole-source Great Miami Aguifer) located
underneath, not due to the concentrations or types of contamination. When this waste is
excavated during the implementation of the selected remedy, it will no longer be a principal
threat to the site, and, under the NCP, is not expected to undergo treatment.

10.6 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES

Natural resources at the FEMP site will be disturbed by construction and excavation activities.
Many impacts will be temporary, pending completion of remedial activities. The implementation
of the Operable Unit 2 remedy will disturb 75 acres of FEMP soils including areas of riparian,
aguatic and managed grassland habitats. All areas imputed by excavation activities will be
regraded to the surrounding grade and revegetated. However, implementation of the remedy well
also reset in permanent commitments.

Implementation of the selected remedy with result in the commitment of 49 acres introduced
grassland/leased pasture habitat, 8.3 acres early/mid-successional and riparian woodland
habitat, and 0.65 acres drainage-ditch wetland habitat. Longterm impacts will also occur from
the implementation of an on-property borrow area. If this area is selected for borrow,
approximately 17acres of woodlands and associated species will be committed. In addition, 3.0
acres of swale/forested wetland and associated habitat could also be committed as a result of
on-site borrow activity.

The introduced grassland/leased pasture areas are general inhabited by small mammals and several

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specks of birds. Early/mid-successional and riparian woodlands are dominated by white ash
(Fraxinus americana) and American elm (Ulmus americana). Typical pioneer successional species
such as Japanese honeysuckle (Lonicera japonica), blackberry (Rubus sp.), and multiflora rose
(Rosa multiflora) are also present. Habitat exist in the riparian areas for the
Federally-listed endangered Indiana bat (Myotis sodalis).

Several taxa are primarily found only in the riparian area. Two of the most common taxa include
the belted kingfisher (Megaceryle alcyon) and blue jay (Cyanocitta cristata). Based on
incidental observations, Facemire et al, (1990) also reported typical woodland amphibians and
reptiles such as the eastern box turtle (Terrapene Carolina), spring peeper (Hyla crucifer), and
American toad (Bufo americanus). Common bats in the riparian area including the using brown bat
(Eptesicus fuscus), red bat (Lasiurus borealis), and the little brown bat (Myotis lucifugus).

Aguatic habitats to be disturbed include wetlands, Paddys Run, and the Storm Sewer Outfall
Ditch.

On-property drainage ditch/swales support shrub and/or emergent vegetation. Broad-leaf cattail
(Typha latifolia) is the most common species. Numerous woody species in swales include black
willow (Salix nigra), roughleaf dogwood, and American elm. Surveys found state-listed
threatened Sloan's crayfish (Orconectes sloanii) residing in Paddys Run (St. John 1993 and
1994). Paddys Run also supports a diverse community of macroinvertebrates and fish. Habitat in
the Storm Sewer Outfall Ditch is minimal, as the ditch is dry most of the year.

The 100- and 500-year floodplain of Paddys Run will be directly and indirectly impacted as a
result of remedial activities. Limited excavation in the floodplain will occur during remedial
activities at the flyash piles and South Field; however, changes in flood elevation are not be
expected. Engineering controls will be implemented to minimize indirect impacts (i.e., runoff
and sedimentation). Activities performed in the Storm Sewer Outfall Ditch will be in accordance
with 404 guidelines of the Clean Water Act. A Floodplain/Wetland Assessment was completed and
is provided in Appendix H to the Operable Unit 2 FS Report.

Additionally, consumptive use of geologic resources (e.g., guarried rock, sand, and gravel) and
petroleum products (e.g., diesal fuel and gasoline) will be reguired for removal, construction,
and disposal activities. Supplies of these materials will be provided by the construction
contractor.

Additional fuel use will result from limited off-site transport of the materials. Adeguate
supplies will be available without affecting local reguirements for these products. The
treatment processes for the remedial action alternative will reguire the consumptive use of
materials and energy. The stabilization process will reguire additives such as flyash and lime
sludge, which the readily available at the FEMP site.

Approximately 35 acres of the FEMP site, including a 300-foot buffer zone, will be restricted
for future use under the Operable Unit 2 selected remedial alternative. The committed land will
be actively monitored and maintained. Periodic monitoring of surface water and groundwater at
the disposal facility will be performed, and periodic site inspections will identify any damage
to the disposal facility. Maintenance activities will be performed, as necessary. The off-site
facility (for remediation waste exceeding the on-site waste acceptance criteria) is expected to
implement similar measures as reguired under im specific regulatory criteria.

11.0 DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for Remedial Actions at Operable Unit 2 was released for public comment in
October 1994. The Proposed Plan identified Alternative 6, Excavation and On-Site Disposal with

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Off-Site Disposal of Fraction Exceeding the Waste Acceptance Criteria, as the preferred
alternative.

All written and oral comments submitted during the public comment period were reviewed.  Based
on these comments, it was determined that no significant changes to the remedy,  as it was
originally identified in the Proposed Plan, were necessary.

One significant change from the Proposed Plan to this ROD, is a change in the maximum waste
acceptance criteria for the on-site disposal facility.  The Proposed Plan provided a waste
acceptance criteria of 360 pCi/g of uranium-238 and 1,080 ppm of total uranium.   A waste
acceptance criteria of 346 pCi/g of uranium-238 and 1,030 ppm of total uranium was proposed in
the Operable Unit 5 Proposed Plan.  This difference in waste acceptance criteria as due to using
different, but comparable, computer models for the calculations.  The Operable Unit 2 and
Operable Unit 5 waste acceptance criteria are essentially the same, however for consistency,
Operable Unit 2 has adopted the Operable Unit 5 waste acceptance criteria of 346 pCi/g
uranium-238 and 1,030 ppm total uranium.  This significant change has been reflected in this
ROD.

It should be noted that EPA and OEPA approved the Operable Unit 2 FS Report with comments prior
to the public comment period for Operable Unit 2.  The Operable Unit 2 FS Report was revised to
address the comments from EPA and OEPA.  Those comments, and DOE's proposed responses and
revisions, were made known to the public and made available for public review during the public
comment period; the comments and not result in significant changes or changes that could not be
reasonably anticipated by the public.

-------
                                        REFERENCES

ATSDR, 1990, "Toxicological Profile for 2,3,7,8-Tetrachlorodibenzo-p-dioxin, " Draft for Public
Comment, U.S. Public Health Service, Atlanta, Georgia.

Comprehensive Environmental Response, Compensation, and Liability Act  (CERCLA) , as amended,
42 U.S.C. §9601 et seq.

Consent Agreement as Amended Under CERCLA Sections 120 and 106(a), 1991, U.S.
Environmental Protection Agency and U.S. Department of Energy, Administrative Docket No. V-W-
90-C-057.

Consent Decree, 1988, State of Ohio and U.S. Department of Energy, Civil Action No. C-l-86-0217.

Crag, J.R., U.S. Department of Energy, 1994, Letter to D. Ofte, FERMCO, Subject:  Action
Memorandum:  South Field and Inactive Flyash Seepage Control, 10/25/94.

Dispute Resolution Agreement, 1993, U.S. Environmental Protection Agency and U.S. Department of
Energy, Administrative Docket No. V-W-90-C-057.

Dollarhide J., U.S. Environmental Protection Agency Environmental Criteria and Assessment Office
(ECAO), 1993, Letter to P. VanLeeuwen, U.S. Environmental Protection Agency, Region V.

Facemire, C. F., S. I. Guttman, D. R. Sperger, 1990, "Biological and Ecological Site
Characterization of the Feed Materials Production Center," FMPC-SUB 018, prepared for
Westinghouse Materials Co. of Ohio, Cincinnati, OH.

Federal Facility Compliance Agreement, 1986, U.S. Environmental Protection Agency and U.S.
Department of Energy.

Geotrans, Inc., 1987, "Data Input Guide for SWIFTIII, The Sandia Waste  Isolation Flow and
Transport Model for Fractured Media, Release 2.16, Modifications to NUREG/CR-3162," Geotrans,
Herndon, VA.

Jones, T.D. and B.A. Owen, 1989, "Health Risks from Mixtures of Radionuclides and Chemicals in
Drinking Water", Oak Ridge National Laboratory, Oak Ridge, Tennessee, ORNL-6533.

National Oil and Hazardous Substances Pollution Contingency Plan  (NCP), 40 CFR Part 300.

St. John, F. L., 1993, "Report on the Status of the Sloan's Crayfish  (Orconectes sloanii Bundy)
at the Fernald Environmental Management Project," FERMCO, Cincinnati, OH.

St. John, F. L., 1994, "Addendum to the Report on the Status of the Sloan's  Crayfish  (Orconectes
sloanii Bundy) at the Fernald Environmental Management Project," Draft, FERMCO, Cincinnati,
OH.

Stipulated Amendment to Consent Decree, 1993, State of Ohio and U.S. Department of Energy, Civil
No, C-l-86-0217.

U.S. Department of Energy, 1987, "Remedial Investigation and Feasibility Study, Feed Materials
Production Center, Fernald, Ohio, Task 1 Report:  Description of Current Situation, "Vols. 1 and
2, DOE, Oak Ridge Operations, Oak Ridge, TN.

U.S. Department of Energy, 1988a, "FMPC Sampling and Analysis Report," Vols. 1 and 2, Draft,

-------
DOE, Oak Ridge Operations Office, Oak Ridge, TN.

U.S. Department of Energy, 1988b, "Remedial Investigation and Feasibility Study, Feed Materials
Production Cement, Fernald, Ohio, Work Plan Reguirement, "Rev. 3, DOE, Oak Ridge Operations
Office, Oak Ridge, TN.

US. Department of Energy, 1993, "Site-Wide Characterization Report, FEMP, Fernald, Ohio,
Remedial Investigation and Feasibility Study," U.S. DOE, Fernald Office, Fernald, OH.

U.S. Department of Energy, 1994, "Secretarial Policy on the National Environmental Policy Act,"
June 1994, U.S. DOE, Washington, D.C.

U.S. Department of Energy, 1995a, "Final Remedial Investigation Report for Operable Unit 2,
FEMP, Fernald, Ohio, Remedial Investigation and Feasibility Study," U.S. DOE, Fernald Office,
Fernald, OH.

U.S. Department of Energy, 1995b, "Work Plan, Removal Action No. 30:  Seepage Control at the
South Field and Inactive Flyash Pile," U.S. DOE, Fernald Office, Fernald, Ohio.

U.S. Department of Energy, 1995c, "Final Feasiability Study Report for Operable Unit 2, FEMP,
Fernald, Ohio, Remedial Investigation and Feasibility Study," U.S. DOE, Fernald Office, Fernald,
OH.

U.S. Environmental Projection Agency, 1988, "Superfund Exposure Assessment Manual,"
EPA/540/1-88/001, EPA, Office of Remedial Response, Washington, D.C.

U.S. Environmental Projection Agency, 1989a "Risk Assessment Guidance for Superfund:  Human
Health Evaluation Manual, Part A, Interim Final," EPA/540/1-89/002, EPA, Office of Emergency
and Remedial Response, Washington, D.C.

U.S. Environmental Projection Agency, 1989b, "Guidance on Preparing Superfund Decision
Document:  The Proposed Plan, The Record of Decision, Explanation of Significant Differences,
The Record of Decision Amendment," EPA/540/G-89/007, EPA, Office of Emergency Remedial
Response, Washington, D.C.

U.S. Environmental Protection Agency, 1989c, "Interim Procedures for Estimating Risks Associated
with Exposure to Mixtures of Chlorinated Dibenzo-p-dioxin and -Dibenzofurans  (CDDs and CDFs)
and 1989 Update," prepared by the Risk Assessment Forum for the Office of Health and
Environmental Assessment, EPA/625/3-89/016, U.S. EPA Washington, DC.

U.S. Environmental Protection Agency, 1991, "Health Effects Assessment Summary Tables, FY-
1991."  OERR 9200.6-303-91-1) EPA, Washington, D.C.

U.S. Envrionmental Protection Agency, 1992a, "Guidance on Risk Characterization for Risk
Assessors and Risk Managers," Memorandum dated February 26, 1992.

U.S. Environmental Protection Agency, 1992b, "Health Effects Assessment Summary Tables, Annual
Update FY 1992", including Supplement A, July, 1992, Prepared by the Environmental Criteria and
Assessment Office, Cincinnati, OH, for the Office of Emergency and Remedial Response,
Washington, DC.

U.S. Environmental Protection Agency, 1993a, "Integrated Risk Information System  (IRIS),"
computer database, EPA, Washington D.C.

-------
U.S. Environmental Protection Agency, 1993b, "Health Effects Assessment Summary Tables, FY-
1993," OERR, EPA, Washington, B.C.

U.S. Envronmental Protection Agency, 1994, "Integrated Risk Information System  (IRIS)," computer
database, EPA, Washington, DC.

Weston, Inc., Roy F., 1987, "Characterization Investigation Study," prepared for Westinghouse
Materials Company of Ohio, U.S. Department of Energy Feed Materials Production Center, Fernald,
OH.

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                                APPENDIX A

                  APPLICABLE OR RELEVANT AND APPROPRIATE
                 REQUIREMENTS  (ARARs) AND TO BE CONSIDERED
                              CRITERIA  (TBCs)
                                      LIST OF TABLES


Table                                      Title                                     Page

A-l    Chemical-Specific Requirements 	  A-l

A-2    Solid Waste Action-Specific Requirements  	  A-13

A-3    Radioloqical Action-Specific Requirements  	  A-39

A-4    Other Action-Specific Requirements  	  A-53

A-5    Location-Specific Requirements 	  A-61

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EPA National Primary
Drinking Water
Regulations
40 CFR §141.15 and
§141.16
EPA National Primary
Drinking Water
Regulations
40 CFR §141.61
EPA National Primary
Drinking Water
Regulations
40 CFR §141.51
MCLGs for
Inorganic
                                                                         TABLE A-l
                                                               CHEMICAL-SPECIFIC REQUIREMENTS
                                                                        Reguirment

                                                              3ROUNDWATER PROTECTION  STANDARDS
                                                     Radium-226 	   20  pCi/L

                                                     Radium-228 	   20  pCi/L

                                                     Radon-222 	   300 pCi/L

                                                     Uranium 	20  • g/L (30  pCi/L)
Relevant and
Appropriate
                                                                                                                     Final MCLs are not presented
                                                                                                                     for contaminants  for which  the
                                                                                                                     non-zero MCLG is  less  than  or
                                                                                                                     egual to the MCL.

-------
EPA Groundwater
Standards for Remedy
Actions at Inactive
Uranium Processing Sites
40 CFR §192.02(c) (3) (B)
                                                                                    TABLE A-l
                                                                                    (CONTINUED)
                                                                                   Requirement

                                                                   GROUNDWATER PROTECTION STANDARDS  (continued)
Arsenic 	    0.05 mg/ L

Combined radium-226 and radium-228  	    5 pCi/L

Combined uranium-234 and uranium-238  	    30 pCi/L

                                	     15 pCi/L
                                                                 Relevant and
                                                                 Appropriate
                                                                                                                                                           Final MCL  are  not  presented
                                                                                                                                                           for contaminants  for  which the
                                                                                                                                                           non-zero MCLG  is  less than or
                                                                                                                                                           egual to the MCL.
                                                                                                                                                           This MCL is a  stricter state
                                                                                                                                                           standard.

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Human Health
and Agricultural
Water Supply
Criteria
                                             TABLE A-l
                                            (Continued)

                                            Requirement

                                   OHIO WATER QUALITY STANDARDS

                            Paddys  Run and the Great Miami River are designated as:

                              !   warmwater aguatic  life habitat

                              !   agricultural and industrial water  supply

                              !   primary contact recreational  use
                                                                   inside
                                                  outside mixing   mixing
                                                      zone          zone
                                                             Avg.   Max.
                               Parameter  (•g/L)

                               Antimony (total)

                               Arsenic

                               B e r y11i um  (total)

                               Dieldrin
                                190    1,300

                                190    720

                                23    1,000

                               .005

                              0.001
                     Human Health       Agri-
Parameter (•g/L)  (ouside mixing  zone)   cultural
                                                                         100
                                                                         100
                                                                                          In addition  to  these  overall
                                                                                          designations:
                                                                                             !   Ross Rd.  (River Mile  (RM)
                                                                                          95.7) to  Taylorsville  Dam (RM)
                                                                                           92.6)  is  a state resource water
                                                                                             !   RM 130  and RM 118 are
                                                                                           public  water supplies
                                                                                          The  FEMP  effluent  discharge
                                                                                          pipe is located at  RM  24.73,
                                                                                          downstream of the  state
                                                                                          resource  water  and  puplic
                                                                                          water supplies.
                               Polynuclear  Aromatic
                               Hydrocarbons (PAHs)

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                                                                         TABLE A-l
                                                                         (Continued)
                                                                          Requirements

                                                                     RADIATION DOSE LIMITS
                                                                                                                            Determination
Radioactive Waste
Management
DOE Order 5820.2A
Chapter III  (3)(a)(2)
Protection of the
General
Population from
Releases of
Radioactivity
Concentrations of radioactive material  which may be released
to the general environment in surface water,  ground water,
soil,  plants or animals must not  result in  an effective dose
equivalent that exceeds 25 mrem per  year to any member of
the public.   Reasonable effort should be made to maintain
releases of radioactivity in effluents  to the general
environment as low as is reasonable  achievable.
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chather 11(1)(a)
 Public Dose
 Limits
The exposure of members of the  pubic  to  radiation sources
as a consequence of all routhe  DOE  activities  shall not
cause,  in a year, an effectiveness  dose  equivalent greater than 100
mrem.  Dose evaluation should reflect realistic  exposure
conditions.
Radiation public of the
Public and the
Environment
DOE Order 5400.5
Chapter II (1)
 Public Dose
 Limits
National Emission
Standards for Hazardous
Air Pollutants
40 CFR §61.92, 61. 93
Subpart II
[Radiation Protection of
the Public and the
Environment
DOE Order 5400.5
Chather II (1) (b)]
 National
 Emissions
 Standards for
 Emissions of
 Radionuelides
 Other than Radon
 from DOE
 Facilities
The public doese limit consideration  of  all  exposure
modes from all DOE activities  (including remedial activities.)
Effectiveness dose equivalent  is  the  sum of  the  effective dose
equivalent (weighted summation of doses  to various organs of
the body) from exposures to  radiation sources  external to the
body during the year plus the  committed  effective dose
equivalent from radionuclides  taken into the body during the
year.  Medical sources, consumer  products, residual fallout
from past nuclear accidents  and weapons  tests  and naturally
occurring radiation sources  are not included in  this
summary.

Emissions of radionuclides  (except radon-220 and radon-22)
to the ambient for from Departnext of Energy facility shall
not exceed those amounts that  would cause any  member of
the public to reeleve in any year an  effective dose equivalent
of 10 mrem/yr.
                                                                                                                                 Applicable

-------
                                                                                TABLE A-l
                                                                                (continued)
                                                                                 Requirements

                                                                        RADIATION DOSE LIMITS  (continued)
National Emission
Standards for Hazardous
Air Pollutants
40 CFR §61.92, 61.93
Subpart H
[Radiation Protection of
the Puplic and the
Environment
DOE Order 5400.5
Chather H  (1)(b)]
(continued)
National
Emissions
Standards for
Emissions of
Radionuclides
Other than Radon
from DOE
Facilities
To determine compliance with the  standard,  radionuclide
emissions shall be determined  and effective dose equivalent
values to members of the public calculated  usinq EPA
approved samplinq procedures,  computer  models  CAP-8 8 or
AIRDOS-PC, or other procedures for  which  EPA has qranted
prior approval.
                                                                                                                                    Applicable
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chapfor II (3) (a) (5)
                       The absorbed  does  to native aquatic animal orqanisms shall
                       not exceed  1  rad per day from exposure to the radioactive
                       material  in liquid wastes discharqed to natural waterways.
Radiation Protection of the
Public and the
Environment
DOE Other 5400.5
Chapfor IV (4)(c)
                        External  qamma  radiation levels on open lands shall comply
                        with the  basic  public  dose limit of 100 mrem effectiveness dose
                        equivalent  in a year  and the ALARA process,  considerinq
                        appropriate-use scenarios for the area.
                                                          EFFLUENT AND AIR EMMISION STANDARDS
Radiation Protectionn of the
Puplic and the
Environment
DOE Order 5400.5
Chather II (1)(d)
                        It is DOE  policy  to provide a level of protection for persons
                        consuminq  water from a public drinkinq water supply
                        operated by  the DOE,  either directly or throuqh a DOE
                        contractor,  that  is equivalent to that provided to the public by
                        the public community drinkinq water standards of 40 CFR
                        Part  141  (listed  above).   These systems small not cause
                        persons consuminq the water to receive an effective dose
                        equivalent qreater than 4  mrem in a year.   Combined Ra-22 6
                        and Ra-22 8 shall  not exceed 5x10-9 • Ci/mL and qross alpha
                        activity  (excludinq radon  and uranium) shall not exceed
                        1.5x10-8 •Ci/mL.

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                                                                               TABLE A-l
                                                                              (Continued)

         Citation                         Chemical                               Requirements                                      Determination

                                                                EFFLUENT AND AIR EMISSION STANDARDS  (continued)


Radiation Protection of the          Drinking Water       The liquid effluents from DOE activitiess  shall not  cause                    TBC
Public and the                       System  Standards     private or public drinkinq water systems downstream  of  the
Environment                                               facility discharge in exceed the drinkinq  water radioloqical
DOE Order 5400.5                                          limits in 40 CFR Part 141 (listed above).
Radiation Protection of the          Derived              The derived concentration quides  (DCGs)  are provided as
Public and the                       Concentration        reference values for conductinq radioloqical environmental
Environment                          Guides for  Air       protection proqrams at operational DOE facilities  and  sites,
DOE Oder 5400.5                      and Water            DCG values are presented in Fiqures III-l and III-3 of DOE
Chapfor III                                               Other 5400.5 for the followinq expsure mode:
                                                           !   inhalation of air

                                                          The DCG valus for internal exposures are based on  a
                                                          committed effective does equivalent of 100 mrem for the
                                                          radionuclide taken into the body by inqestion or inhalation
                                                          durinq one year.

                                                          The DCG values account for only three exposure pathways
                                                          (inqested water or inhaled air or are immersion and do not
                                                          include offer potentially siqnifleant pathways.  When more
                                                          complex environment pathways are involved, a more
                                                          complete pathway analysis is required for calculatinq public
                                                          radiation doses resultinq from the operation of DOE facilities.

Radiation Protection of the          Discharqe  of         The best available technoloqy is the prescribed level of
Puplic and the                       Liquid Waste  to     treatment for liquid radioactive discharqe to surface waters
Environment                          Surface  Waters       that would otherwise contain radioactive concentrations
DOE Order 5400.5                                          qreater than the DCG values.
Chapter II (3)(a)
                                                          Implementation of the best available technoloqy process is not
                                                          required for waste streams that contain radionuclide
                                                          concentrations of not more than the DCG values at  the point
                                                          of  discharqe to a surface waterway.

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                                                                            TABLE A-l
                                                                            (Continued)
                                                                              Requirements

                                                             EFFLUENT AND AIR EMISSION  STANDARDS (continued)
Radiation Proctection of the
Public and the
Environment
DOE Order 5400.5
Chapter H (3)(a)
(continued)

Radiation Protection of the
Puplic and the
Environment
DOE Order 5400.5
Chapter H (3)(a)(4)

National Emission
Standards for Hazardous
Air Pollutants
40 CFR §61.192
Subchapter Q
National
Emission
Standards for
Radon Emissions
from Department
of Energy
Facilities
                    Liquid  process  waste  streams containing radioactive material
                    in the  solid  present  in the waste stream must not exceed  5
                    pCi/g above background level of settleable solids for alpha-
                    emitting  radionuclides or 50 pCi/g above background of
                    settleable solids  for beta-gamma-emitting radionuclides.
Health and Environmental
Protection Standards  for
Uranium and Thorium
Mill Tailings
40 CFR §192.02  (b)
Subpart A
40 CFR §192.32  (b) (1) (ii)
Subpart D

Radiation Protection  of the
Public and the
Environment
DOE Order 5400.5
Chapter IV  (6)(d)
                      !   long-term management of uranium, thorium,  and their
                     decay  products.

                     Controls  shall  be  designed to provide reasonable  reference
                     that releases  of  radon-222 from the above materials to the
                     atmosphere  will not:
                                                                                                 Relevant and
                                                                                                 Appropriate

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                                                         Lead

                                                         Nitrogen Dioxide

                                                         Particulate Matter
                                                                             TABLE  A-l
                                                                            (Continued)

                                                                              Requirements

                                                          EFFLUENT AND AIR  EMISSION  STANDARDS (continued)

Health and Environmental           Control of Radon       !   increase the annual average concentration  of radon-222  in         Relevant and
Protection Standards  for           Emissions             air or above any location outside the disposal site by more          Appropriate
Uranium and Thorium
Mill Tailings
40 CFR §192.02  (b)
Subpart A
40 CFR §192.32  (b)(1)(ii)
Subpart D

Radiation Protection  of the
Public and the
Environment
DOE Order 5400.5
Chapter IV  (6)(d)
(continued)

                                   National
                                   Ambient Air
                                   Quality
                                   Standards             Criteria Pollutant     Primary  Standard    Averaging Time

-------
Review of New Sources of
Ai r T oxi c Emi s s i ons
OEPA Proposed Policy
January 1994
Health and Environmental
Protection Standards  for
Uranium and Thorium
Mill Tailings
40 CFR §192.12(a)
Subpart B
40 CFR §192.20
Subpart C
De Minimis
Emission Levels
for Carcinogens
                                                                            TABLE A-l
                                                                            (Continued)

                                                                             Reguirements

                                                          EFFLUENT AND AIR EMISSION STANDARDS  (continued)
                                                             Carcinogen

                                                         Chromium VI

                                                         All Others
                                                EPA Class

                                                   A

                                                A,  Bl,  B2
                            RADIONUCLIDE  CONCENTRATIONS IN SOILS

                      Remedial  actions  shall  be conducted so as to provue
                      reasonable  assurance  as,  as  a result of residual radioactive
                      materials,  the  concentration of radium-226 in land averaged
                      over any  area of  100  m2 shall not exceed the background
                      level by  more than:
Relevant and
Appropriate
Health and Environmental
Protection Standards  for
Uranium and Thorium
Mill Tailings
40 CFR §192.21  (f) and
§192.22 (b)
Subpart C
                      Compliance with  this  reguirement should be shown through
                      measurements  performed with the accuracy of currently
                      available types  of  field and laboratory instruments in
                      conj unction with reasonable survey and sampling procedures.

                      Where radionuclides  other than radium-22 6 and its decay
                      product  are present  in sufficient guantity and concentration to
                      constitute a  significant radiation hazard from residual
                      radioactive material,  remedial actions shall,  in addition  to
                      satisfying the standards of 40 CFR §§ 192.02,  Subpart A and.
                      192.12 Subpart B (both listed above), reduce other residual
                      radioactivity to levels that are low as is reasonably
                      achievable.

-------
Health and Environmental
Protection Standards for
Uranium and Thorium
Mill Tailings
40 CFR §192.32  (b) (2)
Subpart D
Health and Environmental
Protection Standards for
Uranium and Thorium
Mill Tailings
40 CFR §§ 192AO-192.42
Subpart E
Management
Thorium
Byproduct
Material
                                          TABLE A-l
                                         (Continued)

                                           Reguirements

                          RADIONUCLIDE  CONCENTRATIONS IN SOILS (continued)

                      The reguirements  for the management of uranium byproduct
                      materials  after  closure  of a  disposal area (40 CFR §192.32
                       (b)(1))  shall  not apply  to any portion of a disposal site whic
                      contains a concentration of radium-22 6 in land, averaged over
                      areas  of 100m2,  which,  as a result of uranium byproduct
                      material,  does not exceed the background level by more than
                      the limits specified in  40 CFR §192.12 (a).
                         !   the provisions for the management of uranium  byproduct
                      material  (40  CFR §192.32)  shall apply to thorium byproduct
Relevant and
Appropriate
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chapter IV (4)(a)
                      With the  concurrence  of EPA,  alternative provisions may be
                      substitued  for  any  of the above reguirement provided the
                      alternative  provisions will provide at least an eguivalent level
                      of provisions  for human health and environment.

                      Guidelines  for  residual concentrations of radionuclides others
                      than thorium and radium shall be derived from the basic dose
                      limits by means of  an environmental pathway analysis using
                      specific  property data where  available.   Procedures for these
                      derivations  are given in DOE/CH-8901.   Residual
                      concentrations  of radioactive material in soil are defined as
                      those in  excess of  background concentrations averaged over
                      an area of  100  m2.

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Radiation Proctection of the
Puplic and the
Environment
DOE Order 5400.5
Chapter IV (4)(a)(2).(3)
Generic
Guidelines for
Residual
Concentrations
                                                                            TABLE A-l
                                                                            (Continued)

                                                                             Requirements

                                                             RADIONUCLIDE CONCENTRATIONS IN SOILS  (continued)
Radiation Protection of the
Puplic and the
Environment
DOE Order 5400.5
Chare IV  (4)(a)(2),(3)
(continued)
                      These guidelines  take  into account ingrowth of radium-22 6
                      from thorium-23 0  and  of  radium-228 from thorium-23 0,  and
                      assume  secular  eguilibrium.   If both thorium-23 0 and radium-
                      226, or both thorium-232  and radium-228,  are present and
                      not in  secular  eguilibrium,  the appropriate guideline is
                      applied as  a limit  for the radionuclide with the high
                      concentration.
                                                         If other mixtures of radionuclides occur,  the  concentrations  of
                                                         individual radionuclides shall be reduced  so that  either  the
                                                         does for the mixture will net exceed the basic does  limit or
                                                         the sum of the ratios of the soil concentration of each
                                                         radionuclide to the allowable limit for  that radionuclide will
                                                         not exceed 1.   Explicit formulas for calculating residual
                                                         concentrations guidelines for mixings are  given in DOE/CH-
                                                         8901.
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chare IV  (4)(a)(1)
                      guideline by  a  factor  of (100/A)0.5 [where A is the area  (in
                      sguare meters)  of  the  region in which the concentrations the
                      elevated],  limits  for  "hot  spots" shall also be developed and
                      applied.

                      Procedures  for  calculating  these hot spots limit,  which
                      depend on the extend  of  the elevated local concentrations, are
                      given in DOE/CH-8901.   In addition, reasonable efforts shall
                      be made to  remove  any  source of radionuclides that exceeds
                      30 times the  appropriate limit in the soil, irrespective of the
                      average concentration  in the soil.

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                                                                           TABLE A-l
                                                                           (Continued)
EPA Guidance
methods for Evaluating
the Attainment of Cleanup
Standards,  Vol.  1
This document describes methods  for  testing whether soil
chemical concentrations at a  site  are  statistically below a
cleanup standard or ARAR.  If it can be  reasonably
concluded that the remaining  soil  or treated soil at a site has
concentrations that are statistically  less  than relevant cleanup
standards then the site can be j udged  protective of human
health and the environment.
                                                                           LEAD STANDARDS
Revised Interim Soil Lead
Guidance for CERCLA
Sites and RCRA
Corrective Action
Facilities  (OSWER
Directive 9355.4-12)
EPA recommends using 400 ppm  soil  lead  as  a screening
level for lead in soil  for residential  scenarios  at CERCLA
sites and at RCRA Corrective  Acton sites .   Residential areas
with soil lead below 400 ppm  generally  reguire no further
action.

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                                                                      TABLE A-2
                                                         SOLID WASTE ACTION-SPECIFIC REQUIREMENTS
Citation                        Action                               Requirements

                                                                       DEFINITIONS
                            Definition             Solid waste means any garbage, refuse, sludge  from  a
                                                   waste treatment plant,  water supply treatment  plant,  or  air
                                                   pollution control facility and other  discarded material,
                                                   ieluding solid, liguid, semisolid, or contained  gaseous
                                                   material resulting from industrial, commercial,  mining,
                                                   and agricultural operations and from  community activities,
                                                   but does not include source, special  nuclear,  or byproduct
                                                   material as defined by the Atomic Energy Act of  1954.

                            Definition             Solid wastes means such unwanted residual  solid  or
                                                   semisolid material as results from industrial, commericial,
                                                   agricultural,  and community operations, excluding earth  or
                                                   material from contruction, mining, or demolition
                                                   operations, or other waste materials  the type  that  would
                                                   normally be included in demolition debris, nontoxic
                                                   flyash, spent nontoxic foundry sand,  and slag  and other
                                                   substances that are not harmful or inimical  to public
                                                   health, and includes, but is not limited to, garbage,  tires,
                                                   combustable and noneombustable material, street  dirt,  and
                                                   debris.  Solid waste does not include any  material  that  is
                                                   an infectious waste or a hazardous waste.

                                                   For the purpose of this definition, "semisolid material"
                                                   does not contain liguids which can be readily  released
                                                   under normal climatic conditions, as  determined  by
                                                   method 9095 (paint filter liguids test) in SW-846:   "Test
                                                   Methods for Evaluating Solid Wastes,  Physical/Chemical
                                                   Methods".

                            Definition
                                                    !   it is listed in  40  CFR  §§  261.30  - 261.35.

                                                    !   it is a mixture  of  solid and hazardous wastes.

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                                                                            TABLE A-2

                                                                            (Continued)
                                                                           Requirements

                                                                        DEFINITIONS  (continued)
                                                                                                                             Determination
Ohio Infection Waste
Regulations
OAC 3745-27-01  (B)(15)
OAC 3745-27-30  (A) , (E) ,
(H)
ORC 3734 .021  (A) (1) (c),
(d)
Infectious waste is defined  by  9  categories  of waste
including human blood specimens  and  blood products,
sharp wastes used in the treatment or  inoculation of human
beings,  and any other waste  materials  generated in the
diagnosis, treatment, or immunization  of human beings.

A generator who places all sharp  infectious  wastes and all
unused hypodermic needles, syringes, and scalpel blades
into a "SHARPS" container before  they  are transported
and who generated less than  50  Ibs.  of infectious wastes
each month and dues not hold a  certificate of registration
as a generator of infectious wastes  may transport and
dispose of infectious wastes in  the  same manner as solid
wastes.
                                                                                                                                Applicable
                                  Definition
Infectious waste that is  also  radioactive shall be managed
in accordance with applicable  Ohio  Department of Health
and U.S. Nuclear Regulartory Commission regulations.

Flyash waste, bottom ash  waste,  flag  waste,  and fly gas
emission control waste, generated primarily  from the
combustion of coal or other fossil  fuels,  are excluded from
the definition of hazardous waste.
Ohio Petroleum
Contaminated Soil Policy
OEPA Policy PP 01 03
200
                                  Definition
The basis of the "contained  in"  policy is  that
environmental media, such  as  soil  or  groundwater,  are not
considered to be waste material.   Because  they are not a
solid waste, the mixture rule,  as  solid forth in OAC 3745-
51-03, does not apply when they  become contaminated
with a listed hazardous waste but  only contains the waste.
The results of this policy is that if the  waste constituentss
can be removed, the soil is  no  longer considered to
contain a hazardous waste.   Therefore,  since soil is not a
waste material it does not have  to be de-listed in order for
as the soil contains the waste material,  it must be managed
as a hazardous waste.

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                                                                            TABLE A-2
                                                                            (Continued)

                                      Action                               Requirements

                                                                        DEFINITIONS  (continued)

Ohio Petroleum                    Definition             If we apply this concept to petroleum-contaminated  soil,
Contaminated Soil Policy                                 the soils containing a petroleum hydrocarbon would  not
OEPA Policyy PP 01 03                                    need to be managed as a solid waste if the  contaminants
200 (continued)                                          were removed.

                                  Definition
                                                           !   waste is  capped  in  place ,  including grading prior to
                                                         capping;
                                                           !   waste is processed  within the  unit in order to improve
                                                         its  structural stability for closure or  for movement  of
                                                         equipment over the area.

                                  Definition             Remediation waste means all solid and hazardous  waste ,
                                                         and  all media ( including groundwater surface water , soils ,
                                                         and  sediments )  and debris , which contain  listed  hazardous
                                                         wastes or which themselves exhibit a hazardous waste
                                                         characteristic,  that are managed for the  purpose of
                                                         implementing corrective action  requirements under 4 0
                                                         CFR  §264.101 and RCRA section 3008(h).   For a given
                                                         facility, remediation wastes may include  only from
                                                         within the facility boundary, but may include waste
                                                         managed in implementing RCRA sections 3004 (v) or 3008
                                                         (h)  for releases beyond the facility boundary .

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                                         TABLE  A-2
                                         (Continued)
                                         Requirements

                                      DEFINITIONS  (continued)
Definition
                      For the purpose  of  implementing corrective action for
                      solid waste management  units,  the Regional Administrator
                      may designate  an area at  the  facility as a corrective action
                      management unit  (CAMU).   One  or more CAMU's may
                      be designated  at a  facility.
                                     of
                        !   Consolidation or placement of remediation wastes  intc
                      or with  a  CAMU  does  not  constitute creation of a unit
                      subj ect  to minimum technology requirements.
                        !   Waste management activities associated with  the
                      CAMU shall not  ereare  unacceptable risks to humans or to
                      the environment  resulting from exposure in wastes.

                         !   The CAMU shall include uncontaminated areas  of  the
                      facility  only if including such areas for the purpose of
                      managing  remediation waste is  more protection than
                      management of such  wastes at contaminated areas of the
                      facility.

                         !   Areas with the CAMU, where wastes  remain  in
                      place after  closure of the CAMU,  shall be managed and
                      contained so as  to  minimize future releases,  to the extent
                     practicable.

                         !   The CAMU shall expedite the timining of remedial
                     activity  implementation,  when appropriate and applicable.

                         !   The CAMU shall enable the use, when appropriate,  of
                      treatment technologies (including innovative technologies)
                      to enhance the  long-term effectiveness of remedial actions
                      by reducing  the  toxicity, mobility, or volume of wastes
                      that will remain in place after closure of the CAMU.
Under all of the remedial
alternatives, any hazardous waste
from the firing range is being  sent
off-site for disposal.  This  CAMU
rule would only be used if
Operable Unit 5 plans to dispose
hazardous waste  in  a centralized
disposal cell; the cell would then
have to be designed  to meet RCRA
standards and it would not be cost-
effective to  send the firing  range
material off-site for disposal.
Because this is dependent on
Oprable Unit 5, the  RCRA
disposal requirements will  be
addressed in Operable Unit 5.
ARARs.

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Resource,  Conservation,
and Recovery Act
40 CFR §264.552  (a) , (c)
(continued)
                                   Definition
                                   Definition
                                                                            TABLE A-2
                                                                            (Continued)
               DEFINITIONS  (continued)

  !    The  CAMU  shall,  to the extent practicable, minimize
the  land area of the  facility upon which wastes well remain
in place after closure  of the CAMU.
                                                         For temporary tanks and container  storage  areas  used for
                                                         treatment or storage of remediation wastes  during remedial
                                                         activities,  the Regional Administrator  may  determine that
                                                         a design, operating, or closure  standard applicable to such
                                                         units may be replaced by alternative  reguirements which
                                                         are protective of human health and the  environment.
                                                           !   located within  the facility boundary; and
 Relevant  and
Appropriate
                                                                        SOLID WASTE DISPOSAL
                                                           !   sanitary  landfill

                                                           !   incineration

                                                           !   composting

                                                         Methods not mentioned above and  not  prohibited by this
                                                         chapter,  OAC 3745-27, may be uand  provided  that such
                                                         methods are demonstrated to the  satis faction of the
                                                         Director to be capable of disposing  of  solid waste without
                                                         creating a nuisance or a health  hazard,  without causing
                                                         and  any regulation adopted by the  Director  pursuant to
                                                         Ohio Revised Code Chapter 3704  (Air  Pollution Control).
                                                                                                                               Applicable

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                                                                            TABLE A-2
                                                                           (Continued)
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-08  (c)(1),
(2) , (3) , (4) ,  (5) , (6) , (7) , (9)
                                  Open  Burning
                                  Prohibited
                                   Surface  Water
Landfill
Construction
                      The solid waste  disposal  facility or practice shall not
                      engage in open burning  of residential,  commercial,
                      institutional, or  industrial  solid waste.   This reguirement
                      does not apply to  land-clearing debris,  diseased trees,
                      debris from emergency clean-up operations,  and ordnance.

                      A solid waste disposal  facility shall not  cause a discharge
                      of pollutants into waters of  the United States that is in
                      violation of  the reguirements of the NPDES  under section
                      402 of the Clean Water  Act,  as amended.

                      A solid waste disposal  facility shall not  cause a discharge
                      of dredged material  or  fill material to waters of the United
                      States that is in  violation  of the reguirements under section
                      404 of the Clean Water  Act,  as amended.

                      A solid waste disposal  facility of practice shall not cause
                      non-point source pollution of waters of the United States
                      that violates applicable  legal reguirements implementing an
                      area-wide or  Statewide  water  guality management than that
                      has been approved  by the  Administrator under section 208
                      of the Clean  Water Act,  as amended.

                      A solid waste disposal  facility or practice shall not
                      contaminate an underground drinking water  source beyond
                      the solid waste  boundary.
                                                                                                                                Applicable
                                                                                                                                 Applicable
                                                           !   constructed of  a  soil  with a maximum cand size of 3
                                                         inches  or half the lift thickness, whichever  is  less.

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                                                           !    compacted  to at least 95 § of the maximum "Standard
                                                         Proctor Density" using ASTM D-498  or  at  least 90% of
                                                         the  maximum "Modified Proctor  Density" using ASTM D-
                                                         1557.
                                                         Alternatives for the above reguirements  may be used if it
                                                         is demonstrated to the satis faction  of the  Director that the
                                                         materials and technigues will  result in  each lift having a
                                                         maximum permeability of 1 x  10-7  cm/s.

                                                         Additionally, the recompacted  soil liner shall:

                                                           !   not  comprised  of  solid  waste.

                                                           !   be  constructed  using  the  same  number of passes and
                                                         lift thickness, and the same or  similar  type and weight of
                                                         compaction eguipment established  by  testing (as  defined in
                                                         in is table).

                                                           !   be  placed  on the  bottom and exterior excavated sides
                                                         of the landfill and have a minimum bottom slope  of 2 %
                                                         and  a maximum slope based on:
                                                                            TABLE A-2
                                                                            (Continued)

                                       Action                               Reguirement

                                                                    SOLID WASTE DISPOSAL  (continued)

Ohio Solid Waste                  Landfill                  !    constructed  of  soil  with:                                          Applicable
Disposal Regulations
OAC 3745-27-08  (C)(1),
(2) , (3) , (4) ,  (5) , (6) , (7) , (9)
(continued)

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                                                                            TABLE A-2
                                                                            (Continued)

                                       Action                               Requirement

                                                                    SOLID WASTE DISPOSAL  (continued)

Ohio Solid Waste                   Landfill                     -  slope stability;
Disposal Residual                  Construction
OAC 3745-27-08  (C)(1),                                         -  maximum friction angle  between  any  soil-
(2 ) , (3), (4), (5), (6), (7), (9)                                       geosynthetic interface  and  between  any
(continued)                                                       geosynthetic-geosynthetic interface;  and
                                                                  be able to bear the weight  of  the  landfill and its
                                                                  construction operations without  causing or allowing
                                                                  a failure of the liner to occur  through settling; and
                                                           !   be  at  least  5  feet thick,  although the Director may
                                                         approve an alternate thickness,  to  be  no  less  than 3 feet,
                                                         based upon be result of  calculations or on a design that is
                                                         no less protective of human health  and the environment.

                                                           !   be  at  least  3  feet thick with a geosynthetic clay  liner
                                                        that  meet the specification in paragraph  (c)(3)  of this
                                                        rule  although the Director may approve  an  alternate
                                                        thickness to be no less than 1 1/2  feet, based  upon the
                                                        results of calculations or on  a  design  that is  no less
                                                        protective of human health and the  environment.

                                                           !   have a  factor  of  safety  for hydrostatic uplift not less
                                                         than 1.4.

                                                           !   be  adegutely protected  from damage due to
                                                         desiccation, freeze/thaw cycles, wet/dry  cycles,  and the
                                                         intrusion of objects during construction  and operation.

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                                                         Other materials for thickness may be  used  if,  at  a
                                                         minimum, the flexible membrane liner  meets  all the
                                                         following:

                                                           !   negligibly permeable  to fluid  migration.

                                                           !   physically and  chemically  resistant to chemical attack
                                                         by the solid waste, leachate, or other materials  which  may
                                                         come in contack with the flexible membrane  liner.

                                                           !   seamed to allow no more than  negligible amounts of
                                                         leakage with seaming material that  is physically  and
                                                         chemically resistant to  chemical attack  by  the solid waste,
                                                         leachate,  or other material may come  in  contain
                                                         with the seams.
                                                           !   have  a minimum  thickness  of 4 0 mils.

                                                                    Geosynthetic Clay Liner
                                                                            TABLE A-2
                                                                            (Continued)

                                      Action                               Reguirement

                                                                    SOLID WASTE DISPOSAL  (continued)

Ohio Solid Waste                   Landfill                                                                                      Applicable
Disposal Regulations               Construction
OAC 3745-27-08  (C)(l),                                                Flexible Membrane Liner
(2) , (3) , (4) ,  (5) , (6) , (7) , (9)
(continued)                                              The flexible membrane liner shall be:

                                                            !  placed  on  file  recompacted  soil liner.

                                                            !  sixty mil  high  density  polyethylene (HOPE).

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                                                                            TABLE A-2
                                                                            (Continued)

                                       Action                              Requirement

                                                                    SOLID WASTE DISPOSAL  (continued)

Ohio Solid Waste                   Landfill                 !   negligibly  permeable  to fluid migration.                         Applicable
Disposal Regulations               Construction
OAC 3745-27-08  (c)(1),                                     !   be  installed  to allow no more than negligible amounts
(2), (3), (4), (5), (6), (7), (9)                              ofleakage by a minimum overlap  of  6  inches,  or,  for  end
(continued)                                              of panel seams,  a minimum  over of  12  inches.   Overlap
                                                         shall be increased to accordance with manufacturers
                                                         specifications or to account  for shrinkage  due to weather
                                                         conditions.

                                                           !   have a  benonite mass  per unit area of at least 1 pound
                                                         per  sguare foot.

                                                           !   be  installed  in accordance  with the manufacturers
                                                         specifications in regards  to  handling,  overlap,  and the  use
                                                         of granular or powdered bentonite  to  enhance  bonding  at
                                                         the  seams.

                                                           !   be  constructed  above  the recompacted soil liner.

                                                                       Leachate Management  System

                                                         The  leachate management system shall:
                                                                  have a minimum permeability  of  1  x  10-3  cm/s;

                                                                  have a minimum thickness  of  1  foot;

                                                                  have a negligible amount  of  fines;  and

                                                                  not contain carbonate material.

                                                         An alternate material and/or thickness may be  used if
                                                         it is demonstrated to the satis faction  of  the  Director
                                                         that the material meet the requirements.

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                                                                            TABLE A-2
                                                                            (Continued)

                                       Action                              Requirement

                                                                    SOLID WASTE DISPOSAL  (continued)

Ohio Solid Waste                 Landfill                   !   include  leachate  collection pipes to remove leachate             Applicable
Disposal Regulations             Construction            from the bottom of the landfill.   The  pipes  must:
OAC 3745-27-08  (C)(1),
(2), (3), (4), (5), (6), (7), (9)                                    -  be imbedded in the drainage layer;
(continued)
                                                                  have a minimum slope of  0.5 %;
                                                                  be physically and chemically  resistant  to attack by
                                                                  the solid waste, leachate,  or other  that
                                                                  they may come in contact waste.   Sealing material
                                                                  and means of access  for clean-out devices shall
                                                                  also be physically and chemically resistant to attack
                                                                  by the solid waste,  leachate,  or  other  materials that
                                                                  they may come in contact with.

                                                         An alternate means for leachate removal may be used
                                                         if it is demonstrated to the  satis faction  of  the Director
                                                         that the means for leachate removal  meet the
                                                         requirements.

                                                           !   include  a  filter  layer  to prevent clogging of the
                                                         leachate collection system.

                                                           !   include  a  protective  layer to protect the recompacted
                                                         soil liner, flexible membrane  liner, geosynthetic clay liner
                                                         (if  applicable), and leachate  collection system  from the
                                                         intrusion of objects during construction and  operation.

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                                                                            TABLE A-2
                                                                            (Continued)
                                                         Any leachate conveyance and storage  structures  located
                                                         outside the limit of solid waste placement  shall  be no less
                                                         protective of the environment than the  landfill facility,  as
                                                         determined by the Director, and:
                                                           !   Storage  tanks  must  be  provided with spill containment

                                                           !   Leachate  must  be  double-cased

                                                           !   Storage  structures  must have a minimum of 1 week of
                                                         storage capacity using design assumptions  simulating final
                                                         closure.

                                                           !   If at  any time leachate is evaluated to be hazardous in
                                                         accordance waste rule 3745-52-11  of  the  OAC,  it  shall be
                                                         managed in accordance waste  Chapter  3745-50  to 3745-69
                                                         of the OAC,  and the generator standards  for  storage shall
                                                         apply in accordance with Chapter  3745-52  of  the  OAC.
                                                                    SOLID WASTE DISPOSAL  (continued)

Ohio Solid Waste                  Landfill                  !   include  lift  stations  which are to be protected from             Applicable
Disposal Regulations              Construction           adverse effects from leachate and differential  sealing.   If
OAC 3745-27-08  (C)(1),                                   manholes used as lift stations,  they  must  be  eguipped
(2),(3),(4),(5),(6),(7),(9)                              with automatic high level alarms located no  greater than 6
(continued)                                              feet above the invert of the leachare inlet  pipe.   Lift
                                                         station pipes should be of  adeguate  capacity  and shall
                                                         automatically commence pumping before the  leachate
                                                         elevation activities the high level  alarm.

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                                                                            TABLE A-2
                                                                            (Continued)

                                       Action                               Requirement                                      Determination

                                                                    SOLID WASTE DISPOSAL  (continued)

Ohio Solid Waste                   Landfill                                                                                      Applicable
Disposal Regulations               Construction
OAC 3745-27-08  (C)(l),                                                   Surface Water  Control
(2) , (3) , (4) ,  (5) , (6) , (7) , (9)
(continued)                                                !   Any  permanent or  temporary surface water control
                                                         structures shall be designed to  accommodate,  by  non-
                                                         mechanical means,  file peak flow from  the  25-year/24-
                                                         hour storm event.
                                                           !   At  least  3  permanent third order benchmarks on
                                                         separate sides of the landfill  facility  shall be within easy
                                                         access to the limits of solid waste  placement and shall be
                                                         constructed in accordance with  OAC 3745-27-08 (C) (7) (a)-
                                                         (C) .
                                                           !   Any  permanent  groundwater control structures shall
                                                         adequate control groundwater  infiltration through the use
                                                         of non-mechanical means such  as  impermeable barriers or
                                                         permeable drainage structures.

                                                           !   No permanent  groundwater control structures may be
                                                         used to dewater and aquifer system,  except if the recharge
                                                         and  discharge zone of the  aquifer  system are located
                                                         entirely within the boundary  of  the  landfill facility.

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                                                           !   a run-off  control  system from the active portion of the
                                                         landfill to collect and control at least the  water volume
                                                         resulting from a 24-hour, 25-year  storm.

Ohio Solid Waste                   Landfill               Prior to being used in the construction of the  recompacted
Disposal Regulation                Construction          soil liner and drainage layer of the sanitary landfill  or the
OAC 3745-27-08  (D) and                                   landlift cap,  the following characteristic of the earthen
(E)                                                       material must be determined to show that the  material is
                                                         suitable for  use in construction of the landfill.
                                                         The following tests shall be performed on  representative
                                                         samples at least once for every 1,500 yd3  of  soil  except
                                                         the recompacted permeable test, which shall be
                                                         performed at least once for every 10,000 yd3  of  soil.

                                                           !  recompacted permeable  at  construction
                                                         specifications;
                                                           !   grain
                                                         and  hydrometer methods; and

                                                           !   Atterberg  limits  using  ASTM D-4318.
                                                                            TABLE A-2
                                                                            (Continued)

                                      Action                               Reguirement

                                                                    SOLID WASTE DISPOSAL  (continued)

EPA Criteria for                   Landfill  Design       The liner and leachate System shall be designed  and                  Relevant and
Municipal Solid Waste              Criteria               constructed to maintain less than a 3 0-cm depth  of leachate          Appropriate
Landfills                                                over the liner.
40 CFR §258.40
EPA Criteria for                   Run-On/Run-Off        The landfill shall have:                                             Relevant and
Municipal Solid Waste              Control  Systems                                                                             Appropriate
Landfills
40 CFR §258.26

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Ohio Solid Waste
Disposal Regulations
OAC 3745-27-08  (D) and
(E)  (continued)
                                          TABLE A-2
                                         (Continued)

                                         Requirement

                                  SOLID  WASTE DISPOSAL (continued)




                                  Granular Drainage Material Specifications
                                                           !   permeability;

                                                           !   grain  size  distrubution using ASTM D-4 22 for the sieve
                                                         method; and

                                                           !   chemical  compatibility testing may be required by the
                                                         Director.
                                                                                                                                Applicable
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-08
(C) (1) ,  (m) , (o) and
(C) (2) (g)
Landfill
Construction
                                                         Geosynthetics, other synthetic  materials,  and j oint sealing
                                                         compounds used in the construction  of  the  flexible
                                                         membrane liner, geosynthetic  clay liner,  and leachate
                                                         management them for a sanitary  landfill  facility or a
                                                         sanitary landfill cap system  shall  be  shown to:
                                                                                                                   the
                                                                                  ig USEPA  Method 9090  or other
                                                                                                                               Applicable

-------
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-08
(C) (1) (m) ,  (o) and
(C)(2)(g)  (continued)
                                                                            TABLE A-2
                                                                           (Continued)

                                                                           Reguirement

                                                                    SOLID WASTE DISPOSAL  (continued)
                                                         The recompacted soil liner and the recompacted  soil
                                                         barrier layer in the cap system shall be modeled  by  the
                                                         construction of test pads.   The test pads  shall:

                                                           I
                                                           !   be constructed  to  establish the construction details
                                                         which are necessary to obtain sufficient compaction  to
                                                         satis fy the permeability reguirement.  The  construction
                                                         details include:
                                                                                                                                Applicable
                                                           !   have a minimum width  three  times  the width of the
                                                         compaction eguipment,  and a minimum length two  times
                                                        the length of compaction eguipment, including  power
                                                        eguipment and any attachments.

                                                           I

-------
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-08
(C) (1) (m) ,  (o) and
(C)(2)(g)  (continued)
                                                                            TABLE A-2
                                                                           (Continued)
           SOLID WASTE DISPOSAL  (continued)

   !   be  tested  for  field permeability,  following the
completion of test pad construction.  For  each lift a
minimum of 3 rests for moisture  content  and  density shall
be performed.
                                                         Moisture content and density testing of the recompacted
                                                         soil liner and recompacted soil barrier in the  cap  system
                                                         shall be performed at a freguency of no less than 5  tests
                                                         per acre per lift.  Any penetrations shall be repaired using
                                                         methods acceptable to the Director.

                                                                    Flexible Membrane Liner Testing
                                                           !   Destructive testing  for  peel  and shear shall be
                                                         performed at least once for every 500  feet  of seam  length.
                                                         An alternate means maybe used if it is demonstrated to
                                                         satis faction of the Director that the  alternate means
                                                         meets the reguirements.

-------
                   TABLE A-2
                   (Continued)
                  Requirement

           SOLID WASTE DISPOSAL  (continued)
  !   testing  frequency;

  !   parameters  and  remove  locations;

  !   procedures  to be  followed if a test fails;
  !    contingency  plan  for anticipated construction
difficulty.
  I
      in-situ  foundation preparation;
  !    recompacted  soil  and/or geosynthetic clay liner system;

  !    flexible  membrane liner;

  !    leachate  management  system;

  !    cap  system;

  !    permanent ground  water control structure and

  !    explosive gas  control/extraction systems.
                                                                    Applicable
                                                                    Applicable

-------
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-19  (J) (1) ,
(4)
                                   Sanitary  Landfill
                                   Operation
                   TABLE A-2
                   (Continued)

                   Requirement

           SOLID WASTE DISPOSAL  (continued)

To demonstrate that the solid wages  to  be  received at the
landfill facility  will not compromise the  integrity of any
material used to construct the landfill facility,  the Director
may reguire chemical compatibility testing to be
performed.

The integrity of the engineered  components of the  landfill
facility shall be  maintained and any damage to,  or failure
or, the components shall be repaired.

Surface water shall be diverted  from areas where  solid
waste is being, or has been, deposited.  The facility shall
be designed, controls, maintained, and  provided  with
surface water control structures, as necessary,  to control
run-on and run-off of surface water  to  ensure minimal
infiltration of water through the cover material  and cap
system, and minimal erosion of the cover material  and cap
system.  If ponding or erosion occurs on areas of  the
landfill facility  where solid waste  is  being,  or  has been,
deposited, action  will be taken  to correct the conditions
causing the ponding or erosion.
                                                                                                                              Applicable
                                                                                                                              Applicable
                                                           !   leachate shall be  contained  and properly managed at
                                                         the  sanitary landfill facility.

                                                           !   if necessary, leachate  shall be collected and disposed in
                                                         accordance with paragraph  (K)(5)  and  (K)(6) of OAC
                                                         3745-27-19.

                                                           !   actions shall be taken  to minimize,  control,  or
                                                         eliminate the conditions which  contribute to  the production
                                                         of leachate.
                                                                                                                              Applicable

-------
                   TABLE A-2
                   (Continued)
                  Requirement

           SOLID WASTE DISPOSAL  (continued)

The collection pipe network  of the  leachate  management
system shall be inspected  after  placement  of the initial lift
of waste to ensure that  crushing has  not occurred and shall
be inspected annually thereafter to ensure that clogging
has not occurred.
Applicable
If authorized by the Director,  leachate  may be temporarily
stored within the limits of  solid  waste  placement until the
leachate can be treated and  disposed.

The groundwater monitoring system  for  detection
monitoring, assessment monitoring,  or  corrective measures
shall consist of a sufficient number  of  wells, installed at
appropriate locations and depths,  to  yield groundwater
samples from both the uppermost  aguifer  system and any
significant zones of saturation  that  exist above the
uppermost aguifer them that:
                                                                     Applicable
placement.

The groundwater monitoring program  shall  include
consistent sampling and  analysis  procedures  and statistical
methods that are protective  of  human  health  and the
environment and that are designed to  ensure  monitoring
results that provide an  accurate  presentation of
groundwater guality at the background and downgradient
well.

-------
Final Closure of
Landfill Facilities
                                         TABLE  A-2
                                        (Continued)

                                        Requirement

                                SOLID WASTE  DISPOSAL (continued)

                     At final closure of a landfill facility:

                        !   all  land surfaces  shall be graded to prevent ponding  of
                     water where  solid  waste has  been placed.   Drainage
                     facilities shall be provided  to direct surface water from the
                     landfill facility.

                        !   a  groundwater monitoring system shall be designed  and
                     installed in  accordance with  OAC 3745-27-10,  if a system
                     is not  already  in  place.

Final Closure of     Closure of the  sanitary landfill facility must be completed
Landfill Facilities  in a manner  that mimimizes the need for further
                     maintain and  minimizes  post-closure formation and
                     release of leachate and explosive gases to air,  soil,
                     groundwater,  or surface water  to the extent necessary to
                     protect human health and  the  environment.
                                                                                           Applicable
Landfill Cap
System
                         !   The cap system shall, at a minimum, consist of the
                      following  (from  bottom to top):

                                   Recompacted Soil  Barrier Layer

                      The recompacted  soil  barrier  layer of the cap shall be:

-------
                                                           !   Be constructed  of  a  soil  with 10 0 % of the particles
                                                         have a maximum dimension not greater than  2  inches  and
                                                         with not more than 10% of the particles, by  weight,
                                                         having a dimension greater than 0.75 inches.

                                                           !   Be compacted m  at  least  95%  of the maximum
                                                         "Standard Proctor Density" using ASTM  D-698  or  at  least
                                                         90 %  of the maximum "Modified Proctor Density" testing
                                                         ASTM D-1557.
                                                           !   The particle  size  and  proctor  density reguired shall be
                                                         verified by tests performed on presentative  samples
                                                         based on the variability and homogeneity  of  the  material,
                                                         but  no less than a minimum of once  for  every 5300  cubic
                                                         yards of material used in the engineered  subgrade.
                                                                            TABLE A-2
                                                                            (Continued)

                                      Action                               Reguirement

                                                                    SOLID WASTE DISPOSAL  (continued)

Ohio Solid Waste                   Construction of a        !   a minimum  of  18  inches thick and constructed in                Applicable
Disposal Regulations               Landfill  Cap          accordance with the specifications outlined  above  for
OAC 3745-27-08  (C)((15)            System                 construction of the recompacted  sort liner for  a landfill
(continued)                                              facility ((C)(1)(a) to (C)(1)(g) and  (C)(1)(m)  to  (C)(1)(o)
                                                         of OAC 3745-27-08) with the  exception  that the  maximum
                                                         permeability of the recompacted  soil barrier  shall  be  1x10-
                                                         6 cm/sec;  OR

                                                           !   a geosynthetic clay  liner  of  egual or less permeability
                                                        as the recompacted soil barrier layer,  with an engineered
                                                        subgrade  constructed in accordance with the following
                                                        reguirements:

                                                           !   The thickness  of  the  subgrade shall be  sufficient to
                                                         achieve  an evenly graded surface and shall be a minimum

-------
                                                                            TABLE A-2
                                                                           (Continued)

                                      Action                               Requirement

                                                                    SOLID WASTE DISPOSAL  (continued)

Ohio Solid Waste                   Construction  of a       !   Field density testing  shall be  performed at a frequency
Disposal Regulation                Landfill  Cap           not  less than 5 tests per acre.  Any penetration  in the
OAC 3745-27-08  (C) (15)             System                 subgrade as a result of the testing must be repaired  using
(continued)                                              bentonite or  a bentonite-soil mixture.

                                                                        Flexible Membrane Liner

                                                         The  flexible  membrane liner for  the cap system  shall  be
                                                         constructed on top of the soil barrier layer  or  geosynthetic
                                                         clay liner in accordance with the specifications  listed
                                                         above for a flexible membrane liner for a  landfill facility
                                                         [OAC 3745-27-08 (c)(2)].

                                                                             Drainage Layer

                                                         The  drainage  layer shall be:

                                                           !   a minimum of 1  foot  of granular material;  OR
                                                                         Frost Protection Layer

                                                         The frost protection layer shall be:

                                                           !  placed on top  of the  drainage  layer

                                                           !  a minimum of 30 inches  thick.

-------
Ohio Solid Waste
Disposal Regulations
OAC 3745-27-08  (C)(15)
(continued)
                                                                            TABLE A-2
                                                                            (Continued)

                                                                           Requirement

                                                                    SOLID WASTE DISPOSAL  (continued)
                                                                                                                                Applicable
                                                                         Soil Vegetative Layer

                                                         The soil vegetative layer shall:
                                                           !   have soil  of  sufficient  thickness and fertility to support
                                                         its  vegetation and to protect the recompacted  soil  barrier
                                                         layer and flexible membrane liner from damage  due to
                                                         root penetration.
                                   Final  Closure  of
                                   Landfill  Facilities
A notation must be recorded  on  the  deed  to the sanitary
landfill facility property,  or  on some of other instrument
which is normally examined during title  search,  that will
in perpetuity notify any potential  purchaser  of the property
that the land has been used  as  a sanitary landfill facility.
The notation shall include information describing acreage,
exact location, depth, volume,  and  nature of  the solid
waste deposited in the unit  landfill  facility.

-------
                                                                           TABLE A-2
                                                                            (Continued)
                                                                           Requirement

                                                                    SOLID WASTE DISPOSAL  (continued)

                                                         Following completion of  final  closure  activities in
                                                         accordance with rule 3745-27-11  of  the OAC,  post-closure
                                                         care activities shall be concluded  at  the sanitary landfill
                                                         facility for a minimum of  30 years.
EPA Criteria for
Municipal Solid Waste
Landfills
40 CFR §258.61
                                                         system, any explosive gas  extraction  and/or control
                                                         system, any explosive gas  monitoring  system,  and the
                                                         groundwater monitoring system
                     necessary  to  correct the effects of settling, dead
                     vegetation, subsidence,  erosion, leachate outbreak, or
                     other  events,  and preventing run-on and ran-off from
                     eroding  or otherwise damaging the cap system

                     The  Director  of Ohio EPA may allow the owner or
                     operator to stop managing leachate if the owner or
                     operator demonstrate that leachate no longer poses a
                     threat to  human health and the environment.
                                                                     Relevant and
                                                                     Appropriate
PCB Criteria
Processing, Distribution,
and Use Prohibitions
40 CFR §761.3
Excluded PCB
Material
         POLYCHLORINATED BIPHENYL  (PCB)  DISPOSAL

PCB materials which appear at  concentration less than 5 0
ppm are excluded from the PCB  disposal  requirements in
this regulation.
Operable Unit 2  does not contain
PCB material which have a
concentration greater than 50 ppm.

-------
                   TABLE A-2
                   (Continued)
                  Requirement

       ASBESTOS MANAGEMENT AND  DISPOSAL
   !   cover  the  asbestos-containing waste material with at
least 6 inches of compacted nonasbestos-containing
material and grow and maintain  a  cover  of vegetation on
the area adequate to prevent  exposure of  the  asbestos-
containing waste material; or
 The Federal requirement is
relevant and appropriate because  it
specifically applies to a type  of
facility that  is  not  found  in
Operable Unitis 2.  The Ohio
requirement is generally applicable
to  any  inactive asbestos waste
 disposal site.

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Definition
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chapter IV
Definition
TABLE A-3
RADIOLOGICAL ACTION-SPECIFIC REQUIREMENTS

Requirement

DEFINITIONS
! high-level radioactive waste, the highly radioactive
material resulting from the processing of spent nuclear
fuel, including liguid waste produces directly in
reprocessing and any solid material derived from such
liguid waste that contains fissions products in sufficient
concentrations.

! spent nuclear fuel, fuel that has been withdrawn from a
nuclear reactor following irradiation, the constituent
elements of which have not been separated by
reprocessing.

! transuranic waste, material contaminated with elements
that have an atomic number greater than 92, including
neptanium, plutonium, americium, and curium, and that
are in concentrations greater than 10 nanocuries per gram.

! byproduct material, the tailings or wastes produced by
the extraction or concenstration of uranium or thorium from
any ore processed primary for its source material content.

Residual radiactive material is defined as:

! residual concentrations of radionuclies in soil (soil is
defined as unconsolidated earth material, including rubble
and debris that might be present in the earth material);

! concentrations of airborne radon decay products;

! external gamma radiation;

! surface contamination; and

-------
                                                                            TABLE A-3
                                                                            (Continued)

                                       Action                               Requirement

                                                                     DEFINITIONS  (continued)

Radioactive Waste                  Definition
Management
DOE Order 5820.2A
Chapter III  (3)(i)(6)
Attachment 2  (1)                                          Waste containing amounts of radionuclides below
                                                         regulatory concern, as defined  by Federal regulations,  may
                                                         be disposed without regard to radioactivity content.

                                                                         DOE ALARA POLICY

Radiation Protection of the        As  Low As             The order adopts in the ALARA process  in planning and
Public and the                     Reasonable            carrying out all DOE  activities.   ALARA requires
Environment                        Achievable            judgement with respect to what  is reasonable achievable.
DOE Order 5400.5                   (ALARA)  Process       Factors that relate to social,  technological,  economic, and
Chapter 1(4)  and                                         other public policy considerations whall be evaluated to the
Chapter II  (2)                                           extent practicable.

                                                         Factors to be considered, at a  minimum,  shall  include:

                                                            !   maximum  dose  to  members  of the public;

                                                            !   collective  dose  to  the  population;
                                                            !   doses  for  each porcess alternative;

                                                            !   cost  for  each of the technological altenatives;

                                                            !   examination of the changes in cost among alternatives;
                                                              and

                                                            !   changes  in social impact associated with process
                                                              alternatives  (e.g.,  differential  doses from various
                                                              pathways).

-------
                                                                            TABLE A-3
                                                                            (Continued)
                                                                           Requirement

                                                                   DOE ALARA POLICY  (continued)
Radiation Protection of the
Puplic and the
Environment
DOE Order 5400.5
Chapter I (4)  and
Chapter II  (2)   (continued)
Radiation Protection of the
Public and the
Environment
DOE Order 5400.5
Chapter II (3)(b)
  Except for meeting requirements  of  NEPA,  qualitative
  analysis are acceptable,  in most  instances,  for ALARA
  judgements, especially when the  potential doses are well
  below the dose limit.  The bases  for  these  j udgements
  should be documented.  More detailed  analyses  should be
  considered if the decision might  result  in  doses that
  approach the limit.

GENERAL RADIOACTIVE MATERIALS DISPOSAL  REQUIREMENTS

  New or increased discharges of radionuclides  in liquid
  waste to active soil columns  and  virgin  soil  columns is
  prohibited.
                                                              MANAGEMENT OF LOW-LEVEL RADIOACTIVE  WASTE
                                                           !   protection  of  public  health and safety;

                                                           !   protection  of  the  public and the environment from
                                                         releases of radioactivity  (see chemical-specific
                                                         reguirements for radionactive dose  limitations);  and
                                                         Technical and administrative controls  shall  be  directed to
                                                         reducing the gross volume of waste  generated and/or the
                                                         amount of radioactivity requiring disposal.   Waste
                                                         reduction efforts shall include  consideration of process
                                                         modification, process optimization, materials substitution,
                                                         and decontamination.

-------
Radioactive Waste
Management
DOE Order 5820.2A
Chapter III  (3) (c)
(continued)
                                                                            TABLE A-3
                                                                            (Continued)

                                                                            Requirement

                                                     MANAGEMENT OF LOW-LEVEL  RADIOACTIVE  WASTE (continued)
                                                         Each DOE level-low waste  generator  shall separate
                                                         uncontaminated waste  from low-level waste to facility
                                                         cost effective treatment  and  disposal.

                                                         Each DOE low-level waste  generator  preparing a design
                                                         for a new process or  process  change shall incorporate
                                                         principles into the design that  will minimize the generation
                                                         of low-level waste.

                                                         Low-level waste shall be  characterized  with sufficient
                                                         accuracy to permit proper segregation,  treatment, storage,
                                                         and disposal.  This characterization shall ensure that, upon
                                                         generation after processing,  the actual physically and
                                                         chemical characteristics  and  maj or  radionuclide content are
                                                         recorded and known during all stages of the waste
                                                         management process.
                                                            !   maj or  radionuclides and their concentrations;  and

                                                            !   packaging data,  package weight, and external volume.
 These requirements will  apply
when low-level radioactive  waste
is transported off-site  for disposal.

-------
                                   Waste  Treatment
                                                                            TABLE A-3
                                                                            (Continued)

                                                                           Requirement

                                                       MANAGEMENT OF LOW-LEVEL RADIOACTIVE WASTE  (continued)
                                                         Waste treatment techniques such  as  incineration,  shreddinq,
                                                         and compaction to reduce volume  and provide  more  stable
                                                         waste forms shall be implemented as necessary  to  meet
                                                         performance requirement.  Use of waste  treatment
                                                         techniques to increase the lift  of  the  disposal  facility and
                                                         improve lonq-term facility performance,  by improved site
                                                         stability and reduction of infiltration water,  is required to
                                                         the extent it is cost effective.
                                   Waste  Shipment
Radioactive Waste
Manaqement
DOE Order 5820.2a
Chapter III  (3)(i)(1)-(6)
Generators shall provide an  annual  forecast  in the third
quarter of the fiscal year to the  field  orqanizations
manaqinq the off-site disposal  facility  to which the waste is
to be shipped.

Generator must receive advance  approval  from the
receivinq facility and shall certify  prior to shipment that
waste meets the receivinq facility  waste acceptance criteria
The certification proqram shall  be  auditable and able to
withstand independent review.

Low-level waste shall be disposed  of  by  methods
appropriate to achieve the performance obj ectives stated in
paraqraph 3a (listed above), consistent  with the radiation
dose limits in paraqraph 3b  (see chemical-sped fie
requirements).

-------
                                                                            TABLE A-3
                                                                            (Continued)

                                       Action                               Requirement

                                                       MANAGEMENT OF LOW-LEVEL RADIOACTIVE  WASTE  (continued)

Radioactive Waste                  Waste  Disposal        Engineered modifications  (stabilization,  packaging,  burial
Management                                               depth, barriers) for specific waste  types and for specific
DOE Order 5820.2A                                        waste compositions for each disposal site shall be
Chapter III  (3)(i)(l)-(6)                                developed to achieve the performance objective.  Site
(continued)                                              specific waste classification limits may  be developed if
                                                         operationally useful in determining  how  specific wastes
                                                         should be stabilized and packaged  for disposal.

                                                         Disposition of waste designated  as greater than class C, as
                                                         defined as 10 CFR  §61.55, must be  handled as a special
                                                         case.   Disposal systems for such waste must be justified by
                                                         a specific performance assessment  through the NEPA
                                                         process and with the concurrence of  DOE  headquarters.

                                                         The following are  additional disposal requirement intended
                                                         either to improre  stability of the disposal site or  to
                                                         specifications handling and provide  protection of the health and
                                                         safety of personnel at the disposal  site:

                                                            !   Waste must  not  be  packaged for  disposal in cardboard
                                                         or fiberboard boxes, unless such boxes meet DOT
                                                         requirements and contain established waste with a minimum
                                                         of void space.  For all types of contains,  void spaces
                                                         within the waste and between the waste and its packaging
                                                         shall be reduced as much are practical.

                                                            !   Liquid wastes,  or  wastes  containing free  liquid, must  be
                                                         converted into a form that contains  as little freestanding
                                                         and noncorrosive liquid as is reasonable  achievable, but,  in
                                                         no case, shall the liquid exceed 1 percent of the volume of
                                                         the waste when the waste is in a disposal contain, or 0.5
                                                         percent of the volume of the waste processed to a stable
                                                         form.

-------
TABLE A-3
(Continued)

Action Requirement

MANAGEMENT OF LOW-LEVEL RADIOACTIVE WASTE (continued)

Radioactive Waste Waste Disposal ! Waste must not contain, or be capable of generating
Management quantities of toxic gases, vapors, or fumes harmful to
DOE Order 5820.2A persons transporting, handling, or diposing of the waste.
Chapter III (3)(i)(l)-(6) This does not apply to radioactive gaseous waste packaged
(continued) as identified in the next requirement.
! Waste must not be pyrophoric. Pyrophoric materials
contained in waste shall be treated, prepared, and packaged
to be nonflammable.

Radioactive Waste
Management
DOE Order 5820.2A Design design criteria shall be based on analyses of physiographic,
Chapter III (3)(i)(8) environmental, and hydrogeological data to assure that the
policy and requirements of this Order can be met. The
criteria shall be also based on assessments of projected
waste volumes, waste characteristics, and facility and
disposal site performance.
Radioactive Waste
Management
DOE Order 5820.2A
Chather III (3)(i)(9) ! protect the environment, health and safety of the
public, and facility personnel;

! ensure the security of the facility:

! minimized the need for long-term control; and

! meet the requirements of the closure/post-closure plan.

Permanent identification markers for disposal excavations

and monitoring wells shall be emplaced.

-------
                                                                            TABLE A-3
                                                                            (Continued)
Radioactive Waste
Management
DOE Order 5820.2A
Chapter III  (3)(i)(9)
(continued)
                                                                           Requirement

                                                       MANAGEMENT OF LOW-LEVEL RADIOACTIVE  WASTE  (continued)
                                                         Site-specific comprehensive  closure  plans  shall be
                                                         developed for new and existing  operating low-level waste
                                                         disposal sites, the plan  shall  address  closure of disposal
                                                         sites with a 5-year period after  each is filled and shall
                                                         conform to the requirements  of  the NEPA process.
                                                         Performance obj ectives  for testing disposal sites shall be
                                                         developed on a case-by-case  as  part  of  the NEPA
                                                         process.
                                                         Corrective measures shall  be  applied  to new disposal sites
                                                         or individual disposal units  if  conditions  occur or are
                                                         forecasted that could j eopardize attainment of the
                                                         performance obj ectives of  this Order.

                                                         Inactive disposal facilities, disposal  sites,  and disposal units
                                                         shall be managed in conformance  with  RCRA,  CERCLA,
                                                         and the super fund Amendments  and Reauthorizaion Act
                                                         (SARA).

                                                         Closure plans for new and  existing  operating low-level
                                                         waste disposal facilities  shall  be  reviewed and approved by
                                                         the appropriate field organization.

-------
Radioactive Waste
Management
DOE Order 5820.2A
Chapter III  (3) (j )
(continued)
                                   Environmental
                                   Monitoring
                     TABLE A-3
                     (Continued)

                     Reguirement

MANAGEMENT OF LOW-LEVEL  RADIOACTIVE  WASTE (continued)

  Termination of monitoring  and  maintenance  activities at
  closed facilities  or sites  shall be  based  on an analysis of
  site performance at the end of the institutional control
  period.



  Each low-level waste treatment,  storage,  and disposal
  facility shall be  monitored by an  environmental monitoring
  program that, at a minimum,  meets  the following
  reguirements:

     !   The program shall be  designed to measure:

           operational effluent  releases;

           migration of  radionuclides;

           disposal  unit subsidence; and
                                                           !   Based  on  the  characteristics of the facility being
                                                         monitored, the program may  include,  but  not necessarily
                                                         be limited to, monitoring surface soil,  air,
                                                           !    The monitoring program shall be capable of detecting
                                                         changing trends in  performance  sufficiently in advance to
                                                         allow application of any necessary  corrective action prior
                                                         to exceeding performance obj ective.   The  monitoring
                                                         program shall be able to ascertain  whether  or not effluents
                                                         from each treatment, storage, or  disposal facility or
                                                         disposal site meet  the reguirements  of  applicable EH
                                                         Order.

-------
                   TABLE A-3
                   (Continued)

                   Requirement

    LOW-LEVEL RADIOACTIVE WASTE  CONFINEMENT

Low-level solid waste that is disposed  to the ground shall
be contained by a  site-specific  system  of barrier that may
include,  but not necessarily be  limited to,  waste form,
waste packaging, and the geologic  setting.

When site permeability characteristics  do not provide the
required confinement capabilities,  the  confinement system
shall be augmented by the following:

   !  constructing  low  permeability walls around the low-
level waste;

   !  lining the walls  and  bottom of the excavated area with
low permeability material; and
Means shall be provided to minimize  contact  of emplaced
low-level waste with water.  Active  water  control measures
shall not be required following  permanent  closure.   Typical
requirements for water control are as  follows:

   !   placing  a  layer  of  higher permeable material beneath
the low-level waste to channel any percolating water to a
s ump ;
   !   use  of  a  suitable low-permeability cover material e.g.,
clay) over the disposal  area  to  prevent  contain of the waste
by infiltrating rainwater.  This  cover material shall be
protected by a layer of  overburden  (e.g.,  sand,  gravel,  top
soil).
   !   temporary  protective covers (e.g., tarpaulin) before the
completion of the natural  in-piace  soil barrier over  the low-
level waste;

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                                                                              TABLE A-3
                                                                              (Continued)
General Desert Criteria
DOE Order 6430.1A
1324-6
                                                                             Requirement

                                                         LOW-LEVEL RADIOACTIVE WASTE CONFINEMENT  (Continued)

                                                             !   revegation  of  the  overburden layer;  and

                                                             !   other  suitable and reliable means for minimizing water
                                                           contact with low-level waste.
                                                             !   Primarily  confinement  consists  of process systems
                                                           equipment and its associated ventilation  and  off-gas  system,
                                                           storage containers,  or other waste and  site-specific
                                                           engineered barriers.

                                                             !   Secondary  confinement  consists  of process cell barriers
                                                           and  the ventilation systems associated  with the cells  or
                                                           building, or a large storage building or  structure.   In  some
                                                           cases,  a drum, cask, or other waste  and site-specific
                                                           engineered barrier shall provide secondary confinement.
                                                             !   In the absence  of  unplanned natural processes or human
                                                           contact with a low-leve waste disposal  facility,  calculated
                                                           contaminant levels in groundwater at the  site  boundary
                                                           shall not exceed the maximum contaminant  levels  (MCLs)
                                                           established pursuant to the Safe Drinking Water Act  (see
                                                           chemical-specific requirements).

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                                                                            TABLE A-3
                                                                            (Continued)
                                                      LOW-LEVEL RADIOACTIVE WASTE CONFINEMENT  (continued)

                                                           !    In  the  event  of human-induces activities following
                                                         permanent closure, or reasonably  forseeable  but
                                                         unplanned natural processes, the  guidelines  of DOE Order
                                                         6430.1 A, Section 1300-1.4.2, Accidental  Realease, shall
                                                         not  be violated.   Institutional controls  may be  relied on for
                                                         a limited time following closure.   For  the purposes of
                                                         calculation,  these controls  shall  be  relied  on for more
                                                         than 100 years following permanent closure.
Health and Environmental
Protection Standards  for
Uranium and Thorium
Mill Tailings
40 CFR §19202  (a)
Subpart A

Health and Environmental
Protection Standards  for
Uranium and Thorium
Mill Tailings
40 CFR §192.20
Subpart C

Health and Environmental
Protection Standards  for
Uranium and Thorium
Mill Tailings
40 CFR §192.32  (b)(1)(i)
Subpart D
Implementation
                         Reasonable assurance  to  show compliance with 40 CFR
                         §192 . 02  (Subpart A) standards should be done through the
                         use  of analytical  models  and site-specific analyses.
                         Disposal areas  for  the  management of uranium byproduct
                         material after  closure  shall  each comply with the closure
                         performance  standard  in 40  CFR §264.111 with respect to
                         nonradiological  hazards and shll be designed to provide
                         reasonable assurane of  control of radiological hazards to
                         be effective  for 1,000  years,  to the extent reasonable, and,
                         in any case,  for at least  200  years

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                                                                            TABLE A-3
                                                                            (Continued)
Health and Environmental
Protection Standards for
Uranium and Thorium
Mill Tailing
40 CFR §§ 192.40-192.42
Subpart E
Management of
Thorium Byproduct
Material
The provided for the management  of  uranium byproduct
material  (40 CFR §192.32)  shall  apply  to thorium
byproduct material and provision applicable to the element
uranium shall also apply to  the  element  thorium
                                                          MANAGEMENT OF RESIDUAL RADIOACTIVE MATERIAL
Radiation Protection of
Public and the
DOE Order 5400.5
Chapter II (5)

Radiation Protection of
Puplic and the
Environment
DOE Order 5400.5
Chaptern IV  (6)
Radiation Protection of the
Puplic and the
Environment
DOE Order 5400.5
Chapter IV (6)(d)
                                   Release  of  Property
 Control of Residual
 Radioactive
 Material Above the
 Guidelines
  Residual radiactive material  with  concentration above the
  generic guidelines  (see  chemical-specific reguirements)
  shall be managed in accordance  with  Chapter II,
  Reguirements for Radiation  Protection  of the Public and
  the Environment, and  operational and control
  reguirements.

  To properly manage uranium, thorium, and their decay
  products, assess to property  and use of on-site materials
  contaminated by residual  radioactive material  should be
  controlled through appropriate  administrative  in physical
  controls such as those described in  40 CFR 192.   These
  controls should be designed to  be  effective to the extent
  reasonable for at least  200 years.
Radian Protection of the
Public and the
Environment
DOE Order 5400.5
Chapter IV (7)
                        If special  specific  property circumstances indicate that the
                        concentration  guidelines  or authorized limits are not
                        appropriate, supplemental limits or an exception may be
                        reguested to those guidelines or limits.

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                                                                            TABLE A-4
                                                               OTHER ACTION-SPECIFIC REQUIREMENTS

      Citation                        Action



Ohio General Provision             Prevention  of  Air     Measures shall be taken to adopt and maintain  a  program            Applicable
on Air Pollution Control           Pollution Nuisance     for the prevention, control, and abatement of  air  pollution
OAC 3745-15-07                                           in order to protect and enhance the quality  of the state's
ORC 3704.01-.05                                          air resource so as to promote the public health, welfare,
                                                         and economic vitality of the people of the state.

                                                         The emission of escape into open air from any  source
                                                         whatsoever of smoke, ashes, dust, dirt, grime, acids,
                                                         fumes,  gases,  vapor, odors, and combinations  of  the
                                                         above in such a manner or in such amounts as  to  endanger
                                                         the health, safety, or welfare of the public  or  to cause
                                                         unreasonable inj ury or damage to property shall  be
                                                         declared to be a public nuisance.  It is unlawful  for  any
                                                         person to cause, permit, or maintain any such  public
                                                         nuisance.

Ohio Permit to Install             Best Available        The installation or modification and operation of  an  air
New Sources of Pollution           Technology  (BAT)       contaminant source must employ the best available
OAC 3745-31-05 (A)(3)                                    technology.

Ohio Ambient Air Quality           Particulate Ambient   The level of the primary and secondary 24-hour ambient             Applicable
Standards                          Air Quality           air guality standards for total suspended particulates is  150
OAC 3745-17-02                     Standards              • g/m3, 24-hour average concentration.
OAC 3745-17-05
                                                         The significant and avoidable deterioration  of  air  guality
                                                         in any part of the area where presently  existing  air  guality
                                                         is egual to or better than the particulate ambient  air
                                                         guality standards shall be prohibited.

                                                         Visible particulate emissions from any stack  shall  not              Applicable
                                                         exceed 20 percent opacity, as a six-minute average.
                                                         Transient exceedance limits are included in  this
                                                         regulation.

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                                                                            TABLE A-4
                                                                 OTHER ACTION-SPECIFIC REQUIREMENTS
Ohio Emissions of
Particulate Matter
OAC 3745-17-07(B) (4) ,
(5),(6)
There shall be no visible particulate  emissions  from any
paved roadways or parking area except  for  a  period of time
not to exceed six minutes during  any sixty-minutes
observation period.
                                                         There shall be no visible particulate emissions  from  any
                                                         unpaved roadway, parking area, or material storage  piles
                                                         except for a period of time not to exceed thirteen  minutes
                                                         during any sixty-minute observation period.

                                                         No person cause or permit any fugitive dust  source
                                                         to be operated; or any material to be handled, transported
                                                         or stored; or a building or its appurtenances  or  a  road to
                                                         be used constructed, altered, repaired or demolished
                                                         without taking or installing reasonably available control
                                                         measures to prevent fugitive dust from becoming  airbone.
                                                         Such reasonable available control measures shall  include,
                                                         but not be limited to, one or more of the following which
                                                         are appropriate to minimize or eliminate visible  particulate
                                                         emissions of fugitive dust:

                                                           !  the  use of water  or  other  suitable  dust suppression
                                                         chemicals or the control of fugitive dust from the
                                                         demolition of existing building or structures, construction
                                                         operation, the grading or roads or the clearing  of  land; or

                                                           !  the  periodic  application  of  asphalt,  oil, water, or other
                                                         suitable dust suppression chemicals on dirt  or gravel roads
                                                         and parking lots,  and any other surfaces which cause
                                                         emissions of fugitive dust.
                                                                                              This  reguirement  is  applicable only
                                                                                              to certain  cities  in Butler and
                                                                                              Hamilton  Counties.
                                   Restriction
                                   Particulate
                                   Emissions
The following are restriction  for particulates  from any
operation, process, or activity which  releases  or  may
release particulate emission into the  ambient  air.   These
limits are based on the weight of material  being
processed.
                                                                                                                              Applicable

-------
Ohio Particulate Matter
Standards
OAC 3745-17-11
(continued)
                                       Action
Restriction on
Particulate
Emissions
                                          TABLE A-4
                                         (continued)

                                         Requirement

                             AIR  POLLUTION CONTROL (Continued)
Process Weight at
Maximum Capacity
     Ib/hr.
Standard of Performance
for Nonmetallic Mineral
Processing Plant
40 CFR §60.672
(a) , (d) ,  (e)
National Pollutant
Discharge Elimination
System
40 CFR §122.26  (a)(1)(ii)
40 CFR §122.26  (b) (14)
(v) , (x)
                                                                                                                      Engineering  controls  will be
                                                                                                                      implemented  to  monitor and
                                                                                                                      control  stormwater  runoff during
                                                                                                                      removal,  treatment,  and disposal of
                                                                                                                      Operable  Unit 2 material.

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                                                                            TABLE A-4
                                                                            (continued)
National Pollutant
Discharge Elimination
System
40 CFR §122.26  (a)(1)(ii)
40 CFR §122.26  (b) (14)
(v),(x)  (continued)
Guidelines for
Specification of Disposal
Sites for Dredged or Fill
Material
40 CFR §230.10
                                  Storm Water              !   construction activity including clearing grading, and
                                  Discharge             excavation activities that disturbs  5  acres or more of total
                                  Associated with       land area.
                                  Industrial Activity
                                                           !    if  there  is  a  practicable alternative to the proposed
                                                         discharge which would have less  adverse  impact on the
                                                         aguatic ecosystem, so long as, the  alternative does  not
                                                         have other significant adverse environmental
                                                         conseguences.

                                                           !    unless appropriate  and  practicable steps have been
                                                         taken which will minimize potential adverse impacts  of the
                                                         discharge on the aguatic ecosystem.
                                                                                                                              Applicable
                                                           !    causes  or  contributes,  after consideration of disposal
                                                           !    j eopardizes  the continued existence of species listed  as
                                                         endangered or threatened under  the  Endangered  Species
                                                         Act  of 1973, as amended, or  results  in  likelihood of the
                                                         destruction or adverse modification  or  a habitat which is
                                                         determined to be as  critical habitat  under  the Endangered
                                                         Species Act of 1973,  as amended.

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                                                                            TABLE A-4
                                                                           (continued)
Clean Water Act                   Nationwide  Permits      An activity is authorized under an NWP only  if  that               Applicable          In a January 17, 1992 letter  to  the
Nionwide Permit                   -  Terms  and            activity and the permittee satisfy all of the following                               U.S. Army Corps of Engineers,
Program                           Conditions              NWPs terms and conditions.   Potentially applicable NWPs                               OEPA conditionally certified  that
33U.S.C. §1341(a)(l),(d)                                 include:                                                                               proj ects authorized by these
33 CFR §330.1  (c)                                                                                                                               Nationwide Permits will comply
                                                           !  Nationwide  Permit  #26  - Headwaters  and  Isolated                                  with the  applicable  privis ions  of
                                                         Waters Discharges                                                                      the Federal Water Pollution
                                                                                                                                                Control Act.
                                                                  The permittee notifies the district  engineer  if  the
                                                                  discharge would cause the loss of waters  of the
                                                                  United States greater than one acre.

                                                                  For discharge in special aguatic sites, including
                                                                  wetlands, the notification must also include  a
                                                                  delineation of affected special aguatic sites,
                                                                  including wetlands.

                                                                  The discharge, including all attendant  features,
                                                                  both temporary and permanent, is part  of  a single
                                                                  and complete proj ect.

                                                           !   Nationwide  Permit #38 -  Cleanup  of  Hazardous  and
                                                         Toxic Waste

                                                                  This permit authorizes activities reguired
                                                                  to effect the containments,  stablization  or removal
                                                                  of hazardous or toxic waste  material that are
                                                                  performed ordered, or sponsored by  a government
                                                                  agency with established legal or regulatory
                                                                  authority provided the permittee notifies the district
                                                                  engineer.

                                                                  For discharge in special aguatic sites, including
                                                                  wetland, the notification must also  include a
                                                                  delineation of affected special aguatic sites,
                                                                  including wetlands.

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                                                                           TABLE A-4
                                                                           (continued)
Clean Water Act
Nationwide Permit
Program
33 U.S.C. §1341  (a)(1),(d)
33 CFR §330.1  (c)
(continued)

Clean Water Act
Nationwide Permit
Program
33 CFR §330.4  (c)(1)
Ohio Section 401 Water
Quality Certification
OAC 3745-32
         This nationwide permits does  not  authorize the            Applicable
         establishment of new disposal sites  or  the
         expansion of existing sites used  for the disposal of
         hazardous or toxic waste.
State 401 water quality certification  pursuant  to section           Applicable
401 of the Clean Water Act, or waiver  thereof,  is
required prior to the issuance or  reissuance  of individual
or nationwide permit authorizing activities which may
result in a discharge into waters  of the  United States
                                                        Permit will be required for the discharge  of  dredged or
                                                        fill material into waters of the United  States  including
                                                        waste.   Certain discharges specified  in  33  CFR  Part
                                                        330 are permitted by that regulation  (nationwide  permits).

                                                        If a discharge of dredged or fill material  is not and
                                                        by 33 CFR Part 330  (Nationwide Permits), an individual
                                                        section 404 permits will be required  for the  discharge of
                                                        dredged or fill material into waters  of  the United States.

                                                        Discharges of dredged or fill material into waters of the
                                                        United States done by or on behalf  of any  Federal agency,
                                                        other than the Corps of Engineers,  the subj ect  to the
                                                        authorization procedures of these regulations.
                                                        No person shall cause pollution  or place  or  cause to be
                                                        placed any sewage, industrial waste,  or other  wastes in a
                                                        location where they cause pollution  of any waters of the
                                                        state.
                                                                                                                             Applicable

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                   TABLE A-4
                   (continued)
No person to whom a permit has been  issued  shall  place
or discharge, or cause to be placed  or  discharged,  in any
waters of the state any sewage,  industrial  waste,  or  other
wastes in excess of the permissive discharges  specified
under such existing permit without first  receiving a  permit
from the Director to do so.
             NOISE POLLUTION  CONTROL

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                                                                            TABLE A-5
                                                                   LOCATION-SPECIFIC REQUIREMENTS

                                                                           Requirement

                                                               THREATENED AND ENDANGERED SPECIES PROTECTION
Procedures for
Implementing the
National Environmental
Policy Act
40 CFR §6.302(h)
Endangered and
Threatened Wildlife and
Plants
50 CFR §17.21,  §12.94
Endangered Species
and Critical Habit
All Federal agencies must insure that  any  action
authorized, funded, or carried  out by  them is  not likely
to jeopardize the continued existence  of any  listed
species or result in the destruction or adverse
modification of the constituent elements essential to the
conservation of a listed species within a  define critical
habitat.
                                                                                                                             Applicable
In 1994, surveys were conducted  for
potential threatened or endangered
plant species; no individuals were
found.   In 1993 and 1994, surveys
have verified the preference of  the  state-
threatened Sloan's crayfish
[Oronectes sloanii]  in Paddys Run.
Suitable habit for the Indiana bat
[Myotis sodalis], a federally-listed
endangered species,  also exists  on the
Fernald property.
                                                         A biological assessment shall evaluate the potential
                                                         effects of the action on listed and proposed  critical
                                                         habitat and determine whether any such species  or
                                                         habit are likely to be adversely affected by  the action
                                                         and is used in determining whether gases consultation
                                                         or a conference is necessary.
                                                                                                                              Applicable
                                                                                                                     No  critical  habitat is present on the
                                                                                                                     Fernald  property.
                                   Endangered  Animal
                                   Species
                                                                                                                              Applicable
Ohio Endangered Species
Regulations
ORC 1518.02
OAC 1501:18-1
                      No person shall  root  up,  inj ure,  destroy,  remove,  or
                      carry away on or  from public  highways,  public
                      property, or waters of the  state,  or  on or from the
                      property of another,  without  the  written permission of
                      the owner, lessee, or other person entitled to
                      possession, any  endangered  or threatened plant listed in
                      OAC 1501:18-1.
                                                                                                                              Applicable

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Classification of Solid
Wase Disposal Facilities
and Practices
40 CFR §257.3-2
                                                                            TABLE A-5
                                                                            (Continued)

                                                                           Requirement

                                                    THREATENED AND ENDANGERED SPECIES PROTECTION  (continued)
                                                         Solid waste disposal facilities or practices  shall  not
                                                         result in the destruction or adverse modification of  the
                                                         critical habitat of endangered or threatened  species  as
                                                         identified in 50 CFR Part 17.
                                  Antiquity
                                  Preservation
Archaeoloqical
Resources Protection Act
16 U,S.C. §47099
Procedures for
Implementing the
Nationly Environmental
Policy Act
40 CFR §6.301(c)
HISTORIC AND CULTURAL RESOURCE  PROTECTION

   No person may appropriate excavate,  inj ure,  or
   destroy any historic or prehistoric  ruin  or  monument,
   or any obj ect of antiquity situated  or  controlled by the
   Government of the United States.
   Whenever any Federal agency  finds,  or  is  notified,  in
   writing by an appropriate history  or archaeological
   authority, that its activities  in  connection  with any
   Federal construction project  or  Federal  licensed
   proj ect, activity, or program may  cause  irreparable loss
   or destruction of significant scientific  prehistorical,
   historical, or archaeological data, such  agency shall
   notify the Secretary of the  Interior,  in  writing and
   shall provide the Secretary with appropriate
   information concerning the proj ect, program,  or
   acitvity.
                                                                                                                              Applicable
                                                                                                                                Applicable
An assessment of the Operable Unit  2
waste units was performed  in March
1993 and it was determined that  the
areas had already been sufficiently
disturbed so that the would be no
requirement to consult the State
study area.  Any other proposed  areas
of distrubance for Operabler Unit 2
remedial actions will be survyed and
the SHPO consulted as necessary.

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                                                                            TABLE A-5
                                                                            (Continued)
                                                                           Requirement

                                                       HISTORIC AND CULTURAL RESOURCE PROTECTION  (continued)
Archaeological
Resources Potection Act
16 U.S.C. §47099
Procedures for
Implementing the
National Environmental
Policy Act
40 CFR §6.301(c)
Protection of
Archaeological
Resources
43 CFR §7.4(a)
(continued)
No person may excavate,  remove,  damage,  or
otherwise alter or deface  or  attempt  to  excavate,
 remove,  damage, or otherwise  alter or deface any
archaeological resource  located  on public lands  unle
such activity is pursuant  to  a permit.
If an EPA activities may cause  irreparable  loss  or
destruction of significant  scientific,  prehistoric
historic, or archaeological data,  the  responsible official
or the secretary of the Interior  is  authorized to
undertake data recovery preservation activities.
Procedures for
Implementing the
National Environmental
Policy Act
40 CFR §6.301  (a),(b)
A Federal agency must take  into  account  how each of
its undertaking could affect  historic  properties.   The
purpose of this Act is not  only  to  protect  those
properties listed in or  eligible for the National  Register
of Historic Places, but  also  those  properties  that have
not been listed or formally determined eligible for the
listings.
                                                         Prior to any Federal undertaking which  may  directly
                                                         and adversely affect any National  Historic  Landmark,
                                                         the head of the responsible agency shall, to the extent
                                                         possible,  minimize the harm to  such landmark.
Native American Graves
Protection and
Repatriation Act
25 U.S.C. §3001
                                                                                                                              Applicable

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                                                                            TABLE A-5
                                                                           (Continued)
      Citation
                                                                           Requirement

                                                       HISTORIC AND CULTURAL RESOURCE PROTECTION  (continued)
                                                                 FLOODPLAIN/WETLANDS PROTECTION
Procedures for
Implementating the
National Environmental
Policy Act
40 CFR §6.302(a)
Protection of
Wetlands
Federal agencies conduction certain  activities  must
avoid, to the extent possible, the adverse  impacts
associated with the destruction or loss  of  wetlands  and
to avoid support of new construction  in  wetlands  when
a practicable alternative exists.
                                                                                                                                Applicable
 An updated site-wide delineation of
 Fernald wetlands, performed in
 accordance with the U.S. Army Corps
 of Engineers Wetland Delineation
 Manual, was completed in March
 1993.  Although there are wetlands
 located near the Lime Sludge Ponds,
 the Solid Waste Landfill is the only
 subunit with wetlands located inside
 the battery limits.  These wetlands
 may be affected during the Operable
 Unit 2 remedial action.  Wetlands  in
 other areas of the site may also be
 impacted by construction and
 operation of the on-site disposal
 facility.  A Wetland/Floodplain
 Assessment was conducted.
Procedures for
Implementing the
National Environmental
Policy Act
40 CFR §6.302(b)
Floodplain
Management
Federal agencies must evaluate the potential  effects  of
action they may take in a floodplain to  avoid,  to  the
extent possible, adverse effects associated with direct
and indirect development of a floodplain.
 An update flood plain determination
 was performed for Paddys Run in
October 1993 using the Army Corps
 of Engineers'  standard HEC2 water
 surface profile analysis program.  The
 10 0-year flood elevations reach the
 wastern slope of the Inactive Flyash
 Pile and the toe of the South Field
 slope.   Indirect, short-term floodplain
 impacts will occure during remediation.
 A Wetland/Floodplain Assessment was

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                                                                            TABLE A-5
                                                                            (Continued)

                                                                           Requirement

                                                               FLOODPLAINS/WETS PROTECTION  (continued)

DOE Compliance with                Eloodplain/Wetlands   DOE shall excercise leadership  and  take  action to:
Floodplain/Wetlands
Environmental Review                                        !   avoid  to  the  extent  possible the long- and short-term
Requirements                                             adverse impacts associated with the destruction of
10 CFR §10223 (a) ,                                        wetlands the occupancy and modification  of
(b)(1),(2),(3),(5),(6),(c),                              floodplains and wetlands, and avoid direct and indirect
(d),(e)                                                   support of floodplain and wetlands  development
                                                         whenever there is a practicable alternative.

                                                            !   incorporate  floodplain  management goals and
                                                         wetland protection consideration into its  planning,
                                                         regulatory, and decision-making process ess and shall to
                                                         the extent practicable:
                                                           !   undertake  a  careful evaluation of the potential
                                                         effect of any DOE acton  taken  in  a  floodplain and
                                                         any  new construction undertaken by  DOE  in wastelands
                                                         not  located in a floodplain

                                                           !   identify,  evaluate  and as appropriate implement
                                                         alternative/wetlands impacts

                                                           !   provide  opportunity for early public review of any
                                                         plans or proposals for actions in floodplains and new
                                                         construction in wetlands

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                                                                            TABLE A-5
                                                                            (Continued)
DOE Compliance with
Floodplain/Wetlands
Environmental Review
Requirements
10 CFR §1022.5(b),(h)
DOE Compliance with
Floodplain/Wetlands
Environmental Review
Requirements
10 CFR §1022.11(a) , (b) ,
(c)
                                   Floodplain/Wetlands
DOE Compliance with
Floodplain/Wetlands
Environmental Review
Requirements
10 CFR §1022.12(a)
                                   Floodplan/Wetlands
                                   Floodplain/Wetlands
This part shall apply to all  proposed  floodplain/
wetlands, actions, includinq  those  sponsored j ointly with
other agencies, where practicable alternatives  to  the
proposed actions are still  available.

The policies and procedures of  this part  which  are
applicable to floodplain action shall  apply to  all
proposed actions which occur  in a wetlands  located in a
floodplain.

Concurrent with its review  of a proposed  action to
determine appropriate NEPA  requirements,  DOE shall
determine applicability of  the  floodplain management
and wetlands protection requirements of this part.

In making a floodplain determination DOE  shall  utilize
the Flood Insurance Rate Maps (FIRMs)  or  the Flood
Hazard Boundary Maps  (FHBMs)  prepared  by  the
Federal Insurance Administration of the Department of
Housing and Urban Development to determine  if a
proposed action is located  in the base or critical action
floodplain, as appropriate.   For a  proposed action in an
area of predominantly Federal or State land holdings
where FIRM or FHBM maps are not available,
information shall be sought from the land administering
agency  (e.g., Bureau of Land  Management,  Soil

floodplain analysis expertise.

If DOE determines, pursuant to  10 CFR  §§  1022.5 and
1022.11, that this part is  applicable  to  the proposed
area, DOE shall prepart a  floodplain/wetlands
assessment, according to the  requirements in this
section  (10 CFR §1022.12).
                                                                                                                              Applicable

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                                                                            TABLE A-5
                                                                           (Continued)
DOE Compliance with
Floodplain/Wetland
Environmental Review
Requirements
10 CFR §1022.15(a)
                                   Eloodplain/Wetlands
                                   Floodplain
                                   Stream,  Lake,
                                   Wetland
If DOE finds that no practicable  alternative  to  locating
in the floodplain/wetlands is available,  consistent with
the policy set forth in Executive Order  11988, DOE
shall, prior to taking action, design,  or modify its
action in order to minimize potential harm to or within
the floodplain/wetlands.
                                                                                                                              Applicable
                                                                                                                              Applicable
Safe Drinking Water Act
42 U.S.C. §1424(e)
All Federal financially assisted projects  constructed in
the area of a soil source aguifer  and  its  principal
recharge zone will be subj ect to EPA's  review to
insure that these projects are designed and  constructed
so that they do not create a significant hazard  to public
health.
                                                         A sanitary landfill facility may not be located within
                                                         the surface and subsurface areas surrounding a public
                                                         water supply well through which contaminants may
                                                         move toward and may reach the public water supply
                                                         well within a period of 5 years.
                                                                                                                              Applicable
A notthe in 53 FR 15876  (May  4,
1988) designated the Buried Valley
Aguifer System of the Great Miami/
Little Miami River Basins of
southern Ohio as a sole  or
principal source of drinking  water.
The Fernald site is located above this
aguifer.

-------
                                                                            TABLE A-5
                                                                           (Continued)
                                  Any                    A sanitary landfill facility cannot be located above  an
                                                         unconsolidated aquifer capable of sustaning a yield of
                                                         100 gallons per minute for a 24-hour period to an
                                                         existing or future water supply well located with
                                                         1,000 feet of the limits of solid waste placement,
                                                         unless deemed acceptable by the Director.

                                  Water  Supply  Well      The limits of sold waste placement cannot be located
                                  or Developed  Spring   within 1,000 feet of an existing water supply well or
                                                         developed spring unless it is defined acceptable by the
                                                         Director or it is:

                                                           !   controlled by  the  applicant,  is needed  as  a source of
                                                         nonpotable water,   no other reasonable alternate water
                                                         source is available, and the well is constructed to
                                                         prevent contamination of the groundwater, OR
Applicable
OEPA Guidance on Solid
Waste Siting Criteria:
Material Acceptable to
the Director
GD202.104
                                  Any
                                                         The isolation distance between the uppermost aguifer
                                                         system and the bottom of the recompacted soil liner of
                                                         a sanitary landfill system cannot be less than 15 feet  of
                                                         in site or added geologic material defined acceptable
                                                         by the Director.
                                                           !   the geologic material must  be  impermeable enough
                                                          ~j  it will  not store,  transmit or yield a significant
                                                                              well or spring
                                                         amount of water to
                                                                                                                              Applicable

-------
                                                                            TABLE A-5
                                                                           (Continued)
OEPA Guidance on Solid            Any                      !   the geologic material  must  be  able to impede both
Waste Siting Criteria:                                   physically and chemically, the flow of  leachate
Material Acceptable to                                   constituents through it
the Director
GD202.104  (continued)
                                                           !   be recompacted  in  a manner  that when the landfill
                                                         is constructed on it, no damage to the landfill  liner  will
                                                         occur due to settling of the added material

Ohio Solid Waste                  Any                    The  limits of waste placement cannot  be located  waste                Applicable
Disposal Regulations                                     300  feet of the sanitary landfill facility's  property  line,
OAC 3745-27-07                                           unless deemed acceptable by the Director.
(H) (4) (b)

                                  Any                    The  limits of solid waste placement  cannot be  located                Applicable
                                                         within 1,000 feet of an existing domicile whose  owner
                                                         has  not consented in writing to the  location  of  the
                                                         sanitary landfill facility.

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                                         TABLE  A-5
                                        (Continued)
Protection of Human
Health and the
Environment
The director of environmental protection shall adopt
and may modify, suspend, or  repeal  rules for  all solid
waste facilities in order to ensure that the  facilities
be located, maintained,  and  operated,  and will undergo
closure and post-closure care,  in a sanitary  manner so
as not to create a nuisance, cause  or  contribute to
water pollution, create  a health hazard,  or violate 40
CFR § 257.3-2 or 257.3-8.
                              RADIOLOGICAL  SITING CRITERIA

                      Disposal  site  selection criteria (based on planned waste
                      confinement  technology)  shall be developed for
                      establishing new  low-level waste disposal sites.

                      Disposal  site  selection shall be based on an evaluation
                      of the  propective site  in conjunction with planned
                      waste confinement technology, and in accordance with
                      the National Environmental Policy Act process.
                         !   Site selection criteria shall address the  impact  on
                      current  and  projected  population,  land use resources
                      development  plans  and  nearby public facilities,
                      accessibility  to transportation routes and utilities, and
                      the location of waste  generation.

-------
Joint NRC-EPA
Guidance on Siting of
Mixed Low-Level
Radioactive and
Hazardous Waste Units
(March 13, 1987)
                   TABLE A-5
                   (Continued)

                   Requirement

     RADIOLOGICAL  SITING CRITERIA  (continued)

Areas with highly  vulnerable hydrogeology deserve
special attention  in the sitting of  a  mixed low-level
waste disposal facility.  Hydrogeology is considered
vulnerable when groundwater travel time along  any
10 0-foot flow path from the edge of  the engineered
containment structure in less than approximately 100
years.   Disposal sites located  in areas of vulnerable
hydrogeology may reguire extensive,  site-specific
investigations which could lead to and provide bases
for restrictions or modification to  design or  operating
pratices.   However, a finding that a site is  located in
an area of vulnerable hydrogeology alone,  based on the
EPA criteria, is not considered sufficient to  prohibit
siting under RCRA.

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               OPERABLE UNIT 2





            RESPONSIVENESS SUMMARY








                                     TABLE OF CONTENTS





Table of Content	  i





List of Tables 	 iii





List of Acronyms aand Abbreviation 	  iv





1.0     Purpose/Overview 	 RS-1-1





2.0     Puplic Involvement 	 RS-2-1





3.0     Summary of Issues and Responses 	 RS-3-1





        Issue 1   On-Property Disposal Versus Off-Site Disposal  	 RS-3-7





                  (a)       Opposition to On-Site Disposal Facility 	 RS-3-7





                  (b)       Acceptance of On-Site Disposal Facility 	 RS-3-9





                  (c)       Disposal at the Nevada Test Site 	 RS-3-10





                  (d)       Commercial Off-Site Disposal Facility 	 RS-3-11





                  (e)       Off-Site Regional Disposal Facility 	 RS-3-11





                  (f)       Protection of the Great Miami Aquifer 	 RS-3-11





        Issue 2   Design of the Disposal Facility 	 RS-3-13





                 (a)         Buffer Zone 	 RS-3-13





                 (b)         Meaning of Permanence 	 RS-3-13





                 (c)         Fixing a Problem May Create Bigger Problems 	 RS-3-14





                 (d)         Independent Expert 	 RS-3-14





                 (e)         Size 	 RS-3-15





        Issue 3   Waste to be placed in the Disposal Facility 	 RS-3-17





                 (a)         Waste from Other Sites 	 RS-3-17





                 (b)         Implementation of Waste Acceptance Criteria 	 RS-3-17





                 (c)         Calculation of Waste Acceptance Criteria 	 RS-3-19





        Issue 4   Excavation and Monitoring Techniques During Remedial Activities... RS-3-23

-------
         (a)         Real-Time Monitoring 	 RS-3-23





         (b)         Dilution of Waste 	 RS-3-24





         (c)         As Low As Reasonably Achievable  (ALARA) 	 RS-3-24





         (d)         Pollution Prevention 	 RS-3-24





         (e)         Transition 	 RS-3-25





Issue 5   Monitoring/Maintenance of Disposal Facility 	 RS-3-27





         (a)         Long-Term Monitoring/Maintenance 	 RS-3-27





         (b)         Costs and Commitment 	 RS-3-28





         (c)         Availability of Data and Reports 	 RS-3-29





Issue 6   Cost 	 RS-3-31





         (a)         Alleged Misreprsentation of Monitoring/Maintenance Cost. RS-3-31





         (b)         Cost Should Not Be A Factor 	 RS-3-32





         (c)         Site-Wide Perspective 	 RS-3-32





Issue 7   Future Use/Ownership 	 RS-3-33





         (a)         Ownership of FEMP Site 	 RS-3-33





         (b)         Above Background Levels - Puplic's hight-To-Know 	 RS-3-33





         (c)         Future Monetary Benefit 	 RS-3-34





Issue 8  Puplic Participation Process 	 RS-3-35





         (a)         Extension of the Pubic Comment Period  	 RS-3-35





         (b)         Pubic Involvement After the ROD  	 RS-3-35





         (c)         Future Review of the ROD 	 RS-3-36





         (d)         NTS Review 	 RS-3-37





         (e)         Puplic Understanding 	 RS-3-38





Issue 9  Misrepresentation of Risk and Background 	 RS-3-39





         (a)         Risk Levels 	 RS-3-39





         (b)         Background Levels 	 RS-3-40





Issue 10  Use of New Technology in the Future 	 RS-3-43

-------
                  (a)        Review of New Technologies 	 RS-3-43

                  (b)        Retrievability of Waste 	 RS-3-44

        Issue 11  Intergration and Consistency with Other Operable Units 	 RS-3-45

                  (a)        Consistent Cleanup Levels 	 RS-3-45

                  (b)        Comprehensive ROD 	 RS-3-45

        Issue 12   Transportation 	 RS-3-47

                  (a)        Safer Transportation Methods 	 RS-3-47

        Issue 13   Process Knowledge 	 RS-3-48

4.0     Summary of Comments Not Resulting in Issues 	  RS-4-1

Attachment I - Formal Oral and Written Comments

Attachment II - Puplic Meeting Transcript

Attachment III - Distribution List

                                  LIST OF TABLES

  Table                                                                                 Page

  Table RS-3-1    Summary of Issue Statements 	  RS-3-2

  Table RS3-2     Comment Identification and Tracking 	  RS-3-4

  Table RS-9-1    Conversion of Uranium Isotopic Action to Total Uranium
                  in mg/kg (ppm)  for Surface Soil 	 RS-3-41
ALARA
ARARs
CAB
CERCLA
CFR
COG
DOE
EPA
FCTF
FEMP
FS
FS/PP-EA
ILCR
mg/g
NCP
OEPA
      ACRONYMS AND ABBREVIATIONS1

as low as reasonable achievable
applicable or relevant and appropriate reguirements
Citizens Advisory Board (state of Nevada)
Comprehensive Environmental Response, Compensation, and Liability Act
Code of Federal Regulations
contaminant of concern
U.S. Department of Energy
U.S. Environmental Protection Agency
Fernald Citizen Tast Force
Fernald Environmental Management Project
feasibility study (process)
Feasibility Study/Proposed Plan-Environmental Assessment  (report)
incremental lifetime cancer risk
milligram per kilogram
National Oil and Hazardous Substances Pollution Contingency Plan
Ohio Environmental Protection Agency

-------
pCi/g                 picoCurie per gram
PEIC                  Public Environmental Information Center
ppm                   parts per million
RA                    remedial action
RD                    remedial design
RI                    remedial investigation (process)
RI/FS                 remedial investigation/feasibility study
ROD                   Record of Decision
SARA                  Superfund Amendments and Reauthorization Act

IWhen an acronym is used that may not be familiar to the majority of the reader,  the acronym is
redefined.

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

This Responsiveness Summary has been prepared pursuant to the terms of the 1991 Amended Consent
Agreement between DOE and EPA (and the 1993 Amendment) ,  as well as other reguirements,
including:

          !    The  Comprehensive  Environmental Response,  Compensation,  and Liability Act
              (CERCLA) as amended by the Superfund Amendments and Reauthorization Act
              (SARA), 42 United States Code  (U.S.C.) Section 9601, et. seg.;

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

          !    Community Regulations  in Superfund:   A Handbook,  Jan.  1992,  EPA/540/R-92/009;  and

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

As stated above, this Responsiveness Summary documents EPA and DOE responses to all comments
received during the Operable Unit 2 public comment period.  After public comments and concerns
were formally submitted to DOE,  in oral and written form, the comments were summarized into
issue statements and responded to accordingly.  Copies of the actual comments received the
included in Attachthment I.

Section 2.0 of this Responsiveness Summary gives an overview of public involvement for the
Fernald Environmental Management Project  (FEMP) and public involvement during development and
approval of the Operable Unit 2 Remedial Investigation  (RI) Report and Feasibility
Study/Proposed Plan - Environmental Assessment (FS/PP-EA) .  Section 3.0 discussed development of
the issue statements and presents public concerns and DOE responses.  Section 4.0 presents
comments which did not result in issues.

                             2.0   PUBLIC INVOLVEMENT

DOE's formal community relations program for the Fernald site, which began in 1985, focused on
opening the lines of communication with members of the public residing near the FEMP site.  A
variety of forums were used to provide information to the community, including a periodic
newsletter, regular community meeting, and availability sessions.  Other activities included
site tours, open houses, a speakers bureau, community assessments, and the development of fact
sheets.

Several reading rooms, which were later consolidated into one facility located near the FEMP
site, were opened to house information about all aspects of the Remedial
Investigation/Feasibility Study (RI/FS) process.   In 1990, DOE established an Administrative
Record for the site.  The local Administrative Record is located in the Public Environmental
Information Center  (PEIC) at 10845 Hamilton-Cleves Highway, Harrison, Ohio 45030; a copy of the
Administrative Record is also maintained at the offices of EPA region V in Chicago, Illinois.

-------
In November 1993 DOE implemented a public involvement program m the FEMP site which aimed at
involving community members and other interested parties in decision making at the FEMP site.
This public involvement program (which operates today) consists of three elements:  (1) public
information activities, (2) management involvement, and  (3) person-to-person communication.  As
a result of this public involvement program and the community relations activities reguired
under CERCLA, DOE provided the public with opportunities to comment on decisions relating to the
remediation Operable Unit 2.

The RI Report and the FS/PP-EA were made available to the public on February 18, 1994 and April
29, 1994, respectively.  Notices of availability for inspection of both documents were published
in May 1994 in the Harrison Press, the Hamilton Journal, and The Cincinnati Enguirer.   A
workshop was hand on May 10,  1994 to present the results of the RI and to answer guestions from
the public.

A general overview of the Operable Unit 2 subtunits was provided, the nature and extent of
contamination in the soils and groundwater were illustrated testing solid block modeling, and
the results of the Operable Unit 2 Baseline Risk Assessment were presented.  Another public
workshop was hand on June 28, 1994 to discuss the FS/PP-EA that had recently been submitted to
EPA and Ohio Environmental Protection Agency (OEPA) .   The purpose of this informational meeting
was to discuss the alternatives considered for remediation of Operable Unit 2 and explain how
the preferred remedial alternative was identified.  The workshop also emphasized ways the public
could become  involved in the decision-making for Operable Unit 2.

On September 13, 1994, OEPA sponsored a public workshop on the possibility of establishing a
disposal facility on the FEMP property as a component of remedial actions.  The purpose of this
meeting was to discuss the waiver from an applicable or relevant and appropriate reguirements
(ARAR) that was reguested from EPA in the Operable Unit 2 FS/PP-EA to allow disposal of FEMP
low-level remediation waste on FEMP property.  This waiver was necessary because Ohio Solid
Waste Disposal Regulations prohibit placement of a new solid waste disposal facility over a
high-yield solid-source aguifer.  (See Section 7.5.4 in the Decision Summary for more
information on the waiver).  On October 25, 1994 DOE hand a public workshop to discuss any
comments and concerns of implementing an on-site disposal facility.

Information postcard were mailed reminding stakeholders of the October 25, 1994 workshop
(discussed above), the upcoming public comment period, and the November 8, 1994 formal public
meeting.  A notify of available announcing the opening of the formal public comment period
(scheduled to end on November 25,  1994) for the FS/PP-EA was public on October 26, 1994.  On
November 3, 1994, OEPA held an availability session for members of the public to discuss the
Operable Unit 2 Proposed Plan.  A formal public meeting was then held on November 8, 1994.  At
this meeting, representatives from DOE, EPA, and OEPA answered guestions about the preferred
remedial alternative and other alternative under consideration for Operable Unit 2.   The first
part of the meeting consisted of a brief presentation and the opportunity for guestions and
answers.  The second part of the meeting waste dedicated to receiving formal comments from the
public on the Operable Unit 2 Proposed Plan.  OEPA sponsored a second meeting with the elected
official of Ross, Crosby,  and Morgan townships to discuss the Operable Unit 2 Proposed Plan and
waiver on November 30, 1994.
In response to a November 21, 1994 reguest from the public for more time to review the remedial
alternatives, the comment period was extended to December 30, 1994.  A notice appeared in the
Harrison Press, Hamilton Journal, and The Cincinnati Enguirer announcing this extension in
addition to the mailing of informational postcards.  On December 19, 1994, DOE amended the
monthly Crosby Township Trustee meeting to give a briefing on the Operable Unit 2 preferred
remedial alternative.  A second extension was granted pursuant to stakeholder reguest dated

-------
December 30, 1994 which extended the public comment period to January 20, 1995.  A notice
appeared in the Hamilton Journal and The Cincinnati Enquirer an January 6, 1995 notifying
stakeholders of the second extension and information postcards were again mailed.  DOE feet with
the Ross Township facilities en January 5, 1995 to again discuss the Operable Unit 2 preferred
remedial alternative.

Responses to comments received during the public comment period and at the public meeting the
included in this Responsiveness Summary, which is part of the Regulations of Decision  (ROD).
The ROD presents the selected remedial action for Operable Unit 2 at the FEMP site in Fernald,
Ohio, chosen in accordance with CERCIA  (as amended by SARA) and, to the extent practicable the
NCP.  The, information that the Operable Unit 2 decision is based upon can be found in the
Administrative Record.
                         3.0 SUMMARY OF ISSUES AND RESPONSES

The Operable Unit 2 FS/PP-EA was released for public comment on October 26, 1994.   DOE has
reviewed all written and oral comments submitted during the public comment period and determined
that no significant changes to the preferred remedial alternative were necessary.

This responsiveness summary focuses on the formal comments submitted during the public comment
period and oral comments received during the November 8, 1994 formal public meeting held in
Harrison Ohio.  Within this responsiveness summary, oral and written comments  (see Attachment I)
were categorized into significant issues (see Table RS-3-1).  For each of these issues, an issue
statement has been prepared that advises 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 issues raised during other informal question and
answer sessions to ensure that all significant issues have been represented by the issue
statements.

 For the purpose of development issue statements, a comment is considered significant if it
involves:

          !   the  definition of the  preferred remedial  alternative;
          !   public  or  state acceptance  of  the  preferred remedial  alternative;
          !   the  implementation of  impacts  of the  preferred remedial  alternative;
          !   conclusions  drawn from evaluations or assessments  provided within the
             document:
              conclusion of  the work performed;  or
              enforceability of the  decision reached.

 At the end of each issue statement, the specific comment letter(s) the identified in
parentheses. So that comment responses can be easily found, the comment letters, commentors,
relevant issues, and page numbers are cross-referenced in Table RS-3-2.   These comments are also
part of the Administrative Record for this action.   The text of the ROD has been modified based
on a number of public comments contained herein.  Although these changes are not specifically
summarized or highlighted, they can be found in both the Declaration Statement and Decision
Summary.

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                                   TABLE RS-3-1
                           SUMMARY OF ISSUE STATEMENTS

ISSUE NUMBER                           TOPIC OF ISSUE
1                  ON-PROPERTY DISPOSAL VERSUS OFF-SITE DISPOSAL
                   (a)    Opposition to On-Site Disposal Facility
                   (b)    Acceptance of On-Site Disposal Facility
                   (c)    Disposal in the Nevada Test Site
                   (d)    Commericial Off-Site Disposal Facility
                   (e)    Off-Site Regional Disposal Facility
                   (d)    Protection of the Great Miami Aquifer
2                  DESIGN OF THE DISPOSAL FACILITY
                   (a)    Buffer Zone
                   (b)    Meaning of Permanence
                   (c)    Fixing a Problem May Create Bigger Problems
                   (d)    Independent Expert
                   (e)    Size
3                  WASTE TO BE PLACED IN THE DISPOSAL FACILITY
                   (a)    Waste from Other Sites
                   (b)    Implementation of Waste Acceptance Criteria
                   (c)    Calculation of Waste Acceptance Criteria
4                  EXCAVATION AND MONITORING TECHNIQUES DURING REMEDIAL
                   ACTIVITIES
                   (a)    Real-Time Monitoring
                   (b)    Dilution of Waste
                   (c)    As Low As Reasonable Achievable  (ALARA)
                   (d)    Pollution Prevention
                   (e)    Transition
5                  MONITORING/MAINTENANCE OF THE DISPOSAL FACILITY
                   (a)    Long-Term Monitoring/Maintenance
                   (b)    Costs and Commitment
                   (c)    Available of Data and Reports
6                  COST
                   (a)    Alleged Misrepresentation of Monitoring/Maintenance Cost
                   (b)    Cost Should Not Be A Factor
                   (c)    Site-Wide Perspective
7                  FUTURE USE/OWNERSHIP
                   (a)    Ownerstop of FEMP Site
                   (b)    Above Background Levds - Public's Right-To-Know
                   (c)    Future Monetary Benefit
8                  PUBLIC PARTICIPATION PROCESS
                   (a)    Extension of the Public Commnet Period
                   (b)    Puplic Involvement After the ROD
                   (c)    Future Review of the ROD
                   (d)    NTS Review
                   (e)    Public Understanding

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                               TABLE RS-3-1
                                (Continued)

ISSUE NUMBER                   TOPIC OF ISSUE
9                   MISREPRESENTATION OF RISK AND BACKGROUND  LEVELS
                     (a)    Risk Levels
                     (b)    Background Levels
10                  USE OF NEW TECHNOLOGY IN THE FUTURE
                     (a)    Review of New Technologies
                     (b)    Retrievability of Waste
11                  INTEGRATION AND CONSISTENCY WITH OTHER  OPERABLE  UNITS
                     (a)    Consistence Cleanup Levis
                     (b)    Comprehensive ROD
12                  TRANSPORTATION
                     (a)    Safer Transportation Methods
13                  PROCESS KNOWLEDGE

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             TABLE RS-3-2
COMMENT IDENTIFICATION AND TRACKING
            Page Number of Original
Comment                  Commentor
               Issue Identification
Letter                                                                              Comment

   A       Russ Becknet, Resident of Ross Townshot                                   RS-I-1
          la, 2b, 5b, 6a
   B       Board of Trustees, Ross Township                                          RS-I-3
          la, 8a
   C       Louis C. Bogar, Resident of Hamilton, Ohio                                RS-I-5
          la, If, 2b, 2c, 3c, 4a, 6a, 9a, 9b, lOa
   D       Robert L. Copeland, Morgan Township Trustee                               RS-I-9
          Ib, If 2e, 3a
   E       Lisa Crawford, Resident of Harrison, OH                                   RS-I-11
          Ib, 2a, 3a, 3b, 4a, 4c, 4d, 4e, 5a, 5c, 6c, 7a, 8b, lOa
   F       Vickey Dastillung, Resident of Ross Township                              RS-I-16
          Ib, If, 2d, 3a, 3b, 4a, 4c, 5a, 5b, 5c, 6a, 7b, 8b, 8c, 9a,  lOa,  lOb,  lib
   G       Pamela Dunn,  Resident of Harrison, Ohio                                   RS-I-19
          Ib, 2a, 3a, 3b, 4a, 4c, 4d, 5a, 7a, 8b, lOa
   H       Daryl Huff, Resident of Moran Township                                    RS-I-21
          la, Id, 2b, 3a, 3b, 6a, 7c, 8b, 8e
   I       Dick Kasparek, Resident of Hamilton, Ohio                                 RS-I-23
          3c, lla, 13a
   J       Dr. William M. Kuhlmann, Resident of                                      RS-I-24
          la, If, 6a, 12a
           Harrison, Ohio
   K       Paul Liebendorfer, Bureau of Federal Facilities,                          RS-I-25
          Ib
           State of Nevada
   L       Betty C. McKay, Resident of Harrison, Ohio                                RS-I-27
          2a, 3a, 3b, 4a, 5a, 7a, 8b
   M       Donald J. Meyer, Attorney at Law, Harrison,                               RS-I-28
          la, le, 5b, 7c
           Ohio
   N       Dianne R. Nielsen, Department of                                          RS-I-30
          Ib
           Environmental Quality State of Utah
   0       Thomas A. Schneider, Ohio Environmental                                   RS-I-31
          Ib, 3a, 3b, 4a, 4d, 5a, 5c, 7a, 8b, lOa
           Protection Agency
   P       Joan K. Pottenger, Resident of Harrison, Ohio                             RS-I-34
          la
   Q       H. Thomas & Carolyn A. Rasche, Residents of                               RS-I-35
          la
           Ross, Ohio
   R       Larry Stebbins, Resident of Ross Township                                 RS-I-36
          la, 3a, 4b
   S       Richard Strimple                                                          RS-I-37
          If

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                                                                     TABLE RS-3-2
                                                                       (Continued)
Comment
Letter
                         Commentor
                                                        Page Number  of Original
                                                                  Comment
                                                                                                                       Issue  Identification
  T
  U
  V
  W

  X
  Y

  Z
  AA

  BB
  CC
Gary Storer, Crosby Township Trustee
Judy Suzurikawa, Cincinnati Water Works
Donald H. Thiem, Resident of Hamilton, Ohio
Unidentified Commentor  (Puplic Meeting
Evaluation Sheet)
Unidentified Speaker  (Puplic meeting)
William L. Vasconi, Chair, Nevada Test Site,
Community Advisory Board
J.E. Walther, Resident of Hamilton, Ohio
Tom Willsey, President, Ross Township Board
of Trustees
Edwa Yocum, Resident of Crosby Township
David Young, Ross Township Trustee
RS-I-38
RS-I-41
RS-I-42
RS-I-43

RS-I-45
RS-I-46

RS-I-48
RS-I-49

RS-I-53
RS-I-54
la,  5b,  6a,  6b
If,  8a
la,  2e
Ib

la,  Ic,  If,  3b,  5b
Ib,  8d

la,  1L 2a,  2b, 9a, 12a
la,  2b,  6b,  8a

la,  2a,  3a,  3b,  4a,  5a,  7a
la

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ISSUE 1 - ON-PROPERTY VERSUS OFF-SITE DISPOSAL

Comment.

(a) OPPOSITION TO ON-SITE DISPOSAL FACILITY. Stakeholders identified their opposition to the
disposition of waste at the FEMP site for various reason (1) the remediation waste resulting
from cleanup of the FEMP site should be transported to and disposed of at the Envirocare
facility near Clive, Utah because the geology and arid environment at the Envirocare site is
more suitable to support a disposal facility (2) several members of the community were under the
impression that all contamination at the FEMP site would be excavated and sent off site; (3)
environmental factor (e.g., population density geology, etc.) at the FEMP site could result in
potential problems for the implementation of an on-site disposal facility; and (4) the only
reason for on-site disposal is cost. (Comment letters A, B, C, J, H, P, Q, T, V, X, Z, AA, and
CC. )

Response.

(a)(1) DOE agrees that overall the geologic features and arid environment of the
Envirocare facility in Clive, Utah (as well as DOE's Nevada Test Site, northwest of Las Vegas)
may present more favorable conditions for waste dispose, especially for high levels of
contamination. However, some FEMP remediation waste can be safely disposed of at the FEMP site.
In the Operable Unit 2 FS/PP-EA, DOE, in accordance with the CERCLA process, balanced the nine
evaluation criteria to determine the preferred remedial alternative. That evaluation summarized
in this ROD. Threshold reguirement (i.e., protection of human health and the environment and
meeting ARARs or justifying a waiver) are met by both the on-site and off-site disposal
alternatives. DOE has taken a balanced approach in proposing a solution for disposal of
Operable Unit 2 remediation waste and other FEMP remediation wrote. The balance consists of
sending the most contaminated waste (i.e., Operable Unit 1 and Operable Unit 4) to western
disposal facilities and disposing of the low-level remediation wrote at the FEMP site. This is
based on the ability to dispose of the low-level remediation waste safely at the FEMP site and
the western states" resistance to being the "dumping" ground for All wrote. DOE believes,
after taking all factors into consideration, the preferred remedial action for Operable Unit 2
(i.e., implementation of an on-site disposal facility) is in the best interest of stakeholders,
both in Ohio and in the western states.

(2) DOE acknowledges community non-acceptance of an on-site disposal facility as expressed by
the commentors concerns stated above. DOE also understands that some members of the community
were expecting all FEMP waste to be removed and sent off site. DOE proposes to remove and
dispose off site the portion of FEMP remediation waste which cannot be safely managed at the
FEMP site. However, other factors, such as the implementability of Alternative 3 (Off-Site
Disposal), have led DOE to propose the disposal of some FEMP remediation waste in an on-site
disposal facility. One implementing factor involves the uncertainty as to the amount of time
needed for coordination of several stakeholders - stakeholders in Nevada and/or Utah and
stakeholder in states that waste would have to be stopped through. Other factors include
approval of an Environmental Impact Statement in Nevada Test Site (NTS) and issuance of a final
ruling by DOE Headguarters to allow disposal of DOE remediation waste at permitted commercial
disposal facilities.

Unfortunately, waste disposal is an intensely debated issue across the country and not just
near the FEMP site. Citizens in western states have expressed reluctant acceptance of
managing some waste but are opposed to taking all FEMP remediation waste. Due to these issues,
EPA and OEPA support DOE in this balanced approach to waste management where the low-volume,
high-concentration waste go off site for disposal and the high-volume, low-concentration waste,
that can be safely disposed of in an engineered disposal facility on site, are managed at the

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FEMP site.

(3) When evaluating alternative, DOE considered potential impacts on and potential impacts from
environmental factors such as socioeconomic (including population demographics, land use of
areas adjacent to the site, and potential risks to the surrounding population), groundwater,
geology, and biotic resources.

Cleanup alternatives must be compacted against the nine evaluation criteria defined by the NCP.
A cleanup alternative must first meet the two "threshold criteria" - Overall Protection of Human
Health and the Environment and Compliance with ARARs for justification of an ARAR waiver),
before being evaluated against the next five "primary balancing criteria." The "primary
balancing criteria" include Long-Term Effectiveness and Permanence; Reduction of Toxicity,
Mobility or Volume, through Treatment; Short-Term Effectiveness; Implementability; and Cost.
The last two criteria, State Acceptanece and Community Acceptance, are the "modifying Criteria"
and the evaluated after the public comment period. Both Alternative 3 (Off-Site Dispose) and
Alternative 6 (On-Site Disposal with Off-Site Disposal of Fraction Exceeding Waste Acceptance
Criteria) meet the two threshold criteria. It is the evaluation of the "primary balancing
criteria" that there is a difference between the alternatives. As discussed earlier, the
implementability of Alternative 3 is uncertain. Under Alternative 6 the remediation waste
resulting from cleanup of Operable Unit 2 would be placed in an engineered disposal facility
testing proven materials, methods, and designs. In addition in the incorporation of a leachate
collection and leak detection system, this engineered facility would include containment
features that would be the primary means for ensuring long-term protection of human health and
the environment. Additionally, it is important to note that modeling of the facility to
determine protectiveness relied only on natural barrier protection and and not take into
account any layers composed of synthetic materials (i.e., flexible membrane liner, leachate
collection, and leak detection. Alternative 6 would be implemented in a safe, straightforward
manner and would be designed to provide long-term protection of human health and the
environment.

(4) Cost is one of five primary balancing criteria of CERCLA used to determine the most
appropriate solution. Cost was therefore considered; however, as one of nine evaluation
criteria cost was not the sole deciding factor. See discussion above in Issue 1(a)(3).
Comment.

(b) ACCEPTANCE OF ON-SITE DISPOSAL FACILITY. Several members of the local public and OEPA
expressed their acceptance of the on-site disposal facility with the view that waste disposal is
a global issue (technological, political, and practical considerations need to be factored into
decision-making) and members of the community in other states do not want FEMP waste in their
backyard either. Community members thick that DOE should get the worst staff out of here and
take responsibility for the rest that they can safely keep here. However, these same commentors
also stated that certain conditions must be feet (e.g., buffer zone, geological support). Some
of these commentors, including OEPA, discussed specific reguirement (e.g., no hazardous waste
storage, waiver must be very site specific) that they felt should be included in the EPA CERCLA
ARAR waiver of the Ohio Solid Waste Siting Criteria.

Stakeholders from Nevada and Utah were also supportive of the Operable Unit 2 preferred
remedial alternative. Stakeholders in both states conveyed that as a result of DOE taking this
balanced approach (excavation and disposal of Operable Unit 2 remediation waste in an on-site
disposal facility and excavation and disposal of Operable Unit 2 remediation waste which does
not meet waste acceptance criteria [i.e, 346 pCi/g uranium-238, or 1,030 parts per million (ppm)
total uranium] at either the NTS or Envirocare facility), their support for waste disposal

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facilities in thor own states receiving out-of-state waste would continue. (Comment letters D,
E, F, G, K, N, 0, R, W, E and BB.)

Response.

(b) Through the selection of this alternative, DOE is taking responsibility for what can be
safely disposal at the FEMP site while ensuring protection of human health and the environment.
As the commentors correctly indicate, it is the EPA that would be granting the waiver to DOE.
The justification for this waiver is provided in the Decision Summary of this ROD and is
suported by the Administrative Record for Operable Unit 2.
Comment.

(c) DISPOSAL AT THE NEVADA TEST SITE. One commentor was concerned that the Nevada Test Site
(NTS) was not considered in DOE's evaluation of alternatives.(Comment letter X.)
Response.

(c) Both NTS and Envirocare weight considered for the off-site disposal alternative (Alternative
3) in the Operable Unit 2 FS/PP-EA. The NTS was original used as the "representative off-site
disposal facility" for cost estimates of Alternative 3. However due to the high cost of
disposal at the NTS, EPA directed DOE to use a different facility for the cost estimate so that
a more accurate comparison could be made between the alternatives. Because the costs weight
significantly lower, the Envirocare facility was chosen as the representative facility for
purpose of the FS. However, DOE has not yet made a final decision as to which off-the facility
Operable Unit 2 remediation waste would be sent to under Alternative 3 or Alternative 6. Both
the NTS and Envirocare the still being evaluated and will be competed.
Comment.

(d) COMMERCIAL OFF-SITE DISPOSAL FACILITY. One commentor was concerned that DOE headguarters
had still not issued a final ruling on the current ban of disposing DOE waste at permitted
commercial disposal facilities. (Comment letter H.)

Response.

(d) DOE Headguarters has not issued a final ruling to allow the general disposal of DOE
remediation waste at permitted commercial disposal facilities; however, DOE Headguarters did
issue an exemption (on November 8, 1994) for Operable Unit 1 waste to go to the Envirocare
facility. Since Operable Unit 2 material that exceeds the waste acceptance criteria and the
Firing Range material would be sent off site to a commercial disposal facility, a similar
exemption would be necessary unless DOE changes its policy.

Comment.

(e) OFF-SITE REGIONAL DISPOSAL FACILITY. One commentor suggested that another disposal site in
Ohio be found which does not present the same risk to the aguifer as the FEMP size. (Comment
letter M.)

Response.

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(e) The alternatives that were identified for Operable Unit 2 remediation waste cover a broad
range of remedial option, including on- and off-site disposal. The alternative identified in
the comment (a new, off-site disposal facility) is a combination of the concept presented in
Alternative 3 (an existing, off-site disposal facility) and Alternative 6 (a new, on-site
disposal facility). The cost of such an alternative would be expected to be between the costs
of the two alternatives noted. However, the length of time for permitting and resolution of
political issues for constructing a new low-level disposal facility (somewhere in Ohio) is
believed to impact implementability so extensively as to be prohibitive. The potential for
disposal of FEMP remediation waste to become entangled with the highly controversial development
of a disposal facility for commercial low-level remediation waste from compact states could also
prohibit a timely cleanup of Operable Unit 2. For these reasons, establishment of a new,
off-site disposal facility within the State of Ohio waste not considered for detailed analysis
of potential remedies for Operable Unit 2.

Comment.

(f) PROTECTION OF THE GREAT MIAMI AQUIFER. (1) Several commentors were concerned that the
on-site disposal facility would not be protective of the Great Miami Aguifer (a high-yielding
size-source aguifer) which provides water to residents and industries in the area. One
commentor noted that the proposed location of the disposal facility is on an uncontaminated area
and that failure of the disposal facility would provide direct access to the aguifer and result
in additional contamination. Other commentors felt that the disposal facility should be placed
over the best geology at the FEMP and that all ARARs for protection of the aguifer must be met.
One commentor expressed content that the aguifer would be polluted forever and true cleanup
would never occur. (Comment letters C, D, F, J, S, U, X, and Z.)

Response.

(f) The overall protectiveness of the disposal facility has been determined through
conservative modeling assumptions which were based on the natural protection of the gray clay
located under the proposed location of the disposal facility and and not include the
additional protection due to the synthetic membrane, clay layer, leachate collection system, and
leak detection system in the engineered disposal facility. A leak detection system has been
included in the design so that repairs to the facility could be implemented before any
contamination reaches the sole-source aguifer.

The on-site disposal facility will be constructed over the most suitable geology available at
the FEMP in order to provide the greatest amount of natural protection for the aguifer. All
ARARs for protection of the groundwater (including Safe Drinking Water Ohio standards) will
either be met or a waiver will be justified (as in the case of the Ohio reguirement prohibiting
disposal over a high-yield, sole-source aguifer).

It is DOE's belief that the aguifer will not be polluted forever. Operable Unit 5 is
currently conducting the South Plume Removal Action to pump contaminated groundwater to a
treatment facility. The remedial action and final cleanup levels for restoration of the aguifer
well be determined in the Operable Unit 5 ROD. The treated water, from both the removal action
and remedial action, will be discharged to the Great Miami River in compliance with regulations,
including the Clean Water Act. As with the CERCLA selection of remedy process preceding
Operable Unit 3 (Interim Remedial Action), 4 and 1 and this Operable Unit 2, the public well
have the opportunity to comment on and provide input to the decision-making process for the
selection of remedy for Operable Unit 5.
ISSUE 2 - DESIGN OF THE DISPOSAL FACILITY

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Comment.

(a) BUFFER ZONE. Members of the community expressed concern over the buffer zone around the
disposal facility. Some asked that at least 300 feet around the facility be maintained and
another requested a "minimum two-mile safety buffer zone." (Comment letters E, G, L, Z, and
BB. )

Response.

(a) Regulations specify that a 300-foot. (91-meter) buffer zone mint be between the limits, of
waste placement and the property boundary. The disposal facility cap reduces direct exposure to
below detectable quantities at the surface, thus not posinq a risk to human health or the
environment; therefore, a distance farther away (e.g., two-mile buffer zones) would not provide
any additional margin of safety. The buffer zone around the disposal facility is not to provide
a "safe" distance in reqard to risk/exposure, but rather to allow adequate easement for
operation, maintenace, and monitorinq of the facility; hence, a two-mile buffer zone is not
necessary and will not be implemented. The on-site disposal facility will include at least a
300-foot buffer zone (are discussed in Section 9.0 of the Decision Summary).

Comment.

(b) MEANING OF PERMANENCE. Many commentors expressed concern over the term "permanence" beinq
utilized to explain the assumed protection of the disposal facility. (Comment letters A, C, H,
Z, and AA.)
Response.

(b) Lonq-term effectiveness and permanence is one of the nine criteria used to evaluate a
proposed remedy. In accordance with the NCP, permanence is measured on a scale, from remedial
actions that require lonq-term maintenance on the lower end of the scale (i.e., less permanent)
to remedial actions that permanently destroy contaminants and require no lonq-term maintenance
at the hiqher end of the scale. One of the ARARs places a yardstick by which permanence can be
judqed by requirinq disposal facilities be desiqned to be protective for 1,000 years (with a
minimum of 200 years). The modelinq to predict lonq-term possible contaminant transport waste
performed for 1,000 years, with waste acceptance criteria for the disposal facility based on
levels to be protective durinq this time period. The permanence of the disposal facility
materials and construction will be maximized by testinq the best available demonstrated
technoloqy and will be monitored for continued effectiveness.
Comment.

(c) FIXING A PROBLEM MAY CREATE BIGGER PROBLEMS. One commentor contended that if a failure of
the disposal facility waste directed, the only waste to the fix the problem would be to diq into
the facility thus possibly creatinq the potential for additional contamination. (Comment letter
C.)

Response.

(c) As desiqned, the composite cap is the primary means of protection for the on-site disposal
facility. An inspection and maintenance proqram will be effect throuqh the service life of the
facility to document and maintain performance objective. In the event of unobserved cap

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failure, there would be an increase in rainwater infiltration through the facility with a
resultant increase in flow in the underlying leachate collection system.  This would serve as a
warning to help in preventing contaminant transport to the aquifer and trigger an investigation
to isolate the failed zone.  Cap repair would then be initiated without digging into the
contained waste.

The integrity of the bottom liner can also be monitored by the leak detection system.  It
should be noted that the design of the facility  (see Issue 5) and the waste acceptance
criteria were developed conservatively as the of the man-made layers of the disposal facility
was assumed during modeling.  Even with the assumed failure the facility maintains protection of
human health and the environment, including the aguifer.  If a failure necessitates removal of
the waste or portions of the waste material, the material can be effectively and safety removal
using excavation techniques similar to those used for the Operable Unit 2 subunits.

Comment.

(d) INDEPENDENT EXPERT.  One commentor expressed interest in having an independent expert
oversee the engineering, construction, and "filling" of the disposal facility to insure the
activities the performed properly.  The commentor also insisted that reports from the
independent review(s) be part of the public record.  (Comment letter F.)
Response.

(d) EPA and OEPA the responsible for performing oversight activities at the FEMP site
(including all activities associated with the implementation of an on-site disposal facility).

In addition, encouraged public involvement during the remedial design  (RD) and remedial action
(RA) process will foster further independent reviews of proposed remedial activities. RD and RA
documents  (e.g., work plans) as well as documents developed from the oversight process, will be
made available for public inspection and copying at the PEIC. Additionally, EPA Technical
Assistance Grant (TAGs) are made available to the public to fund activities such as independent
oversight of disposal facility design, construction, and monitoring.
Comment.

(e) SIZE.  One commentor was concerned that the disposal facility would consume approximately
184 acres and that there could not possibly be that much material on site.  (Comment Letter D and
V.)

Response.

(e) During development of the FS Reports for Operable Units 2 and 5, a number of different
alternatives have been evaluated.  Those alternatives extentine varying levels of protectiveness
and types of land use.  When those factors are varied, the amount of material estimated to
require disposal varies as a direct result.  As the stakeholders come to agreement about
acceptable land use and acceptable protectiveness, the range of material, volume targeted for
disposal will be narrowed.

For informational purposes, the Operable Unit 2 FS/PP-EA presents an extreme case disposal
facility that covers an area of over 200 acres and has a capacity of 8.5 million cubic yards.
However,  the capacity of that conceptual facility was based on the most conservative assumptions
about land use and protectiveness a the FEMP site.  Based on the Operable Unit 2 and Operable

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Unit 5 Proposed Plans and the latest estimates from Operable Unit 3, a site-wide disposal
facility would realistically be expected to hold between 2.0 and 2.5 million cubic yards of soil
and debris. This Operable Unit 2 ROD specifically addresses approximately 300,000 cubic yards
of waste material from Operable Unit 2 which would require 35 acres (including the buffer zone)
for disposal. The estimates of the total maximum and probable amounts were provided to 1)
ensure space for all possible remediation wastes from Operable Unit 2, Operable Unit 5, and
Operable Unit 3 should their respective RODs select on-site dispose, and 2) allow the public a
more comprehensive view of an on-size disposal facility if Operable Unit 5 and Operable Unit 3
remediation wastes are left on site.
ISSUE 3 - WASTE TO BE PLACED IN THE DISPOSAL FACILITY
Comment.

(a) WASTE FROM OTHER SITES. Many stakeholders aand OEPA expressed the following opinion: if
the FEMP site is used for waste disposal, it should be used solely to dispose of waste
associated with cleanup of the FEMP site. No other DOE or commercial waste (or anything not
currently on-site, except for samples that were sent on-site for characterization or
treatability studies) should be brought to the FEMP for on-site disposal. (Comment letters D, E,
F, G, H, L, 0, R, and BB. )

Response.

(a) The decision contained within this ROD is specific to Operable Unit 2 remediation waste
based on the comparison of the nine CERCLA criteria (as discussed in Section 8.0 of the Decision
Summary). Additionally, the EPA waiver to allow waste disposal over a high-yield sole-source
aguifer cannot be transferred to any other FEMP waste or off-site waste. Based on the nine
evaluation criteria, Operable Unit 3 and 5 will similarly decide whether other FEMP remediation
waste will remain on-site for disposal. These decisions will be documented in subsequent RODs.
The disposal of any off-site waste in this on-site disposal facility will not occur.
Comment.

(b) IMPLEMENTATION OF WASTE ACCEPTANCE CRITERIA. Many commentors, including OEPA, had concerns
related to the waste acceptance criteria (defined as the maximum concentration of a given
contaminant that can be placed into the on-site disposal facility while maintaining long-term
protection of the aquifer). These concerns include:

(1) that dilution of waste concentration during excavation occur to allow the FEMP

site to actually increase the quantity of waste that could stay on property (i.e.,
meet waste acceptance criteria); (2) the 360 pCi/g for uranium-238 should be the upper
limit for the waste acceptance criteria and not an average, and that this value should
also consider the flexibility of being lowered based on other operable unit decision;
(3) other waste besides uranium-238 (e.g., other uranium isotopes, thorium, etc.)
should have to meet waste acceptance criteria; and (4) no characteristic hazardous
waste should be disposed of in the on-site disposal facility (other commentors
proposed no hazardous toxic, and/or radioactive waste be disposed of in the on-site
disposal facility). (Comment letters E, F, G, H, L, 0, X and BB.)

Response.

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(b)(1) A small amount of mixing may occur during normal excavation, but it is not DOE's
intent to increase the volume of waste to be disposed of on site (as declared in Section 9.0
of the Decision on Summary). During remediation DOE intends to excavate "hot spot" with
concentrations greater thlan 346 pCi/g for uranium-238, or 1,030 ppm total uranium before
excavating waste that will be disposed of in the disposal facility. Screening and testing of
the two types of excavation materials ("hotspot" material and less contaminated material) will
be performed to verify that the materials were being stopped to the proper disposal facility.
Following excavation of each "hot spot," the in-place material will be monitored to confirm "hot
spot" removal. If test results show the remaining in-place material above cleanup levels, it
will be excavated and another round of testing will be performed to confirm the removal of that
material in order to verify shipping to the proper disposal facility. By phasing the screening
and confirmation testing in this manner, the opportunity for "hot" material to be inadvertently
mixed with less contaminated material will be minimized.

(2) The waste acceptance criteria of 346 pCi/g for uranium-238, or 1,030 ppm total uranium well
be a maximum level for disposal of Operable Unit 2 remediation waste in the on-site disposal
facility (as defined in the Decision Summary). The waste acceptance criteria for uranium-238
may be modified based on other operable unit waste forms (e.g., building rubble from Operable
Unit 3); however, alternate uranium-238 waste acceptance criteria would be equivalent to
Operable Unit 2 waste acceptance criteria in terms of level of protection of human health and
the environment. It is important to note that while other operable unit's uranium cleanup
levels may differ from those for Operable Unit 2 because of variations in localized
hydrogeology, the waste acceptance criteria for all operable units considering on-site disposal
will be evaluated at the same disposal local collection as DOE intents to build only one on-site
disposal facility.

(3) Uranium-238 waste determined to present the greatest risk in the Operable Unit 2 risk
assessment for future uses of the Great Miami Aquifer; therefore, the waste acceptance
criteria for Operable Unit 2 remediation waste waste identified in terms of uranium-238.

The disposal of all Operable Unit 2 remediation waste below the uranium-238 waste acceptance
criteria in an on-site engineered disposal facility waste evaluated in the residual risk
assessment developed for the Operable Unit 2 FS/PP-EA. The residual risk of the disposal
facility from all Operable Unit 2 contaminants is 1.6x10-6. The waste acceptance criteria for
uranium-238 ware established to protect future groundwater quality. If it is proposed that
waste from other operable units will be managed in the on-site engineered disposal facility, a
similar analysis will be done by those operable units and may result in additional waste
acceptance criterion for other contaminants.

(4) For Operable Unit 2, the only waste material that would be considered hazardous the Firing
Range waste, after it is excavated and actively managed. This waste (approximately 300 cubic
yards) will be shipped off site. Operable Unit 2 does not have any waste that would be
considered toxic according to the Toxic Substances Control Act.
Comment.

(c) CALCULATION OF WASTE ACCEPTANCE CRITERIA. (1) It waste noted that the waste acceptance
criteria should be in parts per million of total uranium (based on normal enrichment) instead of
pCi/g of uranium-238 because it is difficult to determine uranium-238 activity with field
instruments and it is easier and cheaper to do total uranium chemical analysis in a laboratory
than to do a more expensive isotopic analysis for uranium-238. (2) Several commentors
questioned the results of converting the waste acceptance criteria for uranium-238 from pCi/g to
ppm that were presented in the public meeting. One commentor also mentioned that it is

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inappropriate to compare uranium-238 levels in Operable Unit 4 to other operate units because
radium-226 is the major contaminant for Operable Unit 4, not uranium-238. (3) One commentor
felt that radioactivity from all radionuclides should be addressed, not just uranium-238. (4)
In addition, average and maximum waste uranium-238 concentrations presented in the public
meeting were meaningless because they were not connected to any statistical method and the
cleanup levels presented at that time did not seem to correlate with either average or maximum
values. (Comment letters C and I.)

Response.

(c)(1) Uranium-238 mass is 99.27% of the total uranium mass; conseguently, the two terms are
freguently interchanged. A waste acceptance criteria of 360 pCi/g for uranium-238 is eguivalent
to 1,071 ppm total uranium (routinely rounded to 1,080 ppm total uranium). Please note that as
a result of EPA comments, the waste acceptance criteria for uranium-238 has been changed to 346
pCi/g, or 1,030 ppm total uranium. As indicated in the comments, it is likely that testing for
total uranium will be the easier, less expensive means of determining uranium concentrations.
However, the final choices for testing methods to be used during remediation, both in the field
and laboratory, will be made during remedial design after evaluation of the anticipated number
of tests, the reguired accuracy and precision, the elapsed time reguired for each method, and
the cost of the various methods. (2) Because of the uncertainty associated with any estimate of
exposure point concentration for soil, the 95 percent upper confidence level on the calculated
mean for either a normal or lognormal distribution is the recommended value used in EPA risk
assessments. The total uranium waste acceptance criteria of 1,071 ppm, or 1,080 ppm is
correct (although as a result of EPA comments, the waste acceptance criteria for uranium-238 has
been changed to 346 pCi/g, or 1,030 ppm total uranium). If the total activity of uranium-238,
uranium-235, and uranium-234 was 360 pCi/g, then the total uranium concentrations would be 532
ppm using a conversion factor of 676 pCi/milligram (mg). The 360 pCi/g value, however, is the
urauium-238 activity only, which is converted to a 1,071 ppm concentration by a 336 pCi/mg
conversion factor. Since the uranium-238 mass is 99.27% of the total uranium mass, they the
essentially the same. The table on page RS-3-35 illustrates this conversion.

It is agreed that the contamination in the Operable Uuit 4 silos is not accurately represented
by a uranium-238 comparison alone. When the figure in guestion was prepared, an additional
figure comparing radium-226 concentrations ware also drafted. The second figure waste
eliminated from the presentation due to time constraints. Given that radium-226 is the major
contaminant in Operable Unit 4, it is interesting to note that the concentrations of uranium-238
in Operable Unit 4 the still significantly greater than those for Operable Unit 2.

(3) From a remediation viewpoint, the total activity of all radiosotopes is of concern; hence,
cleanup levels have been established for many radioisotopes. For waste acceptance criteria,
however, the concern is with contaminant transport and time of travel to the aguifer. All
contaminant, except uranium-238, have been modeled and determined to not impact groundwater in
the future. Therefore the concentration of uranium in the disposal facility must be limited to
protect groundwater. (4) The average and maximum concentration for total uranium presented in a
chart at the October 25, 1994 public meeting were taken from Appendix A of the Operable Unit 2
FS/PP-EA. The average value is either a mean or an estimated mean, depending on the
distribution of the data sets, and the maximum value is the maximum detected value in the data
set. Maximum concentrations were not considered outliers in the data set, but rather "hot spot"
in the sampling. The cleanup level is the concentration at which a 1x10-6 ILCR is achieved plus
background. It is independent of data sets except for background data. The cleanup levels were
provided for comparison.
ISSUE 4 - EXCAVATION AND MONITORING TECHNIQUES DURING REMEDIAL ACTIVITIES

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Comment.

(a) REAL-TIME MONITORING. (1) Several Members of the community and OEPA expressed concern that
"real-time" monitoring be implemented during the entire remedial action process and the data
from that monitoring be provided in a timely manner. One commentor expressed interest in seeing
how DOE intends to implement real-time monitoring considering open field conditions and variable
wind velocities. (2) OEPA also felt that DOE should attempt to incorporate any new development
in real-time monitoring from the DOE Office of Technology Development as wall as the private
sector. Another commentor agreed that the best available eguipment and technigues be used to
protect workers and the community. (3) One commentor reguested that DOE develop air emission
action levels so that work can be halted if real-time monitoring detects elevated emissions.
(Comment letters C, E, G, L, 0, and BB.)

Response.

(a)(1) Real-time monitoring involves the use of devices that can guickly give an accurate
reading of for emissions without having to take a sample and send it to a laboratory for
time-consuming analysis. Real-time monitoring can be used for a variety of contaminants,
including radioactivity. Protection of workers and the community is the main goal of a
real-time monitoring program and will be used during remedial activities; however, the type of
real-time monitoring will vary depending on the activity/action. A short-term risk assessment
was preformed for the selected Operable Unit 2 alternative, showing that the risk to the
remediation worker, nonremediation worker, and off-site citizen would be within acceptable
levels. DOE is committed to monitoring and performing remedial activities to ensure that this
protection is provided and will incorporate real-time monitoring, as appropriate into RA work
plans. In response to the commentor who waste concerned about variable wind velocities and
directions, the effect of variable wind velocities and directions will be mitigated by placing
monitoring devices around the construction areas. Summaries of the monitoring data, real-time
and other, waste be made available to EPA and OEPA and the public through the PEIC.

(2) If new technology is developed for real-time monitoring, either by DOE or by the private
sector, DOE waste evaluate it for use at its facilities including the FEMP site. This
technology must, however, be workable in field conditions to ensure the reliability and
effectiveness of the monitoring program.

(3) Action levels for stopping work based upon protection of both workers and the community
already exit. The Occupational Safety and Health Act and DOE have established standards to
protect workers. DOE has also established radiation dose limits for the public in DOE Other
5400.5. DOE will comply with all of these regulations during remediations of the FEMP site. It
is DOE's as low as reasonable achievable (ALARA) policy to established action levels much lower
than these testingulated levels to ensure that the regulated levels the not exceeded.
Comment.

(b) DILUTIONS OF WASTE. See Issue 3(b)(1)

Response.

(b) See response to Issue 3(b(l).

Comment.

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(c) AS LOW AS REASONABLY ACHIEVABLE (ALARA). It was expressed that during remedial design,
ALARA principles be incorporated. (Comment letter E, F, and G.)

Response.

(c) The DOE process (reguired by DOE Order 5400.5) whereby exposures and releases of radioactive
material the reduced to levels ALARA will be applied during RD and field activities. This ALARA
process was explicitly incorporated into the development of cleanup criteria for site soil so
that future radiation (residual) doses are reduced to levels as far below applicable standards
as reasonable achievable. In addition, ALARA will be incorporated into the RD and RA work plans
to minimize exposure to workers and the general public.
Comment.

(d) POLLUTION PREVENTION. Commentors, including OEPA, expressed the need for DOE to include
pollution prevention during design and implementation of the Operable Unit 2 remedial action
whenever possible. One commentor suggested planting fast-growing trees around the perimeter of
the site to reduce are emissions from going off-site. (Comments letters E, G, 0, and R.)

Response.

(d) Throughout the RD and RA process, appropriate measures will be evaluated, utilized, and
monitored to minimize the increase of waste, emissions, runoff, etc. resulting from
remedial activities. Operable Unit 2 remediation is expected to take 4.25 years; hence,
planting trees that well grow guickly enough may be difficult. However, existing trees will be
maintained whenever possible.
Comment.

(e) TRANSITION. A commentor expressed concern over the potential for "lag time" between
excavation and final disposition. (Comment letter E.)

Response.

(e) This concern correctly implies that the period of time from soil and waste
removal/excavation to the placement in the disposal facility should to be kept to a minimum.
The disposal facility availability and operation will be coordinated with excavation of Operable
Unit 2 materials to allow direct placement of waste, whenever possible. The main factor that
may cause short delays in placement of waste in the disposal facility would be inclement
weather. The actual procedures for achieving this goal will be presented in greater detail in
RA work plans.
ISSUE 5 - MONITORING/MAINTENANCE OF THE DISPOSAL FACILITY

Comment.

(a) LONG-TERM MONITORING/MAINTENANCE. Members of the community felt DOE should commit to an
appropriate long-term monitoring and maintenance program to verify and maintain the performance
of the on-site disposal facility. One commentor reguested yearly inspections. Another
commentor expressed concern that this commitment to monitoring and maintenance be detailed in
DOE's administrative others. (Comment letters E, F, G, L, 0 and BB.)

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Response.

(a) As stated and the Decision Summary, DOE is committed to performing long-term monitoring and
maintenace of the disposal facility, the five Operable Unit 2 subunits, and surrounding areas.
Specific plans (RA Works Plans) addressing the parameters and the freguency of monitoring and
inspection will be developed with the detailed design activities that will be performed after
the ROD has been signed. These plans waste be made available for public inspection. In
addtion, CERCLA reguires a review every five years of any remedial action with on-site disposal
to ensure protection of human health and the environment. Five-year reviews the conducted to
assure continued protection of human health and the environment. The specific content of the
reviews will be determined in the Remedial Action Work Plan, however it is expected to include
review of monitoring data, engineering controls, and maintenance activity. Monitoring and
maintenance reguirements have been mandated by both the State of Ohio and DOE. Operable Unit 2
monitoring and maintenance activities waste be at a minimum complete in compliance with Ohio
Solid Waste Landfill Regulations (Ohio Administrative Code 3745-27) and DOE Other 5820.2A
(Radioactive Waste Management).

The overall protectiveness of the disposal facility has been determined through conservative
modeling assumptions. The modeling utilized to established the uranium waste acceptance
criteria for the disposal facility waste based on the natural protection of the gray clay
located under the proposed location of the disposal facility and and not consider the additional
protection due to the synthetic membranes in the engineered disposal facility, the clay liner,
or the leachate collection and leak detection system. Additional factors of safety will be
evaluated during the engineering design and construction of the disposal facility.
Comment.

(b) COSTS AND COMMITMENT. (1) One commentor asked how DOE could be assured future generations
would continue monitoring and maintenance of the disposal facility - DOE should not impose that
burden on future generations. (2) Several commentors guestioned what would happen if Congress
cuts DOE's budget. One commentor further reguested a description of the worst case scenarios
for the disposal facility, the community, and the environment in the event of budget cuts.
Another commentor stated that public notice and comment with the stakeholders should be a part
of any dramatic budget cuts. The commentor further stated that if another agency were to assume
DOE's remediation and operation and maintenance functions at the site, such an agency must
assume all DOE ROD responsibilities. (Comment letters A, F, M, T and X.)

Response.

(b)(1) The commentors' concerns the acknowledged. DOE agrees that one cannot precisely predicts
its future actions or future generations' actions. This is a national issue spanning all types
of waste and disposal facility. While no specific enforceable mechanism has been developed to
ensure multiple generation compliance (greater than 30 years), DOE is committed to monitoring
and maintaining the disposal facility. The scope and freguency for monitoring will be
established in the RA work plans and will be re-evaluated during the five year reviews reguired
by CERCLA when waste remaintain on-site.

EPA will retain regulatory authority to enforce the monitoring and review activities and any
other additional maintenance or remedial activities should they be necessary.

(2) Again, the commentors concerns are acknowledged. In this time of emphasized fiscal
responsibility, budget reductions for governmental departments and agencies across the

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country are a political reality. If a DOE budget reduction were to occur, DOE would need to
evaluate its sites across the DOE complex to determine how to best allocate its financial
resource. DOE would involve its stakeholders in such decisions. (See Issue 8 for further
discussion on the public participation process.) At this time a worst case scenario cannot be
accurately predicted due to the number of variables associated with such a prediction. Regarding
protection of the disposal facility, community, and environment, it is important to keep in mind
that although institutional controls, such as fences and monitoring, will be employed to help
maintain protection during and following remedial activities, reliance on such measures
following waste disposal plays only a minimal role in the continued protection of human health
and the environment.

Continued federal ownership of the FEMP site is a key component of the selected remedy; however,
if another governmental agency or department were to assume responsibility for the FEMP site, it
would be necessary to transfer the property (i.e., deed) to that entity. CERCLA Section 120(h)
reguires that before property can be sold or transferred by a federal department or agency, the
deed must state that all remedial action necessary to protect human health and the environment
has been taken before the date of transfer.

Thus, activities reguired under the Operable Unit 2 ROD would need to be complete before a
transfer could occur. CERCLA further stated that the government would be responsible for any
costs associated with any addtional remedial action, should it be necessary, after a sale or
transfer of the property.
Comment.

(c) AVAILABILITY OF DATA AND REPORTS. Several commentors expressed concern that monitoring data
and 5-year review reports be available to the public. One commentor included a specific list of
organizations that should receive any annual or 5-year review reports (Ross, Crosby, and Morgan
Townships; Butler and Hamilton Counties; EPA, OEPA, and Ohio Department of Heath; and
Congressional and State Representatives). (Comment lethers E, F, and 0.)

Response.

(c) Any report that is submitted to EPA, including monitoring data and maintenance inspection
reports, will be available to the public through the PEIC. The mailing list for any summary
reports or 5-year review reports will be similar to the mailing list for the Site-Wide Annual
Environmental Report (see response 5a on page RS-3-27 for information on CERCLA five-year
reviews.) The organizations and individual listed above are currently receiving the Site-Wide
Annual Environmental Report so they will continue to receive FEMP mailings unless they reguest
to have their name deleted. At any time, a group or individual may reguest to be added to the
mailing list for FEMP publications and notices.
ISSUE 6 - COST

Comment.

(a) ALLEGED MISREPRESENTATION OF MONITORING/MAINTENANCE COST. Many stakeholders expressed
concern over the cost estimated for monitoring and maintenance of the on-site disposal facility.
Many felt costs were inaccurately calculated and that the costs of Alternatives 3 and 6 would
even out if the on-site disposal facility should fail. (Comment letters A, C, F, E, H, Z and
T.)

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Response.

(a) The cost estimates in the Operable Unit 2 FS/PP-EA were prepared on a present worth basis.
Present worth analysis allows projects of varying schedules to be given an unbiased comparison.
In this study, present worth is basically the amount of money that would have to be invested
today to completely pay for all construction costs for an alternative, plus 30 years of
monitoring and maintenance costs following completion. This adheres to EPA protocol for cost
estimation. The 30-year cutoff for monitoring and maintenance costs is used because costs the
relatively minor (in present worth terms) after that period, and because the ability to foresee
financial conditions beyond 30 years is poor. For projects with long term monitoring and
maintenance costs, the costs beyond 30 years can be estimated as the money needed today to
established a fund which, at the end of the 30-year period, would be capable of yielding
sufficient interest to pay for monitoring and maintenance of the on-site disposal facility for
1000 years in the future. The most recent FS estimates and the additional month needed for the
monitoring and maintenance fund the presented in the table below for Alternative 3 and 6.
Alternative 3 (Excavation and Off-Site Disposal) reguires continued monitoring at the subunits
where the waste excavated while Alternative 6 (Excavation and On-Site Disposal with Off-Site
Disposal of Fraction Exceeding Waste Acceptance Criteria) reguires monitoring at both the
subunits and at the on-site disposal facility. The costs beyond 30 years the based on the same
interest rate and inflation rate assumption utilized in the overall estimate.

Estimate with 30 years of Additional Cost for Monitoring
Alternative Monitoring & Maintenance & Maintenace Beyond 30 Years
3: Off-site Disposal $213,000,000 $9,000,000
6: On-site Disposal $106,000,000 $13,000,000
Comment.

(b) COST SHOULD NOT BE A FACTOR. Whether costs are accurately represented or not, others felt
cost should not be a factor in the selection of a remedial action. (Comment letter T and AA.)

Response.

(b) Cost is one of five "primary balancing criteria" (as discussed in Section 8.0 of the
Decision Summary) used to determined the most appropriate solution under the CERCLA process for
selection of a remedy. Cost waste therefore considered, however, as one of nine evaluation
criteria it was not the sole deciding factor. See response to Issue (1)(a) for greater detail.
Comment.

(c) SITE-WIDE PERSPECTIVE. One commentor was interested in reviewing the costs associated with
the possibility for disposal of other operable unit waste (i.e., Operable Unit 5 and Operable
Unit 3) on site. (Comment letter E.)

Response.

(c) The costs presented in the Operable Unit 2 Proposed Plan the for the disposal of Operable
Unit 2 remediation waste only. However, DOE is currently evaluating the potential for disposal
of other operable unit remediation waste in the disposal facility and will provide information
for public review as it becomes available and formally during the Operable Unit 5 and Operable
Unit 3 public comment periods.

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ISSUE 7 - FUTURE USE/OWNERSHIP

Comment.

(a) OWNERSHIP OF FEMP SITE. Members of the community and OEPA suggested that DOE ownership and
the of institutional controls Unit Operable Unit 2 or that portion of the site on which the
on-the disposal facility is located is essential in protecting human health and the environment.
Others expressed that protectiveness could only be ensured if DOE (or the federal government)
maintains ownership of the entire site. One commentor noted that full disclosure and any
restrictions to the FEMP property need to be included in the deed to the property. (Comment
letters E, G, L, 0, and BB.)

Response.

(a) The preferred remedial alternative for Operable Unit 2 reguires continued federal ownership
of the FEMP the with institutional controls (such as fencing and monitoring). At this time, DOE
cannot declare future ownership of the entire site until completion of the remaining operable
unit remedial decision and input from the Fernald Citizen's Task Force (FCTF) [a site specific
advisory board chartered in August 1993 to develop recommendations on futue use(s), cleanup
levels, cleanup priorities, and waste management options at the FEMP solid, and other
stakeholders. Should the future use(s) of the FEMP the change from federal ownership with
institutional controls, the Operable Unit 2 alternative would be re-evaluated to ensure
protection for the designated use. Note that any decision to transfer ownership to a
non-federal entity would be a significant change fundamentally altering the basis features of
the selected remedy resulting in the amendment of the ROD.

Restrictions to the use of the property will be noted on the property deed before the property
could be sold or transferred to another party. Refer to Issue 5(b)(2) for more discussion on
deed restrictions.
Comment.

(b) ABOVE BACKGROUND LEVELS - PUBLIC'S RIGHT-TO-KNOW. One commentor felt that the public had
the fight to know whenever "materials" released from the federal control were above background
levels (even though below cleanup levels. The commentor felt that posting information about
areas that are above background levels (once remedial activities are completed) is essential for
the public to make informed choices as to any exposure they might receive. (Comment letter F.)

Response.

(b) At this time, end-use of the property has not been determined. However, DOE will identify
any necessary the use to ensure safe use of the property in areas that the above background
levels (but meet or are below cleanup criteria). DOE, EPA, and OEPA, as wall as the FCTF,
maintain that the feature use(s) and cleanup levels on the FEMP site will be protective of human
health and the environment.
Comment.

(c) FUTURE MONETARY BENEFIT. Commentors expressed the opinion that it is in the best interest
of are residents as well as the federal government to have contaminants removed to enable the
site to be converted to a use which will be a monetary tests to both the community and federal

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government.  One commentor waste concerned that DOE will bury the waste and move away leaving
area residents with no benefit from the site having been there.   (Comment letters H and M.)

Response.

(c) DOE, EPA, and OEPA the working closely with the FCTF [as discussed in Issue  (a)]  in an
effort to logically reach a balanced decision regarding the most feasible future land use(s) for
the FEMP site.  The FCTF, based on input from the community and other stakeholders, well make a
recommendation to DOE as to what the end-the of the FEMP site should be.  The FCTF embody
several values in their recommendation including environmental, economic, social and human,  and
long-term management.  DOE will give full consideration to the FCTF recommendation when making
its design on future use(s)  of the FEMP site.
                               ISSUE 8 - PUBLIC PARTICIPATION PROCESS
Comment.

(a) EXTENSION OF THE PUBLIC COMMENT PERIOD.  On November 21, 1994 a formal reguest to extend the
public comment period by 30 days waste made by Betty Brown on behalf of the Ross Township
Trustees.  On December 20, 1994, the Ross Township Trusses reguested a second 30-day extension.
Other stakeholders expressed concern about not having sufficient time to review the remedial
alternative.  (Comment letters B, U, and AA.)

Response.

(a) DOE considered both reguest for extension of the public review period in accordance with the
provision of the NCP, 40 Code of Federal Regulations (CFR) 300.430(f)(3)(i)(C).  In accordance
with Sections XVIII.B.5 and XVIII.D of the 1991 Amended Consent Agreement, DOE reguested EPA
concurrence for the initial 30-day schedule extension to the public review period.  The EPA
orallu concurred on November 22, 1994 with written concurrence on December 14,  1994.  DOE issued
formal public notification of the first extension on November 30, 1994.  Following the second
30-day extension reguest received on December 30, 1994, DOE granted a 20-day extension to allow
for appropriate stakeholder review while maintaining established schedule.  Documentation of
these  decisions can be found in the Administrative Record located locally in the PEIC ast 10845
Kami1ton-Cleves Highway, Harrison, Ohio 45030.
Comment.    (b) PUBIC INVOLVEMENT AFTER THE ROD.  Stakeholders, including OEPA, expressed a
desire to continue the same level of public involvement in post-RI/FS activities.  Some members
of the community reguested that DOE formally specify the level of public involvement during RD
and RA in the ROD.   (Comment letters E, F, G, H, L, and 0.)

Response.

(b) As a result of some of these same concerns during the Operable Unit 4 public review
process, DOE revised the FEMP Community Relations Plan to include public participation during RD
and RA.

The Revised Community Relations Plan was reviewed by OEPA and EPA and was distributed for
stakeholder review.  OEPA approved the document in December 1994 and EPA approved the document
in January 1995.  Additional revisions of the Community Relations Plan are anticipated to focus
on public involvement during long-term monitoring and maintenance and CERCLA five-year reviews.

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The frequency for the review and revision of the Community Relations Plan waste be agreed upon
between EPA and DOE after input is solicited from the public.
Comment.

(c) FUTURE REVIEW OF THE ROD.  One commentor was concerned that a mechanism for stakeholders to
initiate a request for future review or possible amendment of the ROD be included in the ROD.
The commentor was also concerned that if for some reason the ROD could not be fully implemented,
the ROD should be reopened with full public participation.  This commentor also stated that the
ROD should be enforceable with fines and lawsuits, if necessary.  (Comment letter F.)

Response.

(c) The ROD is a siqned, legally enforceable document.  After signature of the ROD by EPA, if
the remedial action differs significantly from the remedy selected in the ROD with respect to
scope, performance, or cost, DOE would either:

1) Publish an explanation of significant difference  (when a remedial action difference
significantly change, but does not fundamentally alter the remedy selected in the ROD with
respect to scope, performance, or cost)  to be made available to the public in the Administrative
Record and Information Repository (i.e., PEIC) along with publication in a major local newspaper
of general circulation  (a notice briefly summarizing this explanation including the reasons for
such difference); or

2) Propose an amendment to the ROD (when a remedial action difference fundamentally alters the
basic features of the selected remedy with respect to scope, performance, or cost).   To amend
the ROD,  DOE would issue a notice of availability and brief description of the proposed
amendment in a major local newspaper of general circulation; make the proposed amendment to the
ROD and information supporting decision available for public comment; and provide a reasonable
opportunity to comment, not less than 30 calendar days.

In the event of a ROD modification DOE will notify stakeholders and provide an opportunity to
voice questions and concerns.  A workshop would be offered if the modification is an
"explanation of significant differences."  In the case of a ROD amendment, a workshop could be
provided if there was significant interest from the public in having both a formal public
meeting and an informational workshop.

In response to concerns regarding full implementation of the ROD, the primary enforcement
vehicle of the ROD is the 1991 Amended Consent Agreement which requires DOE to implement,
subject to EPA approval, remedial design (RD) and remedial action, (RA).   The 1992 Amended
Consent Agreement includes provisions for stipulated penalties in the event of DOE
non-compliance with RD and RA requirement.   Non-compliance would include failure by DOE to
implement the remedy selected in the ROD.  In addition, Section 310(a)(1) of CERCLA  [42 U.S.C.
§9659(a)(1) ]  affords person the right, under certain circumstances,  to take civil action to
enforce the terms of the 1991 Amended Consent Agreement.
Comment.
(d) NTS REVIEW.  The NTS Citizens Advisory Board  (CAB) is concerned that NTS communities have
been given insufficient time to review and comment on many issues associated with the FEMP site.
The CAB felt that NTS communities should be afforded the same time frame as Ohio residents to

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consider the issues.  (Comment letter Y.)

Response.

(d) DOE agrees that the NTS communities should be given the same amount of time to consider and
comment on issues at the FEMP site that could potentially impact communities surround the NTS.
Representatives from Nevada, including the CAB, the now on the FEMP site document mailing and
postcards were mailed to the CAB and State announcing both public comment period extensions.  If
future problems in obtaining FEMP site documents for review arise, stakeholder should contact:

              Gary Stegner, Director
              Public Information
              Fernald Area Office
              U.S. Department of Energy
              P.O. Box 538705
              Cincinnati, Ohio 45253-8705
              Phone:  (513) 648-3153
Comment.

(e) PUBLIC UNDERSTANDING.  One commentor waste concerned that the public does not truly
understand what a permanent disposal facility means for the area.   (Comment letter H.)

Response.

(3) DOE intends to continue involving community members and other interested parties in decision
making at the FEMP site.  DOE has provided the public with several opportunities to comment on
decisions relating to the remediation of Operable Unit 2. Section 2.0 of this Responsiveness
Summary discusses the community relation activities that were concluded for stakeholders
interested in the Operable Unit 2 remedial action. DOE is committed to public involvement to
ensure informed decisions are made.  If the commentor or other stakeholders have any suggestions
for improving DOE's public involvement program, please contact Gary Stegner a the address listed
in the preceding paragraphs.
                       ISSUE 9 - MISREPRESENTATION OF RISK AND BACKGROUND LEVELS

Comment.

(a) RISK LEVELS.  One commentor expressed content that an Incremental Lifetime Cancer risk
(ILCR) of 1x10-6 (one in million)  is an unjustifiable and ultraconservative risk level and that
the Fernald Citizen Task Force will recommend a remediation goal of 1x10-5  (one in one hundred
thousand which is eguivalent to ten in one million)  in their report to DOE.  The commentor also
recommended that EPA reevaluate the "slope factor" method for determining risk due to
radioactivity.  Another commentor declared the opposite by saying that there is no safe
threshold for human exposure to radioactivity One commentor felt that the cleanup goal should be
background levels.   (Commit letters C, F, and Z.)

Response.

(a) The ILCR range identified by CERCLA regulations is 1x10-6 for 1x10-4 for the entire site.
Separate sets of cleanup levels in Operable Unit 2 were evaluated based on each of the 1x10-6,
1x10-4, and 1x10-4 LLCR levels.  It should be noted that while the cleanup levels set for each

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of thee ILCR levels the protective of human health, it is also important to calculate the total
risk for a remedial altenative from the total exposure to exposure to contaminants of content
through multiple exposure pathways (i.e., additive risk). This evaluation was conducted in the
Operable Unit 2 FS Residual Risk Assessment.

Because of this additive nature of risk and risk contributed from other operable units,
cleanup levels based on 1x10-6 ILCR risk were used as the point of departure for evaluating
Operable Unit 2 alternatives. This is consistent with the evaluation conducted in the Operable
Unit 1 and Operable Unit 4 RI/FS documents.

The Amended Consent Agreement schedule reguired Operable Unit 2 to identify a preferred remedial
alternative before the Fernald Citizens Task Force (FCTF) made final recommendations. As
identified in the Operable Unit 2 FS/PP-EA, DOE will give full consideration to the FCTF
recommendation.

The slope factors used to determine the risk from radioactivity were obtained from the most
current edition available at the time of the evaluation (1993) of the EPA Health Effects
Assessment Summary Table. This table contains the best reliable information that is currently
available and is reguired to be used in CERCLA risk assessment. Any significant changes to
slope factors in the future will be evaluated prior to initiation of remedial action and during
the CERCLA 5-year reviews after the remedial action is initiated. Should a change to the
remedial action be warranted, a modification to the ROD waste be proposed and presented for
public comment. See the response to Issue 8(c) for a discussion of the ROD modification and
associated public involvement process.
Comment.

(b) BACKGROUND LEVELS. One commentor felt that Operable Unit 2 background levels were confusing
and possibly wrong. As an example the commentor cited specific tables from the Operable Unit 2
Proposed Plan (Tables 5.2, 5.3, and 5.4) in which the sum of the background levels for the
uranium isotopes did not egual the background level for total uranium. Additionally, it was
also noted that the background levels for Operable Unit 2 are inconsistent with other operable
units and the statistical uncertainty of the background values is not presented. (Comment
letter C.)
Response.

(b) The background values used for Operable Unit 2 are based on the data in the EPA approved
background reports for groundwater and soil for the FEMP site. The 95th percentile value of the
data waste used to represent background in these reports. The background data for each of the
Operable Unit RI/FS documents were the same. These documents are referenced in the Operable
Unit 2 RI Report and can be found in the Administrative Record at the PEIC. It is important
when comparing numbers to be sure to note whether the background is for surface soil or
subsurface soil. Because of the planned excavations, Operable Unit 2 evaluations used the
background values for subsurface soil.

In the Operable Unit 2 Proposed Plan, the units for the uranium isotopes are in pCi/g while the
unit for total uranium is in parts per million (ppm), therefore they are not directly additive.
The background value for total uranium is determined from a different test method than the
uranium isotopes. The summation of the isotopes converted to total uranium in ppm eguals the
total uranium value within the precision of the test methods. Table 9-1 on the following page
illustrates this conversion.

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                                  TABLE RS-9-1

     CONVERSION OF URANIUM ISOTOPIC ACTIVITY TO TOTAL URANIUM IN MG/KG
                              (PPM) FOR SURFACE SOIL

                                 Activity            Conversion              mg/kg
                                  pCi/g               (divide by)

Uranium-234                       1.24                6.22x 10+3             2.0x10-4
Uranium-235/236                   0.145               2.16                   0.07
Uranium-238                       1.22                3.3x10-1               3.63
Total Uranium                                         3.8

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ISSUE 10 - USE OF NEW TECHNOLOGY IN THE FUTURE

Comment.

(a) REVIEW OF NEW TECHNOLOGIES. One commentor question whether there were any innovative
technologies that could have been incorporated into the Operable Unit 2 preferred remedial
alternative. Several commentors, including OEPA, felt that DOE should continue to review and
consider new technologies, as well as support the development of technology which may reduce the
volume, toxicity, or mobility of the waste for on-site disposal or improve the design of the
disposal facility itself. It was expressed that this review should be carried out before before
and after waste is placed in the on-site disposal facility. One commentor stated that the
technology reviews should be include in the CERCLA 5-year reviews. (Comment letters C, E, F, G,
and 0.)

Response.

(a) DOE considered a range of technologies for use in the Operable Unit 2 remedial action. Two
"innovative" technologies that were evaluated were verification and soil washing. These
technologies were screened out due to either effectiveness, implementability or cost
effectiveness. The details of these and the other technologies that were considered are
included in the Operable Unit 2 FS/PP-EA.

Because DOE has many other sites that will have to manage, treat, and/or dispose of low-level
readioactive waste, new technologies will continue to be evaluated. The DOE Office of
Technology Development oversees technology research and demonstrations at many technology across
the nation. As stated in Section 8.0 of the Decision Summary, if a technology is developed that
may significantly reduce the volume, toxicity, or mobility of Operable Unit 2 waste, it will be
thoroughly evaluated for use at the FEMP site.

Engineering studies will be performed on the geochemical barriers and brickmaking
technologies during the Remedial Design process. These studies would be completed in a
phased approach to determine (1) the effectiveness of the two technologies, and (2) the need for
additional studes. DOE would proceed with further studies only if it is determined that the
technologies are the cost effective and reduce contaminant toxicity, mobility, or volume. If a
decision was made to implement a new technology, the Administrative Record would be reopened and
public comments would be addressed before any additional action would be taken. See response
Issue 8(c) for a discussion of the ROD modification and associated public involvement process.
Comment.

(b) RETRIEVABILITY OF WASTE. One commentor expressed that the disposal facility should be built
a such a way that the contents the safely retrievable. Thus, if future remediations efforts
would be necessary or if a new technology is developed, the waste could be accessed without
unnecessary risk to workers, the community, or the environment. (Comment letter F.)

Response.

(b) Because the Operable Unit 2 remediation waste will be disposed above ground, the waste could
be excavated should it become necessary. Records describing the types of waste in each area of
the facility will be kept such that specific areas of remediation waste could be retrieved if
necessary. If it is necessary excavated the waste, such activity would be planned and
implemented in a manner such that for emissions and exposure to radiation will be kept to a
minimum and would be in compliance with DOE and EPA standards.

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ISSUE 11 - INTEGRATION AND CONSISTENCY WITH OTHER OPERABLE UNITS
Comment.

(a) CONSISTENT CLEANUP LEVELS. One commentor contended that Operable Unit 2 cleanup levels must
be consistent with other operable units (i.e., Operable Unit 1 is 58 pCi/g of uranium-238 and
Operable Unit 2 lists four different levels). (Comment letter I.)

Response.

(a) The cleanup levels for Operable Unit 2 are based on the same level of protection are the
cleanup levels for Operable Unit 4 and Operable Unit 1. Specifically, this level of
protection is not to cause a greater than one in one million increase in an incremental
lifetime cancer risk (ILCR). The main factor that may cause different cleanup levels for the
same level of protection is amount of native till (a type of soil) that is protecting the
Great Miami Aguifer. The Operable Unit 2 subunits are not contiguous areas, and therefore, have
differing types of name till and hydrogeology under each subunit. These specific conditions
were used to develop the cleanup levels for each subunit in Operable Unit 2. For example, the
uranium-238 cleanup level for the Inactive Flyash Pile is 6.12 pCi/g, as compresented to the
Lime Sludge Ponds at 45.3 pCi/g. A portion of the Inactive Flyash Pile is located directly over
the Great Miami Aguifer while the Lime Sludge Ponds have approximately 30 feet of soil between
the bottom of the subunit and the top of the aguifer. Similar differences in the other operable
units result in different cleanup levels but the same level of protectiveness. These differing
cleanup levels allow DOE to ensure protection of the aguifer in the most vulnerable areas. The
methodologies to develop cleanup levels were consistent among operable units, but
location-specific.
Comment.

(b) COMPREHENSIVE ROD. One commentor suggested that DOE take all RODs at the FEMP site and roll
them into one "big picture" ROD that would incorporate any improvements in wording over time.
(Comment letter F.)

Response.

(b) DOE incorporates any new or improved information into subseguent FEMP documentation
(including RODs), where appropriate (e.g., lessons learned). Following the issuance of the ROD
for the last of five operable units, the Amended Consent Agreement provides for a Comprehensive
Site-Wide Operable Unit (Operable Unit 6). If needed, Operable Unit 6 (as discussed in Section
2.0 of the Decision Summary) will be created to perform a final assessment from a site-wide
perspective to ensure that ongoing or planned remedial action identified in the RODs for the
five operable units provide a comprehensive remedy for the FEMP site which is protective of
human health and the environment. If it is determined that the remedial actions specified in
the RODs for Operable Unit 1 through 5 the not protective from a site-wide perspective, an
Operable Unit 6 FS would be initiated with a corresponding ROD if an action alternative is
selected. For any wording improvement that affects the implementation of the preferred remedial
alternative or the basis for the selection of the alternative, a modification to a ROD can be
considered. This would reguire acceptance of the changes by EPA and a formal public comment
period. See response to Issue 8(c) for a discussion of the ROD modification and associated
public involvement process.

-------
ISSUE 12 - TRANSPORTATION

Comment.

(a) SAFER TRANSPORTATION METHODS. Some Members of the community expressed concerns related to
the transportation of Operable Unit 2 waste (exceeding waste acceptance criteria) from the FEMP
site to the off-site disposal facility (e.g., Envirocare in Clive, Utah or the Nevada Test
Site). One individual suggested exploring encapsulation technologies to ensure the site
transport of waste. (Comment letters J and Z.)
Response.

(a) The amount of Operable Unit 2 waste expected to exceed waste acceptance criteria is
approximately 3,100 cubic yands (not including the approximate 300 cubic yards of Firing
Range material to be shipped off site). This material is expected to range between 346 and
1,580 pCifg of uranium-238. These concentrations are lower than the levels in the 600,000 cuhc
yards of waste pit material from Operable Unit 1 (average uranium-238 concentration of 5,563
pCi/g) where the preferred alternative has been identified as transportation of these waste
without encapsulation. Based on evaluation of the same nine criteria that the Operable Unit 1
decision was based on, it is not believed that any treatment other than drying (i.e., removal of
excess water) would be needed to transport Operable Unit 2 remediation waste.

The relatively small guantity of Operable Unit 2 material reguiring off-site disposal would
be packaged in containers suitable for shipment by rail or truck. An off-site disposal
facility has not been identified; however, Envirocare in Clive, Utah was used as the
representative off-site disposal facility for purposes of the cost estimate. If the
representative site is selected, Operable Unit 2 waste material would follow procedures
similar to those established by Operable Unit 1. Operable Unit 1 currently plans to stop waste
material, by rail in gondola cars with hard tops. Each gondola car would be lined with a
flexible membrane liner, bulk material would be placed within liner, the liner would be tied at
the top to enclose the material, and the hard top would be affixed to the gondola car prior to
shipment. A compilation of risks associated with the transportation of waste off site waste
completed for the Operable Unit 2 FS and provided as Appendix E in the Operable Unit 2 FS/PP-EA.
ISSUE 13 - PROCESS KNOWLEDGE
Comment.

(a) One commentor waste concerned that process knowledge was not utilized in determining the
contents of the Solid Waste Landfill. (Comment letter I.)

Response.

(a) DOE conducted extensive research during the RI. This research included in-depth record
searches and interviews with current and further employees. No records were found to exist and
employee knowledge of what waste disposed in the Solid Waste Landfill was limited. Laboratory
testing to determine contaminant levels and trenching to perform a visible inspection of waste
material were conducted in the Solid Waste Landfill during the RI. In addition, remedial
activities in the Solid Waste Landfill will include the excavation and screening of all
material.

-------
             4.0  SUMMARY OF COMMENTS NOT RESULTING IN ISSUES
DOE determined that all public comments received resulted in issues.

-------
                             ATTACHMENT I
                   FORMAL WRITTEN AND ORAL COMMENTS
                                                    53
                                              Commit A
1                   MR. WILLSEY:  Sorry,  one more thing,

2      Don and I have to leave because we have a levy on

3      and we're going to get up to the Board of

4      Elections,  we're supposed to be up there.  Thank

5      you very much.

6                   MR. WARNER:  We appreciate your

7      participation.  Richard Strimple.

8                   MR. STRIMPLE:  I'm going to just

9      make a little statements on water aguifers.   If it

10     is polluted,  it's already polluted.

11                  MR. WARNER:  You are Richard

12     Strimple?

13                  MR. STRIMPLE:  Yes, I'm sorry.   It's

14     polluted forever and there's no going to be a

15     permanent digging it up and hauling it out.   You

16     will dilute it,  you will cut your options, but for

17     somebody to think that they're going to clean it

18     up, it's spitting into the wind, period.

19                  MR. WARNER:  Thank you, Richard.

20     Russ Beckner.

21                  MR. BECKNER:  My name is Russ

22     Beckner, I'm a resident of Ross Township and live

23     1 ,500 feet from the site.

24                  I would just like to go on record

                  Spangler Reporting Services
              PHONE  (513)  381-3330 FAX (513)  381-3342

-------
                                  Comment A (Continued)





1      that I support Alternative 3 versus 6 for the





2      following reasons:   One,  I feel it's definitely the





3      safest choice for the area.  Second, long term it





4      is definitely the least expensive, and long term





5      would only be a few decades, not a century.  Today





6      no one can guarantee that a guality maintenance





7      program will be put in place and maintained because





8      the people doing it are very possibly not even





9      alive today, and I  think some of the things we've





10     seen occur at this  site in the last four decades





11     confirm that.





12                  Also I would ask our EPA





13      representatives to give a second thought,  would





34      they be so positive around the plan they support if





15      they lived 1,500 feet from the site as opposed to





16      the locations they mentioned.  And the last thing,





17      as I said earlier, there's no one that can design





18      anything today that hasn't been designed before and





19      guarantee it will  have a 500-year life.  Thank





2 0      you.





21                  MR. WARNER:   Thank you, Russ.   Are





22      there any other comments from the floor?  That was





23      the last of our registered commenters.  Yes, sir,





24      you want to come up and state your name, please.





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-------
                    Board of Trustees                  Comment B
                       Ross Township
                     Donald H. Thiem
                      David M. Young
                    Thomas E. Willsey, Jr.
Mr. Gary Stegner, Director
Public Information
Fernald Area Office

December 14, 1994

Mr. Gary Stegner,

The Ross Township Trustees representing Ross Township wish to
express our objection with the recent plans to store waste material
at the Fernald site.

Assurances that the clean up would be a complete removal of all
contaminated materials has been told to us time and again over the
years.  For the DOE and the State and Federal EPA to change direction
at this late date in the clean up operation is criminal.

We speak to all agencies before mentioned to reconsider this plan
for all our sakes.  Remove all the waste as originally planned.
                                 
                                 Donald H. Theim
                                 David M. Young
                                 Thomas E. Willsey, Jr.
                                 Board of Trustees, Ross Township
                                                         Comment B  (Continued)

                                                  ROSS
                                                  TOWNSHIP

-------
 TRUSTEES:      Donald H. Thiem   !    Thomas E. Willsey    !    David Young

                             CLERK:     Betty J.  Brown


November 21, 1994

Gary Stegner
Director of Public Information
Fernald Area Office

Dear Mr. Stegner:

The Ross Township Board of Trustees reguest an extension of
30 days regarding comments of the proposed plan for remedial
actions at operably Unit 2.   Extension reguested being from
November 25th to December 25th.

Sincerely,

Ross Township
Board of Trustees

Thomas E. Willsey
Donald H. Thiem
David M. Young




By:  Betty J. Brown
     Ross Township Clerk


2143 Timberman Road  !  Hamilton,  Ohio  45013  !  Phone/FAX (513)  883-2337

-------
Comment C

1994.11.22

Mr. Gary Stegner, Director
Public Information
Fernald Area Office
U. S. Department of Energy
P.O. Box 538705
Cincinnati, OH 45253-8705

Dear Mr. Stegner:

My comments on the cleanup alternatives being considered in the Proposed Plan for

Remedial Actions at Operable Unit 2 (Draft DOE/EA-0953, dtd August 1994) and on
handouts provided at the public meetings on October 25 and November 8, 1994 are
enumerated in the following paragraphs.

Comment 1. I am opposed to the preferred alternative to exacavate and dispose
Operable Unit 2 material on-site with off-site disposal of the fraction which exceeds
waste acceptance criteria ( Alternative 6). The DOE should reexamine the alternatives
because it is not obvious that excavation and off-site disposal (Alternative 3) is not
better alternative from either a technical or economic viewpoint. Even though the
present worth of Alternative 3 is less than a factor of 2 greater than the preferred
alternative there are cost which have not been evaluated with regard to the long term
maintenance, monitoring and protection of the on-site disposal cell. These cost, in the
long term, could very well double the total cost of the preferred alternative.

Comment 2. The propsed disposal cell location on the Fernald Site is not protective
to the Great Miami Aquifer. The location identified public puts the disposal cell directly over
a region of the aquifer (Ross Section of the New Haven Trough) which, at the present
time based on date from OU5, is not contaminated with uranium in surface or sub-
suifare soil, perched water or to any signicant degree in the aquifer itself based on
Type 2 well data. Failure of the disposal to composite liner or composite cap would
provide direct access of contamination to the soil, to perched water and to the
aquifer. Additionally contamination of uncontaminated areas is unacceptable to me.

Comment 3. The design of the disposal cell is not suitable for long term containment
of contaminants. Climatological conditions in southwestern Ohio can be agressive and
severe, and cause deterioration particularly in materials like HOPE membranes and
the geotextile fabric. If some failure of the disposal cell containment were detected at
some future time, the only way to fix the problem would be to dig into the cell thus
providing additional potential for contamination of the environment. Costs for repair of
the cell the indeterminate at present but can be reasonably expected to be large. Similar
disposal cells in the desert southwest or other arid regions of the United States may
very well be suitable locations. The proposed preferred alternative is an example of the
"suck, muck and truck" way of doing remediation work. Are there no innovative
technologies which could be applied to demonstrate a better way?

Comment 4. An ILCR of 10-6 is an unjustified, ultraconservative risk level. Even
though it is stated in 5.1.2.1 of the FS for OU2 that this risk level would help "ensure
that the remediation goal for the entire FEMP site would not exceed 1 X 10-4 due to
the additive nature of risk", it is not intuitively obvious that this, in fact, is true or

-------
justifies such an ultraconservative point of departure. The NCRP Report No. 96
(Comparative Carcinogenicity of Ionizing Radiation and Chemicals) gives a value for
fata cancer risk over 70 years for exposure to natural background radiation including
radan exposure in homes of 3 X 10-3, or more than two orders of magnitude greater
risk from background radiation. A similar result is obtained using the recommendations
in NCRP Report No. 116 (Limitation of Exposure of Ionizing Radiation) for exposure
of memebers of the public. Using the 1 mSv/yr recommended limi, I calculate a lifetime
risk of 4.5 X 10-3, which is in good agreement with the previous value and again is
more than two orders of magnitude greater than is being used in OU2. Accepting the
fact than 1 in 3 Americans will develop fatal cancer means that the total risk including
the incremental risk from OU2 remediation is 0.333334 vice 0.333333 from other
causes. This statistically insignificant increases risk and I suspect it would be
impossible to detect in any reasonably sized cancer mortality study. The DOE should
reconsider the continued use of this ultraconservative ILCR for OU2. The Proposed
Plan already contains the necessary numbers within the EPA target range for CERCLA
cleanup sites to show that there are clear economic incentives to the use of an order of
magnitude larger ILCR from a cleanup level viewpoint without undue increased risk. It
is also my recollection that the Fernald Citizens Task Force will recommend in their
report to the DOE that an ILCR of 1X10-5 be used fro remediation goals at the FEMP
as discussed at their October 8, 1994 meeting. I also recommend that the U.S.E.P.A.
reevaluate their "slope factor" method for determining risk due to radioactivities. It is
time than more modern science be employed for evaluation of these risk factors.

Comment 5. Data for background levels of radioactivities in the Proposed Plan are
confusing at best and misleading at worst. In Tables 5.2, 5.3 and 5.4 values are given
for the three major isotopes or uranium and "Uranium-Total". In these tables the sum
of the three major uranium isotopes does not egual the total uranium (2.3 vice 3.4).
This is clealy wrong. It should also be noted that in the FS for OU2 the numbers are
given to three signigicant figures and the sum of the uranium isotopes is 2.41 with a
total uranium of 3.4. These inconsistencies are nowhere explain. Of greater concern is
the fact that OU5 uses a value of 3.73 mg/kg for the 95th percentile surface
background value, with an average range of surface background values of 2.56 to 4.83
mg/kg. The 3.73 mg/kg value converts to 2.52 pCi/g using a value of 676 pCi/g for
normally uranium. This value does not agree with the value used by OU2. To further add
to the confusion,the Site Environmental Report for 1993 states on page 72 that "Results
from this study show that the mean uranium concentration is 2.1 pCi/g with an upper
limit ( 95% tolerance limit) of 2.8 pCi/g." Although for practical radiation protection
purposes the OU5 and Site Environmental Report numbers the in reasonable
agreement, the OU2 number is not. This is critically important because cleanup levels
the compared to the value of background. Further, background values can not be used as
single point values unless some statistical uncertainty estimate is clearly cited. I have
been unable to find in any OU2 documents any statements regarding statistical
uncertainties or confidence interval estiamtes of mean values. As a minimum, the DOE
should take steps to reguire FERMCO to use a consistent set of values for such
important parameters as background uranium concentrations in the various
environmental media as well as reguiring that statistical estiamtes of the variance of
these parameters be specified.

Comment 6. The number presented at the October 25, 1994 public meeting by
FERMCO the confusing and misleading. In the chart "Comparison of FEMP
Waste Average U-238 Concentrations in Each Operable Unit" there is a line
with no labels on either the ordinate or abscissa. In any event, the Proposed
OU2 On-Site WAG is 360 pCi/g or 1071 ppm U-238. Again, for normally
uranium, 360 pCi/g converts to 724 ppm U-total or about a factors of 2 less

-------
ppm. It is true in normally uranium, U-238 has an isotopic abundance of
99.28% and U-234 is oily 0.0054%. It is also true that about half of the total
radiactivity from U-234. From a remediation viewpoint, the total
radioactivity from uranium and the other radioisotopes is the concern. It is also
inappropriate to cite on this chart OU4 numbers because in OU4, uranium is
not the major issue-Ra-226 is the issue. In any event, I don't understand this
chart. In the same presentation a chart labled "OU2 WASTE VOLUME" was
discussed. Values for average contamination and maximum contamination the
displayed in units of pCi/g U-238. These values the meaningless because
average values should only be used if it has been shown that the measurements
the normally distributed and then an estimate of the variance of the
mesurements should be given also. Maximum contamination levels are also
meaningless unless some estimator is defined-is this an outlier is the basic
guestion? The cleanup levels identified also do not seem to correlate with either
average or maximum levels. Again, by only using U-238 only half of the total
radioactivity of concern is shown. From a practical viewpoint, it would seem to
me to be easier and cheaper to measured total uranium by chemical analysis, e.g.
laser fluorimetry, than stiplulate a cleanup level on U-238 level which implies
far more expensive isotopic analysis.

Comment 7. In the public meeting on October 25, 1994 the FERMCO presenter (Jim
Williams) stated in a response to a guestion from the audience that real time
airborne radioactivity monitoring would be used in field activities during
remediation work. I am curious to learn how FERMCO intends to do this. It seems to
me that this is not a trivial task considering that ordinary air monitoring in open, field
conditions, with variable wind velocities and directions is not obvious or straigh-
forward.

Summary. I have identified my concerns with the Proposed Plan for OU2 and reiterate
that I am opposed to the selected preferred alternative. Overall I judge that the
technical facts in the Proposed Plan lack scientific rigor and the conclusions
presented are not persuasive.
Very Truly

Louis C. Bogar
2080 Smith Road
Hamilton, OH 45013

-------
                               Comment E





1                   MR. WILLIAMS:  Those are millions.





2                   MS. CRAWFORD:  Millions.  Does that





3      include the cost of the cell or does the cost of





4      the cell fall under OU-5?





5                   MR. WILLIAMS:  That includes the





6      cost of the cell for Operable Unit 2, for Operable





7      Unit 2 volumes,  that's correct.





8                   MS. CRAWFORD:  So to get an overall





9      cost of the cell itself,  are we able to do that





10     yet?





11                  MR. WILLIAMS:  Yes, we can, and in





12     fact OU-5 will be submitting their Feasibility





13     Study next week, and that will have the official





14     comparable cost estimates for the OU-5 volumes of





15     material as well as they're also looking at the





16     off-site alternative.  So on more of a site-wide





17     perspective, it will have the capability of looking





18     at on-site versus off-site for a wider range of





19     cleanup volumes.  This is specific to the 300,000





20     cubic yards for OU-2.





21                  MS. CRAWFORD:  Now, I need your





22     little computer man to put up his other little





23     thing that he had up there with them two little hot





24     pink boxes on it.  My guestion is what's in them








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-------
                                    Comment E (Continued)








1      sense of anything like derbies and so forth.  The





2      operational history of the landfill is not well





3      understood.  They didn't keep records.  It was





4      essentially a place to put stuff you didn't want





5      anymore, and so they did that.  However,  just --





6      this is a good time to explain how things would





7      operate.  How do you make sure you didn't miss one,





8      how do you know what you're putting in the cell is





9      what you say you're putting into the disposal





10     facility, and the plan is for every unit of





11     material that comes out of the waste units will be





12     screened and sampled right there before it's taken





13     to the disposal facility to insure that it meets





14     the waste acceptance criteria, and then that





15     characterization will be verified from the





16     stockpile at the disposal facility.  It will be





17     looked at twice before it goes into the disposal





18     facility, and if it doesn't meet the waste





19     acceptance, then it doesn't go into the facility.





20                  MS. CRAWFORD:  Is there going to be





21     like a huge lag time by the time you pull it out of





22     this thing, you test it, and you sift through it to





23     make sure it's what you say it is until you get it





24     to put it in the waste cell?





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-------
                                         Comment E (Continued)

November 20, 1994

                                                  RE:  DOE-FEMP
                                                       O.U.2 Proposed
                                                       Plan - Comments

Mr. Gary Stegner
Director, Public Information
U.S. D.O.E Fernald Area Office
P.O. Box 538705
Cincinnati, OH 45253-8705

Dear Mr. Stegner:

The purpose of this letter is to provide my official comments on
the Operable Unit 2 Proposed Plan.  I want to make it very clear
that I am commenting as an individual resident and not as the
president of F.R.E.S.H, Inc. or as a member of the Fernald
Citizens Task Force.  So, my official comments as a individual
citizens living around the Fernald FEMP I would like the following
comments instituted into the final plan.

1.  While I am not extremely happy with the possibility of having
    a on-site disposal cell, I believe the preferred alternative is
    the appropriate one, when considered in the context of overall
    site clean-up.  I suppose the idea of balanced approach
    where the low volume high concentration wastes go off-site for
    disposal and the high volume lower concentration wastes are
    disposed of on-site in a engineered facility.

2.  The O.U. 2 ROD must place restrictions on the use of the on-
    site disposal facility.  The following restrictions must be
    put into the ROD:

    a.)   No off-site waste will ever be disposed of in this
         disposal cell or anywhere else on the Fernald FEMP
         property.

    b.)   The waste acceptance criteria  (WAG)  for Uranium-238 must
         be set at a maximum of 360 pCi/g with the flexibility of
         being lowered based on other operable unit decisions and
         volumes.  The WAG will be an upper limit concentration
         acceptable into the cell and will be used as an
         "average" limit.

    c.)   No hazardous waste of any kind will be disposed of in this
         on-site waste cell.

3.  DOE should continue to review and consider new technologies
    which may reduce the volume and toxicity of waste being
    disposed of on-site.  They must remain open to new ideas which
    could possibly result in a safer waste form for on-site.

-------
4.        During the implementation of the preferred alternative,  the
         DOE must use excavation and waste management techniques  which
         will prevent the dilution of waste concentrations to meet the
         WAG's.

5.        DOE must do real-time monitoring for discharges to the
         environment.  Data obtained from the real-time monitors  and
         any other monitoring activities should be provided to the
         public in a timely manner.

6.        DOE should make a consorted attempt to include pollution
         prevention whenever possible during the design and operation
         of the OU 2 remedial action system.  All of these should be
         included in the design of the system.

7.        DOE must ensure the public at large that their involvement
         will not be discontinued during the FD/RD.  DOE must commit in
         the ROD for OU 2 to continuing the on-going public involvement
         program during the RD/RD.

8.        DOE must maintain within the OU 2 ROD that the government will
         maintain permanent ownership of the property associated  with
         the OU 2 ROD.   DOE ownership of this property is essential to
         maintaining institutional controls and limiting land-use to
         ensure protectiveness of this site.

9.        While I'm nervous about granting the DOE a USEPA waiver  of the
         Ohio solid waste siting criteria, I would much rather see a
         on-site waste cell instead of seeing the waste capped in
         placed.  But,  at the same time, I would like the restrictions
         described in comment #2 to be included with this waiver.

In summation,  the following issues must be considered for the ROD
of OU 2:

         *  no off-site waste for disposal on-site at Fernald (never and
            none at any time)

         *  DOE/Government must maintain future ownership of the  Fernald
            site (the entire Fernald site)

         *  if we must have a disposal cell, it must have least a 300
            foot buffer zone (more if possible) and it must be
            placed on the best geology of the site

         *  the community/public must have a say and part in the
            disposal cell construction, with specifics

         *  the level of detail in the ROD should be very specific and
            inclusive with the public's comments,  (meet WAC's, no off-
            site waste, meets arars, etc.)

         *  there should/will be real-time monitoring (day to day);
            waste in/out; emissions during construction, etc.

-------
         *  the use of the WAG as an upper limit - 360 pc/g; no averages
            and this will be a maximum.

         *  there will be no dilution to meet the WAC's - can't mix to
            lower the levels (this is totally non-acceptable)

         *  USEPA waiver of siting criteria should only be granted if
            the specifics in comment #2 are followed and adhered to.  The
            waiver must and will state specifically that no waste from
            nowhere will ever be brought into the Fernald FEMP EVER!

         *  With regard to a future waste  cell - there will be annual
            reports and 5 year reviews -- copies of all reports,
            correspondence and annual reports will be sent to local
            government agencies and concerned citizens who reguest them.

         *  During the RD alara pricipals will and must be utilized.

         *  Institutional controls must and will be used with regard to
            the on-site waste cell -- fences, monitoring devices, etc.

         *  There must and will be public participation thru the RD/RA
            process.

         *  This will be DOE/government land with deed restrictions
            and full disclosure about the land.

If you have any guestions, comments or concerns with regard to
these comments, please feel free to contact me.
Sincerely,




Lisa Crawford, Resident
10206 Crosby Road
Harrison, OH 45030

Phone:  (513)738-1688 or 8055

LC:eac

cc:  files

-------
                                               Comment F
   Comments on the Proposed Plan for OU 2 at the FEMP

Being a nearby resident, let the state up front that my preference would be for a total cleanup
of the site that would return the site to background levels and leave no waste on site. However,
since technological, political, and practical considerations must also come into play, I realize
that this facilities probably not going to happen.

However, before the final ROD is decided upon I would like to see a more real realistic
evaluation of the costs of the proposed alternative.  The costs of 0 & M were only figured for
30 yearly.  This may be a standard way of estimating costs, but it does not accurately reflect
the true costs of operating not monitoring a disposal cell at the FEMP versus disposing of the
waste off-site.  Because of the extremely long half-life of uranium the 0 & M costs will
continue year after year indefinitely. However, if the waste were disposed of in arid climate,
the 0 & M costs would be considerably less anot would also be just a portion of the costs of
monitoring a facility in an arid climate which also accepts other wastes.  Also, inevitably the
cell  will fail, and probably need repairs to prevent further contamination of the Great Miami
Aguifer.  Were these repair costs included in the cost estithates?  For a true picture of costs
you must look way beyond a 30 year time frame.

If a cell were built, anot Congress cut the 0 & M funding out, that would be the worst case
scenario for the cell, the community and the environment?
The rest of my comments are aimed at bringing up concerns and suggestions relative to the
Proposed Plan for OU 2. The ROD for OU 2 should clearly deal with or state the
following:

     *  No off-site waste will be brought onto FEMP property
for storage or disposal.   (Define off-site waste as anything
not currently on the site, except for samples that were sent
off-site for characterization or treatability studies)

     *  The ROD should state that DOE will follow a sort of
ALARA-principle in designing and executing the remediation.
The remediation levels should be as close to background as
possible given the technological, risk,  and cost
containts.  If an additional process or activity could be
us substantially closer to background at a reasonable cost
anot risk, this should be pursued.  The goal should be
background levels, not just staying within a remediation
level.

     *  If a disposal cell is built, it will be placed over
the best geology on the site.

     *  If a disposal cell is built, there should be constant
oversight by an independent expert as the engineering,
construction and filling are performed to insure that they
are gone properly.  Reports from the independent expert
should be part of the public record.

-------
     *  If a disposal cell is built, it should be built in
such a way that the contents can be accessed for future
remediation efforts if needed.  This does not mean it must
the in containers in near rows, but be stored in a way that
heavy machinery could get to it without lofting it in the
air or increasing the risks to workers, community or the
environment unnecessarily.

     *  The 5 year reviews of the ROD for effectiveness will
include an analysis of the then current technologies'
ability to pursue further remediation.  If at a future time
a technology would allow for a way to truly deactivate the
radioactivity or hazardous chemicals or for a way to greatly
enhance the long-term storage of the material, we would want
to be able to evaluate if it was desirable to pursue further
action.  This process would also call attention to the
technology research neeas of the DOE.

     *  Copies of the annual reports and the 5 year reviews
should be mailed to:
          1.  Ross, Crosby, and Morgan Townships
          2.  Butler and Hamilton Counties
          3.  OEPA, USEPA, ODH
          4.  Congressional and State Reps that have the FEMP
              in their district
          5.  Any resident, group or agency that wishes to be
              on the mailing list

     *  DOE will be responsible for reguesting proper levels
of funding for remediation and 0 & M  (including future
repairs).   If Congress does not proviae adeguate funding,
letters of inadeguate funding should go out to those on the
above mailing list.  Defining "inadeguate funding" should be
workers out with the stakeholders.  If at some time in the
future another agency takes over the remediation and 0 & M
functions of the site, it must accept the responsibilities
collection the RODs as well.

     *  DOE should commit to detail ing the 0 & M process
within its Administrative orders so that future DOE decision
makers will be clear about the importance of this ongoing
task.

     *  The RODs should be enforcable with fines and lawsuits
if necessary.

     *  A mechanism for the stakeholders to initiate a
reguest for future review and possible amendment of the ROD
should be included in the ROD.  Perhaps a petition with a
certain number of signatures?

     *  If for some reason, the ROD for OU 2 can't be
immplemented fully, the ROD should be reopened with full
public participation.

-------
     *  There needs to be a commitment that all the RODs will
be rolled up into one "big picture" ROD that will
incorporate any improvements in the wordings in the RODs
that have evolved over time.  For example, the ROD for OU 5
may have something in it that no one had thought of when
they were writing earler RODs.  If appropriate, there
should be a mechanism to incorporate it into all of the
RODs.

     *  Air monitoring data during excavation, drying and
transport will be extremely important to the community and
workers.  The best available devices and technigues should
be used to give the workers and community a clear picture of
air emissions.  Action levels should be developed  (with the
community)  so that work can be halted if they occur.

     *  Any waiver given so that a disposal cell can be
built, must include wording to keep all off-site waste from
entering the FEMP for storage or disposal.  It must also be
so site-specific that it does not create a precedent for
future federal or commericial disposal sites in the vicinity
of the FEMP.

     *  A commitment to continue the public involvement
process that has been developed over the years should be
stated clearly in the ROD.  This should extend through
design, remediation, and out into the 0 & M years.

In Section 5.1.1 of the foraft Proposed Plan for OU 2 (Aug.
24, 1994) there is a statements that as long as materials
from the site have no radioactivity above the cleanup
levels, they may be released from federal control.  While
the government may feel that this will be protective of
human health and the environment, I feet that the public has
the right to know whenever materials are above the
background levels for their area.  That way the public can
decide for itself if it wants to be in contact with such
materials.   Also, it allows the public to have the
information needed to determine if any additive or
multiplicative risks need to be considered if such materials
will be combined with other so-called "clean" materials.

Also, once cleanup is considered complete, all areas where
the public will have access and that are above background
(even if they are below the cleanup criteria) should be
posted so that the public can make included choices as to
any exposures they might incur.

Submitted by Vicky Dastlllung
               12/30/94

-------
                                                        Comment G

December 29, 1994


Mr. Gary Stegner

Director, Public Information
U.S. DOE Fernald Office
P.O. Box 538705
Cincinnati, Ohio 45253-8705

RE:  Comments on the Proposed Plan for Remediation of OU 2

Dear Mr. Stegner,

The purpose of this letter is to submit comments on OU 2's Proposed
Plan.  While it would be nice to think that everything on site will
go away, this is not a reasonable assumption nor is it fair to the
people in the western regions to be burdened with this entire
problem.  Nobody really wants this material/contaminates in their
backyard, but I can accept the preferred alternative if the
following issues are addressed and implemented in the OU 2 ROD.

1.  Meaningful public involvement beyond the ROD and throughout
    the RD/RA process.  DOE's commitment to this involvement is
    essential due to the implications of this alternative and must
    be included in the ROD.

2.  Continued efforts in technology development should proceed in
    an attempt to discover more effective methods for treatment
    and disposal of the waste streams designated for the disposal
    cell.  This also applies to the design of the cell itself.

3.  The location of the disposal cell must have at a minimum a 300
    foot buffer zone surrounding the entire cell and maximum
    geological support for additional protection of the aquifer.

4.  The waste acceptance criteria (WAG) must be established at a
    maximum of 360 pCi/g with the option to be lowered depending
    on the decisions yet to be made regarding the entire site.  The
    WAG is to be an upper limit maximum, no averaging or dilution
    of contaminants will be permitted in meeting the WAG.

5.  Waste generated from outside the FEMP will not be allowed to
    be disposed of within the FEMP boundaries under any
    circumstances.  This includes, but is not limited to hazardous,
    toxic, radioactive, and any and all waste/contaminates which
    were not a result of on-site activities.

6.  Additional discharges of contaminates during the remediation
    of OU 2 should be avoided when possible.  Methods to achieve
    minimal releases during remediation should be conducted
    throughout the RD/RA process.

-------
7.  Real time monitoring and other monitoring activities should be
    implemented during remediation and for the period for which
    the materials contained within the disposal cell pose a threat
    and risk to human health and the environment.   These monitoring
    activities should be conducted on a regular and freguent basis
    with the results provided to the public in a timely manner.

8.   The DOE or how it may evolve in the future under another
     name and the federal government must retain ownership of the
     FEMP property.  This is necessary to provide adeguate
     institutional controls in maintaining the disposal cell and
     protecting the surrounding area.  Full disclosure and
     restrictions of the property must be included in the deed to
     the land.  This must be included in the OU 2 ROD.

9.   ALKRA principles must be utilized during the RD process.

10.  A USEPA waiver of the Ohio solid waste siting criteria should
     only be granted if the DOE abides by the WAG upper limit
     stipulations has described in comment #4 above, the waiver
     specifically states that there will be no off-site waste
     disposed of on the FEMP property and no on-site waste will be
     capped and left in place.

Should you have any guestions or comments please feel free to
contact me.

Submitted by,



Pamela Dunn
7781 New Haven Rd.
Harrison, Ohio 45030

cc:file

-------
                                                  Comment H








            FORMAL COMMENTS ON THE OU2 PROPOSED PLAN





    I,  Darryl Huff, am submitting these formal comments on the





Operable Unit 2 Proposed Plan.  I am a Morgan Township resident,





a member of the Fernald Citizens Task Force, and chair of the





Task Force s Waste Disposition Subcommittee.     I submit these





comments, however, as a concerned area resident and not as a





representative of any of the aforementioned groups.





1.   I  do not think forcing area residents to accept a permanent





     disposal cell is fair.  No one asked us whether we wanted





     DOE to come here in the first place; nobody even told us





     what was going on at the site for decades.





2.   When all is said and done, DOE will have buried the waste,





     packed up, and moved out.  Area residents will be left with





     no benefit from the site having been there.  Only the waste





     will remain, and it will stay forever.





3.   Area residents are not being unreasonable in asking DOE to





     ship the OU2 waste off site.  There are 2 reasons for this-





           a) cost:  The cost of the off site option is





           approximately $213 million; the cost of the disposal





           cell option is $110 million.  If something should go





           wrong with the disposal cell, repairs might bring the





           cost of the disposal cell option much closer to that of





           the off site option.





           b) long term safety:  Places like Utah and Nevada are





           much better suited for disposal of the waste because





           they aren't located over water sources and also receive

-------
           less rainfall.

4.          I have doubts that large numbers of the public understand

           what a permanent disposal cell really means to the area.

5.          Extensive opportunities for meaningful public involvement should

           be planned for after the signing of the ROD.   The Community

           Relations Plan draft that was circulated in September does

           not give any concrete examples of what public involvement

           there will be after the ROD is signed.  That is

           unacceptable.  DOE officials must firmly commit themselves

           in writing before the ROD is signed to seeking public

           involvement at specific times during the RD/RA time frame

           and beyond after the ROD is made official.

6.          If DOE does construct a disposal cell on site, absolutely no

           off site waste will be disposed of in the cell.  I add this

           comment reluctantly, as I still do not believe the cell

           should exist.  The land there should be left in the best

           condition possible.  Area residents have already sacrificed

           enough for God and country.

7.          The Waste Acceptance Criteria limit of 360  piC/g must be a

           maximum allowable figure for any waste that goes into the

           cell.  It cannot be an average or a "soft"  ceiling/limit.

8.          DOE headguarters must issue a final ruling on the current

           ban on disposal of DOE waste at permitted commericial

           disposal facilities.  DOE headguarters has  had plenty of

           time to study the problem.

Thank you.

-------
                                                          Comment K
H. DODGION                       STATE OF NEVADA
Administrator                      BOB MILLER                       PETER G. MORROS
                                    Governor                           Director

Administration:                                    Fax  (702) 885-0865
   (702) 687-4570                                                        TDD 687-4878
  Fax 687-5856

Air Quality                                                          Waste Management
Mining Regulation and Reclamation                                    Corrective Actions
Water Quality Planning                                               Federal Facilities
Water Pollution Control

                    DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES

                         DIVISION OF ENVIRONMENTAL PROTECTION

                                  Capitol Complex

                                  333 W. Nye Lane

                            Carson City, Nevada 89710

                                 January 10, 1995
       Gary Stegner, Director
       Public Information
       Fernald Area Office
       U.S. Department of Energy
       P.O. Box 538705
       Cincinnati, Ohio 45253-8705

       RE:  PROPOSED PLAN FOR REMEDIAL ACTIONS AT OPERABLE UNIT 2

             The State of Nevada has reviewed the August 1994 documents
       relathed to the above referenced actions.  We believe the
       Recommended and Preferred Alternative which proposes to excavate
       the radioactive contaminated materials and dispose of the greatest
       extent of these materials on site, should be the selected
       alternative.

              As I am sure you are aware, the National Governors'
       Association  (NGA) has been, for the past two years, facilitating
       discussions between the DOE and representatives from States hosting
       DOE facilities, which includes both Nevada and Ohio.  Although the
       principal focus of these discussions has centered around the
       Federal Facilities Compliance Act LDR mixed waste treatment issue,
       the subseguent disposal of these and all DOE wastes has also been
       a significant concern.  A Disposal subgroup, of which Nevada and
       Ohio were both members, was formed included and reviewed pertinent
       information from all 49 DOE sites.  Presently only 16 sites have
       been determined to warrant further evaluation as to their

-------
       acceptability to support disposal activities.  Fernald remains one
       of these sites.

              It was the consensus and subsequent recommendation of the
       group that DOE must consider appropriate on-site treatment and
       disposal alternatives for all wastes generated at a site.  The
       recommended alternative for Operable Unit 2,  on-site disposal,
       which hare been determined to be a viable option, is consistent with
       the recommendations of this group.  Therefore, the final ROD needs
       to select the recommendation alternative and be supported by the DOE,
      Gary Stegner, Director
      January 10,  1995

      EPA and state of Ohio.  The selection of any other alternative
      would be inconsistent with the past two years of national consensus
      building.

                             Sincerely,

                             

                             Paul Diegendorfer, P.E.
                             Chief
                             Bureau of Federal Facilities
      PL/db

      cc:   Julie Butler,  State Clearinghouse
            John Walker,  NWPO
            John Thomasian, NGA

            Tom Schneider
            Fernald Project Manager
            Ohio EPA
            401  E. 5th St.
            Dayton, OH 45402

            Jim Saric
            Remedial Project Manager
            U. S.  EPA
            Region V - 5HRE - 8J
            77 W.  Jackson Blvd.
            Chicago, IL 60604

            Mike Savage
            Assistant Chief
            Hazardous Waste Division
            Ohio EPA
            P.O. Box 1049
            Columbus, OH 43266

-------
                                

                                              December 29, 1994

Mr. Gary Stegner
Fernald Area Office
P.O. Box 538705
Cincinnati, OH 45253

                   Re:  Operable Unit 2 Proposed Plan

Dear Mr. Stegner:

         This letter is to express my opposition to the Operable
Unit 2 Proposed Plan to put a disposal tell on the Fernald site.

         As you are aware, the proposal calls for the containment
and location of radioactive materials with a radioactive life in
excess of 20,000 years above an aquifer.  While I understand the
efforts that have been put into this project and the representation
that the best available technological knowledge has been applied to
the proposal, it is my concern that the proposal is fraught with
environmental danger.

          As you may be aware, I am one of the founders of the
FRESH organization, and I served as one of the class counsel in the
Fernald litigation.  At the time the waste pits and the K-65 silos
were initially put into operation in the 50's, it was represented
that the best technology was applied to those containment
facilities as well.  However, over the years due to the failure of
the federal government and the operators of the facility to
properly monitor these material containment areas, contamination
occurred to the soil, water, and air as a result of that
negligence.

          Despite the current conditions and the environmental
concern from the DOE, there is no way that we can be assured for
the years in the future that this disposal cell will be
appropriately monitored or that it can effectively contain the
radioactive materials which are being stored.

           It would seem more appropriate to ship these material to
the disposal site in Utah where the environmental risk are very
unital and the operators are willing to receive the materials.

           It is in the best interest, not only of the area
residents, but also of the federal government to have the
contaminants removed from the site since it will enable the site to
be converted to a use which will be a monetary asset to both the
federal government and to the community.

           In the alternative, another site in Ohio should be found
which does not present the site risk of the aquifer as the current

-------
site.  While this may take same time, it test be remembered that we
are looking far into the future when we make this decision.

           It seems short sighted, therefore, to consider the
construction of the disposal cell on the existing Fernald site.

            Your consideration of these comments is appreciated.

                                       Sincerely yours,


                                       

                                       Donald J. Meyer,  Jr.
                                       Attorney at Law

DJM:mbb

-------

       Micheal 0. Leavitt
                 Governor
Dianne R. Nielsen, Ph. D.
       Excecutive Dirctor
        Brent C. Bradford
          Deputy Director

   January 20, 1995
DEPARTMENT OF- ENVIRONMENTAL QUALITY
OFFICE OF THE EXECUTIVE DIRECTOR

168 North 1950 West
P.O. Box 144810
Salt Lake City, Utah 84114-4810
(801)  536-4400 Voice
(801)  536-4401 Fax
(801)  536-4411 T.D.D
   Mr. Gary Stegner, Director
   Publicic Information
   Fernald Area Office
   U.S. Department of Energy
   P.O. Box 538705
   Cincinnati, Ohio 45253-8705

   Dear Mr. Stegner:

   It is our understanding that Envirocare is being used for the disposal of leasite mixed,
low-level radioactive waste and is under consideration for the disposal of additional low level
radioactive waste from the Fernald facility in Ohio.  We appreciate being kept aware of what is
happening and in being given an opportunity to comment on the proposed remediation action.  It
is important to keep all the potential impacted stakeholders involved.

   We understand that a balanced process had been applied to remediation of the Fernald site.
This involved shipment of some wastes to Envirocare, stabilization of some waste on-site, and
shipment of some waste to DOE's Nevada Test Site from the different areas regarding remediation.
We support the balanced process that you have applied this remediation effort. Providing for
onsite disposal of some of the wages gives the public in Utah the perception that an objective,
technical-based decision making process was used.  The end result is that support for Envirocare
receiving out of state waste will continue and not be undermined.

   Please keep us on your mailing list for any proposes that involve shipment of wastes to Utah.

   Best Regards,
   

   Dianne R. Nielsen, Ph.D
   Executive Director

-------
Comment 0

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
December 13, 1994 RE: DOE FEMP
HAMILTON COUNTY
OU2 PROPOSED PLAN -
PUBLIC COMMENTS

Mr. Gary Stegner
Director Pubic Information
U.S. DOE Fernald Area Office
P.O. Box 538705
Cincinnati, OH 45253-8705

Dear Mr. Stegner:

The purpose of this letter is to provide Ohio EPA's official comments on the Operate Unit 2
Proposed Plan during the public comment period. Ohio EPA's comments the are as follows:

1. The OU2 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
OU2. Ohio EPA believes the alternative selected in the Proposed Plan is protection of
human health and the environment. Ohio EPA believes the preferred alternative is the
appropriate one, when considered in the context of overall site cleanup. Ohio EPA
supprts the concept of a balanaced approach where the low volume high concentration
wastes go off-site for disposal and high volume lower concentration wastes are disposed
of in an engineered facility on-site. We believed that this approach provides the most
imnplementable and protective strategy for remediation ofthe FEMP site.

2. The Operable Unit 2 Record of Decision (ROD) should clearly place restriction on the
use ofthe engineered on-site disposal facility DOE. Ohio EPA understands the need to
allow flexibility for incorporation of other opetable units but also feels the following
restriction must be made in the ROD:
a) No off-site waste may be disposed of in the proposed engineered disposal
facility or any other factory on the FEMP site;
b) The disposal facility Waste Acceptance Criteria (WAG) for Uranium-238
should be set at a maximum of 360 pCi/g with the flexibility to be lowered based
upon other operable unit decisions and volumes. The WAG must be an upper
limit of concentration acceptable into the disposal facility and may not be used
as an average limit;
c) No characteristic hazardous waste should be disposed of the facility.

3. DOE should commit to being open to consider new technologies which may reduce the

-------
       volume,  toxicity or mobility of wastes testing disposal of on-site.   Ohio EPA is simply
       requesting that DOE remain open to the area of additional technologies which may result
       in a safer waste form for disposal.

4.     During implementation of the preferred alternative,  DOE must use excavation and waste
       management techniques which will prevent the dilution of waste concentration to meet
       the WACs.

5.     DOE should commit to including and/or developing teal-time monitoring for discharges
       to the environment resulting from remedial actions.   DOE should attempt to incorporate
       any new developments in real-time monitoring from the DOE Office of Technology
       Development as well as the private sector.  Data obtained from real-time monitors and
       any additional monitoring activities should be provided to the Ohio EPA and public in a
       timely manner.

6.     DOE should attempt to incorporate pollution prevention activities whenever possible
       during the design and operation of the OU2 remedial  action system.  All available
       methods to reduce or eliminate discharges and releases from the excavation and disposal
       activities should be considered during the design of the system.

7.     DOE must ensure the public that their involvement will not be diminished during
       Remedial Design and Remedial Action (R.D/RA).   DOE should commit within the
       Record of Decision for OU2 to maintaining the exceptional on-going public involvement
       program during RD/RA.

8.     DOE should make commitments within the OU2 ROD concerning perpetual government
       ownership of properties associated with the OU2 ROD.  DOE must provided commitments
       to ensure the land-use employed the cleanup standards is maintained into the
       future.   DOE ownership is essential to maintaining institutional controls and limiting
       land-use to ensure protectiveness of the site.

9.     With regard to the request for a USEPA waiver of the Ohio solid waste siting criteria,
       Ohio EPA support this waiver only in that it allows  for a remedy more protective than
       capping in place.  Since the DOE FEMP is a CERCLA site and its location would not
       allow issuance of an Ohio EPA exemption of criteria,  Ohio EPA believes a waiver is
       the appropriate mechanism to support the preferred alternative.  Ohio EPA's support of
       the waiver is inherently tied to the restrictions described in comment #2 above.
If you have any personnel concerning these comments please contact me at (513)  285-6466.
Sincerely,


Thomas A. Schnieder
Fernald Project Manager
Office of Federal Facilities Oversight

cc:      Jack V. Kley,  Ohio AGO
         Jim Saric, USEPA
         Terry Hagen,  FERMCO

-------
         Lisa August, Geotrans
         Jean Micheal, PRC
         Manger TPSS, OEPA/DERR
         Jeff Hardly, OEPA/Legal
         Robert Owen, ODH
-------
                                                                              Comment Q

                                November 21, 1994

Mr. Gary Stegner, Director
Public Information
Fernald Area Office
U.S. Department of Energy
P.O. Box 538705
Cincinnati, Ohio 45253-8705

Dear Mr. Stegner:

      We the just one of a number of Ross residence who the opposed to your decision to
inmplement the Remedial Alternative 6 process or (Excavation and On-Site Disposal with Off-Site
Disposal of Fraction Exceeding Waste Acceptance Criteria)  for the removal of waste at Operable
Unit 2 at the FEMP site.

      When we moved into the Ross area five years ago, we were told that they had every
intention of removing all waste material from the site.  Knowing that they had intended to clean
up this area, was a main concern for our decision to move into the Ross area.  If we would have
known then what we know now, we would not be living in Ross today.

       We the totally opposed to the Alternative 6 decision and are only concerned with
removing all waste material from the FEMP site.
                                               Sincerely,
                                               
                                               H. Thomas Rasche & Carolyn A. Rasche
                                               3682 Herman Road
                                               Hamilton, Ohio 45013
                                               (513) 738-5952

/car

-------
                                                Comment S





 1                  MR.  WILLSEY:  Sorry,  one more thing,





 2      Don and I have to leave because we have a levy on





 3      and we're going to get up to the Board of





 4      Elections, we're supposed to be up there.  Thank





 5      you very much.





 6                  MR.  WARNER:  We appreciate your





 7      participation.  Richard Strimple.





 8                  MR.  STRIMPLE:  I'm going to just





 9      make a little statements on water aguifers.  If it





10      is polluted, it's already polluted.





11                  MR.  WARNER:  You are Richard





12      Strimple?





13                  MR.  STRIMPLE:  Yes, I'm sorry.  It' s





14      polluted forever and there's no going to be a





15      permanent digging it up and hauling it out.  You





16      will dilute it,  you will cut your options, but for





17      somebody to think that they're going to clean it





18      up, it's spitting into the wind,  period.





19                  MR.  WARNER:  Thank you, Richard.





20      Russ Beckner.





21                  MR.  BECKNER:  My name is Russ





22      Beckner, I'm a resident of Ross Township and live





23      1,500 feet from the site.





24                  I would just like to go on record








                    Spangler Reporting Services





           PHONE  (513) 381-3330  FAX (513) 381-3342
-------
                                                Comment T








 1                  MR.  STORER:   I'm Gary Storer,  I'm





 2      Crosby Township Trustee and also a resident within





 3      one mile of the plant.





 4                  I wanted to make a point versus





 5      alternative, versus Alternative 6.  I favor





 6      Alternative 3 based on the fact the initial cost,





 7      212 million, will be exceeded by the initial cost





 8      of Alternative 6, which is 110 million,  in the fact





 9      that the required monitoring over a number of years





10      in the future will far exceed Alternative 3.  So





11      basically I don't see putting that burden on, I





12      don't see putting that burden on future





13      generations, however many years it would be down





14      the road, maybe a hundred years or more.  I don' t





15      feel it's fair to put that burden of monitoring,





16      which is going to far exceed Alternative 3.  So I





17      oppose Alternative 6 and I prefer Alternative 3.





18      Thanks.





19                  MR.  WARNER:   Thank you.  Any other





20      comments?





21                  We've got two to read into the record





22      here.  I'm not sure I pronounce this last name,





23      Judy Suzurikawa.  The Cincinnati Water Works





24      received notification of the public hearing and





                    Spangler Reporting Services





              PHONE (513) 381-3330  FAX (513) 381-3342
-------



                                                       Comment V

                                              Donald H. Thiem
                                              3175 Hamilton Scipio Rd.
                                              Hamilton, Ohio 45013

Mr. Gary Stegner Director
Public Information
Fernald Area Office

December 14, 1994

Mr. Gary Stegner,

Please consider:
Before DOE our land was thee of contamination.  Because of DOE, our
land is polluted and the problem has grown to immense proportions.

Years and years of abuse, with no thought to the environment or the
citizens, have compounded this problem.  Over the last ten years we
heard yes, we made mistakes, however, we have learned a lesson,
never again.  This has been the DOE refrain.

Now, we hear save money and lift this burden from DOE's back.  A
91.83 acre landfill is being considered.  Have we learned nothing?

My feelings are, if it must be stored in pits with liners of clay and
polyurethane and capped by the same procedure, then it is too
contaminated for on site storage.
                                               

                                                Donald H.  Thiem
-------
                 EVALUATION FORM
              U.S.  DEPARTMENT OF ENERGY            Comment W
          OPERABLE UNITT 2 PUBLIC MEETING
                 NOVEMBER 8,  1994
    Thank you for attending tonight's meeting.   We would like
your opinion on the information presented this  evening.   Please
take a few minutes to answer the following guestions and turn in

1.   Please indicate your affiliation (check more than one than one,  if
    applicable)

    X    Fernald area resident
    X    FERMCO employee
         DOE employee
         Subcontractor employee
    X    FRESH member
    X    Task Force member
         Representative of a regulatory agency
         Representative of another/organization
    X    Other   (please specify)

2.   Was the format of the meeting

         Not very satisfactory
    X    Satisfactory
         Not at all satisfactory
         Not very satisfactory

3.   How helpful would you rate the information  that was  provided
    during the presentations?

          Very helpful
     X    Helpful
          Not very helpful
          Not at all helpful

4.   Were the presentations

          Too long
          Too short
      X   Adeguate

5.   Was the time allotted for the Q&A session

          Too long
          Too short
      X   Adeguate
6.   During the Q&A session,  were the answers to your guestions

          Very satisfactory
-------
       X   Satisfactory                                       Comment W (Continued)
           Not satisfactory
           Not at all satisfactory

 7.   How comfortable did you feel providing formal comments
     during the formal comment session?
            Very comfortable
            Comfortable
            Not very comfortable
            Not at all comfortable
       X    Did not provide a comment

 8.   Did you understand the purpose for separating the guestion
     and answer session from the formal comment session?

       X    Yes
            No

 9.   Overall,  do you feel this meeting was

            Very valuable

       X    Valuable
            Not very valuable
            Not at all valuable

10.   Overall do you have any additional comments you would like
     to add about the meeting, or suggestions for improvement?

     

 11.   Thank you for taking time to find out this evaluation form.
      
-------
                                               Comment X





1      holes are only so big.





2                   UNIDENTIFIED SPEAKER:   Jim,  your





3      alternative number 3,  you keep mentioning that this





4      material is sited to go to Envirocare in Utah.  Did





5      you look at the cost of sending it to Nevada Test





6      Site since we're talking about splitting out the





7      low level radioactive components?





8                   MR. WILLIAMS:  Yes,  we did,  and the





9      reason why we used Envirocare was it was much more





10     cost effective than the Nevada Test Site primarily





11     due to the transportation and packaging





12     reguirements.





13                  UNIDENTIFIED SPEAKER:   My second





14     guestion would be, you're given a whack for U-238





15     concentrations, are there going to be other whacks





16     as well as for other uranium isotopes as well as





17     thorium and some of the other materials?





18                  MR. WILLIAMS:  Not for Operable Unit





19     2.  Uranium is the only contaminant of concern for





20     groundwater within Operable Unit 2.





21                  MR. BECKNER:  Earlier you used the





22     term design life of 500 years.  Since you could not





23     have possibly tested any of these things for





24     anywhere near that period, I'd like to know how you





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          PHONE (513) 381-3330   FAX (513) 381-3342
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                                                  Comment Y
                        NEVADA TEST SITE
                     COMMUNITY ADVISORY BOARD
December 30, 1994

U.S. Department of Energy
Fernald Area Office
P.O. Box 539705
Cincinnati, OH 45353-8705
Att:  Mr. Gary Stagner, Director
      Public Information
Subject:   FERNALD, OHIO, REMEDIAL INVESTIGATION/FEASIBILITY
           (RI/FS) FOR OPERABLE UNIT 2

Dear Mr. Stagner:

The Nevada Test Site  (NTS) Community Advisory Board  (CAB) appreciates the
opportunity to comment on the RI/FS for Operable Unit 2 at the Fernald, Ohio, Department
of Energy  (DOE) site.  As you're probably aware, the CAB is extremely interested in all
facts of the remediation work taking place at Fernald.  Since the NTS has taken receipt of
many Fernald waste shipments in the past, and may be the recipient of others in the future we
obviously have a stake in decisions being considered at Fernald.  The Board has previously
commented on the recommendations being considered for Operable Unit 4 at Fernald.

Operable Unit 2, as we understand it, is located over a sole-source aguifer which serves as a
water supply for a number of communities in southwestern Ohio.  The recommendations for
remediation of Operable Unit 2, as they have been conveyed to the CAB, are to excavate
flyash materials, solid waste and soild contaminated with relatively benign waste from this
unit, and redispose the waste in engineered "cells" elsewhere on the Fernald property.
Extremely hazardous wastes from the Unit would be excavated and transported to the
Envirocare facility in Utah for final destruction.

The NTS CAB is supportive of this recommendation.  Protecting the local aguifer by
removing the waste to a safer, controlled site at Fernald appears needed to protect this
important water supply source.  Relocating the waste onsite would also eliminate the more
expensive, and potentially more dangerous option of transporting large amount ot waste
potentially thousands of miles.  Since the waste appears to be, for the most part, not
hazardous an onsite solution seems feasible.

Fernald cleanup funds can then be better employed for resolving the facility's more serious
problems.  Given the level funding cuts being proposed for DOE's Environmental
Management program in FY 95 (and probably into the future), it is imperative that the
potentially limited cleanup funds be employed to their maximum utility.

We applaud the efforts at Fernald and other sites to consider, where feasible, on-site
remediations options.  Given the significant amounts of waste present at Fernald and other
locations throughout the nation, it is important that possible health and safety risk to the
public to minimized.  Reducing the numbers and volumes of waste transported is important
in ameliorating some of these risks.
-------
Nevada and Ohio, as you're well aware, were significant participants in developing the United
State's nuclear deterrent option.  The apparent success of this endeavor offers the potential
for a safer and more peaceful world.  Since many states and communities shared in the
development of the nuclear deterrent, NTS CAB members feel that it is also important that all
participate in the solution to the onerous waste problems that most DOE sites are
experiencing.  The on-site solutions being proposed at Fernald are important indicators that
the will and technology exist to address many of these problems at their source in an
eguitable manner.  All sites must bear the burden of sharing in the resolution of these
problems to ensure that they are not simply passed on to other locations.

In closing one final comment is in order.  The NTS CAB is an important stakeholder with
respect to remediation decisions being made at the Fernald, Ohio site.  Despite the
significance of these issues to Southern Nevada, we have been given insufficient time to
consider and comment on the many issues associated with the Fernald site.  Operable Units
2 and 4 are important examples.  The CAB and Southern Nevada citizens need more advance
notification to comprehensively comment on issues such as these that could adversely effect
our communities.  The NTS CAB and our communities should be afforded the same time
frame as Ohio residents to consider these issues when future operable units are remediated.

Once again we are supportive of the onsite recommendations provided for Operable Unit 2.
The CAB looks forward to your incorporation of the Board's comments into remediation
decisions at Operable Unit 2 at the Fernald facility.

If you have questions or require clarification please contact me.

Sincerely,

William L. Vasconi, Chairman
Nevada Test Site, Community Advisory Board
-------
                                                  3686 Cincinnati-Brookville Road
                                                  Hamilton, Ohio 45013
Comment Z

                                                  November 21, 1994

Mr. Ken Morgan
Director, Public Information
U.S. Department of Energy Field Office
P.O. Box 398705
Cincinnati, Ohio 45239-8705

SUBJECT:  PUBLIC COMMENTS ON PROPOSED REMEDIATION PLAN OF FEMP
          OPERABLE UNIT #2 LOW-LEVEL RADIOACTIVE WASTE (DUE
          NOVEMBER 25, 1994)

Dear Mr. Morgan:

The Fernald Site is grossly inappropriate as a permanent storage site for any low
level radioactive waste because of the following considerations:
1.    Area geology and seismic activity.
2.    Area demographics - increasing population density; 19 miles to Cincinnati.
3.    Levels of precipitation and tornado-prone area.
4.    Low depth to ground water - sand and gravel bottomland.
5.    Site over Great Miami Aguifer currently the source of potable water for
      hundreds of thousands of people in Southwestern Ohio and future usage will
      be for millions of people.
6.    People live in houses less than 100 ft. from the FEMP boundary.
7.    The proposed FEMP nature preserve is no place for any kind of hazardous
      radioactive waste.  What radiation does not kill, it mutates.
8.    These is no minimum two-mile "safe" buffer zone between the proposed
      storage site and the FEMP boundary.
9.    These is no permanent "fail-safe" radioactive waste containment facility
      under the above conditions.
10.   There is no safe threshold for human exposure to cancer-causing ionizing
      radiation.  There is danger of exposure to low levels of radiation.
11.   No one likes radioactive waste in their backyard so why should we continue
      to be victimized under a "cloud" of cancer producing radioactivity for
      another 40 years and on into the future to hurt countless more generations!
12.   Evaluation of rail transportation risks should be made for safest route to an
      existing or new isolated waste facility where the radioactive waste will not
      directly or potentially cause harm to any person for the foreseeable future
      and corrective action taken where needed to maximize assured success.

Your help to remove all radioactive waste from FEMP will be appreciated.

                                               Sincerely,

                                                
                                                J. E. Walther
cc:  The Honorable John H. Glenn

-------
                                  Comment AA (Continued)





1      after we've called everybody's name and they've





2      made their comments,  we will open the floor for any





3      additional comments,  and after that we'll read a





4      couple of comments that we've received that were





5      written on the cards.  Again I would like to





6      emphasize that responses will not be presented this





7      evening to your comments.  You will find them in





8      the responsiveness summary document that will be





9      submitted with the draft Record of Decision in





10     January of this year.





11                  If there's no guestions, I would like





12     you to come up to the microphone, clearly state





13     your name, and then present your comment.  Our





14     first commenter will be Tom Willsey.





15                  MR. WILLSEY:  My name is Tom





16     Willsey,  and I'm a township trustee from Ross





17     Township.





18                  A lot of you people have not seen





19     us -- Don King is also here, he's a township





20     trustee.   We have not been to a lot of these





21     meetings  because at this point we have never really





22     been in an adversarial position with you folks, but





23     I think now we are.  I've been a trustee, I'm in my





24     ninth year, so this didn't just happen to the last





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                                  Comment AA (Continued)





1      night.  We've known about the problems and all the





2      things that went on in that plant for some time,





3      and for ten years now we pretty much believed that





4      they were going to clean up,  they were going to





5      move it off site, and we believed that because





6      that's pretty much what you told us.  Now I'm





7      seeing where it's permanent,  lifelong.  I don't





8      think you plan on moving it.   Our people in Ross





9      Township, they have a permanent stake in this, and





10     permanent to them is lifelong because they will be





11     there all their lives.  So we feel that the meaning





12     of permanent means something different to us than





13     it does to you.  We have been dumped on, we've had,





14     of course, the uranium blow on us.  We put up with





15     it for a long time, and like I said, we have been





16     very cooperative to this point.





17                  We've watched different things happen





18     in our area that we're not real happy with, our





19     property values obviously went down, that's a





20     matter of record, I'm not making that up, but we





21     tell people, hey, it's a good area, they're





22     cleaning it up, look at all the things they're





23     doing.  Well, you're not doing that.  We've had it





24     for four years.





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             PHONE  (513) 381-3330  FAX (513) 381-3342
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                                 Comment AA (Continued)





1                   I look at all your charts and your





2      graphs and I see the Alternative 3,  I see





3      Alternative 6, 1,  2, I don't know how many there





4      were,  but the thing that glares out and hits the on





5      the nose on Alternative 3 and Alternative 6 is 212





6      million versus 110 million.  Cost, money.  Quite





7      frankly, if you've ever been to Washington, DC,





8      cost has never been a factor to the federal





9      government.  They're a monument to what you can do





10     with unlimited funds.  On every street corner





11     there's a monument to something or somebody.  So





12     cost should not be a factor.  This cost to the is





13     not a factor.  The well-being off our residents and





14     our township is a factor to the.





15                  We will go on record as being opposed





16     to this, and quite frankly, we're going to try to





17     get a ground swell of people to be opposed to it





18     also.   I didn't want to be adversarial about this





19     and I'm still not.  I just want it moved.  I don't





20     care what it costs.  I'm paying for it anyway.  I





21     would rather pay for it out of my pocket than pay





22     for it with the lives of my family.   Thank you.





23                  MR. WARNER:  Thank you, Tom, we





24     appreciate your comment.





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             PHONE  (513)  381-3330  FAX (513) 381-3342
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                                                 Comment BB
Edwa Yocum
9860 Hamilton Cleves Pk.
Harrison, Ohio 45030
(513) - 738 -1659
November 14, 1994
Gary Stegner
DOE. Director of Public Information
P.O. Box 538705
Cincinnati, Ohio 45253-8705

Reference:  Comment on OU2 alternatives.

            Public participation including a comment period during
            remedial and RODS of OU2.
            As a resident of Crosby Township I prefer the alternative
            three "Off -Site Disposal.
            As a concerned citizen of the United States I will accept
            OU2 alternative six (6) "On - Site disposal with Off
            Site disposal of hazardous waste exceeding the waste
            acceptance criteria.   (WAG - 360pCi/g).
            -  All of the FEMP  ( Fernald) site to be owned by the
               Department of Energy.  (Not only the disposal cell area)
               The disposal cell area will have the protection of
               a buffer zone.  No less than 300 ft around.
               Review of maintenance around cell yearly.
           No other DOE or commercial low level waste for disposal
           be allowed in to the Fernald disposal cell.
           No dilution of waste to meet waste acceptance criteria.
           WAG 360 pCi/g of U-238 be maximum going into the cell.
           Real time monitoring day to day during excavation and
           construction.
           Stated in the Record of Decision (ROD)  that DOE will obey
           all regulation.
                    Meet ARAR protection of the Aguifer.
                    "WAG no dilution of waste.
                    No off site waste from other DOE sites.
-------
                                                  Comment CC
Dear Mr. Stagner:

     I am writing to protest the possibility of having any
contaminated soil or building material left in or on-site in any
type of containment device or sub-unit.

     We, in Ross, have had enough from the government's
over-sights, under-sights, lack of control, too much control and
non-caring attitude toward us and the environment.  My family and
I have made Ross our home and we are tired of the D.O.D., D.O.E.
and the E.P.A.'S lack of concern for us,  our health and
well being.  It states in the Constitution that we are guaranteed
the right and pursuit of happiness but we find that hard to
believe when the government turns thee D.O,D., D.O.E. and E.P.A.
loose on the quality of life and drinking water supply.  The
E.P.A. makes more noise over a single housing unit than that of
the contamination of the ground water under Fernald.

    Stop spending millions on studies of what to do and do what
should be done — GET RID OF IT!!!   Take it back to Nevada.

                              Sincerely,
                              
                              Ross Township Trustee
-------
                                 ATTACHMENT II

                           PUBLIC MEETING TRANSCRIPT
1

2

3

4

5                         U.S. DEPARTMENT OF ENERGY

6

7                     PUBLIC MEETING FOR OPERABLE UNIT 2

8                               PROPOSED PLAN

9

10                             NOVEMBER 8, 1994

11

12                             THE PLANTATIONS

13

14                             -

15

16

17

18

19

20

21

22

23

24

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             PHONE  (513) 381-3330   FAX  (513) 381-3342
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 1                  MR.  WARNER:   Good evening,  welcome





 2      to the public meeting on the Operable Unit 2





 3      Proposed Plan for the remediation of this unit at





 4      the Fernald facility.  My name is Rod Warner.   I'm





 5      the DOE program manager charged with the





 6      remediation of that unit at Fernald.





 7                  We realize that November is a real





 8      busy month for those of you who are involved in the





 9      public participation activities here, and coupled





10      with that there's some holidays and such that it's





11      a little difficult for us to try to pick the most





12      appropriate evening to have this meeting.  We





13      wanted to do it as early into the public comment





14      period as we could, and with that period ending





15      basically the day after Thanksgiving, we opted for





16      this date.  We appreciate your coming out on this





17      busy election day and taking the time to





18      participate in this meeting, and we apologize for





19      any inconvenience we may have caused you with this





20      date.





21                  I think to start the meeting off I





22      would like to go over some ground rules and the





23      agenda that maybe will help the meeting flow a





24      little bit better and get us all out of here at a





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          PHONE (513) 381-3330  FAX (513) 381-3342
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 1      decent hour.  Hopefully you all remembered to





 2      register at the back,  and if you didn't,  you can do





 3      so at the break which will follow this session of





 4      the meeting.  When you register, if you would





 5      please indicate if you would like to make a formal





 6      comment during the formal part of this meeting.





 7      That will just help that part of the session go a





 8      little better.





 9                  On your chairs you should have found





10      some handouts.  I believe there is an evaluation





11      form we would like to have you fill out before you





12      leave the meeting tonight, and also there was a





13      comment card.  Now if you would like to submit a





14      comment during the formal session and you choose





15      not to make it verbally, please wide it down on





16      the comment card and give it to one of the





17      individuals at the front desk, and we will read





18      that into the record during the formal part of this





19      session.





20                  Since this is a formal meeting, we do





21      have a court transcriber here, and all of the





22      comments that we make here tonight will be





23      transcribed basically as accurately as they're





24      said, and we will have a full transcript of this





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            PHONE (513) 381-3330  FAX (513) 381-3342
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 1      meeting available in about two weeks,  and this





 2      transcript will be placed in the Public Information





 3      Center, which is located about a half a mile or so





 4      south of the plant on Route 128.





 5                  Tonight's meeting is going to be





 6      divided into two sessions.  During the first





 7      session we will give you an overview of all the





 8      remedial investigation,  a review of alternatives,





 9      and also our proposed plan for the remediation of





10      this Operable Unit.  This will be followed by a





11      guestion and answer period, an informal session.





12      Feel free to ask guestions as they specifically





13      apply to Operable Unit 2.





14                  After that then we'll have a short





15      break and we'll go into the formal session.  We





16      encourage you during this particular guestion and





17      answer period to ask any guestions that you have,





18      but we ask that you specifically limit them to the





19      Operable Unit 2 proposed plan.  Anything that we





20      present tonight material wise is fair game for you





21      to guestion.  We will try to answer them as best  we





22      can, and this is a real opportunity for you to get





23      that informal response.





24                  At the break then I think it would be





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           PHONE (513)  381-3330    FAX  (513)  381-3342
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 1      a good idea if you would try to interface with some





 2      of the participants.   That way you can get some





 3      real face-to-face interaction with them and maybe





 4      get an increased comfort level of our approaches.





 5      We would ask you to remember that we cannot





 6      presuppose the remedial activities that some of the





 7      other operable units  will be taking, but we have





 8      tried to integrate our plan with them as a





 9      contingency, so please, if you will focus your





10      concerns on specifically Operable Unit 2 this





11      evening.





12                  Following a short break, then we will





13      proceed into the formal session of the meeting.





14      Those of you who signed up on the register





15      indicating that you wanted to make a verbal comment





16      will be called up in  order to make your comment and





17      have it placed into the public record.  After we





18      receive everyone's verbal comments, we'll open the





19      floor again — everybody who has reguested verbal





20      comments,  we'll open  the floor again for any





21      additional commenters, and then after that we will





22      read into the record  any written comments that we





23      receive during the meeting.  This part of the





24      meeting will not be interactive, and by that I mean





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          PHONE (513)  381-3330  FAX (513) 381-3342
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 1      when you make a comment,  it will not be responded





 2      to this evening.   Your responses will be presented





 3      in the responsive summary document which will be





 4      submitted with the draft Record of Decision on





 5      January 5th,  1995.  So you will locate your





 6      responses to your formal comments there.





 7                  Remember that to get a response to





 8      your comment in that document you must either make





 9      a verbal comment this evening,  submit a written





10      card to be read into the record this evening, or





11      submit a written comment sometime before the end of





12      November 26th to DOE, which is  the end of the





13      public comment period.  And I will put a slide up





14      here that shows you that address.  We'll go back





15      over this formal session again  before we start it





16      up.





17                  So with that, I would like to





18      introduce Jim Williams,  FERMCO  Director for





19      Operable Unit 2.   Jim is going  to give you that





20      overview of Operable Unit 2 and our proposed plan,





21      and we hope that you agree with us that our





22      proposed plan does represent the best balance of





23      protectiveness, cost, and implementability.  Jim.





24                 MR. WILLIAMS:   Thank you, Rod.  And





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               PHONE  (513) 381-3330  FAX (513) 381-3342
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 1      good evening everyone.





 2                        First thing I'd like to do this





 3      evening is briefly review where we are and where





 4      we're going in the public participation process for





 5      Operable Unit 2.





 6                      On May 10th of this year we held a





 7      workshop to go over remedial Investigation for





 8      OU-2, and at that time we presented our initial





 9      thoughts on a likely preferred remedial alternative





10      for OU-2.





11                      On June 28th of this year we held a





12      public workshop for the Feasibility Study for





13      OU-2.  Again we went over our thinking with regard





14      to a proposed plan for Operable Unit 2.





15                      On September 13th OEPA had an





16      availability session to discuss the possibility of





17      siting an on-site low level waste facility at





18      Fernald.





19                      On October 25th we had a workshop to





20      discuss the proposed design and location of the





21      disposal facility.





22                      On November 3rd there was an





23      availability session sponsored by OEPA to discuss





24      the OU-2 proposed plan and preferred remedial





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              PHONE (513)  381-3330  FAX (513)  381-3342
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 1      alternative.





 2                      Tonight is the public meeting on the





 3      proposed plan for OU-2.   And there are a couple of





 4      things that I'd like for you to think about with





 5      regard to public participation for OU-2.  First is





 6      that we've listened to your concerns and your ideas





 7      through the process.  Many of you who have been





 8      involved since May realize that we modified our





 9      approach substantially,  significantly, in part due





10      to comments and guestions and concerns by the





11      public and by the regulatory agencies.





12                      Secondly, although this is the public





13      meeting for the proposed plan for OU-2, it's not





14      the end of the process.   The public comment period





15      will extend until the 25th of this month,  and even





16      following the close of the comment period, the





17      public participation process will continue into the





18      remedial design.  FERMCO, the Department of Energy,





19      and the regulatory agencies are committed to





20      continued public involvement into the remedial





21      design process.





22                      So the two things we'd like you to





23      take away are that we are listening to you; egually





24      importantly,  we're responding, we're modifying our





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              PHONE (513) 381-3330  FAX (513) 381-3342
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 1      proposed actions based on the input we receive,  and





 2      your opportunity to participate will continue.





 3                      Would it be possible to dim the





 4      lights just a little bit?





 5                      Next thing I'd like to do is just





 6      very briefly review the contamination, the hazards





 7      at Operable Unit 2, and review the need for a





 8      remedy for remedial action at Operable Unit 2.








 9      This is a three-dimensional picture of





10      contamination at the solid waste landfill.  The





11      image in the reddish color is uranium contamination





12      in the landfill.  The more magenta color is a lower





13      level contamination in the landfill.  It'  s about an





14      acre in size, and most of the volume within the





15      landfill is contaminated with uranium.





16      Contamination has not impacted the Great Miami





17      aguifer.





18                 The next waste unit in Operable Unit





19      2 are the lime sludge ponds.  Again the color





20      coding of the images is the same,  where the





21      purplish or magenta color represents low level





22      uranium contamination at the lime sludge ponds.





23      It's scattered around in the dikes or the berms





24      that are made of earth and they contain the lime





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         PHONE  (513) 381-3330  FAX  (513)  381-3342
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 1      sludge.   Again,  the contamination at the lime





 2      sludge ponds has not affected the Great Miami





 3      aguifer.





 4                This is a picture of contamination at





 5      the three contiguous southern waste units,  and





 6      these are the inactive flyash pile, the South





 7      Field, and the active flyash pile.  The reddish





 8      blob to the left center where John is indicating





 9      with the pointer is uranium contamination at the





10      inactive flyash pile.  To the east, directly to the





11      east is another blob or volume of uranium





12      contamination in the South Field.  The big





13      difference with these waste units is that the





14      contamination in OU-2 has in this area





15      significantly impacted the Great Miami aguifer, and





16      you're looking down the bird's-eye view on the





17      groundwater, and it's color coded to represent





18      uranium contamination in the Great Miami aguifer.





19                  The most significant contamination in





20      the aguifer is directly below the inactive flyash





21      pile.  I trust John is indicating that.  The





22      contamination is approximately 1,000 parts per





23      billion in this area.  And without remediation in





24      Operable Unit 2, there are numerous problems that





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            PHONE (513)  381-3330 FAX  (513) 381-3342
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 1      represent unacceptable risks to human health in the





 2      environment.  And we'll go over those in a little





 3      more detail, but primarily they would involve risks





 4      to users of the groundwater.  As you can see, it's





 5      contaminated.  In the absence of remediation, it





 6      will become more so and the contamination will





 7      spread.   In addition, there is potential exposure





 8      through surface pathways on the ground through





 9      direct radiation, inhalation of suspended dusts,





10      dermal exposure, and ingestion.





11                  Before we can get into the proposed





12      remedy for Operable Unit 2, we need a definition,





13      and that definition is for federal ownership,





14      federal land use at Fernald.  We need this





15      definition because the proposed remedy for Operable





16      Unit 2 will reguire continued federal ownership of





17      at least a portion of the Fernald site into the





18      future.   So what we're talking about, and the





19      functional definition for our purposes of federal





20      land use are when the federal government retains





21      ownership of the FEMP, land use and site access are





22      restricted for authorized government purposes





23      only.  The receptors, in other words, the





24      individuals who could receive risk in the future





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               PHONE (513)  381-3330  FAX (513) 381-3342
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 1      under this scenario are trespassers who come onto





 2      the property,  off-property farmers who are primary





 3      water users,  and users of the Great Miami River





 4      water.  These are the people that have to be





 5      protected in the remedy for Operable Unit 2.





6                   And these are the specific pathways





7       through which these individuals can be exposed to





8       risks from Operable Unit 2.  For the trespasser,





9       there's direct radiation, inhalation,  again that





10      would be primarily of dust from the surface,





11      ingestion of dust or surface water, and dermal or





12      exposure to the skin from contaminated material.





13                  For the off-property farmer,  the





14      primary pathway, the most significant risk would  be





15      ingestion primarily of groundwater.





16                  Those pathways I just described are





17      what have to be controlled by any successful remedy





18      at Operable Unit 2.  In the course of developing





19      and evaluating potential remedies for Operable Unit





20      2, we looked at, by my last count, 28 different





21      remedial alternatives.  Some of these were specific





22      to a specific subunit, but the point is we





23      thoroughly exhausted our imaginations in terms of





24      developing and comparing reasonable and feasible





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           PHONE (513)  381-3330   FAX (513) 381-3342
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 1      alternatives for the remediation of Operable Unit





 2      2.   After the process of studying and screening out





 3      the less feasible alternatives,  when the smoke had





 4      cleared, we were left with four,  one of which is





 5      reguired by CERCLA or Superfund guidance,  and





 6      that's the no action alternative.





 7                      The other three alternatives that





 8      were given a very detailed comparative analysis are





 9      consolidation and containment,  which many of you





10      will remember was the alternative in which we





11      consolidation the waste within the OU-2 waste units





12      where it presently is,  basically moved it around





13      within the waste unit to the safest place,  and then





14      contained it with a cap within the waste unit.





15                  The next alternative is excavation





16      and off-site disposal.   That's pretty clear.  The





17      waste above cleanup levels within each Operable





18      Unit 2 waste unit would be excavated and shipped





19      off-site for disposal.   The disposal facility that





20      we evaluated in this feasibility study was the





21      Envirocare facility in Utah.





22                  The final alternative that was given





23      detailed comparative analysis was excavation and





24      on-site disposal with off-site disposal for the





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            PHONE (513)  381-3330  FAX (513) 381-3342
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 1      fraction exceeding the waste acceptance criteria,





 2      which would be the limits of contamination which





 3      would be accepted at the on-site disposal





 4      facility.





 5                  What I want to spend most of the time





 6      on,  and I  think what is most important for us to





 7      understand, is how do these alternatives compart





 8      and why did we select one for recommendation to you





 9      over the other two.  I hope that it is clear based





10      on the discussion we had of the contamination in





11      the waste  units that the no action alternative is





12      unacceptable.





13                  This picture is a summary in very





14      brief form, one page-of literally thousands of





15      pages of analysis, and somebody has called it our





16      consumer reports table because it's a kind of way





17      of comparing different alternatives that is I hope





18      legible and easy to understand.  What we need to do





19      is spend a little bit of time going through this





20      table, both with respect to the criteria that we





21      use to evaluate these alternatives and the results





22      of the evaluation.  I'm going to have to resort to





23      my pointer so you make sure what I'm talking





24      about.





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               PHONE (513) 381-3330  FAX (513)  381-3342
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 1                  These are the evaluation criteria.





 2      Let's talk about them a little bit.  In the first





 3      place the evaluation criteria are given to us by





 4      EPA,  they're EPA guidance.  They'the the same for





 5      every CERCLA site.   These are the same criteria





 6      that was used to evaluate and select remedial





 7      alternatives for Operable Units 4 and Operable Unit








 8      1.   So the criteria are a given.





 9                  What do they mean?  The first





10      criteria or criterium,  which is singular, overall





11      protection of human health in the environment,  is





12      an absolute or threshold reguirement.  If an





13      alternative doesn't meet this standard, it cannot





14      be carried forward for detailed comparative





15      analysis.  So it's not useful to us in terms of





16      choosing the best alternative, but it's a threshold





17      that each of the alternatives must meet in order to





18      be considered any further.





19                  The same thing is true for the second





20      criterium, which is compliance with ARARs.   ARARs





21      are the laws, regulations, and policies that are





22      pertinent to this project.  And again, all of the





23      alternatives must,  must meet this standard.  You'll





24      notice that one of our alternatives, on-site,





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            PHONE (513) 381-3330  FAX (513) 381-3342
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 1      disposal,  meets it with a footnote,  and that





 2      footnote is important.   It meets the ARARs with





 3      waiver of the OEPA restriction on disposal of solid





 4      waste over a high yield sole source aquifer.  EPA





 5      has already stated its  intent to grant such a





 6      waiver in order for us  to successfully implement





 7      this project.  It's important to realize that this





 8      waiver will be specific to Operable Unit 2 waste





 9      only, and that those wastes would be generated only





10      during the cleanup of this Superfund project at





11      Operable Unit 2.   The disposal of waste from other





12      sites under this  waiver wouldn't be legal.





13                  Now we're going to get into some





14      criteria that are useful in terms of comparing and





15      selecting the best alternative.   The third one,





16      long-term effectiveness and permanence is very





17      important and it's self-explanatory, and for the





18      first time you see a difference among the three





19      action alternatives. And the difference is that





20      the consolidation and containment alternative





21      doesn't rate as highly  as the other two, and the





22      reason for that is as follows:  For off-site





23      disposal you excavate the material,  you transport





24      it off-site, in this case we're talking about





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             PHONE  (513)  381-3330   FAX (513) 381-3342
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 1      shipping it to Utah and placing it in an engineered





 2      facility.   That's a relatively permanent,





 3      long-range effective solution.





 4                  The same is true for Alternative 6,





 5      on-site disposal.  You excavate the material from





 6      the OU-2 waste units,  you put it in an engineered





 7      facility that's engineered for a very long





 8      lifetime.





 9                  With Alternative 2, consolidation and





10      containment, there's a difference, and that





11      difference is that it was not being placed in an





12      engineered facility.  The material was being kept





13      in place and it wouldn't have the liner,  the





14      underdrain, and the leak detection systems that are





15      to be engineered as a part of the recommendation





16      alternative.  By the way, I would point out that at





17      the back of the room there's a life-site





18      cross-section of both the conceptual design for the





19      proposed capping system and liner system for the





20      on-site disposal facility.  It would be a nice idea





21      to take a look at it during the break or





22      afterwards.  I believe that was in response to some





23      discussion we had at our last meeting.





24                  So with respect to long-term





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               PHONE (513)  381-3330  FAX  (513) 381-3342
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 1      effectiveness and permanence,  the on-site disposal





 2      and off-site disposal alternatives are better than





 3      the consolidation and containment, and I'll point





 4      out also that the engineering features associated





 5      with a proposed disposal facility at Fernald far





 6      exceed those of the facility in Utah.  The facility





 7      in Utah, for example, doesn't have the complex





 8      liner, leak detection,  and leachate collection





 9      systems that the facility here would have.





10                  The fourth criterium, reduction of





11      toxicity,  mobility, or volume through treatment,





12      again it doesn't help us differentiate among the





13      alternatives because treatment is not effective for





14      OU-2 wastes.  Concentrations are too low for an





15      effective treatment.





16                  Short-term effectiveness, and this





17      one is a little bit of a misnomer that just comes





18      out of the lingo associated with feasibility





19      studies.  What the short-term effectiveness really





20      is is a measured of the risk to workers and the





21      community during remediation itself.  So the





22      consolidation and containment in place is the least





23      risky thing to do because you're not moving the





24      material around, so it tanks highest in that





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            PHONE (513) 381-3330  FAX (513) 381-3342
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 1      regard.





 2                       I want to skip implementability





 3      because I want to come back to that with a little





 4      more of a detailed summary type of analysis on





 5      that.  So we'll skip over number 6 and come back





 6      later.





 7                  Number 7 is cost,  and that's measured





 8      in terms of the present worth, the total present





 9      worth of implementing each alternative.





10      Consolidation and containment is the least





11      expensive at about $70 million.  Off-site disposal





12      is almost $213 million, and on-site disposal is





13      about $110 million in terms of present value.





14                  State acceptance and community





15      acceptance is what we're doing now.  You're part of





16      the process, and your input will be a part of the





17      decision making.  However, through the process that





18      I explained when I started, we've heard guite a bit





19      of input from the community already.  And it has I





20      would say highly discouraged our consideration of





21      consolidation and containment.  Frankly, the idea





22      of consolidation and containment was not well





23      received by the community or by the State and that





24      has been given significant weight in the remainder





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             PHONE  (513) 381-3330  FAX (513) 381-3342
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 1      of our analysis.





 2                  However,  it is important to keep in





 3      mind when we talk about community acceptance and





 4      State acceptance, we're not just talking about you,





 5      we're not just talking about the Fernald community





 6      because there's also a community in Utah and





 7      communities in every state through which material





 8      must pass for off-site disposal.  Those individuals





 9      are a part of this process as well.  And those





10      states and state agencies are a part of the process





11      as well,  and we have attempted to accommodate that





12      as a part of our analysis.





13                  So let's come back to





14      implementability.  With respect to the darkened





15      circles,  it looks like a drawing, but it's really a





16      little more subtle than that.  We believe that the





17      on-site disposal is the most implementable of the





18      alternatives when we consider cost and the





19      political realities of the situation, political





20      realities of attempting to send all material off





21      Fernald and into Utah and Nevada.  And furthermore,





22      this on-site disposal recommendation is a part of a





23      consolidated comprehensive strategy for waste





24      management at the Fernald project.  This won't be





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              PHONE (513) 381-3330  FAX  (513) 381-3342
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 1      the first time you've heard it whereby the most





 2      hazardous materials are shipped off site.   They





 3      also happen to be a lower quantity of material, and





 4      the large quantities of not so hazardous materials





 5      would stay behind and be placed in an engineered





 6      facility at the Fernald site.





 7                  So to summarize this table and our





 8      analysis, I would say that we believe that on-site





 9      disposal is worth the extra cost compacted to





10      consolidation and containment due to its superior





11      long-term effectiveness and community acceptance.





12      We believe that on-site disposal is preferable to





13      off-site disposal due to its superior





14      implementability and its large favorable cost





15      difference to achieve the same total





16      protectiveness.   So that's basically how we boil it





17      down.





18                  For the record, the preferred





19      alternative is excavation and on-site disposal with





20      off-site disposal of the fraction exceeding waste





21      acceptance criteria.





22                  I want to take just a few minutes and





23      sort of help you visualize what that means, and in





24      particular what this waste acceptance criteria





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           PHONE (513) 381-3330    FAX (513) 381-3342
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 1      means.   If we could dim the lights one more time,  I





 2      think that will be the last time.





 3                  We have calculated that the waste





 4      acceptance criteria for uranium for the on-site





 5      disposal facility should be on the order of 1,000





 6      parts per million total uranium.   That's very





 7      close.   We have identified a couple places in the





 8      OU-2 waste units where we have contamination





 9      exceeding that level and, therefore,  this material





10      would have to be disposed of off-site, and again





11      we're planning on the Envirocare facility in Utah.





12      This is a picture of where that contamination is





13      that exceeds the waste acceptance criteria at the





14      solid waste landfill.  We also have a picture of





15      the material exceeding the waste acceptance





16      criteria; in other words, the material exceeding a





17      thousand parts per million, which is about 360





18      picocuries per gram of U238, those are roughly





19      eguivalent.  And John is pointing to it at the





20      inactive flyash pile.  In total there's about 3,000





21      cubic yards of material in the OU-2 waste units





22      that would have to be sent off-site.   Thank you,





23      John.





24                  For those of you who are more linear





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           PHONE (513) 381-3330    FAX (313)  381-3342
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 1      brain and like things in tabular form,  this table





 2      presents the volume of material that would be





 3      disposed of in the on-site facility by subunit in





 4      OU-2.   You can see that the total is approximately





 5      300,000 cubic yards.  The total that would go





 6      off-site is about 1 percent of that or 3,000 cubic





 7      yards.   The average contamination that would be put





 8      in the disposal facility is very, very low.  As you





 9      can see, the highest subunit is the inactive flyash





10      pile,  and that's only 50 picocuries per gram.  The





11      maximum concentrations are also pointed out, and





12      the cleanup levels are also there for reference.





13                  Implementation of this alternative is





14      relatively straightforward.  We would have to





15      prepare the site, which means preparing for





16      stormwater control, transportation, and so forth.





17      We would excavate the waste material that exceeds





18      cleanup levels at the subunits from OU-2 waste





19      units,  we would carry it either to the on-site





20      disposal facility if it's below the waste





21      acceptance criteria, if it's above, we take it to





22      the railhead for off-site shipment.  We'll restore





23      the excavated waste units with backfilling and





24      grading, revegetation, and we will control any





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              PHONE (513) 381-3330  FAX  (513) 381-3342
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 1      groundwater that's encountered during construction





 2      and any what we call construction water or





 3      stormwater that comes in contact with contaminated





 4      material.   That water will be collected,  tested,





 5      and treated.





 6                  And then in final summary,  a concept





 7      of the remedy,  if you think back to the receptors





 8      and the pathways that we have to manage at Operable





 9      Unit 2, the strategy is to consolidate the material





10      exceeding cleanup levels into a single place,





11      locate that consolidated material in the most





12      suitable place on the site, isolate the material





13      from potential human environmental receptors,





14      monitor the facility to insure that protectiveness





15      performance is maintained over time, and finally to





16      integrate remediation at Operable Unit 2 with the





17      overall site remediation strategy.





18                  That concludes my presentation and I





19      think Rod has the podium next.





20                  MR. WARNER:  Thanks, Jim.  Before we





21      go into the question and answer period, I would





22      like to ask some representatives from our





23      regulatory agencies to come up and say a few





24      words.  I think Jim Saric is here from US EPA,





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          PHONE (513) 381-3330   FAX  (513) 381-3342
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 1      Region 5,  he's our regional program manager.  Jim.





 2                  MR.  SARIC:   I think what you've seen





 3      today, what Jim has gone forward explaining, some





 4      of the preferred alternatives here,  the preferred





 5      remedy is  really something that has gone through a





 6      lot of discussion with our agencies, both the Ohio





 7      EPA and US EPA looking at a large number of





 8      alternatives.  When this first Feasibility Study





 9      and Proposed Plan came forward, it was presented





10      having the capping containment alternative, and it





11      really was through our own looking at the situation





12      here,  we didn't feel real comfortable with that





13      particular alternative,  talking to various





14      citizens,  members of the Task Force, that I think





15      we all together pushed DOE into saying this needed





16      to be changed, something else needed to come





]7      forward.  We also were all under the understanding





18      that this  site-wide kind of conceptual idea of the





19      most hazardous stuff,  if you will, material being





20      disposed of off-site which represents a smaller





21      volume and certainly felt that was probably most





22      important, but yet the idea of having much larger





23      volume of  materials of lower concentrations being





24      disposed on-site in a more managed form.





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              PHONE  (513) 381-3330  FAX (513) 381-3342
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 1                  I think from our perspective,  US EPA,





 2      we support this alternative.  We've done a lot of





 3      review of looking into this thing and the big





 4      picture of how things must go.  I think if you look





 5      at the idea of leaving waste in place or looking at





 6      wastes as they sit today,  and you take that waste





 7      material and you put it in an engineered cell, I





 8      think you're in a lot better state than you would





 9      be by leaving the units in place.





10                  Obviously we're here to hear your





11      comments, and this is by no means a final decision





12      today, and that's why we're here.  We're going to





13      listen to all the comments, we're going to address





14      them, and we're going to look at DOE's responses to





15      them, so if you have any guestions now or if you





16      have any guestions afterwards, feel free to ask the





17      and tonight is the night to participate.  This is a





18      very important stage in this cleanup,  in the idea





19      of the concept of a disposal facility on-site.  So





20      with that, I'll take any guestions later.   Thank





21      you.





22                  MR. WARNER:  Thanks, Jim.   Now I





23      would like to bring up Tom Schneider from Ohio





24      EPA.





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             PHONE (513)  381-3330  FAX  (513) 381-3342
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 1                  MR.  SCHNEIDER:   Good evening.   I





 2      would like to express our appreciation for all of





 3      you coming out tonight to this very important





 4      public comment period with regard to this





 5      alternative and this operable unit and the future





 6      of this site.





 7                  We would like to concur with what Jim





 8      said.  It's been certainly a long process  by which





 9      we got to this alternative and this plan or





10      approach for the waste at Fernald and what we have





11      been referring to at the agency as the balanced





12      approach, and that's where we get the worst waste





13      off site and manage the large volume of low level





14      waste on-site in a safe facility.





15                  So we support DOE's preferred





16      alternative for Operable Unit 2,  and especially in





17      light of those preferred alternatives for  Operable





18      Unit 1 and Operable Unit 4,  and on that note we





19      would like to express our appreciation for DOE





20      wrapping up today the exemption for the OU-1 waste





21      to go to Envirocare.  That was going to be a big





22      concern of mine tonight and they took care of that





23      at the last second this afternoon.  We're  okay to





24      get the waste from OU-1 out to Envirocare  from





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            PHONE (513)  381-3330  FAX (513) 381-3342
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 1      DOE's own internal processes,  so that's a good





 2      point to tack on to what we're proposing here





 3      tonight.





 4                  We look forward to your comments.





 5      Like I said, this alternative addresses the future





 6      of the Fernald site and the cleanups here and your





 7      comments should address those, your comments should





 8      address what you think the site should be in the





 9      future, and particularly the State is concerned





10      with, as is a number of the public, off-site waste





11      potentially coming to this cell.  I'm here to tell





12      you it's going to be the State's -- we're going to





13      use all the tools in our chest to make sure that





14      that doesn't happen.  That will be our effort with





15      regard to how the ROD is written, that will be our





16      effort with regard to how enforcement is taken at





17      the site to be sure that off-site waste doesn't





18      come to this cell.





19                  But your comments during this public





20      comment period can only reinforce the fact that





21      we're willing to take care of our problems here but





22      we are certainly not willing to accept additional





23      waste at the site.  I just recommend that you use





24      this public comment period to the best of your





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          PHONE (513)  381-3330   FAX  (513)  381-3342
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  1     ability.   We look forward to your comments tonight.





  2     The public comment period extends on through the





  3     Friday after Thanksgiving,  the 28th, something like





  4     that -- the 25th.  So if you don't public comment





  5     tonight,  be sure and send something in in writing





  6     if you want to go home and think about it for a





  7     while.  Thanks for coming out.





  8                 MR.  WARNER:   I would like to thank





  9     Tom and Jim for all their support to this process.





 10     It's been tedious, we've had a lot of meetings and





 11     a lot of discussions, but I think where we are





12      tonight indicates we've come an awful long way.





13                  With that I would like to open up the





14      guestion and answer period and use this opportunity





15      to fire away.





16                  MR.  WILLIAMS:  I've been designated





17      to accept your guestions.





18                  MS.  DASTILLUNG:  On Alternative 6





19      when you have the costs there, it's only going out





20      30 years with the operations and maintenance.  How





21      much is it approximately in today's dollars per





22      year that we'll have to pay to monitor that out





23      into infinity?





24                  MR.  WILLIAMS:  Like from the 31st





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            PHONE (513)  381-3330   FAX (513) 381-3342
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 1     year on?





 2                  MS. DASTILLUNG:  Uh-huh.





 3                  MR. WILLIAMS:  In today' s dollars,





 4      those amounts depreciate to almost nothing because





 5      of the discount rate.  That's present net value





 6      accounting.  If somebody offered you a hundred





 7      dollars now or a hundred dollars in 31 years, which





 8      would you take?





 9                  MS. DASTILLUNG:  Okay, well then how





10      much is it going to cost to operate and maintain it





11      collection the year say 15?





12                  MR. WILLIAMS:  What' s our annual





13      budget for operations and maintenance roughly?





14                  MR. JONES:  Well, the annual budget





15      in the earlier years I think is somewhere about a





16      million dollars a year.





17                  MR. WILLIAMS:  But that' s actual





18      operating.





19                  MR. JONES:  That's the operation and





20      maintenance amount.





21                  MR. WILLIAMS:  Your guestion gets





22      more at like after all the waste is in it, it's





23      closed up and it's just sitting there?





24                  MS. DASTILLUNG:  Right.  It would be





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             PHONE (513)  381-3330    FAX  (513) 381-3342
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 1      about a million dollars a year to maintain it?





 2                  MR. JONES:   Yeah.





 3                  MR. WILLIAMS:  About a million a





 4      year.





 5                  MS. DASTILLUNG:  So in a hundred





 6      years beyond that 30 we will have broken even on





 7      the cost then approximately between three and six





 8      or less?





 9                  MR. WILLIAMS:  You can't do that





10      kind of accounting in your head.  It's a problem





11      because of the time value of money.  It's not





12      intuitive.





13                  MS. DASTILLUNG:  Okay.





14                  MR. WILLSEY:  Yes, I heard a few





15      words that kind of brought some guestions to mind.





16      You said that you were going to have a permanent





17      site and it will be a lifelong housing of the





18      contamination.  I think that's probably the same





19      words they used when they built the K-65 silos





20      probably,  and that was probably 30 years or 40





21      years ago, but I think the same technology that was





22      available today was probably as important back then





23      as it is today.  I think they thought they were





24      state of the art back then like you do today.  So





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              PHONE (513) 381-3330  FAX (513) 381-3342
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 1      when you say permanent and you say lifelong, I





 2      don't understand that terminology because I don't





 3      know what that means.





 4                  MR. WILLIAMS:  I don't recall testing





 5      those exact words.





 6                  MR. WILLSEY:  You did because I





 7      wrote them down.





 8                  MR. WILLIAMS:  I did refer to a





 9      design life, and a design life at a disposal





10      facility, which is the -- is an engineering goal





11      for the thing to be essentially perfect for that





12      length of time, is 500 years.  The design life for





13      the K-65 silos was 30 years.





14                  MR. WILLSEY:  I think they had that





15      one pretty well pegged,  didn't they?





16                  MR. WILLIAMS:  They have exceeded





17      their projected design life.





18                  MR. WILLSEY:  You know, lifelong and





19      permanent,  we have a permanent aguifer that that





20      plant sits on and it is permanent, and I understand





21      what that means.  That will be our source of water





22      forever.  I don't know how permanent your liners





23      are going to be, but I know that we have to drink





24      that water forever.





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             PHONE  (513) 381-3330  FAX (513) 381-3342
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 1                  MR.  WILLIAMS:   Right.   The intent is





 2      not to construct the facility and close it and walk





 3      away.  The intent is and the requirement will be to





 4      continuously monitor the facility,  and in the event





 5      that the facility begins to need attention,  it will





 6      receive that attention.   That might be in 500 or a





 7      thousand years,  but the intent and the design is





 8      not one that can be walked away from.  That's why





 9      continued federal ownership, continued federal





10      control is an integral part of the alternative.





11                  MR.  WILLSEY:  Quite frankly, I don't





12      think the ownership is what we're concerned about.





13      I really don't think anyone wants the site.   I





14      think what we're concerned about is who owns the





15      site and if they'll be there 500 years from now or





16      40 years from now when this thing,  if it goes





17      sour.  As I said before, we've lived with this





18      thing since.  the plant was built,  and it was state





19      of the art when it was built, and all this that





20      happened was not going to happen.   That's why we're





21      here.  Personally I want to get rid of it.  We've





22      had it for a long time,  and our residents have





23      suffered for a long time.   But as I said, my





24      question for you, I would like to know what your





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             PHONE  (513) 381-3330  FAX (513)  381-3342
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 1      definition of permanent is because you keep testing





 2      that word.





 3                  MR.  WILLIAMS:   Long-term





 4      effectiveness and permanence is one of the criteria





 5      that we evaluate, and you're talking about an





 6      engineering facility here versus an engineered





 7      facility in Utah, okay.  They're both engineered





 8      facilities.  The engineering design of this





 9      facility is more rigorous and more protected than





10      the one in Utah.  The environments are different.





11      I'm not going to cloud over the issue that the Utah





12      environment is very different than the Ohio





13      environment, but the design life of the Fernald





14      facility was on the order of 30 years.  Most of the





15      material that we're cleaning up now is not the





16      result of any engineered effort at all.  In OU-2,





17      the material that I showed you, it was simply





18      dumped on the ground and covered up.  So again





19      that's not something that is comparable to the





20      alternative we're proposing, which is an engineered





21      facility, the design life of 500 years, and





22      continuous monitoring, continuous review,  and a





23      responsibility for continued maintenance of the





24      facility.





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             PHONE  (513) 381-3330  FAX (513) 381-3342
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1                   MS. YOCUM:  Mine is on the fact





2       sheet that we received in the mail and as you came





3       through the door.  On page 5 in the last paragraph





4       of selecting the preferred remedial alternative, it





5       says by combining all the waste into one disposal





6       location,  Alternative 6 will allow reduced buffer





7       zone, and I'm concerned about the buffer zone.  So





8       what does that mean reduced buffer zone, what is





9       the, do you have one like 300 yards or 300 feet, is





10      there a special number that is a buffer zone and if





11      it's a smaller area?





12                  MR. WILLIAMS:  It's 300 feet and





13      that's a minimum.  That's a minimum from Ohio





14      regulations.





15                  MS. YOCUM:  Then you're talking





16      about reducing it?





17                  MR. WILLIAMS:  No, we're talking





18      about, you know, by putting all the material in one





19      place, you reduce, you know, the places that waste





20      exists, and so, therefore, you reduce the overall





21      impact on site land use.  Basically you have the





22      least perimeter possible, you know, for a disposal





23      facility by putting it in one place.  By





24      concentrating it in one place, it gives you more





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            PHONE (513) 381-3330   FAX (513) 381-3342
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 1      conceptual flexibility of moving it around,  and





 2      that 300 feet is a minimum,  it's not necessarily a





 3      target that we're shooting for.   It all depends on





 4      the ultimate geometry, and it can be any shape





 5      within engineering responsibility.  There's a





 6      degree of flexibility with regard to the shape.  So





 7      the 300 foot buffer zone is a minimum.   And we will





 8      not be able to have any less of a buffer on any





 9      order than that.  But we would only, only





10      conceptually be at most within 300 feet would be on





11      one border.  You wouldn't be talking about





12      impacting multiple borders,  which you would if you





13      didn't consolidate it.





14                  MS. YOCUM:  I have one more





15      guestion.  With the design of the disposal cell --





16      do you have a picture of it on file?





17                  MR. WILLIAMS:  Do we have a picture





18      of it?  We have a rendition.





19                   MS. YOCUM:  I just want to explain





20      the slope, there's going to be water laying on the





21      sides and there's going to be filtration.





22                  MR. WILLIAMS:  No, that's why the





23      sides are sloped.





24                  MS. YOCUM:  But if you constantly





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           PHONE  (513)  381-3330   FAX (513) 381-3342
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 1      have a downpour,  I mean the water is going to





 2      settle,  it's not all going to run off the hill and





 3      just be --





 4                  MR. WILLIAMS:  Well,  as a matter of





 5      fact, that's one of the reasons that the cap, which





 6      is depicted on the back wall there, the cap extends





 7      down the sides as well as on top.





 8                  MS. YOCUM:  It does extend down the





 9      sides?  Because in one of the drawings it didn't





10      look like it extended down the sides and that's why





11      I was wondering.





12                  MR. WILLIAMS:  Once again we have





13      heard input along those lines, and we have





14      responded.





15                  MS. YOCUM:  Okay.





16                  MS. CRAWFORD:  I have a couple





17      guestions, and I need you to put this slide up on





18      your overhead.





19                  MR. WILLIAMS:  The comparison?





20                  MS. CRAWFORD:  Whatever, the one





21      with the little colorful dots on it.  At the bottom





22      it says total present worth cost, and off-site it





23      says 212.8 and on-site it says 110.3 million or





24      billion, whatever.





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            PHONE (513) 381-3330    FAX  (513) 381-3342
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 1                  MR. WILLIAMS:  Those are millions.





 2                  MS. CRAWFORD:  Millions.  Does that





 3      include the cost of the cell or does the cost of





 4      the cell fall under OU-5?





 5                  MR. WILLIAMS:  That includes the





 6      cost of the cell for Operable Unit 2, for Operable





 7      Unit 2 volumes, that's correct.





 8                  MS. CRAWFORD:  So to get an overall





 9      cost of the cell itself,  are we able to do that





10      yet?





11                  MR. WILLIAMS:  Yes, we can, and in





12      fact OU-5 will be submitting their Feasibility





13      Study next week, and that will have the official





14      comparable cost estimates for the OU-5 volumes of





15      material as well as they're also looking at the





16      off-site alternative.  So on more of a site-wide





17      perspective, it will have the capability of looking





18      at on-site versus off-site for a wider range of





19      cleanup volumes.  This is specific to the 300,000





20      cubic yards for OU-2.





21                  MS. CRAWFORD:  Now, I need your





22      little computer man to put up his other little





23      thing that he had up there with them two little hot





24      pink boxes on it.  My guestion is what's in them





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              PHONE (513) 381-3330   FAX (513) 381-3342
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 1      two little pink boxes?





 2                  MR. WILLIAMS:  No,  no, those aren't





 3      boxes.





 4                  MS. CRAWFORD:  You know what I mean,





 5      what's  in those two hot pink areas?





 6                  MR. WILLIAMS:  It's simply a higher





 7      level of uranium.





 8                  MS. CRAWFORD:  Yeah,  I understand





 9      that.  I guess my guestion is -- I don't mean to





10     interrupt you -- what was it, what was buried there





11     that was way higher than the rest of the stuff?





12                  MR. WILLIAMS:  Well,  I guess,  I





13      don't mean to guibble, but when you're talking





14      about way higher, you're talking about maybe 500





15      picocuries per gram versus 50.





16                  MS. CRAWFORD:  It would seem to the





17      that's  way higher, I'm sorry, but it is.  We don't





18      need to argue about that.





19                  MR. WILLIAMS:  Let the show you —





20      where's that -- just for some comparison.   Average





21      OU-2 stuff is about 25, average OU-5 stuff is about





22      the same.  The waste acceptance criteria,  as I





23      mentioned, is 360.  The average OU-4 stuff is about





24      12,000, and the average OU-1 stuff — I'm sorry,





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            PHONE (513) 381-3330   FAX (513) 381-3342
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 1      1200,  and the average OU-1 stuff is about 5500.   So





 2      what you're talking about is about one-tenth the





 3      activity of OU-1 stuff.   Just for perspective.   The





 4      reason it's higher is that there was not a





 5      systematic process of putting stuff over time in





 6      the landfill, it took odds and ends, so there's





 7      just differences,  there's variations within the





 8      landfill.  Parts of it are clean, parts of it are





 9      25, parts of it are 50,  and there's a couple little





10      areas that are 500.  There's nothing particularly





11      remarkable about those samples.





12                  MS. CRAWFORD:  Well, let the guibble





13      back with you.  And say that OU-4 is not going to





14      go in the waste cell, so I'm not even counting OU-4





15      at this point, so I don't think we can compart





16      those two at all.   I guess when you show the





17      something like this and you show the two hot pink





18      little areas, I won't call them boxes but areas, on





19      the screen, it makes the wonder what the heck was





20      buried there that is higher than the other stuff.





21      I think folks would just kind of -- I mean are





22      there derbies buried in there?  And if you don't





23      know,  it's okay to say I don't know.





24                  MR. WILLIAMS:  We have not found any





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           PHONE (513) 381-3330    FAX  (513) 381-3342
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 1      sense of anything like derbies and so forth.  The





 2      operational history of the landfill is not well





 3      understood.  They didn't keep records.  It was





 4      essentially a place to put stuff you didn't want





 5      anymore, and so they did that.  However,  just --





 6      this is a good time to explain how things would





 7      operate.  How do you make sure you didn't miss one,





 8      how do you know what you're putting in the cell is





 9      what you say you're putting into the disposal





10      facility, and the plan is for every unit of





11      material that comes out of the waste units will be





12      screened and sampled right there before it's taken





13      to the disposal facility to insure that it meets





14      the waste acceptance criteria, and then that





15      characterization will be verified from the





16      stockpile at the disposal facility.  It will be





17      looked at twice before it goes into the disposal





18      facility, and if it doesn't meet the waste





19      acceptance, then it doesn't go into the facility.





20                  MS. CRAWFORD:  Is there going to be





21      like a huge lag time by the time you pull it out of





22      this thing, you test it, and you sift through it to





23      make sure it's what you say it is until you get it





24      to put it in the waste cell?





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             PHONE (513) 381-3330   FAX (513) 381-3342
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 1                  MR.  WILLIAMS:   No.   The screening at





 2      the landfill or at the inactive flyash pile is





 3      essentially going to be real time screening testing





 4      real time intruments.  From the stockpile,





 5      however,  at the --





 6                  MS.  CRAWFORD:   Don't use the word





 7      stockpile,  that's not' a good word.





 8                  MR.  WILLIAMS:   The FEMP working





 9      material  at the disposal facility.  The samples





10      will be laboratory samples, and they will take a





11      little longer but just on the order of, days not





12      anything  more than that.





13                  MR.  REISING:  Jim,  I think it is





14      important to respond to Lisa's guestion because





15      remember  we did use trenching in the silos, we put





16      a number  of trenches in there to see the type of





17      material  that was actually in there.  In fact, I





18      think Jerry is here who was the soil scientist in





19      charge of that operation,  and also the fact that





20      the waste sample that you took, and that matrix is





21      a soil matrix, so there was solid waste material in





22      there, and we did go in and try to excavate and





23      find if there were solid objects, et cetera, and we





24      found very little of that.





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              PHONE (513) 381-3330    FAX  (513) 381-3342
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 1                  MS.  CRAWFORD:   I guess I'm just





 2      curious to know what it is that would cause those





 3      two areas to be higher than the rest of it.  I





 4      guess ultimately there could be more than those two





 5      little areas.





 6                  MR.  SCHNEIDER:  Certainly.   I think





 7      that's the benefit of excavating these areas versus





 8      consolidating them in place.  That's been a big





 9      concern of the State, is you can punch a lot of





10      holes in an area like that and still not have a





11      good idea of what's there.  What we do gain out of





12      excavation is a knowledge of everything you pick up





13      out there and we know what goes into the cell and





14      we know what's where.  So I think that's what we





15      gain.  These areas can just be as little as





16      somebody dug up a contaminated soil area which was





17      relatively high contamination, a thousand





18      picocuries, and dumped it into the landfill and it





19      just got mixed in with the rest.  So it's not





20      necessarily that they dumped a particular type of





21      material there,  just what got dumped in the





22      landfill on a daily basis, and those were two hot





23      spots.  I'll be surprised if these are the only two





24      hot spots when they dig that landfill up.  The





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         PHONE (513) 381-3330    FAX  (513) 381-3342
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 1      holes are only so big.





 2                  UNIDENTIFIED SPEAKER:   Jim,  your





 3      alternative number 3,  you keep mentioning that this





 4      material is sited to go to Envirocare in Utah.  Did





 5      you look at the cost of sending it to Nevada Test





 6      Site since we're talking about splitting out the





 7      low level radioactive components?





 8                  MR. WILLIAMS:  Yes, we did,  and the





 9      reason why we used Envirocare was  it was much more





10      cost effective than the Nevada Test Site primarily





11      due to the transportation and packaging





12      reguirements.





13                  UNIDENTIFIED SPEAKER:   My second





14      guestion would be, you're given a  whack for U-238





15      concentrations, are there going to be other whacks





16      as well as for other uranium isotopes as well as





17      thorium and some of the other materials?





18                  MR. WILLIAMS:  Not for Operable Unit





19      2.  Uranium is the only contaminant of concern for





20      groundwater within Operable Unit 2.





21                  MR. BECKNER:  Earlier  you used the





22      term design life of 500 years.  Since you could not





23      have possibly tested any of these  things for





24      anywhere near that period, I'd like to know how you





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             PHONE (513)  381-3330    FAX (513) 381-3342
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 1      can design for 500 years.   Also knowing a design





 2      life is something that's a target and much like say





 3      diesel engines,  some are going to fail at a





 4      thousand miles,  some are going to fail at 200,000,





 5      what would be the low end of failure for that





 6      device if you could guarantee that the mean life





 7      was 500?





 8                  MR.  WILLIAMS:   As you say, there's





 9      not an operational history of hundreds of years for





10      these types of engineering facilities.  The way





11      that's accommodated in the design process is





12      through application of conservatism upon





13      conservatism, belts and suspenders and everything





14      else.  And so I  think the 500-year design life is





15      going to be realistic with respect to an Ohio





16      application.  I  think that it's not meaningful to





17      speculate on what the range would be.





18                  MR.  BECKNER:  Then I suggest you





19      don't guote 500  because you really can't guarantee





20      it or even a fraction of it.





21                  MR.  WILLIAMS:   Well, the engineers





22      have to have a target, that's the design life





23      target.





24                  MR.  BECKNER:  Okay, then say it's a





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               PHONE (513)381-3330   FAX (513) 381-3342
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 1      target.





 2                  The second question,  back to Vicky





 3      was talking about finance,  there's about a hundred





 4      million dollar difference between the plan leaving





 5      it on-site and taking it off-site.  This gentleman





 6      I think guoted I think a million dollars a year





 7      maintenance for the on-site plan.  If there is no





 8      inflation, in about a hundred years you would have





 9      spent as much for the one plan as the other.





10      Knowing inflation,  anybody who has bought a car say





11      20 years ago and bought one recently, I think it





12      would be safe to say that within 50 years or less





13      you'd probably consume that second hundred





14      million.  So I'd contend -- plus if it's gone, you





15      don't have to worry about that maintenance program





16      not only being funded but being carried out.





17                  My last question I guess is of the





18      two EPA representatives, I'm just curious where you





19      live, where your personal residence is, I don't





20      mean address, but like is it in Ross Township?





21                  MR. SARIC:  I don't live in Ross





22      Township, I live in Chicago, the Chicago area.





23                  MR. SCHNEIDER:   Dayton.





24                  UNIDENTIFIED SPEAKER:  Because I





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            PHONE (513) 381-3330 FAX (513) 381-3342
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 1      found them very supportive of the plan,  I was just





 2      curious how close to the area they lived.





 3                  MS. WEATHERUP:  One point I  would





 4      just like to make is that we have the design life





 5      and some of the safety factors that Jim was talking





 6      about is one of the reasons why this site as well





 7      as the uranium mill tailing sites and a  lot of the





 8      other sites have gone to the type of cap that you





 9      see back there, put in large cobble areas to keep





10      burrowing animals and trees from growing, the





11      things that, you know,  that could break  down a cap





12      and cause more infiltration.  In the liner we have





13      not only a leachate collection system,  but also a





14      leak detection system,  and that's something that





]5      you're able to monitor for a very long time, and if





16      there's a problem,  then you'll know about it before





17      it ever begins to impact the aguifer.  So that's





18      why the monitoring is key and that's why having





19      that liner, as Tom was saying, gives that added





20      level of protection and comfort and an ability to





21      do something if the containment isn't lasting.





22                  UNIDENTIFIED SPEAKER:  That  sounds





23      very impressive, but the problem is it still needs





24      to be monitored, it still has to be paid for, and





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         PHONE (513) 381-3330  FAX  (513)  381-3342
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 1      with this gentleman's point he just made,  and I





 2      want to emphasize that point,  that initial cost of





 3      off-site disposal of course is going to exceed





 4      Alternative 6,  but in the long run Alternative 6 is





 5      going to far exceed Alternative 3.  And somebody is





 6      going to have to pay for that, and future





 7      generations are going to have that burden.  Of





 8      course, they'll have the alternative to not pay, to





 9      cancel the monitoring.  Then we run the risk of in





10      the future the aguifer being further contaminated





11      because the monitoring has been cut off.  We favor





12      here, we favor off-site, we favor Alternative 3.





13                  MR. WILLIAMS:  If I can detect a





14      guestion in there, it might have to do with did we





15      accurately consider operations and maintenance in





16      the cost comparison.  Just because we send the





17      material off-site, you know,  from here, it doesn't





18      disappear.  It's still going to reguire operations





19      and maintenance, and people are going to be worried





20      about it and taxpayers are going to go paying for





21      worrying about it whether it's in Utah or here.





22                  UNIDENTIFIED SPEAKER:  But in that





23      area climate you don't have near the concerns you





24      have over an aguifer.





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          PHONE (513)  381-3330  FAX (513) 381-3342
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 1                  MR.  WILLIAMS:  It's a different





 2      climate,  agreed.





 3                  MS.  DUNN:  I want to just respond to





 4      a couple of these comments because I live in Crosby





 5      Township,  less than a mile from the site, and I am





 6      willing to accept the preferred alternative because





 7      there are a lot of other people in this country who





 8      are dealing with this same issue, and they don't





 9      want this stuff in their backyard either, and if we





10      can get the worst of this stuff out of here, I





11      think the least we can do is be responsible for





12      what we can safely keep here.





13                  MR.  WILLIAMS:  Well, if there are no





14      further guestions, I believe we're due for a break





15      of about ten minutes, and then we'll come back and





76      take your comments.





17                  MR.  WARNER:  If you want to register





18      and make a verbal comment, please do so now or hand





19      in any written comments.





20                                         (Brief recess.)





21                  MR.  WARNER:  I think we'll start the





22      formal session of this meeting now.  I'm going to





23      call out the names of those who registered anot





24      indicated they wanted to make a verbal comment, and





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            PHONE (513)  381-3330   FAX  (513)  381-3342
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 1      after we've called everybody's name and they've





 2      made their comments,  we will open the floor for any





 3      additional comments,  and after that we'll read a





 4      couple of comments that we've received that were





 5      written on the cards.  Again I would like to





 6      emphasize that responses will not be presented this





 7      evening to your comments.  You will find them in





 8      the responsiveness summary document that will be





 9      submitted with the draft Record of decision in





10      January of this year.





11                  If there's no guestions, I would like





12      you to come up to the microphone, clearly state





13      your name, and then present your comment.  Our





14      first commenter will be Tom Willsey.





15                  MR. WILLSEY:  My name is Tom





16      Willsey,  and I'm a township trustee from Ross





17      Township.





18                  A lot of you people have not seen





19      us -- Don King is also here, he's a township





20      trustee.   We have not been to a lot of these





21      meetings  because at this point we have never really





22      been in an adversarial position with you folks, but





23      I think now we are.  I've been a trustee, I'm in my





24      ninth year, so this didn't just happen to the last





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           PHONE   (513)  381-3330   FAX (513) 381-3342
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 1      night.   We've known about the problems and all the





 2      things  that went on in that plant for some time,





 3      and for ten years now we pretty much believed that





 4      they were going to clean up,  they were going to





 5      move it off site, and we believed that because





 6      that's  pretty much what you told us.  Now I'm





 7      seeing  where it's permanent,  lifelong.  I don't





 8      think you plan on moving it.   Our people in Ross





 9      Township, they have a permanent stake in this, and





10      permanent to them is lifelong because they will be





11      there all their lives.  So we feel that the meaning





12      of permanent means something different to us than





13      it does to you.  We have been dumped on, we've had,





14      of course, the uranium blow on us.  We put up with





15      it for  a long time, and like I said, we have been





16      very cooperative to this point.





17                  We've watched different things happen





18      in our  area that we're not real happy with, our





19      property values obviously went down, that's a





20      matter  of record, I'm not making that up, but we





21      tell people, hey, it's a good area, they're





22      cleaning it up, look at all the things they're





23      doing.   Well, you're not doing that.  We've had it





24      for four years.





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             PHONE  (513) 381-3330   FAX (513) 381-3342
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 1                  I look at all your charts and your





 2      graphs and I see the Alternative 3,  I see





 3      Alternative 6,  1,  2, I don't know how many there





 4      were,  but the thing that glares out and hits the on





 5      the nose on Alternative 3 and Alternative 6 is 212





 6      million versus  110 million.  Cost,  money.  Quite





 7      frankly, if you've ever been to Washington, DC,





 8      cost has never  been a factor to the federal





 9      government.  They're a monument to what you can do





10      with unlimited  funds.  On every street corner





11      there's a monument to something or somebody.  So





12      cost should not be a factor.  This cost to me is





13      not a factor.  The well-being off our residents and





14      our township is a factor to me.





15                  We  will go on record as being opposed





16      to this, and guite frankly, we're going to try to





17      get a ground swell of people to be opposed to it





18      also.   I didn't want to be adversarial about this





19      and I'm still not.  I just want it moved.  I don't





20      care what it costs.  I'm paying for it anyway.  I





21      would rather pay for it out of my pocket than pay





22      for it with the lives of my family.   Thank you.





23                  MR. WARNER:  Thank you,  Tom, we





24      appreciate your comment.





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            PHONE  (513) 381-3330   FAX (513)  381-3342
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 1                  MR.  WILLSEY:  Sorry,  one more thing,





 2      Don and I have to leave because we have a levy on





 3      and we're going to get up to the Board of





 4      Elections, we're supposed to be up there.  Thank





 5      you very much.





 6                  MR.  WARNER:  We appreciate your





 7      participation.  Richard Strimple.





 8                  MR.  STRIMPLE:  I'm going to just





 9      make a little statements on water aguifers.  If it





10      is polluted, it's already polluted.





11                  MR.  WARNER:  You are Richard





12      Strimple?





13                  MR.  STRIMPLE:  Yes, I'm sorry.  It's





14      polluted forever and there's no going to be a





15      permanent digging it up and hauling it out.  You





16      will dilute it,  you will cut your options, but for





17      somebody to think that they're going to clean it





18      up, it's spitting into the wind,  period.





19                  MR.  WARNER:  Thank you, Richard.





20      Russ Beckner.





21                  MR.  BECKNER:  My name is Russ





22      Beckner, I'm a resident of Ross Township and live





23      1,500 feet from the site.





24                 I would just like to go on record





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            PHONE (513)  381-3330   FAX (513) 381-3342
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 1      that I support Alternative 3 versus 6 for the





 2      following reasons:   One,  I feel it's definitely the





 3      safest choice for the area.   Second, long term it





 4      is definitely the least expensive,  and long term





 5      would only be a few decades, not a century.  Today





 6      no one can guarantee that a quality maintenance





 7      program will be put in place and maintained because





 8      the people doing it are very possibly not even





 9      alive today, and I  think some of the things we've





10      seen occur at this  site in the last four decades





11      confirm that.





12                  Also I  would ask our EPA





13      representatives to  give a second thought, would





14      they be so positive around the plan they support if





15      they lived 1,500 feet from the site as opposed to





16      the locations they  mentioned.  And the last thing,





17      as I said earlier,  there's no one that can design





18      anything today that hasn't been designed before and





19      guarantee it will have a 500-year life.   Thank





2 0      you.





21                  MR. WARNER:  Thank you, Russ.  Are





22      there any other comments from the floor?  That was





23      the last of our registered commenters.  Yes, sir,





24      you want to come up and state your name, please.





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            PHONE (513) 381-3330  FAX (513) 381-3342
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 1                  MR.  STORER:   I'm Gary Storer,  I'm





 2      Crosby Township Trustee and also a resident within





 3      one mile of the plant.





 4                  I wanted to make a point versus





 5      alternative, versus Alternative 6.  I favor





 6      Alternative 3 based on the fact the initial cost,





 7      212 million, will be exceeded by the initial cost





 8      of Alternative 6, which is 110 million,  in the fact





 9      that the required monitoring over a number of years





10      in the future will far exceed Alternative 3.  So





11      basically I don't see putting that burden on, I





12      don't see putting that burden on future





13      generations, however many years it would be down





14      the road, maybe a hundred years or more.  I don' t





15      feel it's fair to put that burden of monitoring,





16      which is going to far exceed Alternative 3.  So I





17      oppose Alternative 6 and I prefer Alternative 3.





18      Thanks.





19                  MR.  WARNER:   Thank you.  Any other





20      comments?





21                  We've got two to read into the record





22      here.  I'm not sure I pronounce this last name,





23      Judy Suzurikawa.  The Cincinnati Water Works





24      received notification of the public hearing and





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           PHONE (513)  381-3330  FAX (513) 381-3342
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 1      comment period on November 7th.   We have not had





 2      suificient time to review the options and their





 3      impact on water quality and the sole source aquifer





 4      which supplies many residents of Butler County and





 5      northern Hamilton County.  Also, wells in the area





 6      of the FERMCO project provide water to major





 7      industries in the Greater Cincinnati area (Fortune





 8      500 companies),  which provide employment, which





 9      contributes to the economic health of the reqion.





10      And Judy is a chemist with the Cincinnati Water





11      Works.  Thank you.





12                  This final comment is from Darrell





13      Huff.  I am submittinq these formal comments on





14      Operable Unit 2 Proposed than.  I'm a Morqan





15      Township resident, a thember of the Fernald Citizens





16      Task Force, the chair of the Citizens Task Force





17      Waste Disposition Subcommittee.   I submit these





18      comments, however, as a concerned area resident and





19      not as a representative of any of the





20      aforementioned qroups.





21                  One, I do not think forcinq area





22      residents to accept a permanent disposal cell is





23      fair.  No one asked us whether we wanted DOE to





24      come here in the first place, nobody even told us





                    Spanqler Reportinq Services





            PHONE  (513)  381-3330   FAX  (513) 381-3342
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 1      what was going on at this site for decades.





 2                  Two,  when all is said and done,  DOE





 3      will have buried the waste,  packed up and moved





 4      out.  Area residents will be left with no benefit





 5      from the site having been there.   Only the waste





 6      will remain,  and it will stay forever.





 7                  Three,  area residents are not being





 8      unreasonable in asking DOE to ship the OU-2  waste





 9      off-site.  There were two reasons for this.   A,





10      cost.  The cost of the off-site option is





11      approximately $213 million.   The cost of disposal





12      cell option is $110 million.  If something should





13      go wrong with the disposal cell,  it might foring the





14      cost of the disposal cell option much closer to





15      that of the off-site option.  B,  long term safety.





16      Places like Utah, Nevada are much better suited for





17      disposal of the waste because they aren't located





18      over water sources and also receive less rainfall.





19                  Four, I have doubts that large





20      numbers of the public understand what a permanent





21      disposal cell really means to the area.





22                  Five, extensive opportunities for





23      meaningful public involvement should be planned for





24      after the signing of the ROD.  The community





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           PHONE (513) 381-3330   FAX (513) 381-3342
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 1      relations plan draft that was circulated in





 2      September does not give any concrete examples of





 3      what public involvement will be after the ROD is





 4      signed.   That is unacceptable.   DOE officials must





 5      firmly commit themselves in writing before the ROD





 6      is signed seeking public involvement, a specific





 7      time frame, the RA time frame and beyond after the





 8      ROD is made official.





 9                  Six, if DOE does not construct a





10      disposal cell on-site,  absolutely no off-site waste





11      will be disposed of in the cell -- excuse me, if





12      DOE does construct a disposal cell on-site.  I add





13      this comment reluctantly as I still do not believe





14      the cell should exist.   The land there should be





15      left in the best condition possible.  Area





16      residents have already sacrificed enough for God





17      and country.





18                  Seven, the waste acceptance criteria





19      of 360 picocuries per gram must be a maximum





20      allowable figure for any waste that goes into the





21      cell.  It cannot be an average or a soil ceiling





22      limit.





23                 Eight, DOE headguarters must issue a





24      final ruling on the current ban on disposal of DOE





                   Spangler Reporting Services





            PHONE  (513) 381-3330   FAX (513) 381-3342
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 1      waste at a permit commercial disposal facility.





 2      DOE headquarters has had plenty of time to study





 3      the problem.  Thank you.





 4                  And that's the final written comment,





 5      so if there are no other comments, we will bring





 6      this meeting to a close and I would like to ask you





 7      to remember to fill out the evaluation form if you





 8      will please, and place them on the desk by the





 9      door.  Again,  thank you all for coming.  It was





10      nice to see some new faces here.





11                       -





12                   MEETING CONCLUDED





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               PHONE (513) 381-3330  FAX  (513)  381-3342
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 1                  CERTIFICATE





 2              I,  LOIS A. ROELL, RPR, the undersigned, a





 3      notary public-court reporter, do hereby certify





 4      that at the time and place stated herein, I





 5      recorded in stenotypy and thereafter had





 6      transcribed with computer-aided transcription the





 7      within (59) fifty-nine pages, and that the





 8      foregoing transcript of proceedings is a complete





 9      and accurate report of my said stenotypy notes.





10





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13      MY COMMISSION EXPIRES:  LOIS A. ROELL, RPR





14      AUGUST 12,  1997.        NOTARY PUBLIC-STATE OF OHIO





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               PHONE (513) 381-3330  FAX  (513) 381-3342
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                           ATTACHMENT III

                          DISTRIBUTION LIST

                        DISTRIBUTION LIST FOR

           THE OPERABLE UNIT 2 ROD - SUBMITTAL TO EPA
EPA AND OEPA
   Saric, USEPA-V, 5HRE-8J
   Jablonowski, USEPA-V, AT-18J
   Barwick, USEPA-V, 5HRE-8J
   Mitchell, OEPA-Dayton
   Kwasniewski, OEPA-Columbus
   Harris, OEPA-Dayton
   Owen, OH Dept. of Health-Columbus
   Proffitt, OEPA-Dayton
   Schneider, OEPA-Dayton
   Ball, ATSDR
   Michaels, PRC
DOE Fernald
R. Warner
D. Rast
C. Fermaintt
E. Skintik
G. Stegner
J. Jalovec
DOE Files  (Original)
G. Becker, MTC
S. Gibson, MTC

DOE Headguarters
M. McCune
K. Chaney
D. Kozlowski
S. Pearce, BA&H

Nevada Distribution
W. Griffin, DOE NTS
State of Nevada
FERMCO
Office of the President  (2 copies)
OP - E. Evered
CRU1 - R. Fellman
CRU3 - S. Houser
CRU3 - L. Goidell
CRU4 - M. Striba
CRU5 - D. Carr
CRU5 - E. Dupuis-Nouille
ENV- R.D. George
EC - T. Hagen
Legal - R. Holmes
NRM - A. Taylor
NRM - J. Mailander
PA - J. Foster
AR Coordinator  (2 copies)

w/o enclosure
J. Thiesing
M. Yates
FERMCO CRU2 Distribution
N. Weatherup
G. Jones
S. Garland
D. Walker
C. Esselman
File Copy
-------