EPA/AMD/R05-00/161
2000
EPA Superfund
Record of Decision Amendment:
FEED MATERIALS PRODUCTION CENTER (USDOE)
EPA ID: OH6890008976
OU04
FERNALD, OH
07/13/2000
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
Mr. Marty Graves jtf?,: '^ "
US EPA Superfund Document Center 5202 G
1200 Pennsylvania Avenue N.W.
Washington DC 20460
Re: FY 2000 ROD Document
Dear Mr. Graves:
US EPA Region 5 is sending the hard copy of the ROD for Feed Materials Production
Center, US DOE, OH6890008976, signed on 7/13/00. Mr. Hans Waetjen from HQ
informed Region 5 on March 28, 2001, that HQ never received the hard copy of the
ROD, and that HQ would like to receive the hard copy of the Decision Documents for US
DOE, Feed Materials Production Center site located at Fernald, Ohio.
Enclosed is the Decision Document for Feed Materials Production Center, US DOE,
OH6890008976.
If you have any questions, please contact Sangsook Choi at (312) 353-1869.
Sincerely yours,
Debra Potter
Chief, Program Management and Information Section
Enclosure
cc: Hans Waetjen, HQ
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Department of Energy
Ohio Field Office
Fernald Area Office
P. O. Box 538705
Cincinnati, Ohio 45253-8705
(513) 648-3155
JUL31 2000
ROD Clearinghouse DOE-0900-00
Superfund Document Center
U.S. EPA Mail Code 5202G
401 M Street, SW
Washington, DC 20460
To Whom It May Concern:
FINAL RECORD OF DECISION AMENDMENT FOR OPERABLE UNIT 4 SILOS 1
AND 2 REMEDIAL ACTIONS
Pursuant to the U.S. Environmental Protection Agency (U.S. EPA) guidance, presented
in Appendix D of "A Guide to Preparing Superfund Proposed Plans, Record of
Decisions (ROD), and Other Remedy Selection Decision Documents," (EPA
540-R-98-031, July 1999), please find enclosed an unbound hard copy of both the
Revised Proposed Plan and the ROD Amendment for OU4 Silos 1 & 2 Remedial
Actions. A copy of the electronic files of the main text and appendices of the Revised
Proposed Plan and the Record of Decision Amendment have also been included with
placeholders for figures.
If you have any questions regarding this documentation, please contact Nina Akgunduz
at (513) 648-3110.
Sincerely,
FEMP:Akgunduz Johnny W. Reising
Associate Director
Environmental Management
Enclosures
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FINAL
RECORD OF DECISION AMENDMENT
FOR OPERABLE UNIT 4 SILOS 1 AND 2 REMEDIAL ACTIONS
AT THE
UNITED STATES DEPARTMENT OF ENERGY
FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
FERNALD, OHIO
40700-RP-0008
June 2000
Revision 0
Prepared Under DOE Contract No. DE-AC24-92OR21972
By Fluor Fernald, Inc.
FERNALD
Environmental Management Project
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RECORD OF DECISION AMENDMENT
FOR OPERABLE UNIT 4 SILOS 1 AND 2 REMEDIAL ACTIONS
AT THE
UNITED STATES DEPARTMENT OF ENERGY
FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
FERNALD, OHIO
JUNE 2000
REVISION 0
William E. Murpr^tel/ Date
Director Ohio Office. Office of Site Closure,
United States Department of Energy
William E. Muno, Director/ / rfate
Superlund Division
United States Environmental Protection Agency - Region V
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FEMP-OU4-RODA FINAL
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DECLARATION STATEMENT
SITE NAME AND LOCATION
Fernald Environmental Management Project (FEMP) Site - Operable Unit 4 (OU4), Silos
1 and 2 material, Fernald, Hamilton County, Ohio.
STATEMENT OF BASIS AND PURPOSE
This Record of Decision Amendment for Remedial Actions at Silos 1 and 2 [hereinafter
called "the ROD Amendment"] addresses the re-evaluation of the treatment component of
the selected remedy for the remediation of the OU4 Silos 1 and 2 material at the FEMP
Site in Fernald, Ohio. The remedial action (RA) identified in this ROD Amendment was
selected in accordance with the Comprehensive Environmental Response, Compensation,
and Liability Act, as amended (CERCLA) and the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) [40 Code of Federal Regulations (CFR) Part 300].
The selected remedy outlined in the OU4 ROD (EPA 1994) consisted of the removal of the
contents of Silos 1, 2, and 3; remediation by vitrification and off-site disposal of the treated
material at the Nevada Test Site (NTS); and the demolition, removal and final disposition
of the contaminated concrete, debris, and soils within the OU4 boundary, in accordance
with the OU3 and OU5 RODs. In July 1997, the EPA directed DOE-FEMP to develop a
supplemental Feasibility Study/Proposed Plan (FS/PP) and subsequent ROD Amendment
to reevaluate the treatment remedy for the Silos 1 and 2 material. In accordance with the
same agreement, an Explanation of Significant Differences (ESD) was prepared (FEMP
1998a) documenting the change in remedy for Silo 3 material. The scope of this ROD
Amendment is limited to revising the treatment portion of the selected remedy for the Silos
1 and 2 material.
DS-1
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The decision presented herein is based on the information available in the administrative
record for OU4, which is maintained in accordance with CERCLA. The major documents
prepared through the CERLCA process include the Remedial Investigation (Rl), the
Feasibility Study (FS), the Proposed Plan (PP), and the ROD for OU4, and the revised FS
and PP for the Silos 1 and 2 material. This decision also considered state and stakeholder
input, including input received during the public hearing held in Fernald, Ohio and the
public meeting held in Las Vegas, Nevada following the issuance of the revised FS and
revised PP for Silos 1 and 2 material. DOE has considered all comments received during
the public comment period on the revised FS and revised PP for Silos 1 and 2 material in
the preparation of this ROD Amendment.
The State of Ohio concurs with the remedy and the applicable or relevant and appropriate
requirements (ARARs) put forth in this ROD Amendment for the remediation of OU4 Silos
1 and 2 material.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from OU4, if not addressed by
implementing the response action selected in this ROD Amendment, may present an
imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
On the basis of the evaluation conducted on the final alternatives as part of the revised
FS/PP, the selected remedy identified in the OU4 ROD addressing Silos 1 and 2 material
at the FEMP has been modified to the following:
DS-2
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Complete removal of contents of Silos 1 and 2 and the Decant Sump Tank
System sludge from the Transfer Tank Area (TTA) followed by treatment using
chemical stabilization to stabilize characteristic metals to meet Resource
Conservation and Recovery Act (RCRA), as amended, toxicity characteristic
limits and attain the Nevada Test Site (NTS) waste acceptance criteria (WAC).
Gross decontamination, demolition, size reduction, and packaging of concrete
from Silos 1 and 2 structures followed by shipment for off-site disposal at the
NTS or an appropriately permitted commercial disposal facility (PCDF).
Disposal of contaminated soil and debris, excluding concrete from Silos 1 and
2 structures, in accordance with the FEMP On-site Disposal Facility (OSDF)
WAC or an appropriate off-site disposal facility, such as the NTS or a PCDF.
In addition, the selected remedy includes the following components, which were not
reevaluated, and remain as documented in the OU4 ROD:
Off-site shipment and disposal of the chemically stabilized waste at the NTS.
Decontamination and dismantlement (D&D) of all structures and remediation
facilities in accordance with the OU3 ROD.
Removal of the earthen berms and excavation of the contaminated soils within
the OU4 boundary, to achieve the remediation levels outlined in the OU5
ROD.
Appropriate treatment and disposal of all secondary wastes at either the NTS
or an appropriate PCDF.
Collection of perched water encountered during remedial activities for
treatment at OU5 water treatment facilities.
Continued access controls and maintenance and monitoring of the stored
waste inventories.
Institutional controls of the OU4 area such as deed and land-use restrictions.
DS-3
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FEMP-OU4-RODA FINAL
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The FEMP OSDF will be available for disposal of debris from Silos 3 and 4 and associated
facilities (the silo superstructures and the Radon Treatment System). Soil and debris from
D&D activities associated with these facilities will be disposed in the OSDF if they meet
the WAC for disposal. Any soils and debris that do not satisfy the OSDF WAC will be
disposed at the NTS or a PCDF.
The concrete from Silos 1 and 2 is more appropriately managed in the same manner as
"Category C, Processed-related Metals." This is due to its prolonged contact with the Silos
1 and 2 material, the likelihood of contaminant migration to the interior of the concrete, and
the uncertainty in the ability to adequately decontaminate it. Therefore, concrete from Silos
1 and 2 is excluded from disposal at the FEMP OSDF. The interior surface of Silos 1 and
2 will be gross decontaminated to remove visible Silos 1 and 2 material before the
structures are demolished, size reduced, and packaged for off-site disposal.
Based on the current operating schedule, however, the FEMP OSDF will not be available
for disposal of soil and debris generated from D&D of the OU4 remediation facilities, which
include the Decant Sump Tank System, other below-grade appurtenances, and OU4 Area
7 soils. Therefore, the revised FS and PP assumed for costing purposes that all soil and
debris from D&D of the OU4 remediation facilities, including treatment facilities, TTA,
Radon Control System (RCS), and Pilot Plant, will be disposed at the NTS. However,
should programmatic changes occur and the OSDF become available, soil and debris
meeting the OSDF WAC will be disposed in the OSDF.
In reaching the decision to implement this remedial alternative, chemical stabilization and
vitrification were identified for detailed analysis in the revised FS based upon screening
of a wide range of potential treatment alternatives.
DS-4
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A description of the alternatives selected for detailed analysis is provided in Section 3 of
the revised FS, which is available in the Administrative Record. The alternatives were
evaluated using the nine criteria specified by the NCR in 40 CFR Part 300. A comparison
of the alternatives against the nine criteria is presented in Section 5 of this ROD
Amendment. The selected remedy satisfies both of the threshold criteria specified by the
NCR and represents the best balance between the alternatives with respect to the five
primary balancing criteria.
This remedy will achieve substantial risk reduction by removing the sources of
contamination, treating the material that poses the highest risk, shipping the treated
material off-site for disposal, and managing the remaining contaminated soils and debris
consistent with the site-wide strategy for the FEMP. The selected alternative provides
treatment to substantially reduce the mobility of the constituents of concern present in the
Silos 1 and 2 material. The selected remedy also provides a high degree of long-term
protectiveness for human health and the environment.
DS-5
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STATUTORY DETERMINATIONS
As documented in Section 7 of this ROD Amendment, the selected remedy satisfies the
statutory requirements specified by the NCR [40 CFR Section 300.430(f)(5)(ii)]. The
selected remedy is protective of human health and the environment, complies with all
federal and state requirements that are applicable or relevant and appropriate to the RA,
and is cost effective. This remedy uses permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable, and satisfies the
statutory preference for remedies that employ treatment, and also reduce toxicity, mobility,
or volume as a principal element. This remedy will result in contaminated debris and soil
being dispositioned in accordance with the EPA-approved RODs for OU3 and OU5,
respectively. This remedy may result in pollutants or contaminants, as defined by
CERCLA, (i.e., contaminated soil and debris in the OSDF) remaining on-site, above
health-based levels. Therefore, a review will be conducted every five years after
commencement of RA to ensure that the remedy continues to provide adequate protection
of human health and the environment.
All practical means to avoid or minimize environmental harm resulting from implementation
of the selected remedy have been adopted. During excavation activities, sediment controls
will be implemented to reduce the possibility of potential surface water runoff and sediment
deposition to Paddys Run. Final site layout and design will include all practicable means
(e.g., sound engineering practices and proper construction practices) to minimize
environmental impacts.
DS-6
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In the OU4 ROD, DOE chose to complete an integrated CERCLA/National Environmental
Protection Act (NEPA) process. This decision was based on the longstanding interest on
the part of local stakeholders to prepare an Environmental Impact Statement (EIS) on the
restoration activities at the FEMP and on the recognition that the draft document was
issued and public comments received. Therefore, the document served as DOE's ROD for
OU4 under both CERCLA and NEPA; however, it is not the intent of the DOE to make a
statement on the legal applicability of NEPA to CERLCA actions.
Under NEPA, DOE is required to prepare a Supplemental EIS (SEIS) when it has made
a substantial change in a proposed action, or if there are new significant circumstances
in the proposed EIS action that are relevant to environmental concerns. Where the
decision to prepare a SEIS is unclear, DOE NEPA regulations require the preparation of
a "Supplement Analysis" (10 CFR Section 1021.314). The revised Silos 1 and 2 FS and
PP also comprised the DOE's draft Supplement Analysis. Both documents were made
available for public review and comment. Based upon the results of the Supplement
Analysis, DOE has determined that there is no new information regarding the proposed
alternatives for remediation of the Silos 1 and 2 material that would constitute a substantial
change to the project scope or would be considered 'significant, new information' related
to the environmental impacts from the EIS alternatives. Therefore, a SEIS is not required
on the remediation of Silos 1 and 2 material.
The public has played a fundamental role in the remedial actions for OU4. DOE will
sustain the same level of public involvement throughout the implementation of the
Remedial Design/Remedial Action (RD/RA) activities, as was proven effective during the
revised FS/PP and ROD Amendment process.
DS-7
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DOE is committed to maintaining public involvement through completion of the Silos 1 and
2 RD/RA activities. Per requirements under the NCR (40 CFR Section 300.435), DOE at
a minimum will:
Upon completion of the final engineering design, prepare a fact sheet
describing the RD (40 CFR Section 300.435).
Provide a public briefing upon completion of the final engineering design and
prior to the beginning of the RA (40 CFR Section 300.435).
Continue to provide project status through the Monthly Progress Briefings.
DS-8
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TABLE OF CONTENTS
Page
List of Acronyms and Abbreviations d-v
1.0 INTRODUCTION 1-1
1.1 Background 1-1
1.2 OU4 Record of Decision 1-3
1.3 Reason for Record of Decision Amendment 1-4
2.0 SITE BACKGROUND 2-1
2.1 Contents of Silos 1 and 2 2-4
2.1.1 Regulatory Classification of Silos 1 and 2 Material 2-5
2.1.2 Packaging and Transportation of Treated Silos 1 and 2 Material 2-6
2.1.3 Disposal of Treated Silos 1 and 2 Material 2-7
2.1.4 Disposal of Secondary Wastes 2-9
2.2 Decant Sump Tank System 2-10
2.3 Radon Treatment System 2-11
2.4 Contaminated Environmental Media 2-11
2.4.1 Principal Threats of Silos 1 and 2 and Related Systems 2-11
2.4.2 Overview of the Nature and Extent of Contamination 2-13
2.5 Purpose and Need for Decision 2-14
2.6 Description of the Original Selected Remedy 2-15
3.0 BASIS FOR MODIFYING THE OU4 RECORD OF DECISION 3-1
3.1 Basis for ROD Amendment 3-1
3.1.1 Technical Basis for the Revised Path Forward 3-1
3.1.2 Regulatory Basis for the ROD Amendment 3-3
3.1.3 Basis for Modification of the Selected Remedy for Silos 1 and 2 Remedial Actions 3-4
3.2 Post-ROD Information Base 3-4
3.2.1 Vitrification Pilot Plant Final Reports 3-5
3.2.2 Melter Incident Report 3-5
3.2.3 Independent Review Team Report 3-6
d-i
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3.2.4 Waste Vitrification Systems Lessons Learned 3-7
3.2.5 Proof of Principle Testing Final Reports 3-7
3.2.6 U.S. EPA REACHITDatabase 3-8
4.0 DESCRIPTION OF SIGNIFICANT DIFFERENCES OR NEW ALTERNATIVES 4-1
4.1 Description of the Originally Selected Remedy 4-1
4.2 The OU4 Modified Selected Remedy 4-3
4.2.1 Removal of Silos 1 and 2 Material and Decant Sump Tank Contents 4-4
4.2.2 Chemical Stabilization of Silos 1 and 2 and Decant Sump Tank Contents 4-5
4.2.3 Off-site Shipment and Disposal of Treated Material 4-5
4.2.4 Soils and Debris 4-6
4.2.5 Perched Water 4-8
4.2.6 Cost 4-8
4.2.7 Measures to Control Environmental Impacts 4-9
5.0 DESCRIPTION AND EVALUATION OF ALTERNATIVES 5-1
5.1 Treatment Alternatives for the Silos 1 and 2 Material 5-1
5.2 Evaluation Criteria 5-2
5.2.1 Threshold Criteria 5-5
5.2.2 Primary Balancing Criteria 5-7
6.0 SUPPORT AGENCY COMMENTS 6-1
6.1 State Acceptance 6-1
7.0 STATUTORY DETERMINATIONS 7-1
7.1 Protection of Human Health and the Environment 7-2
7.2 Compliance with Applicable or Relevant and Appropriate Requirements 7-3
7.3 Cost Effectiveness 7-4
7.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable 7-4
7.5 Preference for Treatment as a Principal Element 7-5
7.6 Irreversible and Irretrievable Commitment of Resources 7-5
d-ii
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8.0 COMMUNITY PARTICIPATION 8-1
8.1 Community Acceptance 8-1
8.2 Community Participation 8-3
8.3 Post-ROD Amendment Community Participation 8-4
9.0 BIBLIOGRAPHY 9-1
LIST OF APPENDICES
Appendix A Applicable or Relevant and Appropriate Requirements/To Be Considered
Criteria for Management of the Silos 1 and 2 Material a-i
Appendix B Responsiveness Summary/Fernald Environmental Management
Project/Silos 1 and 2 Material b-i
d-iii
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LIST OF TABLES
TABLE 4.2-1
TABLE 5.2-1
TABLE 5.2-2
TABLE 6.1-1
TABLE 8.1-1
Cost Estimate for the Revised Remedy ($ Millions) 4-9
Summary of Key Hazards to On-site Workers 5-13
Feasibility Study Summary Cost Data (All Alternatives) 5-23
OEPA Comments Issued During Formal Public Comment Period 6-2
Summary of Public Involvement Opportunities 8-2
LIST OF FIGURES
FIGURE 1.1-1
FIGURE 2.1-1
FIGURE 5.2-1
FIGURE 5.2-2
FIGURE 5.2-3
FIGURE 5.2-4
FIGURE 5.2-5
FIGURE 5.2-6
FIGURE 5.2-7
FEMP Facility Location Map 1-2
Waste Storage Area 2-2
Comparative Analysis Summary 5-4
Summary of Discriminating Criteria and their Components 5-10
Total Solid Waste Volume Summary 5-11
Time to Achieve Protection Schedule Comparison 5-16
Summary of Total Required Operating Hours 5-17
Implementability Summary Table 5-19
Feasibility Study Cost Comparison 5-24
d-iv
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ACRONYMS AND ABBREVIATIONS
A-M
ACA
AEA
ARAR
AWWT
CAT
CERCLA
CFR
CHEM1
CHEM2
CMSA
COC
D&D
DOE
DOE-FEMP
DOE-NV
DOT
DWPF
EIS
EPA
ESD
FEMP
FMPC
FR
FS
FS/PP
ILCR
IRT
LSA
Amended Consent Agreement
Atomic Energy Act
applicable or relevant and appropriate requirement
Advanced Wastewater Treatment
Critical Analysis Team
Comprehensive Environmental Response, Compensation, and
Liability Act, as amended
Code of Federal Regulations
Removal, On-site Chemical Stabilization — Cement-based, Off-site
Disposal at the NTS
Removal, On-site Chemical Stabilization — Other, Off-site
Disposal at the NTS
consolidated metropolitan statistical area
constituent of concern
decontamination and demolition
U.S. Department of Energy
U.S. Department of Energy-Fernald Environmental Management
Project
U.S. Department of Energy-Nevada Operations Office
U.S. Department of Transportation
Defense Waste Processing Facility
Environmental Impact Statement
U.S. Environmental Protection Agency
Explanation of Significant Differences
Fernald Environmental Management Project
Feed Materials Production Center
Federal Register
Feasibility Study
Feasibility Study/Proposed Plan
incremental lifetime cancer risk
Independent Review Team
low specific activity
d-v
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ACRONYMS AND ABBREVIATIONS (cont.)
N-Z
NCR National Oil and Hazardous Substances Pollution Contingency
Plan
NEPA National Environmental Policy Act
NPL National Priorities List
NTS Nevada Test Site
O&M operations and maintenance
OEPA Ohio Environmental Protection Agency
OSDF On-site Disposal Facility
OU operable unit
PCDF permitted commercial disposal facility
PEIC Public Environmental Information Center
POP Proof of Principle
PP Proposed Plan
RA remedial action
RCRA Resource Conservation and Recovery Act, as amended
Rl Remedial Investigation
ROD Record of Decision
RCS Radon Control System
RTS Radon Treatment System
SRS Savannah River Site
TBC to be considered
TCLP Toxicity Characteristic Leaching Procedure
TTA Transfer Tank Area
TVS Oak Ridge Transportable Vitrification System
VIT1 Removal, On-site Vitrification - Joule-heated, Off-site Disposal at
the NTS
VIT2 Removal, On-site Vitrification - Other, Off-site Disposal at the NTS
VITPP Vitrification Pilot Plant
WAC waste acceptance criteria
d-vi
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1.0 INTRODUCTION
1.1 Background
This Record of Decision Amendment for Remedial Actions at Silos 1 and 2 [hereinafter called
"the ROD Amendment"] addresses the re-evaluation of the treatment component of the
selected remedy for the remediation of the Operable Unit 4 (OU4) Silos 1 and 2 material at
the U.S. Department of Energy's (DOE) Fernald Environmental Management Project (FEMP),
formerly known as the Feed Materials Production Center (FMPC). Other components ofthe
selected remedy for OU4 have not been reevaluated and remain as documented in the OU4
ROD. The FEMP is a 425-hectare (1,050 acre) former uranium processing facility located in
southwestern Ohio approximately 18 miles northwest of the city of Cincinnati (see Figure
1.1-1). It is located just north of Fernald, Ohio, a small farming community, and lies on the
boundary between Hamilton and Butler Counties. From 1952 until 1989, the FEMP site
provided high purity uranium (U) metal products to support United States defense programs.
Production was stopped due to declining demand and a recognized need to commit available
resources to remediation. The FEMP site is included on the National Priorities List (NPL) of
the U. S. Environmental Protection Agency (EPA). Inclusion on the NPL reflects the
importance placed by the federal government on ensuring the expedient completion of
cleanup operations at the FEMP. DOE owns the facility and is conducting cleanup activities
at the site under the Comprehensive Environmental Response Compensation and Liability
Act (CERCLA), as amended, and the DOE Environmental Restoration and Waste
Management Program. The EPA and the Ohio Environmental Protection Agency (OEPA)
support the DOE. Together, the three agencies actively promote local community and public
involvement in the decision making process regarding the remediation of the FEMP site.
1-1
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FIGURE 1.1-1
FEMP FACILITY LOCATION
FEMP-OU4-RODA F
4070G-RPJ
June 2000, R
1-2
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1.2 OU4 Record of Decision
The decision documented by the OU4 ROD (EPA 1994) was based on the information
available in the Administrative Record for OU4 and maintained in accordance with the
CERCLA. The documents prepared through the CERCLA process include the Remedial
Investigation (Rl) [FEMP 1993a], the Feasibility Study (FS) [FEMP 1994a], and the Proposed
Plan (PP) [FEMP 1994b] for OU4.
It is DOE policy to integrate the National Environmental Protection Act of 1969 (NEPA) into
the procedural and documentation requirements of CERCLA whenever practical. The OU4
ROD and the other CERCLA documentation (Rl, FS and PP) supporting remedial efforts at
the FEMP site (including OU4) also include the appropriate NEPA evaluations. These
integrated CERLCA/NEPA evaluations considered the potential impacts from remedial
activities at the FEMP. The OU4 FS/PP-Environmental Impact Statement (EIS) [FEMP
1993b) and subsequent OU4 ROD served as U.S. Department of Energy-Fernald
Environmental Management Project's (DOE-FEMP) ROD for OU4 under the CERCLA and
NEPA. It was not the intent of the DOE-FEMP to make a statement on the legal applicability
of NEPA to CERCLA actions.
The original remedy of vitrification was selected with consideration of stakeholder input
including input received from public hearings held on March 21, 1994, in Harrison, Ohio and
on May 11, 1994, in Las Vegas, Nevada and written comments received during the formal
comment period. The OU4 ROD was approved by the EPA in December 1994.
1-3
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1.3 Reason for Record of Decision Amendment
Pursuant to Section 117 of CERCLA and the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) at 40 Code of Federal Regulations (CFR) Section
300.435(c)(2)(ii), a ROD Amendment should be proposed when "differences in the remedial
or enforcement action, settlement, or consent decree fundamentally alter the basic features
of the selected remedy with respect to scope, performance, or cost."
The EPA determined that a ROD Amendment for the Silos 1 and 2 material was required,
because of a significant cost increase associated with implementing the selected treatment
remedy. The EPA determined that although some increase in remedial cost can be
reasonably expected, the anticipated cost increase to implement joule-heated vitrification for
treatment of the Silos 1 and 2 material constituted a fundamental change to the selected
remedy and required a re-examination of the selected remedy and a ROD Amendment (EPA
1997a). DOE is issuing this ROD Amendment in accordance with the NCP [40 CFR Section
300.430(f)(5)].
1-4
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The Revised Feasibility Study Report for Silos 1 and 2 (FEMP 1999a) [hereinafter referred
to as the revised FS] and the Revised Proposed Plan for Silos 1 and 2 (FEMP 1999b)
[hereinafter referred to as the revised PP] included the DOE's NEPA Supplement Analysis.
The revised FS and PP documents were made available for public review and comment.
Under NEPA (10 CFR Part 1021), DOE is required to prepare a Supplemental EIS (SEIS)
when it has made a substantial change in a proposed action, or if there are new significant
circumstances in the proposed EIS action that are relevant to environmental concerns. Where
the need to prepare a SEIS is unclear, DOE NEPA regulations require the preparation of a
"Supplement Analysis" (10 CFR Section 1021.314). Based upon the results of the
Supplement Analysis for Silos 1 and 2, DOE has determined there is no new information
regarding the proposed alternatives for remediation of the Silos 1 and 2 material that would
constitute a substantial change to the project scope or would be considered 'significant, new
information' related to the environmental impacts from the EIS alternatives. Therefore, a SEIS
is not required in order to amend the decision on the remediation of Silos 1 and 2 material.
This ROD Amendment summarizes key information that can be found in greater detail in the
Rl (FEMP 1993a), FS (FEMP 1994a), PP (FEMP 1994b), revised FS and revised PP.
Details on obtaining information relevant to the Silos 1 and 2 remedial selection process is
provided in Section 8.2.
This ROD Amendment, along with the revised FS, revised PP and supporting documents, are
part of the Administrative Record in accordance with to 40 CFR Section 300.825(a)(2).
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2.0 SITE BACKGROUND
This section provides a brief summary of the history of the FEMP and description of OU4. A
more detailed discussion can be found in Section 1 and Section F.2 of Appendix F of the
revised FS.
The FEMP site was constructed from 1950 to 1951 under the authority of the Atomic Energy
Commission, eventually known as the DOE. Between 1952 and 1989, the DOE-FEMP facility
(then called the FMPC) produced high purity uranium metal products for the nation's defense
programs. Production ceased in the summer of 1989 due to a declining demand for uranium
feed product; and, plant activities turned their focus to environmental cleanup. In June 1991,
the site was officially closed for production by an act of Congress. To reflect a new mission
focused on environmental restoration, the name of the facility was changed to the FEMP in
August 1991.
Production operations at the facility were limited to a fenced 55-hectare (136-acre) tract of
land, now known as the former Production Area, located near the center of the FEMP site.
Large quantities of liquid and solid materials were generated during production operations.
Before 1984, solid and slurried materials from uranium processing were stored or disposed
in the on-property Waste Storage Area. This area, located west of the former Production
Area, includes six low-level radioactive waste storage pits; two earthen-bermed, concrete
silos containing a total of 8,012 yds of 11(e)(2) by-product material and 878 yds of a
protective BentoGrout™ clay (Silos 1 and 2); one concrete silo containing 5,088 yd3 of cold
metal oxides (Silo 3); one unused concrete silo (Silo 4); two lime sludge ponds; a burn pit; a
clearwell; and a solid waste landfill (see Figure 2.1-1).
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In order to establish the legal framework by which to address the releases and threats of
hazardous substances from containers and facilities at the FEMP, the DOE-FEMP (as the
lead agency for the remediation of the FEMP site) and the EPA entered into a Consent
Agreement in 1990, as amended (EPA 1991). The Consent Agreement as Amended Under
CERCLA Sections 120 and 106(a) (ACA) is the legal basis that administratively governs the
proper management and restoration of the FEMP site.
The facility and associated environmental issues of the FEMP site are being managed as five
operable units (OUs) in order to promote a more structured and expeditious cleanup. An "OU"
is a term employed under federal environmental regulation to represent a logical grouping of
environmental issues at a cleanup site. Separate RI/FS documentation was prepared and
issued for the five OUs at the FEMP. The five OUs, for which RI/FS documents have been
compiled, are defined within the ACA as:
OU1: Waste Pits 1 through 6, the Clearwell, burn pit, berms, liners, and soil to a
determined depth (estimated to be approximately 3 feet) beneath the waste pits.
OU2: Other waste units including the flyash piles, other South Field disposal areas,
lime sludge ponds, solid waste landfills, berms, liners, and soil within the OU boundary.
OUS: Former production area and production-associated facilities and equipment
(includes all above- and below-grade improvements). This includes, but is not limited
to: all structures, equipment, utilities, drums, tanks, solid waste, waste product, thorium
(Th), effluent lines, a portion of the Silos 1 and 2 material transfer line, wastewater
treatment facilities, fire training facilities, scrap metal piles, feedstocks, and the coal
pile.
OU4: Silos 1, 2, 3, and 4, their contents, berms, and Decant Sump Tank System;
Radon Treatment System (RTS); a portion of concrete trench and Silos 1 and 2
material transfer line within the boundary of OU4; miscellaneous pads and concrete
structures; soils beneath and immediately surrounding Silos 1 through 4; and, perched
groundwater in the vicinity of the silos that may be encountered during the
implementation of cleanup activities.
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• OU5: Environmental media including groundwater (both perched and the Great Miami
Aquifer), surface water, soil not included in the definitions of OUs 1 through 4,
sediment, flora, and fauna.
All five OUs (including OU4) completed the RI/FS process and have initiated remedial actions
(RAs) in accordance with their respective EPA-approved final RODs. The original selected
remedy for Silos 1 and 2 within OU4 is being modified through this ROD Amendment.
2.1 Contents of Silos 1 and 2
Silos 1 and 2 contain a total of 8,012 yd3 of 11 (e) (2) by-product material and a total of 878
yd3 of BentoGrout™ clay for a total volume of 8,890 yd3. The BentoGrout™ clay layer was
added in 1991 to the Silo 1 and 2 material in order to reduce the radon (Rn) emanation.
Radionuclides at significant activity levels within these silos are actinium (Ac), radium
(Ra)-226, Th-230, polonium (Po)-210, and a radioactive isotope of lead (Pb-210). These
radionuclides are naturally occurring elements found in the original ores processed at the
FEMP and Mallinckrodt.
Non-radiological constituents detected in significant concentrations in Silos 1 and 2 material
include sodium, magnesium, nickel, barium, lead, calcium, iron, and tributyl phosphate (a
solvent used in the former uranium extraction process at the FEMP). Tests performed on
samples of stored material identified that lead can leach from the untreated material in
concentrations that exceed typical federal guidelines for hazardous wastes.
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The significant concerns associated with the Silos 1 and 2 material include:
• High concentrations of radionuclides, including Ra-226 and Th-230, that are present
in the material;
• An elevated, gamma radiation field in the vicinity of the silos due to the material in the
silos;
• Chronic emissions of Rn-222 (a radioactive gas from the decay of Ra-226) from Silos
1 and 2 material into the atmosphere;
• The structural instability of the silos dome and the age of the remaining portions of the
structures; and
• The potential threat of the silos material leaching Resource Conservation and Recovery
Act, as amended (RCRA) metals and radionuclides into the underlying sole-source
aquifer.
2.1.1 Regulatory Classification of Silos 1 and 2 Material
Silos 1 and 2, known as the "K-65 Silos," contain material generated from the processing of
high-grade uranium ores termed pitchblende. This processing was performed to extract the
uranium compounds from the natural ores. The Silos 1 and 2 material contains high activity
concentrations of radionuclides, including Ra-226 and Th-230. The Silos 1 and 2 material was
generated consequential to the processing of natural uranium ores and is therefore classified
as by-product material, as defined in Section 11 (e)(2) of the Atomic Energy Act, as amended
(AEA).
The Silos 1 and 2 material is a complex wasteform from a regulatory perspective. Applicable
or relevant and appropriate requirements (ARARs) for its remediation are identified in
Appendix A of this ROD Amendment.
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The material contained in Silos 1 and 2 is 11(e)(2) by-product material resulting from the
processing of uranium ore concentrates. It is specifically exempt, as defined, from regulation
as solid waste under the RCRA 40 CFR Section 261.4(a)(4). The referenced exclusion
applies to"... source, special nuclear or by-product material as defined in the Atomic Energy
Act of 1954 as amended, 42 U.S.C. 2011, et seq." Since a material must first be a solid
waste in order to be a hazardous waste, and since the silos material is excluded from
regulation as solid waste, the Silos 1 and 2 material cannot be regulated as hazardous waste
under RCRA. Although the leachability of lead in the Silos 1 and 2 material exceeds the RCRA
toxicity characteristic level, this does not cause the material to become subject to RCRA
regulation, due to a hazardous waste characteristic. The metals are not from an external
source, but are associated with the parent material [whose residues, including any
ancillary metals, are excluded from the definition of solid waste
pursuant to 40 CFR Section 261.4(a)(4)].
2.1.2 Packaging and Transportation of Treated Silos 1 and 2 Material
The Silos 1 and 2 material and secondary waste will be subject to regulations under the U.S.
Department of Transportation (DOT) 49 CFR Subtitle B Chapter I Subchapter C, Hazardous
Materials Regulations.
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Federal Regulations promulgated by the DOT on September 28, 1995 [60 Federal Register
(FR) 50292] categorize low specific activity (LSA) material into three classifications: LSA-I,
LSA-II, andLSA-lll. Evaluation of the radionuclide content for Silos 1 and 2 material indicates
that this material meets one of the criteria for LSA-II material. Specifically, Silos 1 and 2
material is classified as LSA-II because "Class 7 (radioactive) material is essentially uniformly
distributed and the average specific activity does not exceed 10"4A2/g for solids" (49 CFR
Section 173.403).1 Therefore, the OU4 Silos 1 and 2 material is classified as LSA-II material
for proper packaging and transportation.
2.1.3 Disposal of Treated Silos 1 and 2 Material
As discussed in Section 5, all alternatives evaluated in the revised FS will dispose the treated
Silos 1 and 2 material at the Nevada Test Site (NTS). The NTS is a DOE-owned and
managed facility used for the disposal of selected low-level radioactive wastes from other
DOE sites.
DOE derives authority from the AEA to manage small quantities of 11(e)(2) by-product
material as "low-level waste" so that it may dispose of such small waste quantities at DOE
low-level waste disposal facilities (e.g., NTS). Such quantities must not be "too large for
acceptance at DOE low-level waste disposal sites," and such wastes must meet the
requirements for low-level waste in accordance with DOE Order 435.1 Chapter IV(B)(4).
The A2 value is the maximum activity, in curies (Ci), of radioactive material, other than special
form, low specific activity (LSA), or surface contaminated objects permitted in a Type A
package. To be classified as LSA-II material, the average specific activity must be less than one
ten-thousandth (10~4) of the calculated A. value per gram of material. As an example, if a
material has a calculated A2 value of 10,000 Ci, the average specific activity must be less than
1 Ci/g.
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The treated Silos 1 and 2 material is 11(e)(2) by-product material and may be managed as
a low-level waste pursuant to DOE Order 435.1. As a low-level waste, it must meet the NTS
waste acceptance criteria (WAC) and, therefore, may not contain a RCRA listed waste, or
exhibit a RCRA characteristic, regardless of the exclusion defined for by-product material at
40 CFR Section 261.4(a)(4).
DOE-FEMP will be responsible for demonstrating compliance with the NTS WAC.
Specifically, DOE-FEMP will document the absence of the hazardous characteristics defined
at 40 CFR Part 261 Subpart C, especially those toxic constituents identified in Table 1 of 40
CFR Section 261.24 that may have been used in a process, regardless of the waste's
regulatory status. Upon successful review, the Department of Energy-Nevada (DOE-NV)
Radioactive Waste Acceptance Program will document approval of the wastestrearn.
The C ERG LA off-site rule [CERCLA Section 121 (d)(3)] and implementing regulations40 CFR
Section 300.440) requires that waste from a RA that is shipped off-site for treatment and/or
disposal be transferred only to those receiving units at a facility that (1) are operating in
compliance with RCRA and other applicable federal and state requirements, and (2) do not
have any uncontrolled releases of hazardous waste or constituents. The rule applies to any RA
involving off-site treatment, storage or disposal of CERCLA waste, defined in CERCLA
Sections 101(14) and (33); where the RA is being conducted pursuant to CERCLA.
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In a letter dated July 7, 1998, the EPA Region IX granted approval to the NTS to dispose of
CERCLA waste from DOE facilities in Area 3 and Area 5 Radioactive Waste Management
Sites in accordance with the Off-site Rule (40 CFR Section 300.440). EPA Region IX,
clarified their position in a letter dated December 4,1998. The letter states that the CERCLA
Off-site Rule approval for the NTS Area 3 and Area 5 Radioactive Waste Management Sites
includes management of small volumes of 11(e)(2) by-product materials from Fernald OU4
as low-level waste under the provisions of Chapters III and IV of DOE Order 435.1 or any
subsequent applicable DOE directive.
2.1.4 Disposal of Secondary Wastes
The selected remedy includes the decontamination and dismantlement (D&D) of all structures
and remediation facilities and appropriate treatment and disposal of all secondary wastes.
Secondary wastes generated during the treatment operations of the Silos 1 and 2 material
or D&D activities, which cannot be disposed at the NTS without additional treatment, may be
treated and/or disposed at an appropriately licensed off-site facility. Concrete from Silos 1
and 2 structures will undergo gross decontamination, demolition, size reduction, and
packaging for shipment for off-site disposal at the NTS or an appropriately permitted
commercial disposal facility (PCDF). Contaminated soils and debris, excluding concrete from
Silos 1 and 2 structures, will be disposed in accordance with either the FEMP On-site
Disposal Facility (OSDF) WAC or an appropriate off-site disposal facility, such as the NTS
or a PCDF. Perched water encountered during remedial activities will be collected and
directed to the FEMP OU5 water treatment facilities.
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2.2 Decant Sump Tank System
The Decant Sump Tank System was an integral part of the former operations associated with
Silos 1 and 2 and continues to collect groundwater beneath the two silos. Samples collected
in 1991 from the water within the Decant Sump Tank System revealed elevated
concentrations of Pb-210, Po-210, Ra-226, and U-235. Analytical results also revealed the
presence of above-background concentrations of strontium (Sr)-90 and technetium (Tc)-99.
With the exception of these latter two constituents, radiological contaminants present in the
Decant Sump Tank System are consistent with the relative concentrations of constituents
found in Silos 1 and 2. This result confirms that the Decant Sump Tank System is continuing
to collect leachate from the underdrains in Silos 1 and 2, as it was designed to do. Sr-90 and
Tc-99 were only detected in one decant sump tank sample and the concentrations were only
slightly above the contract required detection limits. Sr-90 and Tc-99 are fission products and
would not be present in the decant sump tank if the liquids consisted solely of leachate from
Silos 1 and 2 collected via the silo underdrains. The presence of these radionuclides may
have come from a number of sources other than leaching of radionuclides from the silo
contents. These sources include: carry-over of other beta emitters during the laboratory
chemical separation process (most probable source); infiltration of meteoric water into the
Decant Sump Tank System; cross-contamination of the sample within the transport tanker
prior to sample collection; or infiltration of perched groundwater into the decant sump tank.
The metals found in liquid samples from the Decant Sump Tank System include aluminum,
antimony, arsenic, chromium, copper, lead, molybdenum, selenium, silver, vanadium, and zinc.
In addition, 18 organic compounds were detected in the Decant Sump Tank System liquids
at low concentrations. With the exception of toluene, all volatile compounds detected were at
or below concentrations that allow a laboratory to accurately quantify the level of the
constituents.
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2.3 Radon Treatment System
The RTS was installed in November 1987, to reduce the radon inventory within the headspace
of Silos 1 and 2. The RTS was sampled during a removal site evaluation in January 1992.
Following the addition of BentoGrout™ clay to Silos 1 and 2 during Removal Action 4, the
RTS was abandoned in place. The predominant contaminant present is Pb-210 and its
associated decay products. Periodic surveys for direct radiation and removable fixed
radioactive contamination reveal that only isolated contamination is present in accessible
portions of the RTS.
2.4 Contaminated Environmental Media
In addition to the waste areas described, contamination is present in environmental media
within the OU4 area, such as surface and subsurface soil, soils within the earthen berm
surrounding Silos 1 and 2, groundwater, surface water, and perched water.
2.4.1 Principal Threats of Silos 1 and 2 and Related Systems
The NCP describes principal threats as those involving liquids, areas contaminated with high
concentrations of toxic compounds, and highly mobile materials. The OU4 Rl provided a
detailed characterization of the Silos 1 and 2 material. The OU4 Rl identified those
contaminants that contributed to an incremental lifetime cancer risk (ILCR) value greater than
the C ERG LA criterion of 1 x 10"6 and a hazard quotient greater than the C ERG LA criterion of
1.0. The OU4 Rl identified the principal threats to human health and the environment posed
by the Silos 1 and 2 material as being from the following four contaminant/transport pathways:
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• Direct radiation
Direct exposure to gamma radiation from radioactive constituents within the
silos.
Direct exposure to gamma radiation from radioactive constituents in surface
soil.
• Air emissions
Dispersion of radon that escapes from the silos into the atmosphere.
Dispersion of volatile organic compounds or fugitive dust generated from soil.
• Surface water runoff
Erosion of contaminated soils into Paddys Run from the vicinity of the silos.
• Groundwater transport
Leaching of contaminants from the silos contents via soils to underlying
groundwater.
Leaching of contaminants from the silos contents via soil to a sand silty/clay
lens in the glacial till, which could carry contaminants to surface water and
sediment in Paddys Run.
Potential remedial alternatives for OU4 were developed in order to mitigate the short-term and
long-term exposure and associated risks from gamma radiation; reduce radon emanation
rates from the Silos 1 and 2 material; minimize the leachability of contaminants from the waste
material; eliminate potential of air dispersion from a silo collapse; eliminate the dispersion of
fugitive dust generated from the soil; and, eliminate contaminated surface water runoff from
contaminated soils into Paddys Run.
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2.4.2 Overview of the Nature and Extent of Contamination
This section summarizes the nature and extent of contamination within environmental media
in the OU4 study area. Also included in this section is an overview of the levels of direct
radiation associated with the current conditions within OU4. Additional detail on these
conditions is provided in Section 4.0 of the OU4 Rl (FEMP 1993a).
2.4.2.1 Surface Soils
Sampling performed as part of the RFS and other site programs in the vicinity of OU4
indicates the occurrence of above background concentrations of uranium, and to a lesser
degree, other radionuclides in the surface soils within and adjacent to the OU4 study area.
These above-background concentrations appear to be generally limited to the upper six
inches of soil. Available survey data and process knowledge do not indicate a direct
relationship between the surface soil contamination in the OU4 study area and the silos
contents.
Soil samples were also collected from the soils contained in the earthen embankment (berm)
surrounding Silos 1 and 2. The analytical data from the berm fill show only slightly elevated
radionuclide activity concentrations.
2.4.2.2 Subsurface Soils
As part of the OU4 Rl, samples were collected from the subsurface soils located under and
adjacent to Silos 1 and 2. Analytical results revealed elevated concentrations of radionuclides
from the uranium decay series in the soils at the interface between the berm and the original
ground level. Elevated concentrations (up to 53 pCi/g for U-238, about 40 times background)
were also noted in slant boreholes, which passed in close proximity to the silos' underdrains.
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2.4.2.3 Groundwater
With the exception of perched groundwater encountered during potential RA, groundwater
within the Great Miami Aquifer underlying the silos area is not within the scope of OU4.
Groundwater in the Great Miami Aquifer underlying the entire FEMP site is being addressed
as part of OU5.
Uranium was the major radionuclide contaminant found in the perched water. Elevated
concentrations of total uranium were detected in the slant boreholes under and around Silos
1 and 2.
2.4.2.4 Great Miami Aquifer
The concentration of total uranium in the upper portion of the Great Miami Aquifer, based on
analysis of samples from the 2000-series wells, ranged from less than 1 ug/L to 40.3 ug/L.
Both upgradient and downgradient wells contain above background concentrations of total
uranium. Therefore, other sources of contamination must exist besides Silos 1 and 2.
2.5 Purpose and Need for Decision
Facilities and environmental media at the FEMP site, including OU4, contain radioactive and
chemical constituents at levels that exceed certain federal and state standards, and guidelines
for protecting human health and the environment. Currently, DOE-FEMP maintains custody
of the property and restricts access with fences and security forces, precluding a member of
the public from being exposed to site areas that have contamination.
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The EPA has established a formalized risk assessment process to determine the necessity
for implementation of cleanup actions. Under this process, several hypothetical scenarios that
could expose members of the public to site contamination were examined. One of these
scenarios assumed that site access was not controlled (i.e., unrestricted) and a member of
the public could be exposed to the higher contamination areas. Results of the risk assessment
performed for this hypothetical, unrestricted access scenario indicated that an individual
establishing residence within the highly contaminated portions of the OU4 area, under existing
conditions, would be subjected to an increased risk of incurring an adverse health effect. Risk
assessment calculations performed for OU4 indicate the projected level of increased risk
exceeds established federal regulatory guidelines. Based on the results of the baseline risk
assessment, the DOE-FEMP concluded in the Rl (FEMP 1993a) that existing site conditions
warrant RA. A summary of the original assessment results can be found in Appendix F of the
revised FS (1999a).
2.6 Description of the Original Selected Remedy
Based of the evaluation of remedial alternatives conducted in the FS/PP (FEMP 1994 a,b),
the major components of the selected remedy documented in the OU4 ROD (EPA 1994) are
as follows:
• Removal of the contents of the Silos 1,2,3 and the decant sump tank sludge.
• Treatment of the Silos 1,2, and 3 material and sludges removed from the silos and the
decant sump tank by vitrification to meet disposal facility WAC.
• Off-site shipment of the vitrified contents of Silos 1,2,3 and the decant sump tank
for disposal at the NTS.
• Demolition of Silos 1, 2, 3 and 4 and decontamination, to the extent practicable, of the
concrete rubble, piping, and other generated construction debris.
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Removal of the earthen berms and excavation of the contaminated soils within the
boundary of OU4, to achieve remediation levels. Placement of clean backfill to
original grade following excavation.
Demolition of the remediation and support facilities after use. Decontamination or
recycling of debris before disposition.
On-property interim storage of excavated contaminated soils and contaminated
debris in a manner consistent with the approved Work Plan forFEMP Removal
Action No. 17 - Improved Storage of Soil and Debris (DOE 1996)2, pending final
disposition of soil and debris in accordance with the RODs of OUs 5 and 3,
respectively.
Continued access controls and maintenance and monitoring of the stored waste
inventories.
Institutional controls of the OU4 area such as deed and land-use restrictions.
Potential, additional treatment of stored OU4 soil and debris using OUS and OUS
waste treatment systems.
Pumping and treating, as required, of any contaminated perched groundwater
encountered during remedial activities.
Disposal of the OU4 FEMP contaminated debris and soils consistent with the RODs
for OUs 3 and 5, respectively.
2 This component of the selected remedy was documented in the Operable Unit 4 Record of
Decision (ROD) in 1994. However, for purposes of this ROD Amendment the reference has
been updated to the most recent revision.
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Although the selected remedy for OU4 specifies on-site disposal for the OU4 soil and debris,
the final decision regarding the final disposition of the OU4 debris and soils was placed in
abeyance, until the OU3 and OU5 RODs were completed. This approach allowed DOE to take
full advantage of planned waste management and treatment strategies developed by these
OUs and enabled the integration of disposal decisions for OU4 contaminated soils and debris
on a site-wide basis. The integration strategy for the OU4 contaminated soils and debris is
discussed in more detail in Section 4.0.
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3.0 BASIS FOR MODIFYING THE OU4 RECORD OF DECISION
3.1 Basis for ROD Amendment
3.1.1 Technical Basis for the Revised Path Forward
The technical basis for reevaluating the path forward for OU4 remediation, and ultimately
modifying the ROD, is presented in detail in Section 1.1 of the revised FS. Following approval
of the OU4 ROD, a treatability study program was initiated in May 1996 to collect quantitative
performance data to support full-scale application of the joule-heated vitrification technology
to the silos material.
During the treatability study program, many technical and operational difficulties were
encountered. These technical and operational issues are discussed in detail in Section 1.1
of the revised FS, and in the VITPP Melter Incident Final Report (FEMP 1997b). Attempts to
resolve these issues during Vitrification Pilot Plant (VITPP) operations resulted in documented
schedule and cost increases.
In September 1996, the DOE requested that the EPA grant an extension of enforceable
milestones associated with implementing vitrification of the silos material due to the
aforementioned difficulties. In October 1996, the EPA denied DOE's request. Pursuant to the
September 1991, Amended Consent Agreement, the EPA and DOE initiated the formal
dispute resolution process and began reevaluating the remediation of the silos material. In
November 1996, the DOE-FEMP formed the Silos Project Independent Review Team (IRT)
as a technical resource to assist the DOE-FEMP in this re-evaluation. The IRT was comprised
of technical representatives from throughout the DOE-FEMP complex and private industry with
expertise in various aspects of chemical stabilization, vitrification, and other treatment
technologies.
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During the final stages of the last campaign of the VITPP to demonstrate lower temperature
processing (<1200°C) of Silos 1 and 2 material, the melter hardware failed (December 26,
1996).
On July 22, 1997, the DOE-FEMP and the EPA signed an, "Agreement Resolving Dispute
Concerning Denial of Request for Extension of Time for Certain OU4 Milestones" (EPA
1997b) [hereafter referred to as "the Settlement"]. The Settlement resolved disputes
concerning the schedule and path forward for the remediation of the Silos 1, 2, and 3
materials. In the Settlement, EPAand DOE-FEMP agreed that DOE-FEMP would supplement
the FS/PP so as to evaluate vitrification and other alternatives for treatment of the Silos 1 and
2 material. In addition, the EPA determined the remedial actions for Silo 3 could be separated
from Silos 1 and 2 and an ESD would be sufficient to document the changes to the Silo 3
remedy.
An ESD was completed by DOE-FEMP and approved by the EPA in March 1998 to
document the change in remedy for treatment and disposal of the Silo 3 material (FEMP
1998a).
The DOE-FEMP has prepared a revised FS and revised PP to recommend a RAforthe Silos
1 and 2 material. The revised FS and the revised PP were made available for stakeholder
review. The revised FS and revised PP provided the basis for selection of the final remedy,
which is documented in this amendment to the OU4 ROD, for Silos 1 and 2. In addition,
comments received from the OEPA and stakeholders on the revised FS and revised PP are
addressed in Section 6.0 and Appendix B, respectively, of this ROD Amendment.
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As part of the revised path forward for Silos 1 and 2, a contract was awarded in February
1999 to retrieve the entire contents of Silos 1 and 2 and the Decant Sump Tank System and
transfer it to a newly constructed, environmentally controlled Transfer Tank Area (TTA). This
allows for storage of the material in a safer configuration than the Silos 1 and 2 structures
while pending remediation by the selected treatment alternative. The contract award includes
the construction of a radon control system (RCS) in conjunction with the TTA to control Rn-222
emanation during the retrieval and storage of Silos 1 and 2 material in the TTA. In addition,
the RCS will control Rn-222 emanation during retrieval, treatment, and storage of Silos 1 and
2 material in the remediation facility.
3.1.2 Regulatory Basis for the ROD Amendment
In the Settlement, EPA directed DOE-FEMP to proceed with the development of a ROD
Amendment for the Silos 1 and 2 material and an ESD for the Silo 3 material.
Pursuant with Section 117 of CERCLA and the NCP at 40 CFR Section 300.435(c)(2)(ii), a
ROD Amendment should be proposed when "differences in the remedial or enforcement
action, settlement, or consent decree fundamentally alter the basic features of the selected
remedy [in the ROD] with respect to scope, performance, or cost."
The EPA determined that although some increase in remediation cost can be reasonably
expected; in this specific case the final remediation cost estimated by DOE-FEMP for the
Silos 1 and 2 material increased significantly [i.e., approximately greater than 3 times the
original estimate]. Therefore, it was EPA's position that the significant anticipated cost
increase changes - resulting from implementability issues with the treatment technology of
joule-heated vitrification for the Silos 1 and 2 material - required a re-examination of the
selected remedy and a ROD Amendment (EPA 1997a).
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3.1.3 Basis for Modification of the Selected Remedy for Silos 1 and 2 Remedial Actions
This ROD Amendment modifies the treatment component of the selected remedy for Silos 1
and 2 material from vitrification to chemical stabilization. The modification of the treatment
component is based on the conclusion that chemical stabilization satisfies both threshold
criteria specified by the NCR and meets the statutory requirements of CERCLA. In addition,
chemical stabilization attains Remedial Action Objectives identified in the OU4 ROD, and has
an overall advantage over vitrification when evaluated against the five primary balancing
criteria specified by the NCR. Specifically, the advantages of chemical stabilization in
implementability and short-term effectiveness (worker risk and time to achieve protection) are
judged to outweigh the advantages of vitrification due to its lower treated waste volume. The
basis for this conclusion is presented in detail in Section 5. As documented in Sections 6
and 8, respectively, state and community acceptance have been addressed in accordance
with the NCR.
3.2 Post-ROD Information Base
Since the approval of the OU4 ROD in December 1994 by the EPA, the DOE-FEMP has
developed an expanded information base with respect to the various treatment technologies
and their application toward the remediation of the Silos 1 and 2 material. This information
has been used in the revised FS for the preliminary screening and re-evaluation of treatment
technologies for the silos material. The various documents comprising this information base
are identified in the revised FS bibliography and are part of in the Administrative Record and
are available for inspection.
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3.2.1 Vitrification Pilot Plant Final Reports
The FEMP joule-heated VITPP treatability study program consisted of three test campaigns
with the following objectives: (1) to determine (using surrogates) whether it was more
economical to vitrify the Silos 1, 2, and 3 materials together or separately; (2) to gain
experience vitrifying silos material and handling high-sulfate, high-barium and lead
concentrations, and BentoGrout™; and (3) to determine maximum production rates through
induced agitation (via bubbling tubes) in the molten glass bath to increase production.
The results of the three test campaigns have been published in three separate Operable Unit
4 Vitrification Pilot Plant reports - Campaign 1, 3 and 4, respectively (FEMP 1996a, 1996b,
1997a). The results of the testing have been factored into the development of the alternatives'
design basis, cost estimates, and the implementability evaluation for the vitrification
technologies.
3.2.2 Melter Incident Report
The VITPP Melter Incident Report (FEMP 1997b) summarizes the findings of three
investigative teams who evaluated the FEMP VITPP melter hardware failure and subsequent
leakage of non-radioactive surrogate glass. The report identifies the causal and contributing
factors that lead to the melter failure, and identifies lessons learned for any future applications
of vitrification technology for the DOE-FEMP silos material or other areas in the DOE
complex.
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3.2.3 Independent Review Team Report
In November 1996, DOE-FEMP formed the Silos Project IRT to provide recommendations
to them and the DOE-FEMP, as an aid in the internal decision process. Specifically, the IRT
assisted and advised the DOE, the public and regulatory agencies in recommending a path
forward for immobilization and disposal of the materials contained in Silos 1, 2 and 3 in OU4
oftheFEMP.
The IRT was composed of 11 members, having backgrounds and experience in several areas
including vitrification, glass furnaces and glass making, cementation, projects and project
management, regulatory, environmental, and safety.
The IRT performed an independent analysis of the VITPP melter incident and other technical
issues associated with the treatment of the Silos 1, 2 and 3 material. Based upon this
analysis, the IRT published theirfinal report (Silos Project IRT 1997) which identifies the IRT's
recommendations for a path forward for remediation of the Silos 1, 2, and 3 material. The
recommendations were based on the information provided through reports, discussions,
presentations and site tours, and supplemented by individual knowledge and study.
The IRT was unable to reach unanimous consensus upon a recommended treatment process
for the Silos 1 and 2 material. Both the majority and minority opinions are formally
documented in the IRT final report.
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3.2.4 Waste Vitrification Systems Lessons Learned
In March 1999, the DOE Office of Environment, Safety and Health published a report to
present lessons learned in the design and operation of waste vitrification systems (DOE
1999). The report summarizes the joule-heated melter technology experiences from four low
level waste vitrification facilities (Fernald VITPP, Savannah River Site (SRS) Vendor
Treatment Facility, Oak Ridge Transportable Vitrification System (TVS), and Hanford
Low-Level Vitrification Project). The report also summarizes technology experiences from
four high-level waste vitrification facilities (SRS Defense Waste Processing Facility (DWPF),
West Valley Demonstration Project Vitrification Facility, Sellafield - UK Waste Vitrification
Plant, and Savannah River Stir Melter). The lessons learned have been used in the evaluation
of the vitrification technologies in Section 3 of the revised FS.
3.2.5 Proof of Principle Testing Final Reports
In accordance with the July 22,1997, dispute settlement between the EPA and DOE- FEMP,
the DOE-FEMP performed the Proof of Principle (POP) Testing Project to support the
technical basis for the alternatives being evaluated in the revised FS. This testing was scoped
and implemented to satisfy agency and stakeholder concerns that the detailed evaluation of
the alternatives and comparative analysis be supported by pilot-scale data resulting from
testing of proven and commercially available remedial technologies. The testing was
performed using non-radioactive surrogates that simulated selected physical and chemical
characteristics of the Silos 1 and 2 material.
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The technologies of the POP Testing Project were based upon the preliminary screening and
technology selection process described in Section 2 of the revised FS. The preliminary
screening and technology selection process resulted in the identification of two technology
families (vitrification and chemical stabilization) with two alternatives each, for detailed
analysis in Section 3 of the revised FS. The following is a list of the technology
families/stabilization alternatives evaluated in the revised FS:
Vitrification - Joule-heated;
Vitrification - Other;
Chemical Stabilization - Cement-based; and
Chemical Stabilization - Other.
3.2.6 U.S. EPA REACHIT Database
In August, 1999, an extensive search was conducted of the EPA's nationwide electronic
database (REACHIT) of remedial sites where the vitrification, solidification/stabilization, and
chemical stabilization treatment technologies have been applied to the remediation of
material contaminated with lead and/or radioactive material. The database search identified
a list of facilities where the technologies, at various stages of implementation, have been
applied to wastestreams reasonably similar to the Silos 1 and 2 material. The results of the
search have been used as part of the implementability evaluation of the technologies in
Section 3 of the revised FS.
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4.0 DESCRIPTION OF SIGNIFICANT DIFFERENCES OR NEW ALTERNATIVES
4.1 Description of the Originally Selected Remedy
The key components of the selected remedy documented in the OU4 ROD (EPA 1994) are
as follows:
Removal of the contents of the Silos 1, 2, and 3 and the Decant Sump Tank
System sludge.
Treatment of the Silos 1, 2, and 3 material and sludges removed from the silos
and the Decant Sump Tank System by vitrification to meet disposal facility
WAC.
Off-site shipment of the vitrified contents of Silos 1, 2, and 3 and the Decant
Sump Tank System for disposal at the NTS.
Demolition of Silos 1,2,3 and 4 and decontamination, to the extent practicable,
of the concrete rubble, piping, and other generated construction debris.
Removal of the earthen berms and excavation of the contaminated soils within
the boundary of OU4, to achieve remediation levels. Placement of clean backfill
to original grade following excavation.
Demolition of the remediation and support facilities after use. Decontamination
or recycling of debris before disposition.
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On-property interim storage of excavated contam inated soils and contam inated
debris in a manner consistent with the approved Work Plan for FEMP
Removal Action No. 17- Improved Storage of Soil and Debris (DOE 1996),
pending final disposition of soil and debris in accordance with the RODs of
OUs 5 and 3, respectively.3
Continued access controls and maintenance and monitoring of the stored
waste inventories.
Institutional controls of the OU4 area such as deed and land-use restrictions.
Potential, additional treatment of stored OU4 soil and debris using OUS and
OUS waste treatment systems.
Pumping and treating, as required, of any contaminated perched groundwater
encountered during remedial activities.
Disposal of the OU4 FEMP contaminated debris and soils consistent with the
RODs for OUs 3 and 5, respectively.
Although the selected remedy documented in the OU4 ROD specifies on-site disposal for the
OU4 soil and debris, the final decision) regarding the final disposition of the OU4 debris and
soils was placed in abeyance, until the OUS and OUS RODs were approved by EPA. This
approach allowed DOE to take full advantage of planned waste management and treatment
strategies by these OUs and enabled the integration of disposal decisions for contam inated
soils and debris on a site-wide basis.
This component of the selected remedy was documented in the Operable Unit 4 Record of
Decision (ROD) in 1994. However, for purposes of the ROD Amendment the reference has
been updated to the most recent revision.
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4.2 The OU4 Modified Select ed Remedy
In accordance with the Settlement, the Silo 3 remedy was separated from Silos 1 and 2
remedy to reduce the technical uncertainties and programmatic risks of developing an
effective treatment process forseparatewastestreams with significantdifferences in chemical
and physical properties. The change in remedy to chemical stabilization for Silo 3 is
documented in an ESD approved by the EPA in March 1998 (FEMP 1998a).
The revised FS/PP reevaluated only the treatment component of the selected remedy for Silos
1 and 2 material. Based on evaluation of the treatment alternatives conducted in the revised
FS/PP, the treatment component of the modified selected remedy for Silos 1 and 2 consists
of:
Complete removal of contents of Silos 1 and 2 and the Decant Sump Tank
System sludge from the TTA, followed by treatment using chemical stabilization
to stabilize characteristic metals to meet RCRA toxicity characteristic limits and
attain the NTS WAC.
Gross decontamination, demolition, size reduction, and packaging of concrete
from Silos 1 and 2 structures followed by shipment for off-site disposal at the
NTS or an appropriate PCDF.
Disposal of contaminated soil and debris, excluding concrete from Silos 1 and
2 structures, in accordance with the FEMP OSDF WAC or an appropriate
off-site disposal facility, such as the NTS or a PCDF.
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The following components of the selected remedy for Silos 1 and 2 material have not been
reevaluated and remain as documented in the OU4 ROD:
Off-site shipment and disposal of the chemically stabilized waste at the NTS.
Decontamination and dismantlement (D&D) of all structures and remediation
facilities in accordance with the OU3 ROD.
Removal of the earthen berms and excavation of the contaminated soils within
the OU4 boundary, to achieve remediation levels in the OU5 ROD.
Appropriate treatment and disposal of all secondary wastes at either the NTS
or an appropriate PCDF.
Collection of perched water encountered during remedial activities for
treatment at OU5 water treatment facilities.
Continued access controls and maintenance and monitoring of the stored
waste inventories.
Institutional controls of the OU4 area such as deed and land-use restrictions.
4.2.1 Removal of Silos 1 and 2 Material and Decant Sump Tank Contents
The material in Silos 1 and 2 and the sludge in the Decant Sump Tank System will be
removed and placed in the TTA. Approximately 6,126m3 (8,012yd3) of 11 (e)(2) by-product
material and 671 m3 (878 yd3) of BentoGrout™ clay from Silos 1 and 2 and 3,785 L (1,000
gallons) of sludge from the decant sump will be removed and placed in the TTA pending
treatment by the selected remedy. The TTA will be equipped with a RCS designed to handle
radon emissions generated during removal and storage.
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4.2.2 Chemical Stabilization of Silos 1 and 2 and Decant Sump Tank Contents
The treatment component of the selected remedy consists of a chemical stabilization system
to immobilize the constituents of concern (COCs) in Silos 1 and 2 material and the Decant
Sump Tank System. For purposes of this selected remedy, chemical stabilization is defined
as a non-thermal treatment process that mixes the Silos 1 and 2 material (including
Bentogrout™) with a variety of chemical additive formulations (e.g., lime, pozzolans, gypsum,
Portland cement, or silicates) to accomplish chemical and physical binding of the COCs. The
wastes removed from the TTA will be transferred to a chemical stabilization facility, which will
be constructed on-site. The chemical binding of the COCs in the stabilized wasteform reduces
their leach rate to meet the NTS WAC. In addition, the stabilized wasteform with sealed
containerization reduces radon emanation to meet regulatory standards. Particulate released
as a result of the stabilization process will be treated by an air emissions treatment system
to satisfy all air-emission ARARs and TBCs. Radon emanated during the treatment process
will be collected and routed to the TTA RCS.
4.2.3 Off-site Shipment and Disposal of Treated Material
Approximately 20,836 m3 (27,254 yd3) to 22,855 m3 (29,895 yd3) of stabilized material from
Silos 1 and 2 and the Decant Sump Tank System will be generated during the treatment
process. Containerization of treated waste to meet DOT shipping requirements and the NTS
WAC will result in a disposal volume of approximately 33,144 m3 (43,352 yd3) to 36,431 m3
(47,652 yd3).
The NTS is a DOE owned and operated disposal site located near Las Vegas, Nevada. The
treated waste will either be shipped to the NTS by truck or by intermodal transport
(combination rail and truck).
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The NTS is located approximately 3,219 kilometers (2,000 miles) from the FEMP. The FEMP
has an approved NTS waste shipment and certification program for low-level radioactive
waste that is periodically audited by the NTS. Disposal of treated Silos 1 and 2 material will
be incorporated into this program. Technical oversight of the waste management activities at
the NTS is provided by the State of Nevada.
Off-site shipments will comply with the DOT regulations found in 49 CFR Parts 171-178
pertaining to the transportation of hazardous and radioactive materials. Additionally, the
packaged, treated Silos 1 and 2 material will meet the NTS WAC.
4.2.4 Soils and Debris
The OSDF will be available for disposal of debris from the existing Silos 3 and 4 structures
and associated facilities (superstructures and RTS). Soil and debris from D&D activities
associated with these facilities will be disposed in the OSDF if they meet the OSDF WAC for
disposal. Any soils and debris that do not satisfy the OSDF WAC will be disposed at the NTS
or an appropriate PCDF.
Criteria for disposal of waste materials into the OSDF are documented in the Waste
Acceptance Criteria Attainment Plan for the On-site Disposal Facility (FEMP 1998b). The
current version was issued in June 1998 following approval by the EPA and Ohio EPA. The
OSDF WAC for debris were established in the OU3 ROD (FEMP 1996c). The OSDF WAC
Attainment Plan provides that these criteria can be applied to debris for other OUs, including
OU4, consistent with provisions of the ROD for each OU.
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The OU3 ROD classified debris into ten distinct material categories based upon similar or
inherent properties and configuration. Two categories, Category C - Process-related Metals
and Category J - Product, Residues, and Special Materials, were administratively excluded
from on-site disposal. In evaluating on-site disposal for concrete (Category E), the OU3 ROD
focused primarily on structural concrete. The evaluation did not consider the potential impact
of prolonged contact with residues or other contaminants, such as a concrete storage silo.
The concrete in Silos 1 and 2 has been in contact with contaminated material for over 30
years. Because of the relatively mobile COCs and the high moisture content associated with
the Silos 1 and 2 material, there is a significant potential for migration of contaminants into the
concrete. The depth and extent of the migration of the COCs into the concrete and the ability
and cost of adequately decontaminating the concrete is uncertain.
Therefore, the concrete from Silos 1 and 2 is excluded from disposal in the OSDF. The
concrete from Silos 1 and 2 will undergo gross decontamination followed by demolition, size
reduction, and packaging for off-site disposal. Disposal of concrete from Silos 1 and 2 will be
at the NTS or an appropriate PCDF.
Based on the current operating schedule, the FEMP OSDF may not be available for disposal
of soil and debris generated from D&D of the Silos 1 and 2 remediation facilities. Therefore,
for costing purposes, the revised FS and PP assume that all soil and debris from D&D of the
OU4 remediation facilities will be disposed at the NTS. However, should programmatic
changes occur and the OSDF become available, soil and debris meeting the OSDF WAC
would be disposed in the OSDF in the same manner as discussed above for Silos 3 and 4
and associated facilities.
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4.2.5 Perched Water
The OU5 RI/FS process examined perched groundwater on a site-wide basis. It should be
noted, however, that in accordance with the ACA each OU must address perched
groundwater envisioned to be encountered as a consequence of conducting RAs. An example
of such an incidence is the collection of perched groundwater in deep excavations completed
to remove underground tank systems (Silos 1 and 2 decant sump tank), pits, or foundations.
This collected water will be directed to the FEMP OU5 wastewater treatment systems.
Process wastewaters generated during RAs conducted by all OUs will be directed to the OU5
treatment systems [i.e., the Advanced Wastewater Treatment (AWWT) facility]. OUS has
established pretreatment requirements to ensure that incoming wastewater streams do not
exceed available treatment capabilities.
4.2.6 Cost
The total estimated cost for implementing the selected remedy that includes using a chemical
stabilization technology to treat the Silos 1 and 2 material is approximately three-hundred
($300) million dollars. Table 4.2-1 summarizes the major cost elements of the two alternative
processes that represented the chemical stabilization technology in the revised Silos 1 and
2 FS. The cost estimates were prepared so as to define each cost element based on the
preconceptual design specified in the revised Silos 1 and 2 FS. The cost estimates include
capital costs, operation and maintenance (O&M) costs, waste shipping and disposal costs,
D&D costs, engineering costs, project management costs, and the cost of borrowing money.
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TABLE 4.2-1
COST ESTIMATE FOR THE REVISED REMEDY ($ MILLIONS)
Preferred Alternative
Process Option
Capital Cost
Operation and Maintenance Cost
Waste Shipping and Disposal Cost
Packaging
Transportation
Disposal
D&D Cost
Engineering Cost
Project Management Cost
Cost of Money
Summary Cost (un-escalated)
Chemical Stabilization
CHEM1
55
77
34
14
10
34
24
21
28
297
CHEM2
56
83
33
13
9
36
24
21
28
303
4.2.7 Measures to Control Environmental Impacts
In accordance with DOE regulations for implementing the NEPA (10 CFR Part 1021), DOE
has factored environmental impacts into the decision making process for the OU4 RA. All
practical measures will be employed at the FEMP site to minimize environmental impacts to
human health and the environment during the implementation of the OU4 RA.
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Measures to control environmental impacts will be implemented during RD and the RA to
minimize impacts to natural resources (e.g., wildlife and wildlife habitat, cultural resources,
wetlands, surface water, groundwater). OU4 remedial activities will not impact floodplain
areas at the FEMP. Although the 100 to 500-year floodplain of Paddys Run is located near
the silos and associated support facilities, direct physical impact to the floodplain will not
occur. The implementation of engineering controls will minimize any indirect impact such as
runoff and sediment deposition to the floodplain. In addition, changes in flood elevation will not
occur. The following provides is a discussion of the measures that will be taken to minimize
impacts to human health and the environment on and adjacent to the FEMP site.
Excavation activities and the construction and operation of the various support facilities (e.g.,
waste processing facility and storage facility) will result in the disturbance of approximately 1.0
hectare (2.5 acres) of terrestrial and managed field habitat and the potential for increased
erosion and sediment loads to surface water (i.e., Paddys Run). However, appropriate
engineering controls such as silt fences, vegetative cover, and runoff control systems will be
used to minimize runoff to Paddys Run and its associated aquatic habitat, including the
state-threatened Sloan's crayfish (orconectes sloanii). In addition, appropriate air emission
treatment systems will be used during the operation of the chemical stabilization facility to
minimize the potential for increased emissions to the ambient air and resulting impacts to
on-site and off-site personnel and to surrounding riparian habitat.
Groundwater, surface water, and air monitoring will be performed before, during, and after
remedial activities. If adverse effects are detected in any of these environmental media, work
will be immediately stopped until the effects are controlled and/or the appropriate response
actions are executed.
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The selected remedy for OU4 includes the removal of the contaminated surface soil from the
entire OU4 area and re-grading with clean fill material, as required. Therefore, the primary
residual contaminant would be uranium, below the final remediation level established in the
OU5 ROD (FEMP 1996c) for the subsurface soil. Because the contact of ecological receptors
is limited (near background levels) to surface soil and surface waters, residual ecological risks
associated with the OU4 preferred alternative would be indistinguishable from those risks
posed by background levels in the soil.
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5.0 DESCRIPTION AND EVALUATION OF ALTERNATIVES
5.1 Treatment Alternatives for the Silos 1 and 2 Material
The Detailed Analysis in the revised FS evaluated vitrification and chemical stabilization,
using two of the commercially available process options for each treatment technology. Two
representative process options were chosen for chemical stabilization and vitrification, in
order to provide a balanced analysis of the two technologies against the NCR evaluation
criteria. The preconceptual designs used in the revised FS are based upon data and design
information developed from POP testing and have been developed as viable ways to
remediate the Silos 1 and 2 material. Although two options for each technology were selected
for the analysis, equivalent commercially demonstrated processes that are consistent, with the
selected remedy, will not be precluded from consideration, consistent with the final selected
remedy, during remedial design.
In the detailed analysis, no significant differences were identified to provide a compelling
reason to select a given process option (i.e., CHEM1 vs. CHEM2, or VIT1 vs. VIT2) over
another process option. For this reason, the Comparative Analysis of Alternatives in the
revised FS, which is summarized in this section, compared the vitrification and chemical
stabilization technologies.
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5.2 Evaluation Criteria
Section 4 of the revised FS presents a comparative analysis of alternatives for the treatment
of the Silos 1 and 2 material with respect to the nine evaluation criteria specified by the NCR
to meet the requirements of CERCLA.
The NCR divides the evaluation criteria used in this comparative analysis into three
categories: threshold, primary balancing, and modifying criteria. More detailed definitions of
the evaluation criteria can be found in Section 3.1.2, Overview of the Detailed Analysis of the
revised FS.
Threshold criteria consist of the two criteria that must be satisfied in order to be the selected
alternative:
• Overall protection of human health and the environment; and
• Compliance with ARARs.
These criteria are of greatest importance in the comparative analysis because they reflect the
key statutory mandates of CERCLA, as amended. An alternative must satisfy both of these
threshold criteria before it is eligible to be selected as the final remedy.
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Primary balancing criteria consist of the five criteria under which the relative advantages and
disadvantages of the alternatives are compared to determine the best overall remedy:
• Long-term effectiveness and permanence;
• Reduction of toxicity, mobility, or volume through treatment;
• Short-term effectiveness;
• Implementability; and
• Cost.
The first and second balancing criteria reflect the statutory preference for treatment as a
principal element of the remedy and the bias against off-site land disposal of untreated
material. Together with the third and fourth balancing criteria, they form the basis for
determining the general feasibility of each potential remedy. In addition, the primary balancing
criteria are used to determine whether costs are proportional to the overall protectiveness,
considering both the remediation activity and the time period following restoration of the OU4
area. By this approach, it can be determined whether a potential remedy is cost-effective.
The final two criteria, identified in the NCR as modifying criteria, are state acceptance and
community acceptance. These two criteria are evaluated based on input received from the
state and public through comments on the revised FS and PP. These comments are
addressed in this ROD Amendment in Section 6 and Appendix B, respectively.
Figure 5.2-1 summarizes the comparative analysis of the alternatives.
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5.2-1
ITEM
Overall Protection of Human Health and the
Environment
Compliance with Applicable or Relevant
Appropriate Requirements
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume through
Treatment
Short-Term Effectiveness
Jmplementability
Cost
State Acceptance
Community Acceptance
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The Comparative Analysis summarized in this section, is documented in detail in Section 4
of the revised FS.
5.2.1 Threshold Criteria
5.2.1.1 Overall Protection of Human Health and the Environment
Both vitrification and chemical stabilization provide overall protection of human health and the
environment. Both alternatives limit exposure to contaminants by removing the sources of
contamination, effectively treating the source materials to minimize the mobility of
contaminants, and disposing the treated material in a protective manner off-site at the NTS.
The nature and extent of impacts to biota from implementing the technologies are similar.
Each alternative involves site preparation and construction for a processing facility, removal
of the silos material from the TTA, remediation of the silos material, and transport of the
treated material to the NTS for disposal. Short-term impacts include the temporary loss of
habitats at the FEMP site and possible impacts from accidental spills of construction and
operation materials. Mitigative measures would be employed to minimize these short-term
risks.
5.2.1.2 Compliance with ARARs
The vitrification and chemical stabilization technologies attain the threshold criterion of
compliance with ARARs. A comprehensive list of ARARs is presented in Appendix A of this
ROD Amendment. Key requirements are discussed in Section 3 of the revised FS within the
evaluation of each alternative against this criterion. The following paragraphs summarize
those evaluations.
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Chemical-specific ARARs
Both vitrification and chemical stabilization technologies meet the chemical-specific ARARs
associated with potential releases to groundwater, surface water, and air. The most critical
chemical-specific ARAR is the radon flux limit (specified in the National Emissions Standards
for Hazardous Air Pollutants, 40 CFR Part 61 Subpart Q) of 20 picoCuries per square meter-
second (pCi/m2-s) . This limit applies to interim storage or final disposal of Silos 1 and 2
material. Both alternatives meet this ARAR during interim storage and after disposal. Both
alternatives meet requirements for control of radon, particulate, and other air emissions from
remedial activities by incorporating air emission treatment. The impact of radon emissions
during remediation is evaluated as part of the short-term effectiveness criterion.
Location-specific ARARs
Vitrification and chemical stabilization technologies meet the location-specific ARARs as they
relate to floodplains, wetlands, and endangered species and their habitats. Compliance with
these alternatives is met through proper planning, siting, design, and operational procedures.
Action-specific ARARs
Vitrificationand chemical stabilization technologies meetthe action-specific ARARs identified
for these alternatives. Appropriate engineering controls are implemented for each alternative
to comply with Ohio Water Quality Standards and Air Quality Standards. Hazardous material
transportation requirements are complied with by following the regulations under 40 CFR
Parts 262 and 263, and the appropriate DOT shipping standards under 49 CFR Subchapter
C Hazardous Materials Regulations.
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5.2.2 Primary Balancing Criteria
5.2.2.1 Long-term Effectiveness and Permanence
Both vitrification and chemical stabilization technologies ensure long-term protectiveness of
human health and the environment through treatment. Toxicity Characteristic Leaching
Procedure (TCLP) analysis indicates that the vitrification and chemical stabilization process
options evaluated during POP testing produced wasteforms that consistently met the NTS
WAC and were durable based on leach rate data. The TCLP test is used to simulate the
leaching effects of acidic groundwater infiltrating the disposal cell and contacting disposed
waste. This test measures the ability of the stabilized waste particles to resist leaching even
if the original wasteform (e.g. monolith) has been compromised.
Both alternatives include treatment that permanently reduces the leachability of COCs. Off-site
disposal at the NTS provides additional protection by eliminating access to the treated
materials and preventing migration of constituents from the materials. Location of the NTS
disposal facility in a sparsely populated, arid environment reduces the potential for leachate
generation, contaminant migration, and prevents direct contact with contaminants. Because
the NTS is owned and maintained by DOE and used for the disposal of low-level wastes from
other DOE sites, the uncertainties associated with institutional controls are minimal. As the
result of a low average annual precipitation and depth to groundwater, impacts to human
health and the environment from possible engineering and institutional controls failure are
minimal.
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There are no long-term environmental impacts at the FEMP site pertaining to the removal and
treatment of Silos 1 and 2 material. The projected FEMP site residual risk to viable receptors
is less than the NCP criterion of 10'6 ILCR, and non-carcinogenic effects are expected to be
below 1.0 (HI) specified by the NCP for both alternatives. Long-term environmental impacts
at the NTS involve some permanent disturbance of soils (i.e., acquisition of borrow material)
associated with disposal activities. Significant long-term impacts are not expected to water
quality or hydrology, air quality, biotic resources, socioeconomics or land use, or cultural
resources. Wetland orfloodplain areas have not been delineated at the NTS.
Long-term effects of waste disposal and necessary engineering and administrative controls
that need to be incorporated into the design of the disposal cell will be determined based on
results of a performance assessment (PA) conducted by the NTS. The NTS has previously
conducted a PA on the Area 5 Radioactive Waste Management Site (Area #5). The PA
resulted in the establishment of volumetric radionuclide concentration limits for acceptance
for disposal in Area #5.
An informal review of the Area #5 PA indicates that chemical stabilized Silos 1 and 2 waste
would meet the radionuclide concentration limits. Upon finalization of this ROD Amendment,
a formal review of the treated Silos 1 and 2 waste against the Area #5 concentration limits will
be conducted to determine if Area #5 at the NTS remains suitable for disposal of treated Silos
1 and 2 waste. If treated Silos 1 and 2 waste fail to meet the radionuclide concentration limits
for Area #5, a PA specific to the characteristics associated with treated Silos 1 and 2 waste
will be conducted by the NTS in accordance with DOE Order 435.1.
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The three discriminating criteria for comparison of vitrification and chemical stabilization were
determined to be reduction of toxicity, mobility, or volume through treatment; short-term
effectiveness; implementability; and cost. Figure 5.2-2 presents a summary of the
comparison of the vitrification and chemical stabilization technologies against these criteria,
as well as each criterion's subcriteria.
5.2.2.2 Reduction of Toxicity. Mobility, or Volume through Treatment
Overall, this criterion favors vitrification due to the reduction in treated material volume.
Figure 5.2-3 presents a comparison of the expected primary and secondary waste disposal
volumes associated with the vitrification and chemical stabilization alternatives. This figure
illustrates that, while vitrification results in a reduction in volume of the Silos 1 and 2 material,
addition of the chemical fixatives and additives in the chemical stabilization process results
in an increase in volume of the treated material compared to the volume of untreated material.
Both of the technologies provide treatment that substantially reduces the mobility of COCs in
the Silos 1 and 2 material through treatment. Toxicity Characteristic Leaching Procedure
(TCLP) tests conducted on the treated surrogate material during POP testing indicate that
either alternative can reduce the leachate concentrations of hazardous metals to below RCRA
toxicity characteristic limits. Vitrification chemically binds the contaminants in a glass-like
matrix that significantly reduces contaminant mobility. Chemical stabilization reduces the
mobility of contaminants by converting the contaminants into a less soluble form and binding
them into a stabilized matrix.
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5.2-2
Of
i
OF TOXICfTY, MOBIUTY, OR
THROUGH TREATMEMT
Treated Waste Volume
Secondary Waste Generation
Reduction in Mobility of COCs
Radon Attenuation by Treated Wast* Form
Worker Risk
Transportation Risk
Off-site/Enviranmental Impact
Time to Achieve Protection
fMPLBWENTASIUTY
Sftateup
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Operabflity
Ease of Acceleration
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5-10
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en
FIGURE 5.2-3
TOTAL SOLID WASTE VOLUME SUMMARY
o
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B PRIMARY
WASTE
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The vitrified Silos 1 and 2 material reduces radon emanation more effectively than does the
chemically stabilized material. However, the combination of radon mitigation provided by the
chemically stabilized material plus the engineered barriers and packaging associated with
the disposal of treated materials, effectively controls radon emanation. Both alternatives
provide effective control of radon emanation from the treated Silos 1 and 2 material. The
impact of radon emissions during remediation is evaluated as part of the short-term
effectiveness criterion.
5.2.2.3 Short-term Effectiveness
The NCR identifies the components of short-term effectiveness as short-term risks to the
community during implementation of the alternative; potential impacts to workers during RA;
potential environmental impacts during implementation; and time until protection is achieved.
Although each alternative is favorable in individual aspects of short-term effectiveness, from
an overall perspective, this criterion favors chemical stabilization due to lower on-site worker
risk and higher schedule certainty. The basis for determination of risks is detailed in
Appendices B and E of the revised FS.
Worker Risk
Vitrification presents an increased non-radiological risk to the worker during on-site
operations due to the greater number of person-hours estimated to complete remediation and
increased physical hazards in the work place. An occupational hazard analysis was performed
on the proposed design for each alternative (Appendix B of the revised FS). The hazard
analysis evaluated the potential physical and chemical hazards to the workers involved with
the on-site O&M activities. Table 5.2-1 presents a summary of the discriminating hazards
posed to workers as determined by the analyses of the alternatives.
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TABLES 5.2-1
SUMMARY OF KEY HAZARDS TO ON-SITE WORKERS
Physical hazards due to vehicle and container
movement
Falls
Exposure to hazardous chemicals and
toxicants
Electrical shock
Human hazards
High or changing pressure
Thermal hazards
Spills/loss of containment
Greater hazard for chemical stabilization due
to greater number of containers
Greater hazard for vitrification - more elevated
equipment
Greater hazard for vitrification - toxic
constituents (SOX, NOX, lead - storage of
caustic for scrubber, and gases)
Greater hazard for vitrification - higher power
requirements, more complex electrical system
Greater hazard for vitrification - greater
number of work hours
Greater hazard for vitrification - remote
potential for over-pressurization of the melter;
potential releases from Emergency Off-gas
System
Greater hazard for vitrification - high
temperature in melter; handling of molten
glass; high temperature off-gas
Greater hazard for vitrification - molten glass,
toxic off-gas constituents, higher radon
concentrations and caustic storage result in
greater consequences for spills, leaks, etc.
The vitrification process liberates essentially all of the radon from the Silos 1 and 2 material during
the treatment process. Chemical stabilization liberates less radon during the treatment process, but
continues to generate radon during subsequent product handling operations. In both cases,
sufficient radon control is provided to mitigate radon releases and attain environmental and worker
protection limits. The calculated radon concentrations due to projected routine emissions for either
alternative show no measurable impact to FEMP fenceline radon concentrations.
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Both vitrification and chemical stabilization are able to meet the radon flux limit of 20 pCi/m2 s during
interim storage at the FEMP and after disposal. Sufficient attenuation of radon is provided by the
vitrified material without reliance on the packaging or disposal configuration. Although the chemical
stabilization process provides attenuation of radon, it is reliant on packaging to meet the radon flux
limit.
Transportation Risk
Appendix E of the revised FS evaluates the short-term risks associated with the transportation, both
by direct truck and intermodal shipments, of the treated silos material to the NTS. The
implementation of either transportation option presents a minimal risk to the public, within the
CERCLA target risk range of 1x10"4 to 1x10~6. However, due to the greater number of shipments
required to ship the larger volume of treated material, the transportation risk is incrementally higher
for chemical stabilization.
For both technologies, transportation to the NTS complies with DOT regulations and DOE
guidelines. The transportation of the Silos 1 and 2 material to the NTS by either truck or intermodal
shipments is protective of human health and the environment. In addition, the anticipated shipping
rate of 7 to 20 shipments per week does not represent a significant impact on total highway traffic.
Off-site Environmental Impact
Short-term impacts associated with both technologies include temporary disruption of several acres
of land at the FEMP site for construction of the treatment facility and material handling. There is a
potential for increased fugitive dust during construction activities; however, appropriate controls
minimize the potential short-term impacts.
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Time to Achieve Protection
Due to a shorter design-construction start-up period, and a more feasible schedule acceleration,
chemical stabilization is preferred with respect to time to achieve protection. Figure 5.2-4 presents
a comparative summary of each alternative's schedule.
The time period between the approval of the ROD Amendment and the initiation of treatment
operations (i.e., design, construction, construction acceptance testing, preoperations, and start-up)
for the Silos 1 and 2 remediation is estimated to be 62 months for vitrification, compared to 54
months for chemical stabilization. The difference of eight months between the two schedules is
primarily attributed to the time required, based upon lessons learned during start-up of DOE
vitrification facilities, to perform Proof of Process testing during start-up of the vitrification facility. In
addition, the technical risk evaluation results in a calculated schedule uncertainty of 14-16 months
for vitrification compared to 8-10 months for chemical stabilization.
While vitrification requires full-time (24 hr/day, 7 days/wk) operation to complete treatment within
the three-year period evaluated in the revised FS, chemical stabilization can complete treatment
within three years with less than full-time operation (e.g., 16 hrs/day, 5 days/week and 24 hrs/day,
5 days/week). Less than full-time operation would leave 'excess' operating time (shifts per day or
days per week) available to recover from unplanned downtime. This excess operating time results
in higher confidence in the ability of the chemical stabilization alternative to complete treatment
within a given timeframe. Figure 5.2-5 presents the total operating hours required to treat the Silos
1 and 2 material in three years at the scale proposed by the POP vendors.
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FIGURE 5.2-4
TIME TO ACHIEVE PROTECTION
SCHEDULE COMPARISON
Oi
CHEM2
CHEM1
VTT2
VIT1
0
50 100
MONTHS
B DESIGN
63 CONSTHUCT1ON/CAT
B PREOiP / STARTUP
m OFJJKA TJQNS
B SCHHDULRIUNCfltTABiilTY
ESBUIWWN/JMD
150
m
•p
o
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FIGURE 5.2-5
SUMMARY OF TOTAL REQUIRED OPERATING HOURS
CHCM&
5.2.2.4 Implementability
Overall, this criterion favors chemical stabilization due to a greater degree of commercial
demonstration of the treatment technology, less complexity of integrated systems, and greater
confidence in its ability to be successfully implemented.
Figure 5.2-6 summarizes the implementability analysis.
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Both vitrification and chemical stabilization are difficult to implement because of the nature of
the Silos 1 and 2 material, which requires remote operations. Although operational risks for
both can be controlled, chemical stabilization is preferred because there is more
demonstrated commercial experience with this technology. In addition, chemical stabilization
is less complex than vitrification and therefore more certain in its ability to be successfully
implemented; and, it offers greater opportunity for schedule acceleration and recovery in the
event of unplanned downtime.
Both vitrification and chem ical stabilization have encountered difficulties in treating radioactive
wastes in the DOE-complex. However, there is significantly more demonstrated experience
in the commercial sector on both radioactive, hazardous and mixed wastes with the chemical
stabilization technology than with the vitrification technology. In addition, based on evaluation
of existing facilities, the production rate required for the vitrification process to treat Silos 1
and 2 material within an acceptable timeframe is at the upper limit of the current capacities
of existing vitrification facilities treating radioactive material. The production rate required for
the chemical stabilization process is well within the limits of the capacity demonstrated by
existing chemical stabilization facilities.
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ITEM
it
v
U.
£
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To treat Silos 1 and 2 material within a three-year time period (assumed as a common basis
for the comparative analysis), the vitrification process would have to produce 15 tons of
vitrified material per day. Within the experience of the vitrification technology, there are no
facilities in the DOE-complex and only two facilities (vitrification-other facilities) in the
commercial sector operating at the required capacity. This limited experience at the required
capacity results in increased uncertainty as to whether the current technology has the
capability to treat Silos 1 and 2 material at the required capacity. In comparison, to treat Silos
1 and 2 material within a three-year time period, the chemical stabilization process would
have to process 12 cubic yards (yd3) of Silos 1 and 2 material per day. There have been a
number of chemical stabilization facilities in both the DOE-complex and the commercial sector
that have operated at the required capacity. Because there is a greater degree of commercial
demonstration of the chemical stabilization process at the required capacity, there is less
uncertainty in its ability to treat Silos 1 and 2 at the required capacity.
Vitrification has more unit operations associated with it than chemical stabilization and is
therefore considered to be more complex to operate and maintain than chemical stabilization.
The integrated operation of complex systems associated with the vitrification process
increases the likelihood of process upsets and resulting downtime. In addition, the complexity
of process control associated with vitrification complicates melter operation. Included in the
complexity of the process control are critical parameters that are not readily measured, such
as viscosity, electrical conductivity, liquidus temperature, and sulfate formation. Furthermore,
as stated under the discussion of short-term effectiveness, the hazards inherent to the
vitrification process incrementally increase the risk to the workers during maintenance
activities, and make recovery from upsets more difficult.
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The two vitrification processes propose to operate 24 hr/day for 7 days/wkfor three years. The
two chemical stabilization processes propose to operate 16 to 24 hr/day for 5 days/wk for
three years. Based on the current designs, the chemical stabilization process has a better
opportunity to improve schedule and accelerate remediation. In addition, based on current
designs, the chemical stabilization has a better opportunity to recover from process upsets
or other downtime.
Based on the above evaluation, chemical stabilization is the preferred alternative to
implement. Chemical stabilization has a greater degree of commercial demonstration at the
required capacity, is less complex to operate, and provides more opportunity to recover from
process upsets and other downtime, as well as more opportunity to improve schedule.
5.2.2.5 Cost
The cost evaluation is based on estimates that were developed on information from the four
preconceptual designs presented in Appendix G of the revised FS and the
technology-specific POP testing information presented in Appendix H of the revised FS using
a variety of cost-estimating methods.
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The cost estimates were developed for (1) capital costs; (2) O&M costs; (3) waste shipping
and disposal costs; (4) D&D costs; (5) engineering costs; (6) project management costs; and
(7) cost of borrowing money. The cost estimates are prepared so as to estimate and evaluate
each cost element identified in the preconceptual design. Therefore, the accuracy of the
estimates is a function of the preconceptual designs. The accuracy of all four estimates is
considered +50/-30%, which is consistent with CERCLA guidance (EPA 1988). Given the fact
that potential contractors will be given the opportunity to propose their unique designs based
on their commercial experience, the actual design may change significantly. The subject
accuracy establishes a range that is likely to capture that which is ultimately bid in response
to a request for proposal to remediate the Silos 1 and 2 material and baselined following this
ROD Amendment. All estimates were developed in fiscal year 1999 (FY99) dollars so that the
alternatives with costs incurred over differing time periods can be evaluated on an equivalent
basis.
Table 5.2-2 and Figure 5.2-7 summarize the major cost elements for the four processes.
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TABLE 5.2-2
FEASIBILITY STUDY SUMMARY COST DATA (ALL ALTERNATIVES)
Alternative
Process Option
Capital Cost
O&M Cost
Waste Disposal Cost
D&D Cost
Engineering Cost
Project Management
Cost
Cost of Money
Summary cost
(un-escalated)
Vitrification
VIT1
$69
$134
$25
$35
$25
$22
$46
$356
VIT2
$67
$133
$20
$38
$25
$22
$37
$342
Chemical Stabilization
CHEM1
$55
$77
$58
$34
$24
$21
$28
$297
CHEM2
$56
$83
$55
$36
$24
$21
$28
$303
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All four process options are cost effective; the costs appear proportional to the overall
protectiveness provided by the alternatives, both during and following the remediation period.
The cost differential between the vitrification and chemical stabilization alternatives is
approximately 16%, with the cost of chemical stabilization being lower. The following
discussion identifies the differences between the four alternatives for the key cost elements.
Capital Cost
Vitrification has a higher estimated capital cost than chemical stabilization due to the
complexity of the process equipment. The need for sizeable interim storage areas for
chemical stabilization partially off-sets the higher equipment costs of the vitrification
alternative.
Operations and Maintenance Cost
Vitrification has a higher estimated O&M cost than chemical stabilization for the following
reasons:
Vitrification operations are on a 24 hr/day, 7 days/wk schedule;
Vitrification requires an additional 8-month proof of process testing (full-scale
surrogate operations);
Vitrification has more expensive spare parts (specialized). Melter refractory life
is limited and may need to be replaced during the 3 years of operation; and
Vitrification uses more costly consumables (chemicals, supplies) and uses
(electricity, natural gas).
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Waste Shipping and Disposal Cost
Chemical stabilization has higher estimated packaging, transportation, and disposal costs
than vitrification. The lowerwaste loading (chemical stabilization) produces a greater volume
of treated material resulting in an increased number of disposal containers, shipments, and
disposal volume.
D&D Cost
The D&D costs are roughly equivalent for both alternatives. Vitrification has a higher D&D cost
due to the more complicated plant layout (multiple floors, equipment). However, the difference
is offset by the D&D cost of chemical stabilization having more building debris to handle due
to the larger interim storage facility.
Engineering Cost
Vitrification has a slightly higher estimated engineering cost than chemical stabilization due
to the complexity of the process design.
Project Management Cost
Vitrification has higher estimated project management costs than chemical stabilization due
to the vitrification schedule being longer, with project management being level-of-effort based
on the schedule duration.
Cost of Money
Based on the contracting strategy planned for the remediation of the Silos 1 and 2 material,
the contractor must borrow money to finance the design and construction effort, well in
advance of being reimbursed in accordance with a predetermined pay item schedule. Since
vitrification has a higher upfront capital cost investment, vitrification has a higher cost of
borrowing money than chemical stabilization.
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6.0 SUPPORT AGENCY COMMENTS
6.1 State Acceptance
The State of Ohio concurs with the selected remedy and the ARARs put forth in this ROD
Amendment for the remediation of the OU4 Silos 1 and 2 material. Tables 6.1-1 presents the
OEPA comments issued during the formal public comment period and DOE responses to the
comments.
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TABLE 6.1-1
OEPA COMMENTS ISSUED DURING FORMAL PUBLIC COMMENT PERIOD
Response
General
The OU4 Silos 1 and 2 Proposed Plan is the culmination of
efforts by U.S. DOE, Ohio EPA, and U.S. EPA to understand
and develop a plan for treating and disposing of the K-65 silos
and their contents. Ohio EPA believes the alternative selected
in the Proposed Plan is protective of human health and the
environment. Ohio EPA supports the preferred alternative of
chemical stabilization for the K-65 wastes. The preferred
alternative is more implementable and will result in
substantially less secondary wastes. Of significant importance
to Ohio EPA during considering the alternatives is the release
of radon gas during treatment. Ohio EPA believes the preferred
alternative provides a substantial reduction in air pollution
releases and increased reliability of emissions controls over
the other alternative considered.
The DOE acknowledges OEPA's support of
chemical stabilization as the preferred
technology for the treatment of the Silos 1 and 2
material.
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TABLE 6.1-1 (CONTINUED)
DOE should commit to including and/or developing real-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
Science & Technology 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.
As part of the remedial design activities for the
Silos 1 and 2 remedial actions, a preliminary and
final safety assessment will be conducted by
DOE to establish the safety basis and design
objectives for the construction and the operation
of all remedial facilities. The safety basis
includes those measures (i.e., procedures,
training, monitoring equipment) necessary to
ensure that facilities will be constructed and
operated in a safe manner and in compliance with
ARARs.
6-3
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TABLE 6.1-1 (continued)
FEMP-OU4-RODA FINAL
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Comment
Response
2
(cont.)
It is the DOE policy in its conduct of operations to require facility
operations procedures to be developed and adhered to during all
remedial actions. Training of personnel to those procedures will
be paramount to ensure safe conduct of all operations. DOE and
Fluor Fernald, Inc. have developed and maintain the necessary
emergency plans and procedures to adequately define the
emergency management program, provide guidance for all
emergency responders, proper notification of the public, ensure
adequate monitoring and performance for critical systems, and to
meet all regulatory requirements.
Developing a plan for the use of "real-time" monitoring is an
integral part of the remedial design which will be developed in
partnership with EPA and OEPA. Results of "real-time" radon
monitoring are currently available through the Integrated
Environmental Monitoring Program and the Fernald Website
(www.fernald.aovV As the project develops, the Silos 1 and 2
Project will define occupational monitoring requirements,
including "real-time" monitoring. These results will also be made
available to the affected workforce.
DOE expects to work closely with the EPA and OEPA to
establish monitoring programs responsive to the environmental,
public health, and occupational concerns regarding remediation
of Silos 1 and 2 material.
6-4
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TABLE 6.1-1 (continued)
FEMP-OU4-RODA FINAL
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General
DOE should attempt to incorporate pollution
prevention activities whenever possible during
the design and operation of the Silos 1 and 2
remedial action systems, including using this
as a criterion in selection of a contractor. All
available methods to reduce or eliminate
discharges and releases should be considered
during the design of the system. The
consideration of reducing decontamination and
demolition volumes and cost should be part of
the contractor selection and design activities.
It is DOE policy, in accordance with Executive Order 12856,
whenever feasible to apply pollution prevention and waste
minimization principles into the design and operation of all its
facilities. Accordingly, the technical specification for the Request
for Proposal to be issued for this project contains provisions for
the future contractor to incorporate pollution prevention and
waste minimization features during the design effort. One of the
evaluation criteria to be used in selecting the future contractor is
the degree to which his design exhibits minimization of primary
and secondary wastestreams. As part of the CERCLA remedial
design process, EPA and OEPA will have the opportunity to
review and approve the Contractor's design.
General
DOE must ensure the public that their
involvement will not be diminished during
Remedial Design and Remedial Action
(RD/RA). DOE should commit within the
Record of Decision for OU4 Silos 1 and 2 to
maintaining the exceptional on-going public
involvement program during RD/RA.
The public has played a fundamental role in shaping the path
forward for the Silos Project. DOE is committed to sustaining
public involvement through completion of the Silos 1 and 2
RD/RA activities. The Record of Decision Amendment will
reaffirm DOE's commitment to public involvement.
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7.0 STATUTORY DETERMINATIONS
The NCR [40 CFR Section 300.430(f)(5)(ii)] specifies that a ROD shall describe the
following statutory requirements as they relate to the scope and objectives of the action:
i
How the selected remedy is protective of human health and the environment;
! How the remedy will comply with all ARARs established under federal and state
environmental laws (or justify a waiver);
! How the remedy is cost-effective (i.e., provides overall effectiveness proportional
to its costs);
! How the remedy will use permanent solutions and alternative technologies or
recovery technologies to the maximum extent practicable; and
! How the remedy will satisfy the statutory preference for remedies that employ
treatment that permanently and significantly reduces the toxicity, mobility, or
volume of the hazardous substances, pollutants, or contaminants as a principle
element, or if it is not satisfied, explain why a remedy providing reductions in
toxicity, mobility, or volume was not selected.
In addition, CERCLA requires five year reviews to determine if adequate protection of human
health and the environment is being maintained where RAs result in hazardous substances
remaining on-site above health-based levels. A discussion is provided below on how the
selected response actions for Silos 1 and 2 satisfy these statutory requirements.
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7.1 Protection of Human Health and the Environment
The selected remedy achieves the requirement of being protective of human health and the
environment by: (1) removing the sources of contamination, (2) treating and stabilizing the
materials giving rise to the principle threats from Silos 1 and 2, (3) disposing of treated
materials at an off-site location that provides the appropriate level of protectiveness; and, (4)
remediating contaminated soils and debris to protective levels. The contents of Silos 1 and
2 and the Decant Sump Tank System will be removed and treated through a chemical
stabilization process and disposed at the NTS. Chemical stabilization will immobilize these
materials and inhibit leaching of contaminants to the environment when they are disposed.
Concrete from Silos 1 and 2 structures will undergo gross decontamination, demolition, size
reduction, and packaging before being shipped off-site for disposal at the NTS or an
appropriate PCDF. Silos 3 and 4 concrete structures and other facilities (i.e., treatment
facilities, RTS, superstructures) will be removed from OU4 and disposed of in a manner
consistent with the approved OU3 ROD (FEMP 1996c). Contaminated soil will also be
removed and disposed in a manner consistent with the approved OU5 ROD (FEMP 1996d).
Baseline cancer risks from current conditions exceed the 10"4 to 10"6 acceptable risk range.
Under the future land use scenario of continued federal ownership, the residual cancer risk
from Silos 1 and 2 will be reduced to less than 1 x 10"6. There are no short-term threats
associated with the selected remedy that cannot be readily controlled. In addition, no adverse
cross-media impacts are expected from the remedy.
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7.2 Compliance with Applicable or Relevant and Appropriate Requirements
In accordance with Part 121 of CERCLA, the selected remedy will achieve a standard or level
of control consistent with all Federal and State of Ohio ARARs and TBCs. The selected
remedy will also be performed in accordance with all pertinent DOE Orders. Appendix A
provides a listing of the chemical-, action-, and location-specific ARARs and TBCs that are
invoked by this remedy.
Removal, treatment by chemical stabilization, and shipment for off-site disposal of Silos 1 and
2 material will be conducted in accordance with ARARs identified in this ROD Amendment.
Concrete debris from Silos 1 and 2 will be disposed off-site at the NTS or an appropriate
PCDF. Disposition of rubble and debris from Silos 3 and 4 and associated facilities (i.e.,
superstructures, treatment facilities, and the RTS) will be performed in accordance with the
OSDF WAC, and will be conducted in accordance with the ARARs identified in the OU3 ROD.
Disposition of soils from Silos 1 and 2 will be conducted in accordance with ARARs
established in the OU5 ROD. Any interim storage of rubble and debris or soils, prior to final
disposition under the RODs for OU3 and OU5, respectively, will be in accordance with ARARs
identified in this ROD Amendment, pertinent DOE Orders, and applicable site procedures.
Silos 1 and 2 material destined for remediation is by-product material as defined under
Section 11 (e)(2) of the Atomic Energy Act of 1954, and as such, is excluded from RCRA
regulation [40 CFR Section 261.4(a)(4)]. By-product material, as defined by the AEA, includes
tailings or wastes produced by the extraction or concentration of uranium and thorium from any
ore processed primarily for its source material content (42 U.S.C. 2014).
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Since the Silos 1 and 2 material is excluded from regulation as solid or hazardous waste, the
requirements under RCRA are not applicable to Silos 1 and 2 RAs. However, based on
analytical data, the material is sufficiently similar to RCRA hazardous waste because Silos
1 and 2 material exceeds toxicity characteristic levels for various toxicity characteristic metals
under RCRA. Therefore, certain substantive requirements of RCRA are relevant and
appropriate for management of the Silos 1 and 2 material, and are included in the table of
ARARs in Appendix A. The selected remedy will meet all relevant appropriate RCRA
requirements.
7.3 Cost Effectiveness
The selected remedial alternative has been determined to be protective of human health and
the environment, and to be cost effective. The estimated project cost for this remedy is
approximately three-hundred (300) million dollars.
7.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum Extent
Practicable
The EPA and the State of Ohio have determined that the selected remedy for Silos 1 and 2
represents the maximum extent to which permanent solutions and treatment technologies can
be used in a cost-effective manner. Of the alternatives that are protective of human health and
the environment and comply with ARARs, the EPA and the State of Ohio have determined that
this selected remedy provides the best balance of tradeoffs among the alternatives in terms
of long-term effectiveness and permanence, reduction in toxicity, mobility, or volume through
treatment, short-term effectiveness, implementability, and cost. The selected remedy also
meets the statutory preference for treatment as a principle element.
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Chemical stabilization and off-site disposal will provide permanent treatment for the Silos 1
and 2 material. By chemically binding the contaminants into a chemical stabilization matrix,
the mobility of the contaminants significantly reduces the leachability of metal contaminants
of concern to levels that are below RCRA regulatory thresholds. As a result, the selected
remedy would meet the CERCLA criteria for permanent solutions that reduce the toxicity,
mobility, or volume through treatment.
7.5 Preference for Treatment as a Principal Element
The statutory preference for remedies that employ treatment as a principal element is
satisfied. By treating the contents of Silos 1 and 2 in a chemical stabilization process, and
providing for management, including treatment and disposal, of contaminated debris and soils
consistent with the OU3 and OU5 RODs, the selected remedy mitigates the principal threats
posed by OU4 through the use of treatment technologies. The treatment provided by chemical
stabilization accomplishes a significant, permanent reduction in mobility of the COCs.
7.6 Irreversible and Irretrievable Commitment of Resources
Implementing the selected remedy will result in permanent commitment of on-property land
and associated natural resource services for material disposal at the FEMP site and off-site
at the NTS.
Soil at the FEMP site and the NTS will be disturbed by construction and excavation activities.
Many impacts will be temporary, pending completion of remedial activities and restoration
programs. The implementation of the selected remedy will temporarily disturb approximately
13,747 m3 (17,981 yd3) to 13,958 m3 (18,257 yd3) of soil at the FEMP site. All areas disturbed
at the FEMP site will be regraded and revegetated.
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Soil at the NTS will be permanently disturbed for the disposal of chemical stabilized Silos 1
and 2 material. However, disturbance of soil will be in an area previously designated by the
NTS for low-level radioactive waste disposal (Area 5 Radioactive Waste Management Site)
as evaluated in the NTS-EIS.
The area of the FEMP designated for Silos 1 and 2 remedial activities has already been
industrialized, and does not provide a critical habitat for threatened or endangered species.
Therefore, the short-term disturbance of land under the selected remedy is not anticipated to
impact biotic resources. The desert tortoise is the only threatened or endangered species at
the NTS. DOE-NV has evaluated the effects of the programs of the NTS-EIS on the desert
tortoise. Because disposal of chemical stabilized Silos 1 and 2 material will be in an area
previously designated for low-level radioactive waste disposal (Area #5), disturbance of land
at the NTS is not expected to impact biotic resources.
The selected remedy is not anticipated to adversely impact wetlands and associated natural
resource services. Long-term direct impacts to the floodplain resulting in changes of flood
elevations will not occur. Engineering controls would be implemented to minimize or eliminate
any indirect impacts. The NTS does not have any designated wetland areas or floodplain
areas.
The implementation of this alternative is expected to have minor impacts on the surface water
hydrology at the NTS. The NTS lies in an arid region with little rainfall; continuously flowing
streams are nonexistent at the NTS.
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Through erosion control and dust suppression, transport to adjacent surface water bodies of
contaminants disturbed during remediation at the FEMP is not expected. Surface water near
the site would be monitored during remediation in accordance with the existing National
Pollution Discharge Elimination System permit to assess potential impacts to the water from
remediation. Because material would always be contained, remediation activities would not
be expected to increase the release of contaminants to the groundwater.
It is assumed that resources for remedial work will be purchased within the consolidated
metropolitan statistical area (CMSA), resulting in a minor beneficial impact to the CMSA in
the short-term. Furthermore, the removal of the Silos 1 and 2 material reduces impacts to
population and economic growth in the area.
Since 1951, primary land use on the NTS has been nuclear weapons testing and low-level
radioactive waste disposal for on-site and off-site DOE-affiliated generators. The NTS is
surrounded on the east, north, and west sides by public access exclusion zones (e.g. Nellis
Air Force Base Bombing and Gunnery Range). This area provides a buffer zone between the
test areas and public lands of 24 to 105 kilometers (15 to 65 miles). The off-site areas
adjacent to the NTS are predominantly rural; hence, aesthetic impacts are not expected to
change. Therefore, disposal activities associated with the selected remedy do not impact
socioeconomics or land use at the NTS.
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8.0 COMMUNITY PARTICIPATION
8.1 Community Acceptance
Community acceptance is one of the criteria that DOE and EPA are committed to considering
during the decision-making process for selecting a remedy for the Silos 1 and 2 material. The
NCR specifies that the public must be provided the opportunity for input in selection of RAs.
Specifically, the NCR [40 CFR Section 300.435(c)(2)(ii)] specifies that proposed
amendments to the ROD and information supporting the decision be made available for public
comment. This interaction with the community is critical to the CERCLA process and to
making sound environmental decisions.
To augment public involvement throughout the decision-making process, the DOE-FEMP
chartered the Critical Analysis Team (CAT). The CAT, which is comprised of three
independent technical and process oriented leaders, is focused on evaluating the technical
basis and objectivity of the development and evaluation of the remedial alternatives. Through
their development, the revised Silos 1 and 2 FS, the PP, and this ROD Amendment, have
considered input of the CAT. The CAT has provided independent feedback to the public on
its technical evaluation of the documentation supporting this ROD Amendment (FS, PP, POP
test reports).
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During the decision-making process documented in this ROD Amendment, DOE has actively
informed and solicited feedback from stakeholders. The DOE has sponsored several
community briefings and workshops both locally and at the NTS to share the data supporting
the evaluation of alternatives in the revised FS and PP. In addition, the DOE has sponsored
formal public hearings regarding the PP both locally and at the NTS in an effort to provide the
public a forum to provide verbal comments on the preferred alternative identified in the PP.
Table 8.1-1 presents a summary of these public involvement opportunities.
TABLE 8.1-1
SUMMARY OF PUBLIC INVOLVEMENT OPPORTUNITIES
Meeting Topic
Preliminary Screening of Alternatives
Presentation of Proof of Principle testing data
Summary of Detailed Analysis of Silos 1 and 2 FS
Fernald Citizens Advisory Board (FCAB)
FS overview with FCAB
Summary of Comparative Analysis of Silos 1 and 2
FS
Nevada Test Site Citizens Advisory Board
Summary of Silos 1 and 2 FS Comparative
Analysis
FCAB Proposed Plan Summary
Formal Public Hearing on Silos 1 and 2 PP
Formal Public Hearing on Silos 1 and 2 PP
Location/Date
FEMP/December 1997
FEMP/July13, 1999
FEMP/October12, 1999
FEMP/October14, 1999
FEMP/November4and6, 1999
FEMP/November17, 1999
Las Vegas, Nevada/December 1 ,
1999
FEMP/December 6, 1999
FEMP/April 25, 2000
Las Vegas, Nevada/May 3, 2000
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The DOE and EPA have considered all public comments on the preferred alternative
identified in the PP in preparing this ROD Amendment. All written and verbal comments
received during the public comment period have been summarized and responded to in the
Responsiveness Summary section of this ROD Amendment (Appendix B).
8.2 Community Participation
The community is encouraged to read and provide comments on the ROD Amendment for
Silos 1 and 2. This ROD Amendment puts forth a selected RA alternative for the Silos 1 and
2 material based upon the content and conclusions of the FS and PP, as well as input
provided by the EPA, OEPA, and stakeholders.
The revised FS for Silos 1 and 2, PP, ROD Amendment, and other supporting documents are
available from the Administrative Record, located at the PEIC and at the EPA offices in
Chicago, Illinois. Addresses for these Administrative Record locations are provided below.
The dates for the comment period have been announced in the local media and are posted
at the Administrative Record locations; addresses and hours are as follows:
Public Environmental Information Center U.S. EPA Region V
10995 Hamilton-Cleves Highway 77 W. Jackson Blvd.
Harrison, Ohio 45030 Chicago, Illinois 60604
513-648-7480 312-886-0992
Monday, 7:30 a.m. to 8 p.m. Monday - Friday, 8a.m. to 5 p.m.
Tuesday - Thursday, 7:30 a.m. to 5 p.m.
Friday, 7:30 a.m. to 4:30 p.m.
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Your comments may be submitted by mail to:
Mr. Gary Stegner Mr. James A. Saric
U.S. Department of Energy U.S. EPA, 5HRE 8J
Fernald Area Office 77 W. Jackson Blvd.
P.O. Box 398705 Chicago, Illinois 60604
Cincinnati, Ohio 45239-8705
513-648-3131 312-886-0992
The OEPA is participating in the RI/FS and RA processes at the FEMP. For additional
information concerning the state's role in the cleanup process at the FEMP or regarding the
specifics of the revised FS and PP contact:
Tom Schneider
Ohio Environmental Protection Agency
401 E. Fifth Street
Dayton, Ohio 45402-2911
513-285-6466.
For additional information on public participation activities related to the revised Silos 1 and
2 FS, PP, or the FEMP site, visit the DOE-FEMP website at http://www.fernald.aov/.
8.3 Post-ROD Amendment Community Participation
Historically, the public has played a fundamental role in shaping the path forward for the Silos
Project. DOE will sustain the same level of public involvement throughout the implementation
of the Remedial Design/Remedial Action (RD/RA) activities, as was proven effective during
the revised FS/PP and ROD Amendment process.
DOE is committed to maintaining public involvement through completion of the Silos 1 and 2
RD/RA activities. Per requirements under the NCP (40 CFR Section 300.435), DOE at a
minimum will:
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Upon completion of the final engineering design, prepare a fact sheet describing the RD
(40 CFR Section 300.435).
Provide a public briefing upon completion of the final engineering design and prior to the
beginning of the RA (40 CFR Section 300.435).
Continue to provide project status through the Monthly Progress Briefings.
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9.0 BIBLIOGRAPHY
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
1980. U.S. Code. Vol. 42, sees. 9601 - 9675.
[overview at http://www.epa.gov/superfund/whatissf/cercla.htm]
Fernald Environmental Management Project (FEMP). 1993a. Remedial Investigation Report
for Operable Unit 4. Prepared under contract for the U.S. Department of Energy: Fernald
Field Office, Fernald, OH. (4AR Index Numbers Vol. l-lll: U-006-304.15 - 17)
- 1993b. Feasibility Study/Proposed Plan - Final Environmental Impact Statement
(FS/PP-EIS) for Remedial Actions at Operable Unit 4. DOE/EIS-0195D. Prepared under
contract for the U.S. Department of Energy: Fernald Field Office, Fernald, OH. (4AR Index
No. Vol. I-IV: U-006-404.8 - 11; also includes FS Vol. I-IV U-006-404.13 - 16; PP
U-006-405.3; and Rl Vol. l-lll U-006-304.15 -17)
- 1994a. Feasibility Study for Operable Unit 4. Prepared under contract for the U.S.
Department of Energy: Fernald Field Office, Fernald, OH. (4AR Index Numbers Vol. I-IV:
No. U-006-404.13-16)
- 1994b. Proposed Plan for Remedial Actions at Operable Unit 4. Prepared under contract
for the U.S. Department of Energy: Fernald Field Office, Fernald, OH. (4AR Index No.
U-006-405.3)
- 1996a. Operable Unit 4 Vitrification Pilot Plant. Phase I Interim Treatability Study Report,
Campaign 1, 40110-WP-0001, Rev. 0. Prepared under contract for the U.S. Department
of Energy: Fernald Field Office, Fernald, Ohio. (4AR Index No. U-006-409.28)
Documentation of Remedial Investigation/Feasibility Study activities for each operable unit is
made availableforpublicreview. The Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) Administrative Records for the FEMP site are located at the Public
Environmental Information Center (PEIC) in Harrison, OH. 513-648-7480.
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1996b. Operable Unit 4 Vitrification Pilot Plant. Phase I Interim Treatability Study Report,
Campaign 2,40110-WP-0002, Rev. 1. Prepared under contract for the U.S. Department
of Energy: Fernald Field Office, Fernald, OH. (4AR Index No. U-006-409.29)
1996c. Operable Unit 3 Record of Decision for Final Remediation Action. Prepared
under contract for the U.S. Department of Energy: Fernald Field Office, Fernald, OH. (4AR
Index No. U-005-501.9)
1996d. Operable Unit 5 Record of Decision. Prepared under contract for the U.S.
Department of Energy: Fernald Field Office, Fernald, OH. (4AR Index No. U-007-501.4)
1997a. Operable Unit 4 Vitrification Pilot Plant. Phase I Interim Treatability Study Report,
Campaign 4, 40110-WP-0003, Rev. 0. Prepared under contract for the U.S. Department
of Energy: Fernald Field Office, Fernald, Ohio. (4AR Index No. U-006-506.3)
1997b. VITPP Melter Incident Final Report. Prepared under contract for the U.S.
Department of Energy: Fernald Field Office, Fernald, OH. (4AR Index No. U-006-506.2)
1998a. Final Explanation of Significant Differences for Operable Unit 4 Silo 3 Remedial
Action at the Fernald Environmental Management Project. 40400-RP-0004. Prepared
under contract for the U.S. Department of Energy: Fernald Field Office, Fernald, OH. (4 AR
Index No. U-006-503.11)
1998b. Waste Acceptance Criteria Attainment Plan for the On-Site Disposal Facility.
Prepared under contract for the U.S. Department of Energy: Fernald Field Office, Fernald,
OH. (4AR Index No. U-006-409.34)
1999a. Revised Feasibility Study Report for Silos 1 and 2. Prepared under contract for
the U.S. Department of Energy: Fernald Field Office, Fernald, OH. (4AR Index Numbers
Vol. I-IV: U-006-404.18-21)
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- 1999b. Revised Proposed Plan for Remedial Actions at Operable Unit 4. Prepared
under contract for the U.S. Department of Energy: Fernald Field Office, Fernald, OH. (4AR
Index No. U-006^05.4)
National Environmental Policy Act (NEPA). 1969. U.S. Code. Vol. 42, sec. 4332.
[http://www.tis.eh.doe.gov/nepa/policy.htm]
National Oil and Hazardous Substances Pollution Contingency Plan (NCP). lat. rev. 1990.
Federal Register Vol. 55, No. 46. (4AR Index No. U-006-409.23)
[http://www.epa.gov/oerrpage/oilspill/ncpover.htm]
Silos Project Independent Review Team (IRT). 1997. S//os Project Independent Review
Team Final Report. Prepared for Fluor Fernald: Fernald, OH. (4AR Index No. U-006-506.4)
U.S. Department of Energy (DOE). 1996. Work Plan for FEMP Removal Action No. 17 -
Improved Storage of Soil and Debris. (4AR Index No. R-028-204.11 for Work Plan; Addenda
R-028-204.13&14)
- 1999. Office of the Deputy Assistant Secretary for Nuclear and Facility Safety. Waste
Vitrification Systems Lessons Learned. Germantown, MD: Office of Engineering
Assistance and Site Interface. (4AR Index No. U-006-409.11)
U.S. Environmental Protection Agency (EPA). 1988. Office of Emergency and Remedial
Response. Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA. EPA540G89004. Washington, D.C.: Dept. of Commerce National Technical
Information Service (NTIS). (1AR Index No. G-000-1101.2)
- 1991. Consent Agreement as Amended under CERCLA Sections 120 and 106(a) in
Matter of: U.S. Department of Energy Feed Materials Production Center, Fernald, Ohio.
Chicago, IL: Office of Public Affairs, Region 5. (4AR Index No. G-000-710.12)
- 1994. Record of Decision for Operable Unit 4. EPA ID OH6890008976; ROD ID
EPA/ROD/R05-95/287. (4AR Index No. U-006-501.5)
[abstract at http://www.epa.gov/superfund/sites/rodsites/0504934.htm]
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1997a. RE: OU4 Post-ROD Changes, letter from J.A. Saric (USEPA) to J.W. Reising
(USDOE). (4AR Index No. U-006-409.17)
1997b. Agreement Resolving Dispute Concerning Denial of Request for Extension of
Time for Certain Operable Unit 4 Milestones Chicago, IL: Office of Public Affairs, Region
5. Administrative Docket No. V-W-90-C-057. (4AR Index No. U-006-409.16)
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APPENDIX A
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS/
TO BE CONSIDERED CRITERIA FOR MANAGEMENT OF THE
SILOS 1 AND 2 MATERIAL
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TABLE OF CONTENTS
Page
Acronyms and Abbreviations a-ii
Overview A-1
Table A-1
Summary of ARARs for Silos 1 and 2 Material Remedial
Action Alternatives, Chemical-Specific
Table A-2 Summary of ARARs for Silos 1 and 2 Material Remedial
Action Alternatives, Location-Specific
Table A-3 Summary of ARARs for Silos 1 and 2 Material Remedial
Action Alternatives, Action-Specific
A-2
A-7
A-8
Table A-4 Other Requirements for Silos 1 and 2 Remedial Action Alternatives ... A-24
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ACRONYMS AND ABBREVIATIONS
ARAR
BMP
CAA
CFR
COC
CWA
DCG
DOE
EDE
FEMP
mrem
NEPA
NPDES
NTS
NWP
OAC
ORC
OU
pCi/L
RCRA
ROD
TBC
TSD
MCi/L
WAC
applicable or relevant and appropriate requirement
Best Management Practice
Clean Air Act
Code of Federal Regulations
constituent of concern
Clean Water Act
derived concentration guide
U.S. Department of Energy
effective dose equivalent
Fernald Environmental Management Project
milliroentgen per equivalent man
National Environmental Policy Act
National Pollution Discharge Elimination System
Nevada Test Site
Nationwide Permit
Ohio Administrative Code
Ohio Revised Code
operable unit
picoCuries per liter
Resource Conservation and Recovery Act, as amended
Record of Decision
to be considered
treatment, storage, and disposal
microcurie per liter
waste acceptance criteria
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OVERVIEW
Appendix A presents a summary of applicable or relevant and appropriate requirements/to
be considered criteria (ARARs/TBCs) associated with the remedial action selected for Silos
1 and 2 material. These tables group the ARARs/TBCs according to type (i.e.,
Chemical-specific, Location-specific, and Action-specific) and by governing regulatory act
[e.g., Clean Air Act (CAA), Clean Water Act (CWA), Resource Conservation and Recovery
Act, as amended (RCRA), etc.). The tables identify the regulatory requirement, a brief
description of the requirement, and the classification of the ARAR/TBC.
Removal, treatment by chemical stabilization, and shipment for off-site disposal of Silos 1 and
2 material will be conducted in accordance with the ARARs identified in this Record of
Decision (ROD) Amendment. Concrete debris from Silos 1 and 2 will undergo gross
decontamination, demolition, size reduction, and packaging prior to shipment off-site for
disposal at the Nevada Test Site (NTS) or an appropriately licensed commercial disposal
facility. Disposition of rubble and debris from Silos 3 and 4 and associated facilities (i.e.,
superstructures, treatment facilities, and the Radon Treatment System) will be performed in
accordance with the On-site Disposal Facility Waste Acceptance Criteria (WAC), and will be
conducted in accordance with the ARARs identified in the Operable Unit 3 (OU3) ROD.
Disposition of soils from Silos 1 and 2 will be conducted in accordance with ARARs
established in the Operable Unit 5 (OU5) ROD. Any interim storage of rubble and debris or
soils, prior to final disposition under the RODs for OU3 and OU5, respectively, will be in
accordance with ARARs identified in this ROD Amendment, pertinent Department of Energy
(DOE) Orders, and applicable site procedures.
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TABLE A-1
SUMMARY OF ARARS FOR SILOS 1 AND 2 MATERIAL
REMEDIAL ACTION ALTERNATIVES, CHEMICAL-SPECIFIC
Medium
CAA
Requirement
ARAR/TBC
Rationale for Implementation
Air Radionuclide Emissions
(Except Airborne Radon-222),
40 Code of Federal
Regulations (CFR) Part 61
Subpart H.
Emissions of radionuclides to the ambient air
from DOE facilities shall not exceed those
amounts that might cause any member of the
public to receive, in any year, define an
effective dose equivalent (EDE) of 10
milliroentgen equivalent man (mrem) or
greater per year.
Monitoring is required at release points
having potential to discharge radionuclides
that could cause an EDE in excess of 1% of
the standard (0.1 mrem/yr) to any member of
the public.
Applicable
Radioactive materials within Silos 1 and 2 might
contribute to the dosage to members of the public from
the air pathway during implementation of remedial
actions since the National Emissions Standards for
Hazardous Air Pollutants applies to operating units.
Air Radon-222 Emissions, 40 CFR
Part 61 Subpart Q.
No source at a DOE facility shall emit more
than 20 picoCuries per square meter - second
of radon-222 as an average for the entire
source during periods of storage and
disposal.
Applicable
Facilities such as Silos 1 and 2 qualify as sources since
they contain radium-226 in sufficient concentrations to
emit radon-222. This requirement is applicable only to
storage and disposal of radium-bearing by-product
material.
Medium
DOE
Requirement
ARAR/TBC
Rationale for Implementation
Air Residual Radioactive Material,
Proposed 10 CFR Part 834
Interim Storage
The above-background concentration of
radon-222 in air above an interim storage
facility must not exceed: 100 picoCuries per
liter (pCi/L) at any point, an annual average of
30 pCi/L over the facility, or an annual
average of 0.5 pCi/L at or above any location
outside the site.
To be
considered
Management of radium and thorium bearing waste might
result in the release of radon gas to the environment.
A-2
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-1 (continued)
Medium
Air
DOE
(continued)
Radiation
Protection of
the Public and
the
Environment,
Proposed 10
CFR Part 834.
Requirement
Residual concentrations of radionuclides in the air within
uncontrolled areas are limited to those listed below (for known
mixtures of radionuclides, the sum of the ratios of the observed
concentration of each radionuclide to its corresponding limit must
not exceed 1.O.).
Derived Concentration Guide
microCuries per milliliter (uCi/mL)
Isotope Da W Y
Actinium-227 2x10'15 7x10'15 1 x 10~14
I par! 710 Q Y 10'13 b
Pnlnninm 710 1 Y 10~12 1 Y 10~12
Prntartiniiim 7"}1 QY 10"15 1 Y 10"14
RaHium 774 4Y10'12
Rarlinm77fi 1 Y 10'12
RaHium 778 "3Y10"12
Tprhnptiiim QQ 1 Y 10'8 7 Y 10'9
^trnntium QOC *i Y 10'11 Q Y 10'12
Thnrinm778 ^YlO'14 4 Y 10 14
Thnrinm 7"}0 4Y10'14 ^YlO'14
Thnrium 7^7 ?Y 10~15 1 Y 10'14
Uranium-234 4x10'12 2x10'12 9x10'14
Uranium-235 5x10'12 2x10'12 1 x 10'13
Uranium-236 5x10'12 2x10'12 1 x 10'13
Uranium-238 5x10'12 2x10'12 1 x 10~14
a D, W, and Y (days, weeks, years) represent lung retention
classes; removal halftimes assigned to the compounds with
classes D, W, and Y are 0.5, 50, and 500 days, respectively.
Exposure conditions assume an inhalation rate of 8,400 cubic
meters of air per year (based on an exposure over 24 hours per
day, 365 days per year).
b A dashed line means that no limit has been established.
c The value shown for daily derived concentration guide (DCG) is
for strontium radionuclides with a f, value of 3 x 10~1. The value
shown for yearly DCG is for strontium radionuclides for a f, value
of 1 x 10-2.
ARAR/TBC
To be
considered
Rationale for Implementation
Remediation of the Silos 1 and 2 material has the
potential to release radionuclides.
A-3
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-1 (continued)
Medium
Water
DOE
(continued)
Radiation
Protection of
the Public and
the
Environment,
Proposed 10
CFR Part 834.
Requirement
Residual concentrations of radionuclides in water that may be
ingested are listed below. These DCGs for the constituents of
concern (COCs) are based on a committed EDE of mrem/yr,
assuming ingestion of 2 liters/day. Note that these DCGs apply
only if ingestion is the single pathway of exposure.
Ingested Water DCGs
Isotope CuCi/mL)
Actinium-227 1x10~8
Lead-210 3x1 0'8
Polonium-210 8x1 0'8
Protactinium-231 1x1 0~8
Radium-224 4x1 0'7
Radium-226 1x10'7
Radium-228 1x10'7
Technetium-99 1x10'4
Strontium-90 1x1 0~6
Thorium-228 4x1 0'7
Thorium-230 3x1 0'7
Thorium-232 5x1 0'8
Uranium-234 5x1 0'7
Uranium-235 6x1 0'7
Uranium-236 5x1 0'7
Uranium-238 6x1 0'7
ARAR/TBC
To be
considered
Rationale for Implementation
Remediation of the Silos 1 and 2 material has the
potential to release radionuclides.
A-4
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-1 (continued)
Medium
Water
Water
CWA
Ohio Water
Quality
Standards,
Ohio
Administrative
Code (OAC)
3745-1-04.
Ohio Water
Quality
Standards,
OAC 3745-1-
07.
Requirement
"Five Freedoms" for surface water:
Surface waters of the state shall be free from:
objectionable suspended solids;
floating debris, oil and scum;
materials that create a nuisance;
• toxic, harmful or lethal substances; and
nutrients that create nuisance growth
Use Designations and Criteria
All pollutants or combinations of pollutants shall not exceed, outside the
mixing zone, the Numerical and Narrative Criteria for Aquatic Life Habitat
and Water Supply Use Designations listed in Tables 7-1 through 7-15 of
this rule.
The following COCs for OU4 have warm water habitat criteria
concentrations outside the mixing zone as follows:
Average conc.a 30-day Criteria
Constituent micrograms per cone.
liter (ug/L) (ug/L)
antimony 650 190
arsenic 360 190
beryllium Tab. 7-1 Ob Tab. 7-11 c
cadmium Tab. 7-10 Tab. 7-11
chromium Tab. 7-10 Tab. 7-11
copper Tab. 7-1 0 Tab. 7-1 1
cyanide 46 12
lead Tab. 7-10 Tab. 7-11
mercury 1.1 0.20
nickel Tab. 7-10 Tab. 7-11
selenium 20 5.0
silver Tab. 7-10 1.3
thallium 71 16
ARAR/TBC
Relevant and
Appropriate
Applicable
Rationale for Implementation
Pertains to discharges to surface waters
as a result of remediation and to on-site
surface waters affected by site conditions.
Paddys run and the stream segment of
the Great Miami River adjacent to the
Fernald Environmental Management
Project (FEMP) are designated as warm
water aquatic life habitats with use
designations of agricultural and industrial
water supply, and primary contact
recreation. Chemical contaminants within
Silos 1 and 2 might be released during
remediation such that they might
contribute to contamination in these
aquatic habitats. OAC 3745-1-21 (Water
Use Designation for the Great Miami
River) establishes the classification of the
receiving waters for the FEMP.
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-1 (continued)
Medium
CWA
Requirement
ARAR/TBC
Rationale for Implementation
Water
Ohio Water
Quality
Standards, OAC
3745-1-07
(continued).
Constituent
average
conc.a (ug/1)
30-day Criteria cone, (ug/1)
zinc Tab. 7-10 Tab. 7-11
2-butanone 160000 7100
4-nitrophenol 790 35
acetone 550000 78000
aldrin — 0.01
bis(2-ethylhexyl)phthalate 1100 8.4
carbon tetrachloride 1800 280
DDT — 0.001
Dieldrin — 0.005
di-n-butyl-phthalate 350 190
diethylphthalate 2600 120
dimethylphthalate 1700 73
endosulfand — 0.003
endrin — 0.002
fluoranthene 200 8.9
methylene chloride 9700 430
PCBs — 0.001
Phenol 5300 370
Tetrachloroethene 540 73
Toluene 2400 1700
a Criteria concentration shall be met outside mixing zone.
b Criteria concentration based on hardness of water. See Table 7-10 for
calculation to determine maximum concentration outside the mixing zone.
c 30-day average criteria based on hardness of water. See Table 7-11 for
calculation to determine allowable 30-day average concentration outside
the mixing zone.
d No designation was made as to whether endosulfan referred to endosulfan
I or endosulfan II or the sum total of each.
The remaining COCs for OU4 will have criteria concentration levels based on
calculated acute aquatic criteria or chronic aquatic criteria.
A-6
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-2
SUMMARY OF ARARS FOR SILOS 1 AND 2 MATERIAL
REMEDIAL ACTION ALTERNATIVES, LOCATION-SPECIFIC
National Environmental
Protection Act (NEPA)/U.S.
Environmental Protection
Agency
Endangered Species Protection,
50 CFR Part 402 [Ohio Revised
Code (ORC) 1518, 1513.25 and
OAC 1501-18-1-01].
NEPA/DOE
Compliance with
Floodplain/Wetlands
Environmental Review
Requirements, 10 CFR Part 1022
(Executive Order 11990).
Requirement
Federal agencies must not jeopardize the
continued existence of any endangered or
threatened species, or destroy or adversely
modify critical habitat of such species.
Requirement
DOE actions in a wetland must first evaluate
the potential adverse effects that those actions
might have on the wetland and consider the
natural and beneficial values served by the
wetlands.
ARAR/TBC
Relevant and Appropriate
ARAR/TBC
Applicable
Rationale for Implementation
Although the FEMP is located within the range of the
Indiana bat, a federally listed endangered species, no
sighting has occurred on the FEMP. Therefore, this
requirement is relevant and appropriate. Any potential
impacts of the remedial actions on this species must
be evaluated and appropriate action taken.
Rationale for Implementation
This requirement is applicable because the FEMP is a
DOE facility. Several alternatives might result in
destruction or modification of wetland areas.
A-7
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-3
SUMMARY OF ARARS FOR SILOS 1 AND 2
REMEDIAL ACTION ALTERNATIVES, ACTION-SPECIFIC
Atomic Energy Act/DOE
Requirement
ARAR/TBC
Rationale for Implementation
10CFR Part 1021
DOE actions must be subjected to NEPA
evaluation as outlined by the Council on
Environmental Quality regulations in 40 CFR
Part 1500-1508
Applicable
This requirement is applicable because the FEMP is a
DOE facility, and this requirement requires NEPA
evaluation for specific actions at DOE facilities.
CWA
Requirement
ARAR/TBC
Rationale for Implementation
Nationwide Permit Program, 33
CFR Part 330.
The U.S. Corps of Engineers can issue a
Nationwide Permit (NWP) as a general permit
for certain classes of actions that involve
dredge or fill activities in wetlands or navigable
waters. Discharges of dredged or fill material
into wetlands may require a wetland
delineation.
Applicable
Remediation activities may require construction of
access roads and utility lines resulting in minor
wetland disturbances. Dredge and fill activities related
to construction of these access roads and utility lines
will be conducted in accordance with the substantive
terms and conditions of NWP 14 (Road Crossing), and
NWP 12 (Utility Line Backfill and Bedding). Ohio
Environmental Protection Agency as been granted
Section 401 State Water Quality Certification for
NWPs 12 and 14.
Discharge of Stormwater Runoff,
40 CFR Section 122.26 (OAC
3745-38).
Stormwater runoff from landfills, construction
sites, and industrial activities must be
monitored and controlled. A Stormwater
Pollution Prevention Plan is required for
construction activities that result in a total land
disturbance of five or more acres.
Applicable
Required of industrial waste sites and construction
sites of greater than five acres that discharge
Stormwater runoff to the waters of the U.S. Some
remedial alternatives evaluated might disturb more
than five acres of land.
A-8
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-3 (continued)
CWA (continued)
Discharge of Treatment System
Effluent, 40 CFR Section
125.100.
40 CFR Section 125.104.
Safe Drinking Water Act
Ohio Water Well Standards, OAC
3745-9-10.
Requirement
Best Management Practices (BMPs)
Development and implementation of a BMP
program to prevent the release of toxic or
hazardous pollutants to waters of the U.S.
Development and implementation of a sitewide
BMP Program is also required as a condition of
the FEMP National Pollution Discharge
Elimination System (NPDES) Permit.
The BMP program must:
Establish specific objectives for the control
of toxic and hazardous pollutants, and
Include a predication of direction, rate of
flow, and total quantity of toxic and
hazardous pollutants where experience
indicates a reasonable potential for
equipment failure.
Requirement
Abandonment of Test Holes and Wells
Upon completion of testing, a test hole or well
shall be either completely filled with grout or
such material as will prevent contaminants
from entering groundwater.
ARAR/TBC
Relevant and Appropriate
ARAR/TBC
Applicable
Rationale for Implementation
All of the proposed actions have the potential for
releases and runoff from this OU.
This requirement is not applicable because BMP under
the NPDES permit program applies only to ancillary
facilities of manufacturing units that might have
releases of toxic or hazardous pollutants. The purpose
of the BMP program is relevant and appropriate to
prevent releases from spills or runoff during the
implementation of remedial actions. The FEMP has an
approved BMP Plan.
Rationale for Implementation
Test borings and wells might be installed and/or closed
as part of these remedial alternatives.
A-9
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-3 (continued)
Uranium Mill Tailings Radiation
Control Act
Requirement
ARAR/TBC
Rationale for Implementation
Environmental Radiation
Protection Standards for
Management and Disposal of
Spent Nuclear Fuel, High-level
and Transuranic Radioactive
Wastes, 40 CFR Section 191.03
(b)
Establishes standard for management and
storage of spent nuclear fuel, high-level and
transuranic waste to ensure the combined
annual dose does not exceed specified limits.
Relevant and Appropriate
Radiation levels associated with Silos 1 and 2 material
are similar to those associated with waste regulated by
this requirement. On-site activities will have necessary
controls in place to ensure protection of public.
Implementation of Health and
Environmental Protection
Standards for Uranium Mill
Tailings, 40 CFR Part 192
Subpart C.
This subpart contains guidance, criteria, and
supplemental standards for compliance with
Subparts A and B of 40 CFR Part 192.
Relevant and Appropriate
Radioactive materials in this OU are primarily by-
product residues from uranium processing.
Requirements for design of controls should be
consistent with design of controls for other residual
radioactive materials such as mill tailings.
A-10
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TABLE A-3 (continued)
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
RCRA Subtitle C
Requirement
ARAR/TBC
Rationale for Implementation
Hazardous Waste
Determinations, 40 CFR Section
262.11
(OAC 3745-52-11).
Any generator of waste must determine
whether or not the waste is hazardous.
The procedures for determination include:
! Identification of whether a particular
material of concern is a "solid waste";
! Identification of whether a particular
exclusion applies to the material eliminating
it from definition as a "solid waste";
! Identification of whether a particular solid
waste might be classified as a hazardous
waste; and
! Determination of whether a material
otherwise classified as a "hazardous waste"
might be excluded from RCRA regulation.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
These procedures are established to determine
whether wastes are subject to the requirements of
RCRA. The materials in Silos 1 and 2 are specifically
exempt from the applicability of RCRA requirements.
However, these procedures are relevant and
appropriate to determine whether OU4 wastes, whether
excluded or not, exhibit the characteristics of
hazardous waste, or are otherwise similar to RCRA
hazardous waste. The material stored in the silos are
sufficiently similar to hazardous wastes based on the
toxicity characteristic leaching procedure results. Silos
1 and 2 contain materials that must be treated, stored,
and disposed in accordance with RCRA. Other wastes,
such as debris generated during decontamination (e.g.,
concrete scabbling), will also require a hazardous
waste determination.
A-11
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TABLE A-3 (continued)
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
RCRA Subtitle C
Requirement
ARAR/TBC
Rationale for Implementation
Empty Containers, 40 CFR
Section 261.7
(OAC 3745-51-7).
Containers that have held hazardous wastes
are "empty" and exempt from further RCRA
regulations if one or more of the following are
met:
! No more than 2.5 cm (1 inch) of residue
remains on the bottom of their inner liner;
! Less than 3% by weight of total capacity
remains (less than or equal to 110 gallon
container); and
! Less than 0.3% by weight of total capacity
remains (greater than 110 gallon container).
Containers that have held acutely hazardous
("P" listed ) wastes are "empty" and exempt
from further RCRA regulation if:
! They or their inner liners have been triple
rinsed with an adequate solvent or the inner
liner has been removed from the container.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
Containers used to treat or store the contents of Silos
1 and 2 might contain residues that exhibit hazardous
waste characteristics which must be removed before
the containers might be reused or disposed.
Generators Who Transport
Hazardous Waste for Off-site
Treatment, Storage, or Disposal;
40 CFR Sections 262.20 -
33 and 263.20 - 31 (OAC
3745-52-20 through 33
and OAC 3745-53-20
through 31).
Any generator who transports hazardous waste
for off-site treatment, storage or disposal must
originate and follow-up the manifest for off- site
shipments.
Applicable
Any residues determined to be RCRA hazardous
waste removed from this OU for off-site treatment,
storage, or disposal might be subject to the manifest
requirements.
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-3 (continued)
RCRA Subtitle C
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Treatment, Storage, or Disposal
Facility Standards; 40 CFR Part
264 Subpart B (OAC 3745-54-13
through 16).
General Standards
! Waste Analysis - OAC 3745-54-13:
Operators of a facility must obtain a
detailed chemical and physical analysis of
a representative sample of each hazardous
waste to be treated, stored, or disposed of
at the facility prior to treatment, storage, or
disposal.
! Security - OAC 3745-54-14: Operators of a
facility must prevent the unknowing or
unauthorized entry of persons or livestock
into the active portions of the facility,
maintain a 24-hour surveillance system, or
surround the facility with a controlled
access barrier and maintain appropriate
warning signs at facility approaches.
! Inspections - OAC 3745-54-15: Operators of
a facility must: (1) develop a schedule and
regularly inspect monitoring equipment,
safety and emergency equipment, security
devices, and operating and structural
equipment that are important to preventing,
detecting or responding to environmental or
human health hazards; (2) promptly or
immediately remedy defects; and (3)
maintain an inspection log.
! Training - OAC 3745-54-16: Operators must
train personnel, within six months of their
assumption of duties at a facility, in
hazardous waste management procedures
relevant to their positions, including
emergency response training.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid waste that
exhibit a hazardous
characteristic.)
Residues that exhibit a characteristic similar to RCRA
hazardous waste, removed from this OU, might be
treated, stored, and disposed in accordance with
treatment, storage, and disposal (TSD) facility
standards. These requirements are relevant and
appropriate because the residues are sufficiently
similar to hazardous waste.
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-3 (continued)
RCRA Subtitle C
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Treatment, Storage, of Disposal
Facility Preparedness and
Prevention;
40 CFR Part 264 Subpart C and
40 CFR Section 264.31
(OAC 3745-54-31).
40 CFR Section 264.32
(OAC 3745-54-32).
40 CFR Section
264.33 (OAC 3745-54-33).
40 CFR Section
264.34 (OAC 3745-54-34).
40 CFR Section 264.35 (OAC
3745-54-35).
40 CFR Section
264.37 (OAC 3745-54-37).
TSD facility operators must design, construct,
maintain and operate facilities to minimize the
possibility of a fire, explosion, or any unplanned
sudden or nonsudden release of hazardous
waste to air, soil, or surface water which might
threaten human health or the environment.
Facilities must be equipped with an internal
communication or alarm system, a telephone,
or a two-way radio for calling outside to
emergency assistance, fire control, and spill
control. Decontamination equipment and water
must be at an adequate volume and pressure
to supply water hose streams, foam producing
equipment, automatic sprinklers, or water spray
systems.
Fire protection, spill-control and
decontamination equipment, and
communication and alarm systems must be
tested and maintained, and necessary, to
ensure proper emergency operation.
Personnel must have immediate access to
emergency communication or alarm systems
whenever hazardous waste is being handled at
the facility.
Aisle space must be sufficient to allow
unobstructed movement of personnel, fire and
spill control, and decontamination equipment.
Operators must attempt to make arrangements,
appropriate to the waste handled, for
emergency response by local and state fire,
police and medical personnel.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
Residues removed from this OU might be treated,
stored, and disposed in accordance with TSD facility
standards. These requirements are relevant and
appropriate because the residues are sufficiently
similar to hazardous waste.
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-3 (continued)
RCRA Subtitle C
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Treatment, Storage, or Disposal
Facility Contingency Plan and
Emergency Procedures; 40 CFR
Part 264 Subpart D and 40
Section CFR 264.51
(OAC 3745-54-51).
40 CFR Section 264.52
(OAC 3745-54-52).
40 CFR Section
264.55, .56 (OAC
3745-54-55
through 56).
Each facility operator must have a contingency
plan designed to minimized hazards to human
health or the environment due to fires,
explosions, or any unplanned
releases of hazardous waste constituents to
the air, soil, or surface/groundwater.
Contingency plans should address procedures
to implement a response to incidents involving
hazardous waste, and provide for: internal and
external communications, arrangements with
local emergency authorities, an emergency
coordinator list, a facility emergency equipment
list indicating equipment descriptions and
locations, and a facility personnel evacuation
plan.
Each facility must have an emergency
coordinator who: (1) has responsibility for
coordinating emergency response measures;
(2) is on the premises or on call at all times; (3)
is throughly familiar with all aspects of the
contingency plan, facility operations, location
and characteristics of waste handled, location
of pertinent records, and facility layout; and (4)
has the authority to commit the resources
necessary to implement the contingency plan
in the event of an emergency.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
Residues removed from this OU might be treated,
stored, and disposed in accordance with TSD facility
standards. These requirements are relevant and
appropriate because the materials in Silos 1 and 2 are
sufficiently similar to hazardous waste.
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-3 (continued)
RCRA Subtitle C
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Closure, 40 CFR Part 264
Subpart G.
40 CFR Section 264.111 (OAC
3745-55-11).
40 CFR Section 264.114
(OAC 3745-55-14).
40 CFR Section 264.116
(OAC 3745-55-16).
An operator must close facilities in a manner
that:
! Minimizes the need for further
maintenance;
! Minimizes post-closure escape of
hazardous constituents; and
! Complies with specific, unit-type closure
requirements.
Contaminated equipment, structures and soils
must be properly disposed or decontaminated.
Following closure, a survey plot showing the
location of hazardous waste disposal units,
with respect to surveyed benchmarks, must be
filed with the legal total zoning authority.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
These requirements are relevant and appropriate
because the residues are sufficiently similar to
hazardous waste and some remedial alternatives
might require closure as outlined in this standard.
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FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
TABLE A-3 (continued)
RCRA Subtitle C
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Container Storage, 40 CFR Part
264 Subpart I
40 CFR Section 264.171 - 178
(OAC 3745-55-71
through - 78).
Containers of RCRA hazardous waste must be:
! Maintained in good condition;
! Compatible with hazardous waste to be
stored;
! Closed during storage (except to add or
remove waste); and
! Managed in a manner that will not cause
the container to rupture or leak.
Storage areas must be inspected weekly for
leaking and deteriorated containers and
containment systems.
Containers must be placed on a sloped, crack-
free base, and protected from contact with
accumulated liquid. A containment system with
a capacity of 10 percent of the volume of the
largest container of free liquids must be
provided. Spilled or leaked waste must be
removed in a timely manner to prevent overflow
of the containment system.
Incompatible materials must be separated.
Incompatible materials stored near each other
must be separated by a dike or other barrier.
At closure, hazardous waste and residue from
the containment system must be removed, and
containers, liners, bases, and soils must be
removed or decontaminated.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
These requirements are relevant and appropriate for
alternatives utilizing containers for temporary storage
or storage before disposal. These requirements are
relevant and appropriate because the residues in the
silos are sufficiently similar to hazardous waste.
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TABLE A-3 (continued)
RCRA Subtitle C
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Tank Systems, 40 CFR Part 264
Subpart J
(OAC 3745-55-91 through 96).
Design, operating standards, and inspection
requirements for tank units within which
hazardous waste is stored or treated. Includes
the following:
! Tank design must be compatible with the
material being stored.
! Tank must be designed and have sufficient
strength to store or treat waste in order to
ensure that it will not rupture or collapse.
! Tank must have secondary containment
that is capable of detecting and collecting
releases to prevent migration of wastes or
accumulated liquids to the environment.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
Design criteria, operating standards, and inspections
for tank treatment units might be relevant and
appropriate for alternatives utilizing treatment or
storage in a tank prior to disposal. These requirements
are relevant and appropriate because the residues in
the silos are sufficiently similar to hazardous waste.
Closure Requirements for
Tanks, 40 CFR Section 264.197
(OAC 3745-55-97).
At closure, the facility owner must do the
following:
Remove waste residues;
Remove or decontaminate tank system
components;
Remove or decontaminate contaminated
soils and structures;
Manage all of the above as hazardous
wastes; and
If all contaminated soils cannot be
removed, meet the landfill requirements of
40 CFR Section 264.310.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
Silos 1 and 2 are tanks, according to the definitions of
40 CFR Section 264.10, which contain wastes
sufficiently similar to hazardous waste. These
requirements are relevant and appropriate because the
circumstances and wastes subject to potential release
are similar to the releases that RCRA is designed to
address. These standards will also pertain to closure
of any tanks and appurtenances used to store or treat
these residues during remediation.
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RCRA Subtitle C
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Miscellaneous Units, 40 CFR
Part 264 Subpart X (40 CFR
Sections 264.601, .602 and
OAC 3745-57-91 and 92).
Environmental performance standard,
monitoring, inspection, and post-closure care
for treatment in miscellaneous units as defined
in 40 CFR Section 260.10.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
Miscellaneous units might be utilized under various
alternatives to remediate waste that is sufficiently
similar to hazardous wastes. These units might
include mixers, vitrifiers, or other units.
Corrective Action for Solid Waste
Management Units, 40 CFR Part
264 Subpart S and 40 CFR
Sections 264.552, .553.
Corrective action management units might be
designated at the site as areas where
remediation wastes (solid, hazardous, or
contaminated media and debris) might be
placed during the process of remediation.
Temporary units consisting of tanks and
container storage units might be used to store
and treat hazardous waste during the process
of corrective action.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
During the process of remediation, waste materials
might require temporary management in containment
buildings, temporary units, stockpiles, or other land
based units for the purpose of staging, treating or
disposing the material. Materials generated from
remediation of the Silos 1 and 2 material are
considered remediation wastes. Some of the waste
material might exhibit a RCRA characteristic, or
otherwise be sufficiently similar to hazardous
waste to make this requirement relevant and
appropriate.
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TABLE A-3 (continued)
RCRA Subtitle C
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Containment Buildings, 40 CFR
Part 264 Subpart DD and 40
CFR Section 264.1101, .1102.
Hazardous waste and debris might be placed
into units known as containment buildings for
the purpose of interim storage or treatment.
Containment buildings must be fully enclose to
prevent exposure to the elements and ensure
containment of managed wastes. Floor and
containment walls must be designed and
constructed of materials of sufficient strength
and thickness to support themselves, the
waste contents, and any personnel and heavy
equipment that operate within the unit.
Surfaces coming in contact with hazardous
waste must be chemically compatible with
waste. Primary barriers must be constructed to
prevent migration of hazardous constituents
into barrier. Secondary containment systems
including secondary barriers and leak detection
systems must also be constructed for
containment buildings used to manage wastes
containing free liquids.
Controls must be implemented to ensure: the
primary barrier is free of significant cracks,
corrosion, or other deterioration that may allow
release of hazardous waste; the level of
hazardous waste does not exceed height of
containment walls and is otherwise maintained
within containment walls; tracking of waste out
of unit by personnel or equipment used in
handling waste is prevented; and fugitive dust
emissions are controlled at the level of no
visible emissions.
Relevant and Appropriate
(This requirement will be
applicable to non-
excluded solid wastes
that exhibit a hazardous
characteristic.)
During the process of remediation, waste materials
might require temporary management for the
purpose of staging or treating the material. Some of
the waste material might exhibit a RCRA
characteristic, or otherwise be sufficiently similar to
hazardous waste to make this requirement relevant
and appropriate.
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TABLE A-3 (continued)
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RCRA Subtitle C
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Radiation Dose Limit (All
Pathways), Proposed 10 CFR
Part 834.
The exposure of members of the public to
radiation sources as a consequence of all
routine DOE activities shall not cause, in a year,
an EDE greater than 100 mrem from all
exposure pathways.
To be
considered
Radiation sources from this OU (i.e., a DOE-owned
facility) might contribute to the total dosage to
members of the public.
CAA
Requirement
ARAR/TBC
Rational for Implementation
Control of Fugitive Dust, OAC
3745-17-08.
Visible emissions of fugitive dust generated
during grading, loading, or construction
operations and other practices that emit fugitive
dust shall be minimized or eliminated.
Relevant and Appropriate
The implementation of remedial action alternatives will
require the movement of dirt and other material likely
to result in fugitive dust emissions. This requirement is
relevant and appropriate because the FEMP is not
located in an area subject to this regulation.
Prevention of Air Pollution
Nuisance, ORC 3704.01-.05 and
OAC 3745-15-07.
Measures shall be taken to adopt and maintain a
program for the prevention, control, and
abatement of air pollution in order to protect and
enhance the quality of the state's air resource
so as to promote the public health, welfare, and
economic vitality of the people of the state.
The emission or escape into open air from any
source whatsoever of smoke, ashes, dust, dirt,
grime, acids, fumes, gases, vapors, 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 injury or damage to property shall
be declared a public nuisance and is prohibited.
Applicable
During the remediation process, some potential exists
for emissions of radionuclides and toxic chemicals to
the air, which might endanger individuals or damage
property.
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CAA
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Control of Visible Particulate
Emissions from Stationary
Sources, OAC 3745-17-07.
Discharge of particulate emissions of a shade or
density greater than 20 percent opacity into
ambient air from any stack is prohibited.
Transient limits are included in this regulation.
Applicable
Treatment operations for various alternatives might
result in the release of particulate material.
Permit to Install, OAC 3745-31-
05(A)(3).
The director shall issue a permit to install if
he/she determines that the installation or
modification and operation of the air contaminant
source will employ the best available
technology.
Relevant and Appropriate
Although an administrative permit to install is not
required for alternatives involving treatment, the
substantive requirements of this section must be met
by employing Best Available Technology for treating
particulate and other off-gas emissions.
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CAA
(continued)
Requirement
ARAR/TBC
Rationale for Implementation
Restrictions on Participate
Emissions from Industrial
Processes, OAC 3745-17-11.
This requirement establishes numerical emission
release limits for particulate material from industrial
sources.
Any source (operation, process, or activity) shall be
operated so that particulate emissions do not exceed
allowable emission rates specified in this regulation
[based on processing weights (Table 1) or uncontrolled
mass rate of emissions (Figure II) of OAC 3745-17-
11].
A source complies with Table 1 requirements if its rate
of particulate emission is always equal to or less than
the allowable rate of particulate emission based on the
maximum capacity of the source:
Applicable
Treatment operations for various alternatives might
result in release of particulate material that might exceed
these standards.
Process Rate
at Maximum
Capacity
(Ib/hr)
100
200
400
600
800
1000
Allowable Rate
of Particulate
Emission
(Jb/hif
0.551
0.877
1.40
1.83
2.22
2.58
1 Excerpted from Table 1 of OAC 3745-17-
11.
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TABLE A-4
OTHER REQUIREMENTS FOR SILOS 1 AND 2
REMEDIAL ACTION ALTERNATIVES
Title
Requirement
Rationale for Implementation
Occupational Safety and Health
Administration Worker
Protection Requirements,
29 CFR Parts 1904 and 1910.
Establishes requirements to protect workers who could be exposed to
radiation, noise, hazardous wastes, or other contaminants or hazards at the
remediation site.
This OU is a remediation site under Comprehensive
Environmental Response Compensation and Liability
Act, as amended. Compliance with 29 CFR Section
1910.120 is required for sites undergoing remediation by
40 CFR Section 300.150.
Department of Transportation
Requirements for Transportation
of Hazardous Materials,
49 CFR Parts 171-173, 177,
178.
Hazardous materials may not be transported on public highways except in
accordance with these regulations:
Part 171, General Requirements.
Part 172, this part establishes shipping papers, marking, labeling,
placarding, and emergency response information requirements.
Part 173, this part establishes packaging and other shipping
requirements for hazardous materials, including radioactive materials.
Part 177, Requirements of the Transporter.
Part 178, Specifications for Shipping Containers.
Applicable to those alternatives which involve
transportation of the waste materials off-site.
Radioactive materials and materials sufficiently similar
to hazardous wastes might be shipped off-site.
Highway Improvement Act of
1982, 23 United States Code
(USC) 127.
Establishes vehicle weight limits for interstate highways.
Applicable to those alternatives which involve
transportation of the waste materials off-site.
Hazardous Materials
Transportation Act, 49 USC
1801-1812.
Establishes requirements for minimizing environmental impacts of spills or
releases of hazardous materials.
Applicable to those alternatives which involve
transportation of the waste materials off-site.
Radioactive materials and materials sufficiently similar
to hazardous wastes might be shipped off-site.
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TABLE A-4 (continued)
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Title
NTS WAC.
National Historic Preservation
Act, 16USC470etseq.
Archaeological and Historic
Preservation Act, 16 USC 469.
American Indian Religious
Freedom Act, 42 USC 1996.
Native American Graves
Protection and Repatriation Act,
25 USC 3001.
Protection and Enhancement of
Cultural Environment, Executive
Order 11 593.
Fish and Wildlife Coordination
Act, 16 USC66etseq.
Requirement
Establishes which wastes may be disposed at a facility.
Protects sites listed or eligible for listing in the National Register of Historic
Places.
Preserves artifacts and data associated with archaeological finds.
Provides for tribal access by native peoples to grave sites and sites of
cultural, symbolic, or religious significance.
Provides for return of human remains and cultural objects from Native
American graves to affiliated tribes.
Requires inventory of site for potential historic places for eligibility in the
National Register of Historic Places.
Requires consultation with other state agencies on activities that might
affect any body of water for the conservation offish and wildlife resources.
Rationale for Implementation
The NTS WAC would be applicable to disposals at the
NTS. NTS operates under DOE Order 435.1,
"Radioactive Waste Management."
Required by law for the alternatives affected.
Required by law for the alternatives affected.
Required by law for the alternatives affected.
Required by law for the alternatives affected.
Required by law for the alternatives affected.
Required by law for the alternatives affected.
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TABLE A-4 (continued)
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Title
Archaeological Resources
Protection Act, 16 USC 470 (a).
Antiquities Act and Historic
Sites Act, 16 USC 431-433 and
16 USC 461 -4Q7.
Farmland Protection Policy Act,
7 USC 4201 et. Seq.
Occupational Radiation
Protection, 10 CFR Part 835.
DOE Order
5400.3
5400.5
451.1 A
5480.1 B
460.1A
460.2
Requirement
Requires permit for removal of any archaeological resources from federal
lands.
Requires identification and preservation of cultural resources on federal
lands; includes natural landmarks.
Requires protection and maintenance of farmland for its beneficial use as a
national resource.
Provides standards for occupational radiation protection of workers at DOE
facilities.
Title
Hazardous and Mixed Waste Program
Radiation Protection of the Public and the Environment
NEPA Compliance Program
Environmental, Safety, and Health Program for DOE Operations
Packaging and Transportation Safety
Departmental Materials Transportation and Packaging Management
Rationale for Implementation
Required by law for the alternatives affected.
Required by law for the alternatives affected.
Required by law for the alternatives affected.
Required by law for safety and worker protection at DOE
facilities (replaces former DOE Order 5480.1 1).
Rationale for Implementation
Contractual obligation for activities at DOE facilities.
Contractual obligation for activities at DOE facilities.
Contractual obligation for activities at DOE facilities.
Contractual obligation for activities at DOE facilities.
Contractual obligation for activities at DOE facilities.
Contractual obligation for activities at DOE facilities.
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TABLE A-4 (continued)
DOE Order
5480.4
440.1 A
435.1
414.1
430.1A
Title
Environmental Protection, Safety, and Health Protection Standards
Worker Protection for DOE Federal and Contractor Employees
Radioactive Waste Management
Quality Assurance
Life Cycle Asset Management
Rationale for Implementation
Contractual obligation for activities at DOE facilities.
Contractual obligation for activities at DOE facilities.
Contractual obligation for activities at DOE facilities.
Contractual obligation for activities at DOE facilities.
Contractual obligation for activities at DOE facilities.
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APPENDIX B
RESPONSIVENESS SUMMARY
FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
SILOS 1 AND 2 MATERIAL
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TABLE OF CONTENTS
List of Acronyms and Abbreviations b-ii
B.1.0 PURPOSE B.1-1
B.2.0 COMMUNITY PARTICIPATION FOR SILOS 1 AND 2 B.2-1
B.2.1 Public Comment Period B.2-1
B.2.2 Community Involvement B.2-1
B.2.3 Public Meetings B.2-4
B.3.0 SUMMARY OF ISSUES AND RESPONSE B.3-1
LIST OF TABLES
Table B.2-1 Summary of Public Involvement Opportunities B.2-3
Table B.3-1 Formal Verbal and Written Comments Received B.3-3
LIST OF ATTACHMENTS
Attachment B.I Fluor Daniel Fernald Public Hearing - Proposed Plan for
Remedial Actions at Silos 1 and 2 (Harrison, Ohio) B-l-1
Attachment B.ll U.S. Department of Energy Public Meeting - Proposed Plan
for Remedial Actions at Silos 1 and 2 (Las Vegas, Nevada) ... B-ll-1
Attachment B.lll Written Comments Received on the Proposed Plan for
Remedial Actions at Silos 1 and 2 B-lll-1
Attachment B.IV Notices of Public Comment Period and Hearings
Placed in Major Local Newspapers B-IV-1
b-i
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ACRONYMS AND ABBREVIATIONS
ARAR
AWR
CERCLA
CFR
COC
DOE
DOE-NV
DOT
EPA
ESD
FCAB
FEMP
FRESH
FS
NCP
NTS
NTS-CAB
OEPA
ORNL
OSDF
OU
PA
POP
PP
RCRA
RFP
Rl
ROD
TCLP
WAC
applicable or relevant and appropriate requirement
Accelerated Waste Retrieval
Comprehensive Environmental Response, Compensation, and
Liability Act, as amended
Code of Federal Regulations
constituent of concern
U.S. Department of Energy
U.S. Department of Energy-Nevada Field Operations
Department of Transportation
U.S. Environmental Protection Agency
Explanation of Significant Differences
Fernald Community Advisory Board
Fernald Environmental Management Project
Fernald Residents for Environmental Safety and Health
Feasibility Study
National Oil and Hazardous Substances Pollution Contingency Plan
Nevada Test Site
Nevada Test Site Community Advisory Board
Ohio Environmental Protection Agency
Oak Ridge National Laboratory
On-site Disposal Facility
operable unit
performance assessment
Proof of Principle
Proposed Plan
Resource Conservation and Recovery Act, as amended
Request for Proposal
Remedial Investigation
Record of Decision
Toxicity Characteristic Leaching Procedure
waste acceptance criteria
b-ii
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B.1.0 PURPOSE
As stated in the U. S. Environmental Protection Agency (EPA) Guide to Preparing Superfund
proposed Plans, Records of Decision, and Other Remedy selection Decision Documents
(EPA 1999), the responsiveness summary serves three important purposes. First it provides
the U. S. Department of Energy (DOE) with information about community preferences
regarding both the proposed remedial alternative and general concerns about the site.
Second, it demonstrates how public and support agency comments were integrated into the
decision-making process. Third, it allows DOE to formally respond to public comments.
This Responsiveness Summary has been prepared to meet the requirements of Sections
113(k)(2)(B)(iv) and 117(b) of the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended (CERCLA). As the lead agency at the Fernald
Environmental Management Project (FEMP), DOE is required to respond "...to each of the
significant comments, criticisms, and new data submitted in written or oral presentations" on
the Revised Proposed Plan for Remedial Action at Silos 1 and 2 (revised PP).
In addition to CERCLA, this Responsiveness Summary has been prepared pursuant to other
requirements, including:
The 1991 Amended Consent Agreement between DOE and the EPA;
The 1997 Agreement Resolving Dispute Concerning Denial of Request for
Extension of Time for Certain OU4 Milestones;
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40
Code of Federal Regulations (CFR), Part 300;
B.1-1
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Community Relations in Superfund (Handbook), January 1992, EPA
540-R-92-009; and
A Guide to Preparing Superfund Proposed Plans, Records of Decision; and
Other Remedy Selection Decision Documents, July 1999, EPA 540-R-98-031.
This Responsiveness Summary is used as the mechanism for DOE to identify and document
the public involvement with the Revised Feasibility Study for Silos 1 and 2 (revised FS),
revised PP, and Supplement Analysis. After public comments and concerns had been formally
submitted to DOE, in oral and written form, the comments were summarized into issue
statements and responded to accordingly. The actual written comments received are included
in Attachment B.1 of Appendix B.
Section B.2.0 of this Responsiveness Summary gives an overview of the public's involvement
in the development and approval of the revised FS, revised PP, and Supplement Analysis.
Section B.3.0 discusses the development of the issue statements and presents the public
concerns and DOE responses.
B.1-2
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B.2.0 COMMUNITY PARTICIPATION FOR SILOS 1 AND 2
B.2.1 Public Comment Period
The DOE recently held a public comment period from April 3 through May 18, 2000, for
interested parties to comment on the modified selected remedy for the Silos 1 and 2 material
within Operable Unit 4 (OU4) at the FEMP in Fernald, Ohio. In addition, two public hearings,
one in Fernald, Ohio (April 25,2000) and the other in Las Vegas, Nevada (May 3,2000) were
held to provide the public with a forum to submit oral comments on the proposed revised
remedy. The public comment period was held in accordance with Section 117 of CERCLA.
The purpose of this Responsiveness Summary is to document DOE's responses to comments
received during the public comment period. These comments were considered before
selecting the final remedy for the Silos 1 and 2 material, which is detailed in this amendment
to the Record of Decision (ROD).
B.2.2 Community Involvement
DOE is responsible for conducting the community relations for the FEMP. A community
relations program was established for the FEMP in 1985 to provide information about the site
regarding updates and progress of the clean-up activities.
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In November 1993, DOE implemented a public participation program at Fernald to involve
community members and other interested parties in the decision-making process at the site.
This Fernald Community Advisory Board (FCAB), formerly known as the Fernald Citizens
Task Force, was chartered to provide DOE, EPA, and Ohio Environmental Protection Agency
(OEPA) with recommendations about cleanup solutions and future courses of action at the
FEMP. These efforts, along with the community relations activities required by CERCLA,
reflect DOE's intent to fully involve the community in the decision-making process.
More recently, DOE has encouraged public inspection and informal comment on drafts of the
revised FS and revised PP documents, prior to EPA approval. This approach has provided
a genuine opportunity for stakeholders to identify issues, voice their concerns, and learn about
proposed clean-up plans for Silos 1 and 2 material. The informal opportunity for the public to
provide input enabled DOE to address stakeholder questions and concerns in advance of the
formal public comment period.
Two Administrative Records, located at the Public Environmental Information Center in
Harrison, Ohio and EPA Region V offices in Chicago, Illinois have been established to
provide an information repository on the decision-making process for interested members of
the public.
During the decision-making process documented in this ROD Amendment, DOE solicited
feedback and informed stakeholders. The DOE sponsored several community briefings and
workshops both locally and at the Nevada Test Site (NTS) to share the data supporting the
evaluation of alternatives in the revised FS and revised PP on an informal basis. In addition,
the DOE has sponsored formal public hearings regarding the revised PP both locally and at
the NTS to provide the public a forum to submit oral comments on the preferred alternative
identified in the revised PP. Table B.2-1 presents a summary of these public involvement
opportunities.
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TABLE B.2-1
SUMMARY OF PUBLIC INVOLVEMENT OPPORTUNITIES
Meeting Topic
Preliminary Screening of Alternatives
Presentation of Proof of Principle testing data
Summary of Detailed Analysis of Silos 1 and 2 FS
FCAB
FS overview with FCAB
Summary of Comparative Analysis of Silos 1 and 2
FS
Nevada Test Site Citizens Advisory Board (NTS-
CAB) Summary of Silos 1 and 2 FS Comparative
Analysis
FCAB Proposed Plan Summary
Formal Public Hearing on Silos 1 and 2 revised PP
Formal Public Hearing on Silos 1 and 2 revised PP
Location/Date
FEMP/December 1997
FEMP/July13, 1999
FEMP/October12, 1999
FEMP/October14, 1999
FEMP/November4 and 6, 1999
FEMP/November17, 1999
Las Vegas, Nevada/December 1 ,
1999
FEMP/December 6, 1999
FEMP/April 25, 2000
Las Vegas, Nevada/May 3, 2000
B.2-3
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To augment public involvement throughout the revised Silos 1 and 2 remedy decision-making
process [i.e., Proof of Principle (POP) testing, revised FS, revised PP], the DOE utilized an
independent technical review team comprised of technical and process experts to objectively
review and evaluate the remedial alternatives.
B.2.3 Public Meetings
Written transcripts of the public hearings conducted on April 25, 2000 at the Alpha Building,
Classroom D, Harrison, Ohio and on May 3, 2000 at the DOE's Nevada Support Facility,
Sedan Conference Room, Las Vegas, Nevada are attached in Attachments B.I and B.ll,
respectively.
B.2-4
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B.3.0 SUMMARY OF ISSUES AND RESPONSE
The revised FS (including the Supplement Analysis) and revised PP were released for public
comment on April 3, 2000. The DOE reviewed all written and verbal comments submitted
during the public comment period. Upon review of these comments, it was determined that
no significant changes to the remedy, as was originally identified in the revised FS and
revised PP, were necessary.
This Responsiveness Summary document addresses on the formal comments submitted
during the public comment period and oral comments received during the April 25, 2000
public hearing held in Harrison, Ohio and the May 3, 2000 public hearing held in Las Vegas,
Nevada. Within this Responsiveness Summary, verbal and written comments (see
Attachments B.I - B.lll) were categorized into significant issues. For each of these issues,
an issue statement has been prepared that addresses the concerns expressed by 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 questions raised during the
public question and answer sessions to ensure that all significant issues are represented by
the issue statements.
For the purpose of developing issue statements, a comment is considered significant if it
involves:
The definition of the preferred alternative;
Public or state acceptance of the preferred alternative;.
The implementation or impacts of the preferred alternative;
Conclusions drawn from evaluations or assessments provided within the
document;
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Safety of the work performed; or the
Enforceability of the decision reached.
At the end of each issue statement, the specific comment letter(s) or oral comment(s) in which
the issue was raised is identified in parentheses. Each comment is provided an alphabetic
identifier. These comments are also part of the administrative record for this action. Table
B.3-1 provides a cross-reference of the alphabetic identifiers with the commentors. A
reference to Attachment B.I indicates a verbal comment submitted at the Public Hearing held
April 25, 2000 at Fernald. A reference to Attachment B.ll indicates a verbal comment
submitted at the Public Hearing held May 3, 2000 at the NTS. A reference to Attachment
B.lll indicates a written comment submitted during the Public Comment Period held between
April 3 and May 18, 2000.
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TABLE B.3-1
FORMAL VERBAL AND WRITTEN COMMENTS RECEIVED
COMMENT
Commentor
Issue No.
Page No.
RESPONSE
Identification
Page No.
Brief Description of Issue
Formal Verbal Comments
Lisa Crawford Fernald
Residents for
Environmental Safety
and Health (FRESH)
Joanne Wilson
Carol Schroer FRESH
Edwa Yocum FRESH
Douglas Davis Toledo
Engineering Company
(TECO Engineering)
Jerry Gels
Unidentified Speaker
1
2
3
1
1
1
1
2
1
1
B-l-55
B-l-55
B-l-56
B-l-56
B-1-63
B-l-64
B-1-56
B-1-66
B-l-67
B-ll-43
A
B
C
D
E
F
A
G
D
H
B.3-1 1
B.3-12
B.3-1 3
B.3-14
B.3-16
B.3-16
B.3-1 1
B.3-1 7
B.3-14
B.3-1 7
Long-term protectiveness
Completeness of cost estimates in
evaluating alternatives
Waste minimization
Radium extraction for medical use
Ensuring protection of human health
(both worker and the public) and the
environment during remediation
Opposition to disposal of Silos 1
and 2 material in the On-site
Disposal Facility (OSDF) should the
NTS close
Long-term protectiveness
Commercial glass-making
experience in evaluation of
vitrification
Radium extraction for medical use
Energy consumption as criterion for
evaluation of alternatives
B.3-3
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
June 2000, Rev. 0
COMMENT
Commentor
Issue No.
Page No.
RESPONSE
Identification
Page No.
Brief Description of Issue
Formal Verbal Comments
Dennis Bechtel
NTS-CAB
Dale Schutte
John Phillips NTS-CAB
Don Cloquet
1
2
3
4
1
2
1
1
B-ll-44
B-ll-45
B-ll-46
B-ll-48
B-ll-48
B-ll-51
B-ll-49
B-ll-50
I
J
K
L
M
DD
E
M
B.3-18
B.3-20
B.3-21
B.3-22
B.3-23
B.3-42
B.3-16
B.3-23
Rationale for disposal at the NTS
Measures to prevent degradation of
chemical stabilized waste
Cumulative risk from all DOE
shipments to the NTS
State and community acceptance
Minimization of transportation risk
through routing including evaluating
intermodal transportation
Public comment period.
Ensuring protection of human health
(both worker and the public) and the
environment during remediation
Minimization of transportation risk
through routing including evaluating
intermodal transportation
Formal Written Comments
Joanne Wilson
Jerry Gels
1
1a
1b
2
B-lll-2
B-lll-5
B-lll-5
B-lll-5
D
A
N
D
B.3-14
B.3-11
B.3-24
B.3-14
Radium extraction for medical use
Long-term protectiveness
Short-term effectiveness - Worker
risk
Radium extraction for medical use
B.3-4
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
June 2000, Rev. 0
COMMENT
Commentor
Issue No.
Page No.
RESPONSE
Identification
Page No.
Brief Description of Issue
Formal Verbal Comments
Jerry Gels (cont'd)
Kenneth Moore
J.E. Walther
Dennis Bechtel NTS-
CAB
Phil Claire NTS-CAB
3
1
1
1
2a
2b
2c
3
4
5
1
B-lll-5
B-lll-6
B-lll-8
B-lll-10
B-lll-11
B-lll-11
B-lll-11
B-lll-11
B-lll-12
B-lll-13
B-lll-16
O
D
E
I
J
A
P
K
Q
L
I
B.3-25
B.3-14
B.3-16
B.3-18
B.3-20
B.3-11
B.3-26
B.3-21
B.3-27
B.3-22
B.3-18
Health physics evaluation of
radionuclides particularly
radium-226 and radon-222
Radium extraction for medical use
Ensuring protection of human health
(both worker and the public) and the
environment during remedition
Rationale for disposal at the NTS
Measures to prevent degradation of
chemical stabilized waste
Long-term protectiveness
Ability of chemical stabilized waste
to meet the State of Nevada WAC
Cumulative risk from all DOE
shipments to the NTS
Specifying transportation routes to
carriers
State and community acceptance
Rationale for disposal at the NTS
B.3-5
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
June 2000, Rev. 0
COMMENT
Commentor
Issue No.
Page No.
RESPONSE
Identification
Page No.
Brief Description of Issue
Formal Verbal Comments
Phil Claire NTS-CAB
(cont'd)
Kenneth Reim
2a
2b
2c
3
4
5
6
7
8
1
2
B-lll-16
B-lll-16
B-lll-16
B-lll-17
B-lll-17
B-lll-17
B-lll-18
B-lll-18
B-lll-18
B-lll-19
B-lll-19
J
A
P
M
K
Q
L
R
H
H
N
B.3-20
B.3-11
B.3-26
B.3-23
B.3-21
B.3-27
B.3-22
B.3-28
B.3-17
B.3-17
B.3-24
Measures to prevent degradation of
chemical stabilized waste
Long-term protectiveness
Ability of chemical stabilized waste
to meet the State of Nevada WAC
Minimization of transportation risk
through routing including evaluating
intermodal transportation
Cumulative risk from all DOE
shipments to the NTS
Specifying transportation routes to
carriers
State and community acceptance
Equity for NTS stewardship costs
Energy consumption as criterion for
evaluation of alternatives
Energy consumption as criterion for
evaluation of alternatives
Short-term effectiveness - Worker
risk
B.3-6
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
June 2000, Rev. 0
COMMENT
Commentor
Issue No.
Page No.
RESPONSE
Identification
Page No.
Brief Description of Issue
Formal Verbal Comments
Kenneth Reim (cont'd)
Richard Nocilla NTS-
CAB
Telfer
Douglas Davis TECO
Engineering And David
Bennert InnovaTech
Services
3
4
5
1
1
1
2a
2b
3
4
5a
B-lll-19
B-lll-19
B-lll-19
B-lll-21
B-lll-34
B-lll-36
B-lll-36
B-lll-37
B-lll-37
B-lll-37
B-lll-38
S
B
M
M
M
A
T
U
N
S
A
B.3-29
B.3-12
B.3-23
B.3-23
B.3-23
B.3-11
B.3-30
B.3-31
B.3-24
B.3-29
B.3-11
Short-term effectiveness - Time to
achieve protectiveness
Completeness of cost estimates in
evaluating alternatives
Minimization of transportation risk
through routing including evaluating
intermodal transportation
Minimization of transportation risk
through routing including evaluating
intermodal transportation
Minimization of transportation risk
through routing including evaluating
intermodal transportation
Long-term protectiveness
Reduction of toxicity, mobility, or
volume through treatment - Volume
reduction
Reduction of toxicity, mobility, or
volume through treatment -
Secondary waste
Short-term effectiveness - Worker
risk
Short-term effectiveness - Time to
achieve protectiveness
Long-term protectiveness
B.3-7
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
June 2000, Rev. 0
COMMENT
Commentor
Issue No.
Page No.
RESPONSE
Identification
Page No.
Brief Description of Issue
Formal Verbal Comments
Douglas Davis
TECO Engineering
And
David Bennert
InnovaTech Services
(cont'd)
Jim Hansen Geosafe
Corporation
5b
6
7
8
9
10
11
1
2
3
4
B-lll-38
B-lll-38
B-lll-39
B-lll-39
B-lll-40
B-lll-41
B-lll-42
B-lll-43
B-lll-44
B-lll-44
B-lll-46
V
W
w
W
X
Y
z
A
Y,AA
BB
CC
B.3-32
B.3-34
B.3-34
B.3-34
B.3-36
B.3-38
B.3-39
B.3-11
B.3-38 &
B.3-39
B.3-40
B.3-41
Radon emanation over the life of
treated waste
Implementability - Operability and
controllability and exclusion of
commercial glass-making
experience
Implementability - Process
reliability
Implementability - Process control
Optimization of VIT1 container
VIT1 Cost
Reevaluation of VIT1 using 30 ton
per day melter and producing frit
Long-term protectiveness
Representativeness of vitrification
technologies used in the revised FS
for evaluation of the five balancing
criteria
Revising ROD to include off-site
treatment
Exclusion of Geosafe's commercial
experience in treating hazardous
and radioactive waste
B.3-8
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
June 2000, Rev. 0
COMMENT
Commentor
Issue No.
Page No.
RESPONSE
Identification
Page No.
Brief Description of Issue
Formal Verbal Comments
Jim Hansen Geosafe
Corporation (cont'd)
5
6
7
8
9
10
11
12
13
14
15
16
17
B-lll-46
B-lll-46
B-lll-46
B-lll-46
B-lll-47
B-lll-47
B-lll-47
B-lll-47
B-lll-47
B-lll-48
B-lll-48
B-lll-48
B-lll-48
AA
AA
A
A
A
AA
V
N
AA
S
AA
AA
AA
B.3-39
B.3-39
B.3-11
B.3-11
B.3-11
B.3-39
B.3-32
B.3-24
B.3-39
B.3-29
B.3-39
B.3-39
B.3-39
Representativenss of vitrification
technologies used in the revised FS
Representativeness of vitrification
technologies used in the revised FS
Long-term protectiveness
Long-term protectiveness
Long-term protectiveness
Representativeness of vitrification
technologies used in the revised FS
Radon emanation over the life of
treated waste
Short-term effectiveness - Worker
risk
Representativeness of vitrification
technologies used in the revised FS
Short-term effectiveness - Time to
achieve protectiveness
Representativeness of vitrification
technologies used in the revised FS
Representativeness of vitrification
technologies used in the revised FS
Representativeness of vitrification
technologies used in the revised FS
B.3-9
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
June 2000, Rev. 0
COMMENT
Commentor
Issue No.
Page No.
RESPONSE
Identification
Page No.
Brief Description of Issue
Formal Verbal Comments
Jim Hansen Geosafe
Corporation (cont'd)
18
19
20
21
22
23
24
25
26
B-lll-48
B-lll-48
B-lll-48
B-lll-49
B-lll-49
B-lll-49
B-lll-49
B-lll-49
B-lll-49
AA
S
AA
AA
AA
AA
AA
AA
A
B.3-39
B.3-29
B.3-39
B.3-39
B.3-39
B.3-39
B.3-39
B.3-39
B.3-11
Representativeness of vitrification
technologies used in the revised FS
Short-term effectiveness - Time to
achieve protectiveness
Representativeness of vitrification
technologies used in the revised FS
Representativeness of vitrification
technologies used in the revised FS
Representativeness of vitrification
technologies used in the revised FS
Representativeness of vitrification
technologies used in the revised FS
Representativeness of vitrification
technologies used in the revised FS
Representativeness of vitrification
technologies used in the revised FS
Long-term protectiveness
B.3-10
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
June 2000, Rev. O
Issue:
Comment: Commentors expressed concern over the durability of the chemical stabilized
wasteform both during a highway accident and in regard to long-term
protectiveness to human health and the environment after disposal.
Response: Both vitrification and chemical stabilization result in a treated waste that
provides protection of human health and the environment. As documented in the
Remedial Investigation/Feasibility Study (RI/FS) for OU4, the principal chemical
constituent of concern for Silos 1 and 2 material and the focus for stabilization
of the material is lead, whose concentration in leachate can exceed limits
prescribed under the Resource Conservation and Recovery Act, as amended
(RCRA). Both technologies stabilize lead by chemically converting it into a
leach-resistant form. Based on this chemical conversion alone, both
technologies show the ability to reduce the leaching of lead to meet disposal
facility requirements when analyzed using the Toxicity Characteristic Leaching
Procedure (TCLP). Long-term protection of human health and the environment
at the NTS is dependent on the ability of the technologies to reduce leaching by
chemically converting the lead into a leach-resistant chemical form not the
physical integrity of the solidified wasteform.
B.3-11
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
June 2000, Rev. O
In addition, as part of the evaluation of transportation risk, the DOE evaluated
the risk to the public resulting from a transportation accident using the
RADTRAN5® computer model. The resulting risk numbers were based on the
probability of an accident occurring during transportation combined with the
probability of the accident resulting in release of material from the container.
Because the chemical stabilization alternatives result in a greater number of
shipments, the resulting risk from a potential accident is greater than that for
vitrification. However, the resulting incremental lifetime cancer risk from a
potential accident for each alternative is within the CERCLA guidelines.
Issue:
B
Comment: Concern was raised over the completeness of the cost estimate. In particular,
a concern was raised regarding the potential costs for the addition of a
wastewater treatment facility for the CHEM2 alternative.
Response: Although cost-effectiveness is a key factor in selecting the remedy for Silos 1
and 2 material, the difference in estimated cost of the chemical stabilization and
vitrification alternatives was not of sufficient magnitude to be a discriminating
factor between the alternatives. Any potential costs of a wastewater treatment
facility for the CHEM2 alternative would not modify this determination.
B.3-12
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
The total estimated cost for the wastewater treatment system associated with
the CHEM1 process option is approximately $700,000. This includes the costs
associated with engineering, procurement, construction, and operation of the
facility, as well as transportation and disposal of wastewater treatment bag
filters. In the event the CHEM2 process option would require a water treatment
system, it would be conceptually very similar to the one described in the
CHEM1 process. Assuming similar operational costs as those estimated for
the CHEM1 process option results in an increase of approximately $700,000
(0.2% of the current estimated total cost for implementing CHEM2) to the total
cost of the CHEM2 process option.
Issue:
Comment: Concern was raised regarding the DOE's commitment to minimizing the volume
of waste generated by the selected treatment technology.
Response: It is DOE policy, in accordance with Executive Order 12856, whenever feasible
to apply pollution prevention and waste minimization principles into the design
and operation of all its facilities. Accordingly, the technical specification for the
Request for Proposal (RFP) to be issued for this project contains provisions for
the future contractorto incorporate pollution prevention and waste minimization
features during the design effort. One of the evaluation criteria to be used in
selecting the future contractor is the degree to which his design exhibits
minimization of primary and secondary wastestreams. As part of the CERCLA
remedial design process EPA and OEPA will have the opportunity to review
and approve the Contractor's design.
B.3-13
-------
Issue:
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
D
Comment: The decision-making process for the Silos 1 and 2 treatment remedy should
consider the potential medical benefits that the 10 pounds of radium-226 in the
Silos 1 and 2 material may have to offer.
Response: The DOE has taken positive steps to move forward with both the clean up plans
for the radium-bearing Silos 1 and 2 material at the FEMP and to assist the
medical community with efforts to find ways to identify radium sources that may
be available to researchers without impacting the EPA-mandated clean-up
schedule. The DOE's Office of Nuclear Energy's Isotope Production and
Distribution Division has monitored the progress and supported the medical
community's radiotherapy research efforts since the potential opportunities
were first recognized in 1995.
While the actual future need for radium-226 is not yet certain, there are
significant issues which would need to be addressed to determine the
feasibility for recovery of the 10 pounds of radium-226 from the 20,000,000
pounds of Silos 1 and 2 material for medical research. The issues which
include: 1) Determining if the radium-226 can be separated from Silos 1 and
2 material in a medically usable form; 2) Identifying the risk to workers, the
public, and the environment posed by recovery of radium-226; and 3)
Quantifying the costs for recovery of radium-226.
The Silos 1 and 2 material is the most radioactive waste at the FEMP site and
the top priority in the overall cleanup. The CERCLA mandate to protect human
health and the environment requires that DOE move forward with efforts to
clean-up the FEMP site and make the surrounding community a safer place to
live. Therefore, DOE is moving forward with implementation of the chemical
stabilization technology for the remediation of Silos 1 and 2
B.3-14
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
material. However, DOE Office of Nuclear Energy Isotope Production and
Distribution will continue to monitor the progress and maintain its support of
utilizing radioactive material in cancer research.
On June 9,2000, DOE issued a news release announcing steps to expand the
Energy Department's capacity to provide the bismuth-213 isotope extracted
from radioactive materials used in nuclear activities to be used in clinical trials
for the treatment of several forms of cancer. Plans call for increasing the supply
of the isotope bismuth-213, a decay product of uranium-233 currently in storage
at the DOE's Oak Ridge National Laboratory (ORNL), and make it available for
use in an expanded cancer treatment research project.
In the near-term, as funds are available, the DOE plans to increase the supply
of the bismuth-213 by up to 30 percent over the next year and hopes to double
its supply by 2002. Initially, the DOE plans to use the existing extraction and
process line at ORNL. The DOE is also planning some long-term actions that
would allow for future decisions on the extraction of additional isotopes from
larger quantities of uranium-233 at ORNL.
B.3-15
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
Issue:
Comment: Concerns were expressed that the implementation of the selected remedy be
performed in manner protective of human health (both worker and the public)
and the environment.
Response: The contract for the remediation of the Silos 1 and 2 material will require the
Contractor to implement the selected remedy in accordance with applicable
and relevant and appropriate requirements (ARARs), to be considered criteria,
and other requirements [i.e., Occupational Safety and Health Administration,
Department of Transportation (DOT)] that are protective of human health (both
workers and the public) and the environment. These requirements are identified
in the ROD Amendment and the RFP. DOE, the OEPA, and EPA will all
oversee remediation operations to ensure the compliance with identified
requirements and ensure protection of human health and the environment is
maintained.
Issue:
Comment: Concern was expressed that the treated Silos 1 and 2 material not be disposed
in the FEMP OSDF, in the event the NTS was closed for disposal.
Response: Treated Silos 1 and 2 waste and debris from the concrete structures of Silos
1 and 2 are specifically excluded from on-site disposal by the WAC for the
OSDF. Therefore, neither treated Silos 1 and 2 waste nor concrete structures
of Silos 1 and 2 can be disposed in the OSDF. Treated Silos 1 and 2 waste
and debris from concrete structures of Silos 1 and 2 must be disposed at either
the NTS or an appropriately permitted commercial disposal facility.
B.3-16
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
Issue:
Comment: During the evaluation of vitrification, more emphasis could have been given to
the experience of the commercial glass industry in the areas of short-term
effectiveness and implementability.
Response: It is DOE's position that the 15 tons per day melter design, proposed in the
revised FS, exceeded the known limit of the joule-heated vitrification
technology's demonstrated capability on similar wastestreams to Silos 1 and
2 material by a factor of 3 (M-Area melter was 5 tons per day). DOE recognizes
that joule-heated vitrification commercial glass plants routinely operate, at
production rates in excess of 100 tons per day. However, full credit for this
experience cannot be recognized since the commercial glassmaking
feedstreams are very homogeneous to ensure quality control. DOE, Fluor
Fernald, Inc., EPA, and OEPA did not elect to accept the increased risk
associated with the higher capacity melters for use in treating heterogeneous
radioactive or hazardous wastestreams, since none have been demonstrated
at this time.
Issue:
H
Comment: A comment was raised in regard to the evaluation of energy consumption in
comparing vitrification and chemical stabilizations.
B.3-17
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
Response: Energy consumption is evaluated as a sub-criterion to the NCR criterion of
implementability. Based on the evaluation of the two technologies energy
consumption was not considered a discriminating factor. From an operations
viewpoint, vitrification is a greater consumer of energy than chemical
stabilization due to the high operating temperatures and energy needs.
However, chemical stabilization is a greater consumer of energy when
evaluating transportation of treated waste to the NTS due to the larger volume
of treated waste produced. The advantages displayed by chemical stabilization
during operation and the advantages displayed by vitrification with
transportation of treated waste negate each other resulting in energy
consumption being a non-discriminating factor.
Issue:
I
Comment: The rationale for storage of radioactive waste at the NTS should not be
supported because of the isolation of Southern Nevada (which is changing
rapidly) but rather because the disposal facility will be designed to ensure that
the resident population potentially impacted will be protected.
B.3-18
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
Response: In letter dated August 10, 1999, from Frank Di Sanza, DOE-Nevada Field
Operations (NV) to Paul Liebendorfer, Division of Environmental Protection, the
State of Nevada concurred that Silos 1 and 2 material should be considered
small quantity 11 (e)(2) byproduct material per DOE Order 435.1. As such the
letter states that acceptance of the Silos 1 and 2 material for disposal be
contingent upon its ability to meet the NTS WAC. By stating the disposal
requirements must be met, means the 11(e)(2) byproduct material must be
included in the performance assessment (PA) and composite analysis of the
NTS, that adequate controls are established for the wastestream based on the
evaluations, and the minimum disposal requirements be met. DOE Guidance
435.1 -1 uses the Fernald silo material as an example to illustrate this by stating,
"Sufficient capacity is available to dispose of the amount of the waste to be
generated. The waste is included in the performance assessment and
composite analysis, and controls are established. These include provisions for
stabilizing the waste and placing it in specially designed boxes, for additional
analysis of the cover that will eventually be placed on the disposal unit used, and
for additional information in the records for the disposal facility concerning the
nature of the waste in this specific disposal unit."
Long-term effects of waste disposal and necessary engineering and
administrative controls that need to be incorporated into the design of the
disposal cell will be determined based on results of a PA conducted by the
NTS. The NTS has previously conducted a PA on the Area #5 Radioactive
Waste Management Site (Area #5). The PA resulted in the establishment of
volumetric radionuclide concentration limits for acceptance for disposal in Area
#5. In addition, the PA indicated that the risk of potential exposure to the public
from waste disposal activities through surface water is not significant.
B.3-19
-------
Issue:
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
An informal review of the Area #5 PA indicates that chemically stabilized Silos
1 and 2 waste would meet the radionuclide concentration limits. Upon design
of the treatment process for Silos 1 and 2, a final review of the treated Silos 1
and 2 waste against the Area #5 concentration limits will be conducted to
confirm Area #5 at the NTS remains suitable for disposal of treated Silos 1 and
2 waste. If the treated Silos 1 and 2 waste would fail to meet the radionuclide
concentration lim its for Area #5, a PA specific to the characteristics associated
with treated Silos 1 and 2 waste would be conducted by the NTS to
demonstrate the selected disposal location and configuration meets the
long-term performance objectives specified by DOE Order 435.1.
Comment: The revised PP should document how the Chemical Stabilization process
proposed at Fernald will, if selected, avoid the degradation that occurred at the
Rocky Flats facility.
Response: Based on the "Proceedings of the Workshop on Radioactive, Hazardous,
and/or Mixed Waste Sludge Management," dated January 1992, the primary
reasons for some of the Rocky Flats "Pondcrete" product failures were
problems with quality control and process control requirements.
B.3-20
-------
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
Strict quality control and process control requirements will be incorporated into
the contract for remediating Silos 1 and 2 material. The RFP for the
remediation of the Silos 1 and 2 material will require the Contractor to
demonstrate their proposed formulation through treatability testing before
beginning actual treatment operations. The Contractor would be required to
implement a process control philosophy (i.e., sampling and analysis, quality
control, and configuration management) based on its process treatment formula
chemistry to ensure the treated waste meets the NTS WAC.
Issue:
K
Comment: Since the majority of Fernald shipments may occur during the same time frame
as shipments from other sites, DOE needs to evaluate these shipments in a
cumulative sense. In addition to listing shipments from Fernald, DOE must
provide information to enable the public to understand the totality of shipments
from DOE sites to the NTS to enable the public and governments to understand
how these shipments add to the risk.
Response: The "Final Environmental Impact Statement for the Nevada Test Site and
Off-site Locations in the State of Nevada," Appendix I, dated August 1996,
evaluated the risk to the public resulting from the transportation of radioactive
waste to the NTS. The "Record of Decision: Environmental Impact Statement
for the Nevada Test Site and Off-site Locations in State of Nevada" states:
B.3-21
-------
Issue:
FEMP-OU4-RODA FINAL
40700-RP-0008
JUNE 2000, Rev. 0
"Impacts from vehicle transportation of materials to and from the Nevada Test
Site have been analyzed, including Defense Program nuclear material and
waste management activities related to radioactive wastes and hazardous
materials. The majority of the postulated injuries and fatalities in this analysis
would be a result of traffic accidents and not a result of exposure to the
transported material or waste. The results of the transportation risk analysis
show that the human health risks from the transportation of material or waste
are low under any alternative, and are not significant contributors to the total risk
from all operations under these alternatives."
DOE is committed to the safe transport of treated Silos 1 and 2 waste to the
NTS for disposal. Prior to leaving the FEMP, all shipments would be inspected
(e.g., surface radiation levels, proper securing of package) to ensure the
packaging complies with DOT requirements for shipping radioactive material
(49 CFR Part 173 Subpart I). The routes have been selected in accordance
with DOT regulations that require routes be selected based on their ability to
minimize radiological risk (49 CFR Section 379.101), and are consistent with
those routes agreed upon by DOE and stakeholders.
Comment: Community acceptance, of course, should be more than the statements of those
attending public hearings. It should be the total record of meetings with
communities and stakeholders. The record of community acceptance should
be derived from a number of sources and not merely the results of one hearing.
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Response: DOE has included public involvement throughout the remedy selection process.
Public involvement has included observation of the POP Testing and review of
POP test reports and the revised FS design basis by an independent technical
review team, who provided feedback to the public. In addition, public briefings
have been held throughout the remedy selection process at both the FEMP and
Las Vegas, Nevada. Throughout the process DOE has discussed and
incorporated those issues deemed to be important to stakeholders. Table 9.1 -1
of the revised PP presents a summary of the public involvement opportunities
in the remedy selection process for Silos 1 and 2.
In addition to the public having the opportunity to provide oral comments at the
April 25 and May 3, 2000, public hearings, the public has been provided the
opportunity to provide written comments between April 3 and May 18,2000 as
part of the public review process. DOE also conducts monthly briefings with the
public to provide status of remediation activities at Fernald and to provide the
public the opportunity to voice concerns.
Issue:
M
Comment: Concerns were raised in regard to minimizing risk to the public during
transportation. This included evaluating intermodal transportation.
Response: DOE is committed to the safe transport of treated Silos 1 and 2 waste to the
NTS for disposal. Prior to leaving the FEMP, all shipments would be inspected
(e.g., surface radiation levels, proper securing of package) to ensure the
packaging complies with DOE requirements for shipping radioactive material
(49 CFR Part 173 Subpart I. The routes have been selected in accordance with
DOT regulations that require routes be selected
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based on their ability to minimize radiological risk (49 CFR Section 379.101),
and are consistent with those routes agreed upon by DOE and stakeholders.
The FEMP has an established shipping program to the NTS using direct truck
shipments. Therefore, forcosting purposes, the evaluation assumed direct truck
shipments to the NTS. Although costs associated with intermodal transport
were not evaluated as part of this revised FS, the potential risks associated
with intermodal transport were evaluated as part of Appendix E, Summary of
Packaging and Transportation Evaluation, of the revised FS.
Issue: N
Comment: Comments were made in regard to evaluation of risk to workers and the public
in comparing vitrification and chemical stabilization. In particular, it was stated
that safety record in the commercial glass-making industry should be
considered in the evaluation.
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Response: In the evaluation of risk to workers and the public, vitrification displayed an
advantage over chemical stabilization in regard to risk to the public during
transportation. This is due to the volume reduction associated with vitrification
resulting in fewer shipments. However, the advantages displayed by vitrification
in regard to transportation risk are outweighed by the advantages displayed by
chemical stabilization over vitrification in regard to worker risk. As part of the
evaluation process an occupational hazard analysis was performed on the each
alternative. Based on the analysis it was determined that chemical stabilization
presented fewer physical hazards to workers. Because vitrification is a more
complex process in relation to chemical stabilization, it presents more physical
hazards to workers that must be managed through either engineering or
administrative controls.
Issue:
0
Comment: The remediation of Silos 1 and 2 material needs to include environmental
health physics analysis focusing on all radionuclides, but particularly on
radium-226 and releases of radon-222, in Silos 1 and 2 material.
Response: DOE agrees that environmental monitoring is an important aspect of ensuring
protection of human health and the environment during remediation activities.
The DOE has evaluated the current radon monitoring configuration in the Silos
Project Area. The evaluation considered the upcoming remediation activities
of Silo 3, the Accelerated Waste Retrieval (AWR) Project and the full-scale
Silos 1 and 2 remediation facilities. It has been determined that the current
configuration and quantity of the radon monitors was inadequate to monitor the
effectiveness of the environmental controls of the anticipated remediation
activities.
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The DOE and OEPA have agreed on a plan to upgrade the current radon
monitoring system to address anticipated deficiencies. The DOE has recently
augmented the staffing of an independent technical review team to include a
new member who will focus efforts on evaluating the effectiveness of proposed
engineering controls and monitoring systems used by the Silo 3, AWR and
Silos 1 and 2 Projects to address radon and particulate emissions. Based upon
the review of the independent technical review team, additional changes may
be implemented by the Silos Projects.
Issue:
Comment: It is uncertain in the documents whether the chemical stabilization material will
meet the State of Nevada Waste Acceptance Criteria.
Response: In letter dated August 10, 1999, from Frank Di Sanza, DOE-NV to Paul
Liebendorfer, Division of Environmental Protection, the State of Nevada
concurred that Silos 1 and 2 material should be considered small quantity
11 (e)(2) byproduct material per DOE Order 435.1. As such the letter states that
acceptance of the Silos 1 and 2 material for disposal be contingent upon its
ability to meet the NTS WAC. This requires that the Silos 1 and 2 material be
treated so that it no longer exhibits the toxicity characteristic. As documented
in the RI/FS for OU4, the principal chemical constituent of concern for Silos 1
and 2 material and the focus for stabilization of the material is lead, whose
concentration in leachate can exceed limits prescribed under RCRA. Based on
the results of POP testing, as well as treatability tests conducted during the FS
process, chemical stabilization can effectively treat Silos 1 and 2 material to
meet the NTS WAC.
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Q
Comment: While it appears that DOE/Fernald is actively involved in encouraging certain
routes for the transportation of the waste to be used, it is unclear why, based on
the experience of the Waste Isolation Pilot Project with the transportation of
waste, that routes cannot be specified in contracts. Also needing to be noted
is how DOE/Fernald intends on monitoring the shipments to ensure that their
carriers comply with the routing designations and DOT criteria. Tourism is, of
course, Nevada's bread and butter. Given the fact that rightly or wrongly the
public does not distinguish between the types of low-level radioactive waste, it
is important that DOE avoid situations that could potentially adversely impact
our economy and quality of life.
Response: The final selection of routes to transport radioactive material is the responsibility
of the carrier. The DOT regulations under 49 CFR Section 379.101 (a) state:
"Except as provided in paragraph (b) of this section or in circumstances when
there is only one practicable highway route available, considering operating
necessity and safety, a carrier or any person operating a motor vehicle that
contains a Class 7 (radioactive) material, as defined in 49 CFR 172.403, for
which placarding is required under 49 CFR part 172 shall: (1) Ensure that the
motor vehicle is operated on routes that minimize radiological risk."
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Last minute route detours may be required to avoid construction, vehicular
accidents, or inclement weather. The routes have been selected in accordance
with DOT regulations that require routes be selected based on their ability to
minimize radiological risk (49 CFR Section 379.101), and are consistent with
those routes agreed upon by DOE-and stakeholders. Prior to leaving the
FEMP, all shipments would be prepared and inspected to ensure compliance
with DOT requirements for shipping radioactive material (49 CFR Part 173
Subpart I). Compliance includes, but is not limited to, ensuring packaging
maintains radiation levels with DOT specified limits; ensuring shipping papers
have been prepared properly, ensuring container is marked and labeled
properly, and ensuring the transport vehicle is properly placarded.
Issue:
R
Comment: Fernald, and other sites, in remediating their sites adds to the burden of the
NTS and Nevadans. To restore equity as well as to ensure that future
stewardship costs are defrayed, it is important that cost savings at sites being
remediated are made available to the NTS to defray future stewardship costs.
Response: The NTS is a vital link in the DOE-complex environmental restoration mission.
The NTS, as well as other DOE-owned sites are subject to annual funding
requests and federal budgetary approvals by Congress. As such, it is expected
that DOE will continue to request funding on an annual basis to support its
stewardship duties and obligations at the NTS including:
Ensuring safe and compliant storage and disposal of radioactive waste;
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Protecting the environment and personnel from chemical and
radiological hazards in accordance with 40 CFR, RCRA; 10 CFR Part
835, "Occupational Radiation Protection;" DOE Order 435.1,
"Radioactive Waste Management;" state of Nevada and applicable
DOT regulations;
Ensuring that present and future radiation exposures are kept as low as
reasonably achievable and do not exceed the radiation protection
standards established in 10 CFR Part 835, "Occupational Radiation
Protection;"
Ensuring Quality Assurance programs are established and implemented
to fulfill the requirements of DOE Order 435.1, "Radioactive Waste
Management;" and 10 CFR Section 830.120, "Quality Assurance;" and
Being consistent with applicable federal, state, and local regulations.
Issue: S
Comment: Concerns were raised regarding time to completion (time to achieve
protectiveness) as a criterion for evaluating the alternatives. In addition it was
stated that vitrification could accelerate schedule by utilizing a larger melter.
Response: The basis for the project schedules presented in the FS for all four alternatives
was established on historical experience with remediation projects conducted
at the FEMP under CERCLA and DOE Radiological and Safety Programs.
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The time period between the approval of the ROD amendment and the initiation
of treatment operations (i.e., design, construction, construction acceptance
testing, pre-operations, and start-up) for the Silos 1 and 2 remediation is
estimated to be 62 months for vitrification, compared to 54 months for chemical
stabilization. The difference of eight months between the two schedules is
primarily attributed to the time required, based upon lessons learned during
start-up of DOE vitrification facilities, to perform Proof of Process testing during
start-up of the vitrification facility.
The 15 tons per day melter design, proposed in the revised FS, exceeded the
known limit of thejoule-heated vitrification technology's demonstrated capability
on similar wastestreams to Silos 1 and 2 material by a factor of 3 (M-Area
melter was 5 tons per day). DOE recognizes that joule-heated vitrification
commercial glass plants operate continuously, at production rates in excess of
100 tons per day, however, full credit for this experience cannot be recognized
since the commercial glassmaking feedstreams are very homogenous to
ensure quality control. DOE, Fluor Fernald, Inc., EPA, and OEPA did not elect
to accept the increased risk associated with the higher capacity melters for use
in treating heterogeneous radioactive or hazardous wastestreams, since none
have been demonstrated at this time.
Issue:
T
Comment: The large volume reduction offered by vitrification should have been given more
weight. Vitrification technology excelled in this area based on the desire of
DOE to minimize the wasteform produced. Based on the success in reducing
the volume of treated waste, and the demonstrated performance of the wastes,
the vitrification technology should be "Strongly Favored" for this criterion.
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Response: DOE agrees that vitrification has an advantage over chemical stabilization with
regard to reduction in volume of treated waste. However, both technologies
were equal in their ability to reduce the mobility of lead based on TCLP results.
Therefore, vitrification was given a "Favors" rating for the criterion of reduction
of toxicity, mobility, or volume through treatment.
Chemical stabilization is recommended as the preferred treatment alternative
because it meets the threshold criteria and provides the best balance of
tradeoffs compared to vitrification with respect to the five balancing criteria.
Specifically, the advantages of chemical stabilization in implementability
(commercial demonstration, operability, ease of acceleration, and
constructability) and short-term effectiveness (worker risk and time to
protection) are judged to outweigh the advantages of vitrification due to its
lower treated waste volume.
Issue:
U
Comment: The amount of secondary waste generated by vitrification technologies is very
similar to that from chemical stabilization. These differences are insignificant
in terms of the total waste generated, and do not justify a "Favorable" rating for
the stabilization technologies.
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Response: DOE agrees with this statement. As presented in Figure 8.1-1 of the revised
PP that was issued for public review, the subcriterion of "Secondary Waste
Generation" was given a "Neutral" rating between the technologies. However,
the vitrification technologies have the greater potential to generate secondary
wastestreams, which although their volume is relatively small, are more difficult
to handle and to treat for disposal (i.e., salts, reduced metals, spent refractory,
mixed waste).
Issue:
V
Comment: Statements relative to radon release are true; however, they omit recognition
that the overall amount of radon released from the vitrified wasteform throughout
its lifetime will be far less than that released by the chemically stabilized
wasteform.
Response: The cited text by the reviewer refers to a short-term effectiveness discussion in
the revised PP, Section 7.2.2.3. The reviewer's concern is addressed by the
revised PP in the last paragraph of Section 7.2.2.2, Long-term Effectiveness
and Permanence, which states:
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"The vitrified Silos 1 and 2 material reduces radon emanation more effectively
than does the chemically stabilized material. However, the combination of
radon mitigation provided by the chemically stabilized material plus the
engineered barriers and packaging associated with the disposal of treated
materials, effectively controls radon emanation. Both alternatives provide
effective control of radon emanation from the treated Silos 1 and 2 material.
The impact of radon emissions during remediation is evaluated as part of the
short-term effectiveness criterion."
In addition, Section 7.2.1.2 of the revised PP, under the discussion of
compliance with chemical-specificARARs, states:
"Both vitrification and chemical stabilization technologies meet the chemical-
specific ARARs associated with potential releases to groundwater, surface
water, and air. The most critical chemical-specific ARAR relative to airborne
releases relates to radon. The primary limit on radon emanation is the flux limit
specified in National Emissions Standards for Hazardous Air Pollutants, 40
CFR Part 61 Subpart Q, of 20 picoCuries per square meter-second. This limit
applies to interim storage or final disposal of Silos 1 and 2 material. Both
alternatives meet this ARAR during interim storage and after disposal. Both
alternatives meet requirements for control of radon, particulate, and other air
emissions from remediation activities through incorporation of necessary
air-emission treatment. The impact of radon emissions during remediation is
evaluated as part of the short-term effectiveness criterion."
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w
Comment: A comment was raised regarding the evaluation of implementability between
the alternatives. In particular, concerns were raised regarding the evaluation of
operability and controllability, process reliability, and process control, and the
exclusion of commercial glass-making experience for evaluating vitrification.
Response: It is stated in the revised FS and revised PP documents that both technology
families (VIT and CHEM) could treat the Silos 1 and 2 material and that both
technology families would face challenges during implementation of the
technology.
Both vitrification and chemical stabilization are difficult to implement because
of the nature of the Silos 1 and 2 material requiring remote operations.
However, operational risks for both can be controlled. Chemical stabilization is
preferred because there is more demonstrated commercial experience with
this technology, it is less complex than vitrification and therefore more certain
in its ability to be successfully implemented, and it offers the opportunity for
schedule acceleration and recovery in the event of unplanned downtime.
Both vitrification and chemical stabilization have encountered difficulties in
treating radioactive wastes in the DOE-complex. However, there is significantly
more demonstrated experience in the commercial sector with the chemical
stabilization technology than with the vitrification technology. In addition, based
on evaluation of existing facilities, the production rate proposed
for the vitrification process is at the limit of the current capacity of existing
vitrification facilities treating radioactive material, while the
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production rate proposed for the chemical stabilization process is within limits
of the current capacity of existing chemical stabilization facilities.
To treat Silos 1 and 2 material within a three-year time period, the vitrification
process would have to produce 15 tons of vitrified material per day. Within the
limited experience of the vitrification technology, there are no facilities in the
DOE-complex and only two facilities in the commercial sector operating at the
required capacity. This limited experience at the required capacity results in
increased uncertainty as to whether the current technology has the capability to
treat Silos 1 and 2 material at the required capacity. In comparison, to treat
Silos 1 and 2 material within a three-year time period, the chemical stabilization
process would have to process 12 cubic yards of Silos 1 and 2 material per
day. There have been a number of chemical stabilization facilities in both the
DOE-complex and the commercial sector that have operated at the required
capacity. Because there is a greater degree of commercial demonstration of
the chemical stabilization process at the required capacity, there is less
uncertainty in its ability to treat Silos 1 and 2 at the required capacity.
Vitrification has more unit operations associated with it than chemical
stabilization and is therefore considered to be more complex to operate than
chemicalstabilization. The integrated operation of complex systems associated
with the vitrification process increases the likelihood of process upsets and
resulting downtime. In addition, the complexity of process control associated
with vitrification complicates melter operation. Included in the complexity of the
process control are critical parameters that are not readily measured, such as
viscosity, electrical conductivity, liquidus temperature, and sulfate formation.
Furthermore, as stated under the discussion of short-term effectiveness, the
hazards inherent to the
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vitrification process increase the risk to the worker during maintenance
activities.
The two vitrification processes propose to operate 24-hours per day for seven
days per week for three years. The two chemical stabilization processes
propose to operate 16 to 24 hr/day for 5 days/week for three years. Based on
the current designs, the chemical stabilization process has a better opportunity
to improve schedule and accelerate remediation. In addition, based on current
designs, the chemical stabilization has a better opportunity to recover from
process upsets or other downtime.
Based on the above evaluation, chemical stabilization is the preferred
alternative to implement. Chemical stabilization has a greater degree of
commercial demonstration at the required capacity, is less complex to operate,
and provides more opportunity to recover from process upsets and other
downtime, as well as more opportunity to improve schedule.
Issue:
X
Comment: The VIT1 evaluation should be reassessed to include an optimized container
and associated changes such as fritting as favored by optimization. The VIT1
design approach submitted by Envitco relied on a qualified container design
as described in the POP test report. This container design was utilized at the
suggestion of Fluor Fernald, Inc., and Envitco understood that all technology
providers would utilize this container.
Response: Packaging of treated Silos 1 and 2 material was evaluated for two reasons in
the revised FS: 1) to determine impacts on cost from packaging, transportation,
and disposal; and 2) to determine impacts on short-term risk to the public
during transportation. Based on the evaluation presented in the
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revised FS, cost was determined not to be a discriminating factor in the
selection of the treatment technology.
The selected container was an appropriate container to use as a basis for a
CERCLA feasibility study. The container had been designed and tested to
meet the requirements of a DOT 7A-Type A container. The container had also
been designed to provide the shielding necessary to meet the DOT radiation
level limits for shipping radioactive material. Although the container had been
designed to be optimized for vitrified gems, based on the evaluation in the
revised FS, the container would provide approximately an 80% packaging
efficiency for vitrified monoliths in molds. All four proposed containers could be
optimized further from what is presented in the revised FS. However, further
optimization would not result in any modification to the conclusions presented
in the revised FS or the revised PP.
Most of the POP vendors recognized that waste loading was a fundamental
parameter, which affected shielding requirements and packaging efficiency.
For the wasteforms with lower waste loadings (i.e., CHEM1, CHEM2), this
effect was less. However, these alternatives produced three times the waste
volume of the vitrification alternatives, and three times the shipments. Evaluation
of risks to the public during transportation based on the four proposed container
designs and wasteforms indicate that the treated waste can be shipped to the
NTS with minimal risk to the public.
Further optimization of the four containers would not modify the conclusions that
cost is not a discriminating factor and that vitrification is favored over chemical
stabilization for the criterion of transportation risk.
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Y
Comment: The cost data appearing in the revised FS for VIT1 was significantly different
than that presented in the Public Workshop in November 1999. VIT1 costs
increased by over 25%, primarily due to cost of money and operation and
maintenance costs. This magnitude of change did not appear in the cost
assessments for the other technologies. It was not obvious why this would differ
for the different technologies.
Response: The cost information presented in the November 1999 public workshop was
only a "snapshot" of work in progress. The cost estimates were finalized after
incorporating independent review teams' comments in December 1999 and the
entire revised FS was submitted to the EPA. The final revised FS cost
estimates for all four alternatives include modified cost of money calculations
and documented operational risk costs which account for the noted cost
increase in the four alternatives.
The cost estimates are summarized in Volume 2 of the revised FS. The revised
FS cost estimates are comprehensive and reflect the scope.
The conceptual designs and supporting cost estimates in the revised FS have
been reviewed by independent technical review teams and cost experts. The
cost estimates supporting the revised FS were found to be a fair and
reasonable representation of the cost of performing these remediation projects
at the FEMP under a regulated and DOE Radiological and Safety Programs.
Project cost was not considered to be a discriminating factor between the VIT
and CHEM alternatives, because the difference between the two technology
families is 16% and the level of accuracy of the estimates is + 50/-30%.
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Issue:
Comment: It was stated that the VIT1 alternative should be re-evaluated based on a 30 ton
per day melter and the production of frit.
Response: It is DOE's position that the 15 tons per day melter design, proposed in the
revised FS exceeded the known limit of the joule-heated vitrification
technology's demonstrated capability on similar wastestreams to Silos 1 and
2 material by a factor of 3 (M-Area melter was 5 tons per day). A 30 tons per
day would exceed the demonstrated capability by a factor of 6. DOE
recognizes that joule-heated vitrification commercial glass plants routinely
operate, at production rates in excess of 100 tons per day. However, full credit
for this experience cannot be recognized since the commercial glassmaking
feedstreams are very homogeneous to ensure quality control. DOE, Fluor
Fernald, Inc., EPA, and OEPA did not elect to accept the increased risk
associated with the higher capacity melters for use in treating heterogeneous
radioactive or hazardous wastestreams, since none have been demonstrated
at this time.
Issue:
AA
Comment: A comment was issued regarding the representativeness of vitrification
technologies evaluated in the revised FS. In particular, it was stated that the
specific vitrification technologies evaluated are not representative of vitrification
technologies that have been specifically developed for treating earthen
materials such as the Silos 1 and 2 materials.
Response: The joule-heated vitrification technology evaluated in the revised FS and
revised PP was the same representative technology evaluated in the FS and
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PP and ultimately the technology selected as the treatment remedy in the OU4
ROD.
Issue:
The revised FS and revised PP evaluated a wide range of representative
vitrification technologies (i.e., cyclone, plasma arc, insitu) in order to develop
a broader evaluation for the technology family.
In support of the revised FS, the POP Testing Program evaluated the range of
technically representative vitrification technologies (joule-heated, cyclone,
plasma arc and insitu) for pilot-scale testing. The data from the pilot-scale
testing was used with other data, including Geosafe provided information to
evaluate the vitrification technology in the revised FS and revised PP. The
GeoMelt technology was determined to be a representative vitrification
technology. However, through the POP competitive bid process, GeoMelt was
not selected for POP testing.
BB
Comment: A comment was issued stating the ROD should be revised to include off-site
treatment as an alternative.
Response: The off-site treatment option was evaluated as part of the screening of
alternatives in Section 2 of the revised FS. A Commerce Business Daily
announcement was published requesting responses from vendors expressing
an interest in the off-site treatment of the Silos 1 and 2 material. Although a
small number of expressions of interest were received, review of the
documentation provided by the facilities indicated that none possessed both
adequate current treatment capacity and adequate licensing. The lack of off-site
commercial treatment facilities capable of accepting Silos 1 and 2 material,
limits the involvement of the regulators, and the public in selection
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of an off-site treatment process during the post-ROD process and results in a
significant risk in the ability to implement treatment in a timely manner.
Therefore, off-site treatment has been excluded from further consideration as
an alternative for the Silos 1 and 2 material.
Should an off-site treatment facility be identified during post-ROD remedial
activities, the CERCLA process allows for the continued evaluation of a cleanup
decision, as new information is identified.
Issue: CC
Comment: The basis for development of alternatives is said to have included "Commercial
and DOE-complex experience..." It is obvious from the revised FS and the
revised PP that this statement is not true relative to vitrification technologies.
Geosafe has provided information on its GeoMelt vitrification technology to
DOE and Fluor Fernald, Inc., several times; and it is apparent that this
technology has been ignored by the studies. This technology has been used
commercially on hazardous and radioactive waste more than any other
vitrification technology.
Response: DOE did consider the GeoMelt system during the decision-making process and
determ ined GeoMelt to be a representative vitrification technology. Although the
GeoMelt system was not selected for POP testing, this did not preclude the
GeoMelt system from being considered as a viable option should vitrification
have been selected as the preferred remedy for Silos 1 and 2 material. As
stated in Section 6 of the revised PP, under the discussion of each process
option evaluated, "The treatment system described in this section is based
upon data and other information compiled from POP testing and has been
developed as a viable way to implement this alternative. Equivalent systems
may exist and are not precluded from
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consideration, consistent with the final selected remedy, during remedial
design."
In addition, DOE conducted a search identifying remedial sites across the U.S.
and abroad where vitrification and chemical stabilization treatment technologies
have been applied to the remediation of hazardous (lead contaminated) and/or
radioactive material. Tables 3.1-2 through 3.1-5 of the revised FS presents a
list of examples where the application of both vitrification and chemical
stabilization technologies were applied to wastestreams that are reasonably
similar to the Silos 1 and 2 material. The tables, as stated above, are a list of
examples not an all-inclusive list of applications. Although not specifically listed
in the tables, the information provided by Geosafe as part of its POP proposal
was considered by DOE in the evaluation of vitrification.
Issue:
DD
Comment: A concern was raised regarding the issuance of proper notice for the public
hearing process and the perceived short response period regarding the public
hearing.
Response: Per requirements in 40 CFR Section 300.430(f)(3)(i) of the NCP, the lead
agency is required to publish a notice of availability and brief analysis of the PP
in a major local newspaper. The NCP also allows the public a minimum of 30
calendar days to provide written and oral comments on the PP and material
contained in the Administrative Record. In addition, the NCP requires a public
meeting be held during the public comment period.
As the lead agency at the FEMP, the DOE, in accordance with NCP
requirements, issued notices in major local newspapers both in the area
surrounding the FEMP and the area surrounding the NTS. Notices were
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published in three newspapers surrounding the FEMP: the Harrison Press
(March 29, 2000); the Hamilton Journal-News (March 30, 2000); and the
Cincinnati Enquirer (April 2,2000). Notices were published in two newspapers
surrounding the NTS: the Pahrump Valley Times (March 31,2000) and the Las
Vegas Review-Journal (April 1, 2000). Copies of these notices are provided
in Attachment B.IV of Appendix B of this ROD Amendment. The notices
provide information of the time period for the public comment period, which ran
from April 3 through May 18,2000. In addition, the notices provided information
regarding the location and date for the public hearing held in both respective
areas (i.e., FEMP S April 25 and NTS S May 3).
B.3-43
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1
2 ATTACHMENT B.I
3
4
5 FLUOR DANIEL FERNALD
6
7 PUBLIC HEARING
8
9 PROPOSED PLAN FOR REMEDIAL ACTIONS AT
10 SILOS 1 AND 2
11
12
13 APRIL 25, 2000
14 6:30 P.M.
15
16 Alpha Building
17 10967 Hamilton-Cleves Highway
18 Harrison, Ohio
19
20
21
22
23
24
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1 MR. STEGNER: Good evening everyone
2 and thanks for coming. My name is Gary Stegner, I
3 work in Public Affairs for the Department of Energy
4 at Fernald.
5 The purpose of the meeting tonight is
6 to conduct a formal public hearing on the revised
7 proposed plan for Fernald's Operable Unit 4, which
8 includes Silos 1 and 2, also known as K-65 silos.
9 I want to emphasize that the scope of tonight's
10 meeting is exclusively OU-4, and that is the
11 subject we will be discussing for the duration of
12 the meeting.
13 With me tonight are Nina Akgunduz.
14 She's the Department of Energy's Project Manager
15 for the silos project, and Terry Hagen, who is the
16 Fluor Fernald Vice President for Site Closure.
17 I try to remind everybody to please
18 sign the attendance roster, and if you have, I
19 appreciate that. Also hope you've indicated
20 whether or not you want to speak this evening
21 during the formal public hearing portion of
22 tonight. I want to emphasize that you do not have
23 to speak tonight in order for your comments or
24 questions to become part of the public record.
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1 Written comments can be submitted this evening,
2 they can be submitted anytime before the end of the
3 comment period, which is May 18th. You can send
4 those to me at the site or you can fax them to me
5 at the site. My fax number is 648-3073.
6 We have scheduled two hours tonight
7 to allow maximum time for questions and comments.
8 We'll take more time if necessary. Before we begin
9 the formal public hearing, we will present a brief
10 overview of the project, followed by a short
11 informal question and answer session.
12 Also with us tonight we have Don
13 Payne and Dennis Nixon, who will be able to answer
14 questions during the informal question and answer
15 period.
16 Prior to going into the formal public
17 hearing, we will have a break. We will do that a
18 little bit differently. Because this is a formal
19 hearing, we do have a court reporter present. A
20 copy of the transcript should be available in the
21 Public Environmental Information Center within the
22 next two weeks, more or less, and we will let you
23 know when it's in there through one of our
24 mailings.
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1 When we do receive your formal
2 comments, they will be addressed in a formal
3 responsiveness summary. That will be a part of,
4 also part of the Record of Decision document.
5 You can't hear me? We're turning it
6 up. I'll hold it closer. Is it okay now, Carol?
7 Is it okay now, folks? Better?
8 Thanks, Carol. Sorry.
9 With that, let's now go into the
10 overview portion of it. This will take probably —
11 We'll begin with the video, approximately 12 to 15
12 minutes. That will be followed by a presentation
13 by Terry, and then an informal question and answer
14 session, and following that we will take a break
15 and proceed to the formal public hearing. So with
16 that, Terry.
17 (Playing of video.)
18 MR. STEGNER: This video was
19 produced at the request of stakeholders from Nevada
20 to really present a very succinct overview of the
21 project for their stakeholders.
22 Following Terry's presentation, we
23 will go into an informal question and answer
24 session. Once we go into the formal public comment
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1 slot this evening, we will not be responding at
2 that time. We will simply be in a listening and
3 recording mode then. So if you have questions,
4 please raise them during the informal question and
5 comment period.
6 We would ask that, in the interest of
7 time, hold your questions until Terry's
8 presentation is completed, and we will respond to
9 all during the informal question and comment
10 period. Terry.
11 MR.HAGEN: What I'd like to do is
12 summarize the information that was presented in the
13 video and in some instances supplement it with some
14 additional detail against the evaluation criteria
15 that CERCLA requires us to use when we evaluate and
16 select remedies. For those of you who have been
17 with us through this long process, this is going to
18 in essence be a repeat of what we talked about the
19 last time we were together.
20 The CERCLA decision-making criteria
21 are called the nine criteria, and you see them
22 here. They're broken up into three categories.
23 The first two are called threshold criteria, and
24 what that means is by EPA promulgated regulation
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1 you cannot select a remedy that does not meet
2 adequately these two threshold criteria, the first
3 two on the overhead, overall protection of human
4 health and the environment and compliance with
5 applicable or relevant and appropriate
6 requirements. If a potential alternative is
7 demonstrated to meet those threshold criteria, then
8 it's eligible for further evaluation against what
9 are called the balancing criteria. That's the next
10 five.
11 What you are looking for is a
12 qualitative assessment of the trade-offs among
13 those. There's nothing in the guidance that says
14 among these next five balancing criteria one is
15 more important than the other, nor does the
16 guidance tell you how to develop a site specific
17 weighting. It's really dependent upon very site
18 specific circumstances, and it's the job of the
19 responsible party, the stakeholders, and EPA to
20 make those qualitative judgments as to what's the
21 best balance of trade-offs among these five.
22 Finally, the last two, state
23 acceptance and community acceptance, are called
24 modifying criteria, and where those come in
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1 formally, although we have done our best to
2 consider those things to date in developing and
3 presenting the preferred alternative, where those
4 come in formally is as a result of this process
5 where there's a formal public comment period,
6 stakeholders have the opportunity to have their say
7 on what DOE and the regulators have proposed as the
8 remedy, and DOE, as the responsible party, is
9 obligated to consider those comments, make a change
10 in the remedy, if warranted, based on those
11 comments, or at a minimum respond in a
12 responsiveness summary, which becomes part of the
13 Record of Decision to each and every one of those.
14 Since this process isn't done, obviously we don't
15 have any kind of presentation tonight on those.
16 Let me talk briefly about the two
17 threshold criteria, which you'll see are neutral,
18 which means that it was our assessment that both of
19 the technology families, vitrification and chemical
20 stabilization, did indeed meet the threshold
21 criteria, are eligible for selection under CERCLA,
22 and hence went forward for a more detailed review
23 of how the balancing criteria played out.
24 What's the basis for saying both
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1 alternatives meet the threshold criteria starting
2 with overall protection of human health and the
3 environment? First, from a Fernald perspective,
4 all of the materials that are contaminated with
5 metals and radiological contaminants above health
6 based levels are taken up, taken out of the silos,
7 treated and sent in a safe configuration to the
8 Nevada Test Site for disposal. So from the Fernald
9 perspective, we're taking the contamination up and
10 getting it out of here.
11 From the perspective of
12 transportation, which we talk about again later, we
13 did calculations as to what risks would be
14 associated with incident-free transportation, in
15 other words, everything went great, no problems.
16 We also did evaluations of what risk would be
17 presented in an accident scenario, what if
18 something went wrong, and both alternatives,
19 although there are differences which we'll come to
20 here in a little bit, both were well within the
21 CERCLA range of acceptable risk.
22 And then, finally, disposal at the
23 Nevada Test Site, long-term protection is provided
24 there by, number one, the treatment, which
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1 immobilizes the lead, the primary contaminant of
2 concern for the purpose of treatment; the
3 combination of the treatment containerization and
4 disposal at depth mitigates radon attenuation,
5 which is the other significant contaminant of
6 concern, and that combined with the isolated
7 location and access controls that go along with the
8 Nevada Test Site provide for the protection there.
9 And here in a minute when we get into the balancing
10 criteria, the first one is long-term effectiveness
11 and permanence, and as you saw on the slide that I
12 just had, we rated those neutral, both performing
13 approximately the same. The arguments that I just
14 presented apply there as well. That's also the
15 basis under that criterion for rating them as
16 providing equal and adequate long-term protection.
17 Compliance with ARARs, which are
18 applicable or relevant and appropriate
19 requirements, another threshold, again our
20 assessment has concluded that both alternatives
21 adequately satisfy all ARARs. Most notably is the
22 NESHAP Subpart Q radon flux limit, which is met
23 adequately for both alternatives, and we'll talk
24 about radon attenuation here again in a few
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10
1 moments. The treatment under vitrification
2 adequately provides radon attenuation, a
3 combination of packaging and disposal. The whole
4 alternative provides compliance with that ARAR for
5 stabilization.
6 As far as all transportation
7 requirements, Department of Transportation
8 requirements, those will be met. Our analysis
9 indicates that they can be met. And as far as
10 siting requirements, engineering, other action
11 specific requirements, again the consensus was that
12 both alternatives could meet all identified ARARs,
13 which means that both alternative families, both
14 technology families, vitrification and chemical
15 stabilization, are acceptable for further
16 evaluation against the balancing criteria. I just
17 talked about this.
18 And again the same argument that both
19 alternatives adequately protect human health and
20 the environment also apply in our evaluation of
21 long-term effectiveness and permanence. We get it
22 out of here, treat the materials such that the lead
23 is immobilized, and get it into the ground in a
24 stable disposal configuration in an arid, remote
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11
1 environment with access controls to minimize any
2 kind of long-term environmental impact.
3 Now, of the five balancing criteria,
4 it was our assessment, and let me define who "our,"
5 when I say "our," who I'm talking about. Certainly
6 DOE, working with both US and Ohio EPA, as well as
7 receiving input from the Department of Energy
8 Independent Review Team and the Critical Analysis
9 Team, basically felt that there were three primary
10 discriminators, and subsequent interface with the
11 stakeholders, especially with FRESH and the CAB, I
12 think tended to validate that, that, as we just
13 talked about, long-term effectiveness and
14 permanence was neutral.
15 We'll get to cost, which is important
16 but not substantially different among the
17 alternatives, so there was really nothing there
18 that said there's a basis for selecting one over
19 another.
20 We did see what we felt were
21 meaningful differences between the two technologies
22 in the next three balancing criteria that I'm going
23 to talk about. The first one is reduction of
24 toxicity, mobility, or volume through treatment.
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1 The overall conclusion of the groups that I
2 referenced earlier is that there is a clear
3 advantage in this criteria for vitrification, and
4 it's primarily related to the treated waste volume,
5 and I'll reference where the arrows fall here in a
6 little bit.
7 But to move on, roughly because of
8 the nature of the process, the treated volume and
9 then the packaged volume and the amount of material
10 on the road and going into the ground in Nevada is
11 roughly three times greater for the chemical
12 stabilization technologies than the two
13 representative vitrification technologies. And
14 that's primarily because as part of chemical
15 stabilization you add things, additives, chemical
16 additives that achieve the chemical immobilization
17 process, coming along with it a fairly significant
18 volume increase.
19 Vitrification, by the nature of that
20 technology, actually reduces the volume. So this
21 right here is the bottom line for why we felt there
22 was a clear advantage to the vitrification
23 technology family on the overall criterion of
24 reduction of toxicity, mobility, and volume through
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1 treatment.
2 A couple of other things were
3 evaluated, the first one being secondary waste
4 generation. We're showing an advantage to chemical
5 stabilization for that. However, it's not
6 significant, not a discriminator, not something
7 that undoes or overrides or even erodes the
8 significant advantage of vitrification relative to
9 the treated volume. You can see they're about the
10 s ame.
11 Our assessment is that the actual
12 secondary waste produced by vitrification are going
13 to be a little harder to deal with, we'll probably
14 have some mixed waste associated with the
15 refractory brick, and because of the high
16 temperature aspect of the operation, some of the
17 off-gases are expected to be a little bit more
18 difficult to deal with. For instance, we're going
19 to fully liberate the radon that is contained in
20 these wastes, whereas that won't be the case with
21 chemical stabilization, but not a significant
22 discriminator.
23 Reduction in mobility of COCs, let me
24 just say quickly we rated that as neutral, the
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1 reason being is that testing data that came back
2 from our proof of principle testing for both
3 technology families with all four representative
4 technologies adequately treated the lead, the RCRA
5 metals, which is the primary treatment objective.
6 The second contaminant of concern
7 that we're looking at in evaluating what treatment
8 does in relationship to is radon. There is a
9 significant advantage for the vitrification
10 technology for reduction of radon emanation. If
11 you look at the results of our proof of principle
12 testing, basically what that showed is, I
13 referenced earlier the NESHAP, Subpart Q ARAR for
14 radon flux, the treatment through vitrification
15 alone achieves that ARAR. For chemical
16 stabilization, while there is a reduction of radon
17 attenuation through treatment, to achieve that
18 ARAR, we got to do it through a combination of
19 treatment and packaging. So there was an advantage
20 there for vitrification, which again promoted the
21 overall conclusion of reduction of toxicity,
22 mobility, and volume through treatment in favor of
23 vitrification.
24 The second discriminating balancing
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15
1 criteria is called short-term effectiveness, in
2 which we have judged there to be an advantage to
3 chemical stabilization, broken up in several
4 parts. The first one is worker risk, and to
5 summarize some things you heard on the video, the
6 radiological dose that we calculated for on-site
7 workers is about the same. That's not the
8 differentiator here. A little later in the package
9 on implementability I'm going to show a graphic
10 that shows number of hours worked, and what you're
11 going to see is roughly it takes, our current
12 estimate is about 16,000 work hours to implement
13 vitrification, whereas, depending on which
14 representative technology of chemical
15 stabilization, there's going to be anywhere from
16 7,000 to 10,000. So there's a reduced number of
17 operating hours, which statistically translates to
18 a lower probability of some kind of accident during
19 operation.
20 The second thing has to do with
21 worker risk in an upset mode, in which something
22 goes wrong and we've got to go in under let's say
23 nonroutine circumstances and do something about
24 it. As you recall, these are going to be remote
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1 technologies. Maintenance, however, is direct
2 contact. Because of the high temperature, high
3 voltage operation, we think there are greater risks
4 for workers associated with maintenance and upset
5 conditions for the vitrification technology. So
6 that's the worker risk aspect of this.
7 The second aspect of short-term
8 effectiveness is transportation risk, where we
9 judge there to be an advantage for vitrification,
10 and it links back to the exact same piece of data
11 that I gave for reduction of toxicity, mobility,
12 and volume. There's about a third less volume of
13 material for vitrification that has to be shipped
14 over the highways. That directly results in about
15 a third of the statistical chance of some kind of
16 accident happening. So, therefore, we judge there
17 to be an advantage in this for vitrification.
18 A couple of others notes, neither of
19 which undoes the conclusion that I just said, is
20 that the calculated transportation risk for both
21 technologies, including in an accident scenario,
22 were within the CERCLA guidelines, I mentioned that
23 up front, for overall protection of human health
24 and the environment. And, second, one of the
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1 things that was of interest to our stakeholders in
2 Nevada is that because with vitrification you are
3 essentially consolidating that waste --
4 consolidation isn't the right word — concentrating
5 that waste, I'm sorry, the radioactivity associated
6 with the treated material isn't going away, it
7 actually becomes more concentrated. So the dose
8 associated with the treated material is actually
9 higher in chemical stabilization because in effect
10 you're diluting it by adding those additives. So
11 in the event, which we think is the unlikely event,
12 of some kind of an accident scenario where it would
13 come out of the container, out of the packaging, it
14 would be -- it would represent a higher risk to
15 response workers because of that higher dose radon
16 contact.
17 Off-site environmental impacts were
18 judged to be neutral. And we do recognize that
19 there's a higher volume for the chemical
20 stabilization materials, but the basis of that
21 statement is that it's going into a highly impacted
22 area that has been designated for disposal of this
23 type of material. Hence, approximately neutral.
24 There's no meaningful difference in the long-term
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1 impact between the two at the Nevada Test Site.
2 Finally, time to achieve
3 protectiveness, based on the data that came back
4 from the proof of principle testing, there was
5 roughly, I think it was about ten months, as I
6 recall, an advantage to chemical stabilization on
7 the up front design, construction, and start-up
8 that allowed that technology to finish sooner.
9 That's a fairly slight difference, but there was a
10 perceived advantage for chemical stabilization
11 there.
12 The third discriminating criteria of
13 the balancing criteria is implementability, where
14 we have judged there to be an advantage to chemical
15 stabilization. Let me go back and repeat something
16 that the video said. Implementing any of these
17 technologies is going to be a challenge. They've
18 all got their unique aspects that are not going to
19 be easy. Chemical stabilization, for instance,
20 done in a remote environment is not going to be
21 easy. That's the input that we received from our
22 independent reviewers, to a lesser extent our
23 vendors, and that we recognized ourselves. So I
24 don't want anybody to leave with the impression
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1 that we're suggesting that it's a slam dunk for
2 chemical stabilization because we're suggesting
3 there's an advantage. Just that when compared
4 against vitrification, it does appear to be more
5 implementable.
6 What's the basis of that, scaleup
7 neutral? Why are we declaring that neutral?
8 Because for the vitrification technologies, there
9 are instances where there have been applied
10 commercially, not in a radioactive environment, but
11 where there have been applied commercially at a
12 scale actually greater than what we think we need
13 here to get the job done in a timely fashion and
14 numerous instances where chemical stabilization has
15 been applied at a scale that we require here. But
16 since we did find in the real world applications of
17 vitrification where it had been done at the scale,
18 it was rated as neutral.
19 Commercial demonstration, and we have
20 judged there to be an advantage for chemical
21 stabilization there. As we've talked about in past
22 meetings, what we did was is did a survey of the
23 DOE complex, actually extended that to radioactive
24 waste treatment worldwide, and then also looked
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1 across the range of SuperFund Records of Decisions,
2 corrective actions under RCRA, and to a lesser
3 extent remedial actions overseen by the Nuclear
4 Regulatory Commission. There were a dramatically
5 larger number of instances to where chemical
6 stabilization had been applied. And a relatively
7 small, and in some instances no applications of the
8 vitrification technologies at the scale that we
9 need in a radioactive environment.
10 Now, let me go back and repeat what I
11 said at the outset. There are a couple of famous
12 failures of chemical stabilization at the DOE
13 complex that people know about. This is not
14 suggesting that it's a slam dunk. It's simply
15 saying that when reviewed by literature, going
16 through the DOE complex, et cetera, there are a lot
17 more instances to where chemical stabilization has
18 been applied, applied in similar circumstances
19 successfully, which is something that the EPA
20 guidance does ask us to look at and does judge to
21 be a meaningful decision-making input.
22 Operability is again a subcomponent
23 of implementability that we judged there to be an
24 advantage for chemical stabilization. Put simply,
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1 if you look at the unit operations associated with
2 chemical stabilization versus vitrification, there
3 are fewer of them, and that it is our judgment,
4 again looking with DOE, the regulators, with input
5 from our vendors and independent review teams, that
6 they are generally more easy to control. And in
7 addition, there being fewer of them, that in a
8 nutshell is really the quantifiable basis for
9 saying that we think that chemical stabilization
10 technologies will be more readily implementable
11 based on the operability criteria.
12 Something that we also mentioned
13 earlier is that while implementing these
14 technologies will be remote for standard
15 operations, in an upset condition or for routine
16 maintenance, that's going to be direct contact
17 where actually we have to send workers in there,
18 and we think because of the high temperature, high
19 voltage aspects of vitrification, it's going to be
20 more difficult to do in a safe, timely fashion
21 whatever we need to do to recover from an upset or
22 the routine maintenance on these things.
23 To kind of back that up, so to speak,
24 I had mentioned earlier that there's a
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1 significantly larger number of operating hours
2 required to implement remediation if we use
3 vitrification versus stabilization, and I quoted a
4 couple of numbers. To bring that back to this
5 particular evaluation technology, the message here
6 is that the more these things run with more unit
7 operations, the more hours, the more time that
8 these things have to go, it's our experience and we
9 believe the experience of the DOE complex and
10 industry in general of these technologies that more
11 things happen. That's kind of common sense based
12 on any operation that we work with, the longer the
13 operation takes, the more likelihood that you will
14 encounter some kind of maintenance issues, some
15 kind of operability issue.
16 The last balancing criteria is cost.
17 I mentioned at the outset that we did not view this
18 as discriminating, costs. That's not to say that
19 cost effectiveness is not important. In fact, it's
20 a statutory requirement that DOE only select, the
21 EPA only select remedies that are cost effective.
22 We're not saying that it's unimportant. What we're
23 saying is that when we did the cost estimating
24 based on the data that we had from industry, the
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1 DOE complex, and our proof of principle testing,
2 there was only about a 15, 16 percent difference.
3 Within the range of accuracy of this stage of the
4 CERCLA process, which is plus 50 percent minus 30,
5 it was judged that that's just not a meaningful
6 difference. So it wasn't a discriminator in this
7 decision-making process. It is generally -- in
8 fact, it is statutorily required that the remedy be
9 demonstrated to be cost effective.
10 This is a brief summary of what you
11 saw on the video with a little bit of information.
12 The reason we did it is because these are the
13 criteria that we're obligated to use under CERCLA
14 guidance, under EPA guidance to make decisions.
15 Hopefully it's nothing really new. I believe it
16 matches directly what we've talked about in the
17 past.
18 That does conclude the presentation
19 that I've got. I think we're ready for Q&A, Gary.
20 MR. STEGNER: I want to emphasize
21 that if you have questions that you want responded
22 to, now is the time to ask those questions. If
23 you've not received an answer to your question so
24 far tonight or in a previous meeting and you want
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1 clarification on a matter, please raise those
2 questions now. Again, we will not be responding to
3 questions during the formal comment period.
4 JoAnne.
5 MS. WILSON: My name is JoAnne
6 Wilson, and I live in Fairfield, Ohio. Can you
7 tell us how long it is going to take to develop,
8 build the containment buildings that will surround
9 the silos that you'll use for either one of the
10 passages? What time frame are we looking at, and
11 is the money already funded for this part?
12 MR. STEGNER: Yes, we can answer
13 that, JoAnne.
14 MR. HAGEN: We're pulling out a
15 slide right now to try to answer that question.
16 I'm not sure if this is what she asked, by the
17 way.
18 For the alternatives that are being
19 considered in the FS, this is a breakdown of how
20 long we have estimated at this point in time, using
21 the data that's come back from the proof of
22 principle testing and also our review of
23 application of these technologies from around the
24 complex, you see roughly about 120 months.
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1 What this breaks down, the first --
2 just to take these in order — the first block of
3 time is how long we estimate that it will take to
4 design the treatment technology fully,
5 incorporating public involvement and regulatory
6 review and approval. Then we move on to
7 construction. That roughly takes a little over a
8 year and a half for that design process. Moving on
9 to construction, a similar amount of time, about a
10 year and a half. The next stage is once the system
11 is constructed, we don't go to operation until we
12 fully shake down, is my term, until we've
13 demonstrated that we know exactly how to operate
14 this thing right, safely, and efficiently. And
15 then the next stage is actual operations. Right
16 now we're showing that as three years. Our input
17 from vendors from both families is that if we've
18 got adequate funding, we can do it faster, either
19 by upping the capacity of the unit operations as
20 we've assumed in the FS or by adding additional
21 processing capability. The last parts of the
22 process are a little bit of contingency for
23 uncertainty, you know, everything doesn't always go
24 great, so we've added some contingencies with
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1 scheduling. And, finally, safe shutdown of the
2 facilities and disposal goes in a safe manner.
3 Where the difference is, you know,
4 it's a few months here and there, but primarily
5 there was about five or six months advantage to the
6 chemical stabilization technologies in the start-up
7 phase and then a few months here and there, adding
8 up to about a year of estimated schedule advantage
9 for the chemical stabilization alternatives.
10 Now, that's the answer relative to
11 the alternatives that are under consideration for
12 treatment. I had interpreted your question to be
13 related to our advanced waste retrieval project in
14 taking it out of the existing silos and putting it
15 into a safe, homogenized configuration which
16 facilitates treatment and also improves upon the
17 stability of the storage configuration over what's
18 in the silos. So in case I interpreted that right,
19 Dennis, do you want to give a brief update on where
20 we're at on that.
21 MR. NIXON: Yes. The state of the
22 art project is currently in design. The operations
23 are scheduled to begin March of 2001, and that
24 would complete in June of X02. So there would be,
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1 that project would be completed by June of X02.
2 MS. WILSON: Of X02?
3 MR. NIXON: Yes.
4 MS. WILSON: That personally answers
5 my question, but I guess what I'm really trying to
6 get at from you is, there is going to be a
7 containment building of some nature built over the
8 silos sites; is that not correct?
9 MR. NIXON: No, that's not.
10 MS. WILSON: Well, the last time
11 when we had our meeting in November there was a
12 concern over when you opened up the silos, and I
13 believe you stated at that time that there would be
14 some type of, and I call it a containment building,
15 you perhaps have another word for it, which would
16 go over the site so that when the silos are opened
17 and the escaping gases, et cetera, would be
18 collected, and I believe you showed several slides
19 showing how the air would be sucked up and treated.
20 So those buildings that -- First of all, what do
21 you — I'm assuming they would be the same for
22 either project since you would have to open the
23 silos for either.
24 MS. AKGUNDUZ: I'll take that,
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1 JoAnne. What you are referring to is the auxiliary
2 waste retrieval project we have. The structure
3 that you saw from the past meeting is probably the
4 gantry type of thing that's built over the silos to
5 facilitate the deploying the retrieval equipment
6 through the hole top of the silo. Now, in order to
7 retrieve the material, we do have to have a radon
8 control system in operations. The radon control
9 system building is not on top of the silo. It's
10 adjacent to the tanks that we're going to be
11 building that the material is going to be
12 transferred into.
13 MS. WILSON: So there will be
14 actually nothing over either of the silos?
15 MS. AKGUNDUZ: Only the equipment
16 room and the structure that is going to support the
17 equipment room.
18 MR. SCHNEIDER: There's a
19 containment structure around the breach -- I think
20 your question, the answer to your question is, yes,
21 there is a containment structure over the breach in
22 the silos.
23 MS. WILSON: That's what I thought
24 from the last meeting that there was going to be
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1 that, and that is already scheduled, you said it's
2 already being worked on?
3 MR. NIXON: Right, it's being done
4 right now.
5 MS. AKGUNDUZ: March 2001 is when
6 the radon control system will be starting to
7 operate. It won't be the time -- when we actually
8 start retrieving the waste out of the silos will be
9 in the year 2002.
10 MS. WILSON: But you have plans for
11 some type of -- I still say a building, whether
12 it's here or there -- and then along with that
13 process, then, you have also scheduled or are
14 designing or have designed the specialized storage
15 barrels, containers —
16 MR. SCHNEIDER: Tanks.
17 MS. WILSON: — That the material
18 from the silos will go into as a precautionary
19 measure and will wait there until the other
20 material process is chosen to process that; is that
21 correct?
22 MS. AKGUNDUZ: That's correct.
23 MS. WILSON: And these are already
24 funded?
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1 MS. AKGUNDUZ: We are — The way the
2 funds, the funding works is that we are annually
3 funded. Now, these are budgeted; all the scope is
4 budgeted.
5 MS. WILSON: They're in the budget?
6 MS. AKGUNDUZ: Yes, they're in the
7 budget.
8 MS. WILSON: That's probably the
9 word then. And you anticipate the containment
10 affair and the containers would be available then
11 or would be ready to go by 2002, is that your —
12 MS. AKGUNDUZ: Yes. Material will
13 be, yes, it will be starting, we will be starting
14 to retrieve the material out of the silos in 2002.
15 MS. WILSON: Is there any difference
16 in these things for either of the methods that are
17 going to be used?
18 MS. AKGUNDUZ: No.
19 MS. WILSON: Thank you.
20 MR. STEGNER: Pam and then Edwa.
21 MS. DUNN: I just have a couple of
22 quick questions. On your cost comparison, Gary, is
23 transportation part of the waste disposal cost or
24 is transportation cost not reflected in this?
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1 MR. HAGEN: It's part of the
2 transportation disposal costs, right?
3 UNIDENTIFIED SPEAKER: Yes.
4 MR. HAGEN: The answer is yes, it is
5 incorporated into the total cost, and it's
6 reflected into the disposal cost estimate.
7 MS. DUNN: Is also the cost to
8 dispose it that you have to pay the test site part
9 of that number too, or is that mostly
10 transportation?
11 UNIDENTIFIED SPEAKER: Most of that
12 is transportation, most of the disposal cost is
13 transportation.
14 MR. HAGEN: It does include the tip
15 entry at the site as well.
16 MS. DUNN: On the alternatives or
17 your implementability where you talk about your
18 commercial, did you look at commercial uses outside
19 of the US as well as within?
20 MR. HAGEN: Yes.
21 MS. DUNN: There is some success for
22 it outside the US?
23 MR. HAGEN: Yes, we did. And that's
24 also within -- As an appendix to the FS, we present
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1 the results of that survey, and it does
2 specifically mention which international
3 applications we found — well, we focused on it
4 internationally, but we do include every instance
5 to where we applied it internationally, and that's
6 an attachment, an appendix to the FS.
7 MS. YOCUM: I just need some
8 clarification. On chemical stabilization CHEMl, is
9 there a wastewater treatment included in that
10 also? I see it mentioned only in CHEM2.
11 MR. NIXON: Yes, they both have
12 treatment prior to transfer.
13 MS. YOCUM: Okay, then why isn't one
14 mentioned in CHEMl? I mean, it would be easier
15 than me having to ask the question over and over.
16 MR. NIXON: Right. The vendor in
17 the proof of principle testing felt that they could
18 treat the wastewater at the pump filter press
19 would be clean enough to meet the advance
20 wastewater treatment facility acceptance criteria.
21 But if it doesn't — that's in the text of the
22 document -- it's stated if they can't meet that,
23 then a wastewater treatment plant would be
24 provided. It was not required for this, for that
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1 treatment technology because they were able to
2 demonstrate that in their testing.
3 MR. HAGEN: One of the things that
4 we will do during the design phase is require
5 additional testing to document conclusively that
6 they meet it or they can't.
7 MS. YOCUM: That was going to be my
8 next question, how are you going to make sure you
9 can meet that?
10 MR. NIXON: We're going to give them
11 the future contract, and they will have a very
12 strict waste acceptance criteria for a wastewater
13 treatment facility that they will have to meet. As
14 I said, in this case the vendor was able to meet
15 the criteria without further treatment, but if
16 that's not the case, then they would have to comply
17 with that.
18 MS. CRAWFORD: Do the costs over and
19 above that, are those reflected in your cost
20 estimates if they have to go forward and use the
21 wastewater treatment facility?
22 MR. HAGEN: No.
23 MS. CRAWFORD: I think you should go
24 back and add that number in because if that's the
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1 case, if you're using wastewater in CHEM2 and
2 probably 1, if they can't meet the WAC, then common
3 sense would tell us the cost estimates are not
4 correct if you've not factored in the extra costs
5 for the wastewater treatment facility. Which is
6 going to probably bring them neck and neck.
7 MR. NIXON: Well, I can't — it's
8 difficult to address that. We have what we call
9 operational risk dollars in the cost estimates that
10 is for things of that nature. In the event that
11 the vendor proposal would include wastewater
12 treatment because of the process they are
13 providing, then that would be covered under
14 operational risk at that time. There was about a
15 16 percent difference, between CHEM and VIT, which
16 is a fairly significant number in a wastewater
17 treatment plan of this kind. It would be
18 relatively inexpensive.
19 MR. HAGEN: These guys always love
20 it when I make these commitments for them, but one
21 thing we can do in the responsiveness summary is do
22 a specific evaluation and document how many dollars
23 would go along with adding a treatment facility,
24 number one, and then make a conclusion as to
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1 whether it changes the fundamental evaluation,
2 which is that it's an important but not a
3 discriminating decision-making factor. So we can
4 do that.
5 MS. CRAWFORD: We ask for those
6 things because too many times, as you all well
7 know, we get down the pike and all of a sudden it's
8 like, oh, well, we forgot this and we need to add
9 that, and it,'s a little more money here and a
10 little more money there, and then in the long run
11 you haven't saved a whole hell of a lot of money.
12 So I would encourage you to do that.
13 MR. HAGEN: Okay.
14 MR. STEGNER: Sir.
15 MR. DAVIS: I'm Doug Davis from
16 Toledo Engineering. When these materials, treated
17 materials arrive at NTS, what is the time period
18 which you estimate they will require the attention
19 and the maintenance of this test site?
20 MR. HAGEN: Let me answer it this
21 way: One of the things that we've got to do to be
22 able to get these materials in to the ground for
23 permanent disposal at the test site is pass a
24 performance assessment. The life assumed, the life
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1 of disposal assumed in that assessment is 10,000
2 years. So we've got to have a quantitative
3 demonstration that this will remain — this
4 alternative, if implemented, with either waste form
5 going into the ground at Nevada will remain its
6 protectiveness for at least 10,000 years, and that
7 really, I think it starts to drive some of the --
8 What that means is that direct intrusion scenarios
9 tend to drive that risk assessment, but we have
10 been working with the Nevada Test Site and have
11 information from them based on specific evaluation
12 of the untreated waste form for starters, and then
13 secondly what our current estimates of what the
14 characteristics of the treated waste form would be,
15 and both would meet the performance assessment
16 requirements based on a 10,000 year life
17 evaluation.
18 MS. WILSON: What I was asking
19 before, how long do you estimate that the
20 materials, the silo materials will remain in the
21 special containers before either one of the
22 treatments begin?
23 MR. NIXON: Treatment is scheduled
24 to begin in June of X06 for this process. That's
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1 our current based on schedule.
2 MS. WILSON: For either one?
3 MR. NIXON: That's correct, for
4 either technology.
5 MS. WILSON: The building will be in
6 place and it will already be operational by X06?
7 MR. NIXON: Right.
8 MS. WILSON: And these containers
9 are — will be especially built to hold the residue
10 as it now is?
11 MR. NIXON: They're actually tanks.
12 They're steel tanks, and there's shielding, there's
13 a containment around those tanks of concrete.
14 MS. WILSON: A concrete protection?
15 MR. NIXON: Right.
16 MR. STEGNER: Edwa.
17 MS. YOCUM: I have one more. This
18 is always a concern to me, is if NTS closes the
19 gates, what happens to this waste, the silo waste,
20 where will it be disposed?
21 MR. HAGEN: That's not an easy
22 question to answer. The one thing, though, that is
23 clear if you look across the Records of Decision
24 for Fernald, it can't go here. It's not even close
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1 to meeting the waste acceptance criteria for an
2 on-site disposal facility. So while I don't have a
3 good answer for you, there's nothing that we've
4 agreed to together that says it can go to Fernald.
5 MR. STEGNER: Okay. Let's take a
6 short break.
7 MR. HAGEN: There's another
8 question.
9 MR. STEGNER: I'm sorry, go ahead.
10 MR. DAVIS: This will be a very
11 short one. With the materials going to NTS, when
12 the consideration was being made for high level
13 radioactive waste, and I know the materials are
14 significantly different, but the part of the
15 scenario was always the "what if" game played out
16 formally which said, let us assume that the
17 infrastructure to maintain this is gone, and for
18 10,000 years that may be a reasonable assumption,
19 and so for these materials it was always driven
20 very strongly toward the most durable treatment,
21 you know, not depending on the container. So I was
22 curious if this kind of consideration came up in
23 your discussion?
24 MR. BECKMAN: As part of the PA
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1 process, we look at inadvertent scenarios, what
2 happens if somebody built a form on top of a waste
3 cell and sinks its well through the disposal. The
4 container brings the stuff up to the surface and
5 eats it.
6 MR. HAGEN: And they also considered
7 the untreated waste form, right, Steve?
8 MR. BECKMAN: Right. They don't
9 take credit for the waste form.
10 MR. STEGNER: Jerry.
11 MR. GELS: I had a question about
12 the comparative analysis summary. Is the analysis
13 of the treatment technology or the combination of
14 the treatment technology and the burial or ultimate
15 disposal together?
16 MR. BECKMAN: It's together.
17 MR. HAGEN: It's together, right.
18 MR. GELS: It's together, that's
19 what I assumed. So, if you wanted to increase your
20 number, you just bury it deeper or in a drier
21 location? That may be — we're looking at the NTS.
22 MR. HAGEN: Yes. Particularly as it
23 relates to the radon flux. The depth of burial is
24 an issue there and, yes, it's one of the ways to
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1 address that issue. But it does include the entire
2 combination of treatment and disposal.
3 MR. GELS: Okay, one question I had
4 then was with your long-term evaluation for
5 effectiveness and permanence. The neutral decision
6 goes against everything I've heard before about
7 vitrification versus a cement kind of a product,
8 especially as you point out that 10,000 year
9 scenario, we're talking about — I don't know of
10 any — I mean, we found glass materials near
11 volcanoes that have lasted that long, yes, but I've
12 never seen anything that has shown that a cement or
13 concrete product can last 10,000 years.
14 MR. HAGEN: A couple of things. One
15 is that for chemical stabilization, the
16 immobilization of the lead is not through a
17 physical form like you see in concrete blocks in
18 the building down the road. It's actually the
19 chemical reaction that takes place between the
20 pozzolan type additive and the lead itself. In
21 fact, the test that EPA requires to demonstrate,
22 called TCLP, I forget what the letters stand for,
23 actually grinds the material up, the vitrified
24 material, the stabilized material, chemically
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1 stabilized material. So the physical form of the
2 waste is not really what drives the protectiveness,
3 particularly for chemical stabilization, that
4 chemical reaction. So that's the first thing. If
5 there is degradation of the physical consolidated
6 waste form, it doesn't mean that you're losing the
7 immobilization contamination.
8 Secondly, and, you know, this is a
9 statement that we always say respectfully and
10 carefully in Nevada, but given where it is, it is
11 going in fact into a hole created by an explosion
12 of a nuclear weapon, and with the background and
13 other contamination that is in place, the
14 meaningful difference between what we're putting
15 there compared to what is already there and the
16 degree of impact to the environment is just not, in
17 our mind, this is our conclusion, not forcing it on
18 anybody else, especially the citizens of Nevada,
19 but it's just not a meaningful difference. And, by
20 the way, we haven't gotten, you know, that's
21 generally been accepted by the people in Nevada.
22 So that's why we say it's neutral.
23 Is there some basis for saying
24 they're different? Yes. Is it a meaningful
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1 difference in our mind considering that they both
2 achieve the remedial action objective and that the
3 protection for that achievement of the remedial
4 action objective isn't dependent on the physical
5 form of the waste, it's the chemical processes that
6 take place. We don't think there's enough of a
7 difference to say there's an advantage in one
8 direction or another. That's the basis of us
9 calling it neutral.
10 MR. GELS: I don't necessarily
11 disagree with you on the basis of lead and radon,
12 but you've not mentioned radium in this. Was that
13 evaluated, radium 226 as part of the leachate,
14 leachability?
15 MR. HAGEN: Yeah, it was evaluated.
16 It was not judged to be — It is a contaminant of
17 concern, yes, requiring, you know, us to do
18 something from a risk assessment perspective. If
19 you look at what drove the requirement for
20 treatment, that was not a contaminant that required
21 treatment. It was actually just the lead. The
22 second — and I'm talking from a regulatory
23 perspective. Different stakeholders can have
24 different perceptions, and we respect that, but
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1 from a regulatory perspective, the only thing that
2 drove the treatment was the lead and the fact that
3 it is present at leachable concentrations above the
4 RCRA thresholds. That's why we focused on lead and
5 radon, because they both have ARARs that tend to
6 drive the acceptability of disposal as opposed to
7 radium.
8 MR. BECKMAN: But that's looked at
9 in the PA.
10 MR. STEGNER: Sir, you had a
11 question?
12 UNIDENTIFIED SPEAKER: I'm trying to
13 determine which is better, is CHEMl better than
14 CHEM2 or vice versa?
15 MR. HAGEN: Well, what we're going
16 to do if ultimately chemical stabilization is
17 selected is not specify any one iteration of
18 chemical stabilization. What we're going to do is
19 require that the successful offerer provide a
20 technology that uses chemical stabilization, but
21 then let the competitive market give us the best
22 version as it applies for these specific wastes.
23 We're not really trying to say that we know enough
24 that one iteration is better.
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1 The reason is because we selected two
2 representative technologies. There are 20 or 30
3 other different ways to do it out there, and we
4 don't want to make the conclusion that one is
5 better than B because it might produce a false path
6 forward. Okay. We want the best application of
7 chemical stabilization possible out there, the most
8 timely and to a lesser extent cost effective
9 application to come out of a competitive process.
10 That's why we've stayed away from conclusions like
11 which of the two representative technologies are
12 better.
13 UNIDENTIFIED SPEAKER: Well, it
14 looks like vitrification is dead from everything
15 that I've read, and we just ought to forget about
16 that and concentrate now on the chemical
17 stabilization.
18 MR. HAGEN: Well, we propose
19 chemical.
20 UNIDENTIFIED SPEAKER: We still
21 don't know which chemical stabilization is better.
22 So it sounds like you really haven't done your job
23 at this point.
24 MR. HAGEN: Let me go back and say
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1 what I've just said again, and that is that, well,
2 first, we are proposing chemical stabilization as
3 the technology family. It doesn't mean
4 vitrification is dead, that's why we're here
5 tonight, to get public input. Let's just suppose
6 hypothetically that we do go forward with chemical
7 stabilization. What we're saying is that there are
8 a lot of different ways to implement chemical
9 stabilization that are consistent with the way we
10 define the technology and what a successful vendor
11 would have to offer. We don't want to get into the
12 situation to where we artificially limit the best
13 way to do it by only comparing two or three or four
14 vendors. We want to let the competitive market
15 with people that have demonstrated success with
16 their particular version of the technology come and
17 give us the best application. So we want to stay
18 away from that.
19 UNIDENTIFIED SPEAKER: Okay. We're
20 still in the very early process then of selecting
21 the best method?
22 MR. HAGEN: The final vendor.
23 UNIDENTIFIED SPEAKER: Okay.
24 Reading this material here it looks like you've
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1 done the survey, you know, and you've decided on
2 CHEMl or CHEM2 and you know exactly what goes into
3 that, one has fly ash and the other one doesn't,
4 and so forth and so on, but you may go to something
5 completely different from what you've got here?
6 MR.HAGEN: Not completely
7 different. It still has to fundamentally be a
8 chemical stabilization technology where you've got
9 to immobilize the lead to RCRA standards using a
10 chemical process that achieves that reduction in
11 mobility through that chemical reaction. So it's
12 not just anything; it's got to be within that
13 technology family, and again, I know I'm repeating
14 myself, what we want is the best application that's
15 available out there in the competitive market from
16 vendors that have demonstrated the ability to do it
17 right.
18 UNIDENTIFIED SPEAKER: Okay. So in
19 this comment period what are the citizens supposed
20 to do? You haven't really decided the best method
21 yet. What are the citizens supposed to say,
22 vitrification, we don't want that, we want CHEMl
23 and CHEM2, but of the CHEMl and CHEM2, we don't
24 know what the best solution is?
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1 MR. HAGEN: We're not attempting, I
2 apologize, I know I'm not being clear, we're not
3 attempting to make a decision or ask you to decide
4 between CHEMl and CHEM2. We're asking you to give
5 whatever input you want to give, including if you
6 think we have more work to do, tell us that, but
7 what we are specifically asking right now is based
8 on the comparative analysis, that the family of
9 vitrification compared to the family of chemical
10 stabilization, we are proposing chemical
11 stabilization. We want to know what you think of
12 that. I'm not going to tell you how to comment.
13 If you think that there needs to be more public
14 involvement, which there will be, in how we get to
15 the final answer, if you've got particular thoughts
16 on how that public involvement should be
17 structured, what decision points based on what data
18 you want, please comment. But first and foremost,
19 we're asking people to react to our proposal to
20 select some application of chemical stabilization
21 family.
22 UNIDENTIFIED SPEAKER: I see, okay,
23 as opposed to vitrification.
24 MR. HAGEN: Yes.
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1 MR. STEGNER: We'll take two more,
2 you and you.
3 UNIDENTIFIED SPEAKER: I was going
4 to point out for Jerry, he talked about a city in
5 which the volcanic glass being nationally available
6 and have had long age, cementatious rocks are the
7 same. There's all kind of cementatious rocks,
8 including limestone and sandstones, that have been
9 around for millions of years. So I think you can
10 make that same comparison that way.
11 The other thing, Terry, you guys have
12 also looked at the radioactive decay of this
13 material. I know lead was the driving factor, but
14 in terms of where it's going into the Nevada Test.
15 Site, I think from a radioactive standpoint, due to
16 the decay, you don't need 10,000 years to protect
17 this material, do you?
18 UNIDENTIFIED SPEAKER: Sure do.
19 It's there for the term.
20 MR. SCHNEIDER: It's not going to
21 get any less radioactive.
22 UNIDENTIFIED SPEAKER: In 10,000
23 years you'll have six half lives of radium 226, so
24 it should decrease, total activity of the radium
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1 should decrease by l/60th.
2 MR. GELS: More than that.
3 MR. STEGNER: JoAnne.
4 MS. WILSON: This brings up a point
5 that the gentleman brought up here, when you were
6 preparing the plans for either method, I believe
7 you said that you consulted with various companies
8 that were both familiar with and competent,
9 appeared to be competent in handling this. Was it
10 from these people — Was it from these people that
11 you got the general plan for each one of these?
12 MR. HAGEN: The answer is
13 generically, yes. We mentioned that we conducted
14 proof of principle tests using two representative
15 applications of each technology family. We went
16 out competitively and procured the services of four
17 different companies to go do 72-hour test run for
18 each of the technologies. That is the primary
19 basis of the data that we used to develop the
20 alternatives in the FS. That was not the exclusive
21 basis.
22 We also went to other places where
23 it's been done in the DOE complex, talked to them.
24 Did literature reviews, and also used some of our
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1 own experience at Fernald because we have
2 successfully implemented chemical stabilization, on
3 a smaller scale, and we've also gotten experience
4 through the melter, for better or for worse, with
5 vitrification. But having said that, we didn't
6 bias anything with our experience. The primary
7 basis of information was the data from the proof of
8 principles testing.
9 MS. WILSON: Would these same
10 companies then be considered as possible vendors?
11 MR. HAGEN: The answer is that any
12 vendor, let's suppose hypothetically it's chemical
13 stabilization, any vendor that can demonstrate
14 qualifications with that particular technology will
15 have an opportunity to bid on the final job.
16 Conversely, if for some reason it changes to
17 vitrification, the same thing applies. Any company
18 that can demonstrate capabilities with that
19 technology will have the opportunity to propose.
20 MS. WILSON: But I think you also
21 then said that when you chose a vendor, it could
22 quite possibly be up to that vendor to decide how
23 they were going to process material, and it could
24 be a third, fourth or fifth version of say the
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1 chemical stabilization.
2 MR. HAGEN: All within the general,
3 all within the general family, which, a dramatic
4 oversimplification, means you take the material,
5 you add some kind of pozzolanic agent, sometimes
6 it's as simple as a cement derivative, sometimes
7 there are companies that have their own proprietary
8 twist, but in all instances it is the addition of
9 some chemical agent that causes a chemical reaction
10 with your constituents of concern to achieve the
11 remedial action objective. So any offerer has got
12 to be bringing something to the party that works
13 within those constraints.
14 Where are the opportunities for
15 differences? It's slight differences in the
16 additive. As I said, different companies have
17 their own version of the pozzolanic additive that
18 may work better or worse for certain applications
19 that would have to be demonstrated. They also
20 might have what are fairly minor differences in the
21 way it's mixed, for instance, off-loaded -- I'm
22 sorry, taken out of the mixing agent. In other
23 words, process modifications but the same basic
24 technology.
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1 MS. WILSON: But at the same time
2 you couldn't be sure that the results would be the
3 same as what you were saying in these two
4 alternative chemical stabilization methods?
5 MR. HAGEN: No, that's right. I
6 think there's a strong basis of confidence that we
7 would achieve the remedial action objectives.
8 Would there be differences in the treated waste
9 form? There might be slight differences in the
10 leachability rate. In all instances they have to
11 meet the lead leachability standard. And there
12 might be slight differences in the radon
13 attenuation reduction because of a particular
14 chemical or additive that they use. It also might
15 result in differences in the volume; rather than,
16 you know, three times, it might be two and a half
17 times more, or it could be three and a half times
18 more. I don't see it getting much out of that
19 envelope. But, yeah, there are going to be
20 differences, but the bottom line won't change, and
21 that is it's going to be a chemical reduction
22 process that has to meet certain specified
23 performance requirements as designated in the ROD,
24 most notably around this reduction of leachability
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1 of the RCRA constituents. Those are going to be
2 absolutes.
3 MS. WILSON: Okay, thank you.
4 MR. STEGNER: Let's take a break,
5 and we will set up for the formal public comments.
6 MS. CRAWFORD: Can we take like a
7 really short one because some of us need to leave?
8 MR. STEGNER: Yeah, we're going to
9 take five minutes, Lisa.
10 (Brief recess.)
11 MR. STEGNER: All right, this will
12 begin the formal public comment portion of the
13 evening, the public hearing. I want to restate
14 that we will be doing this in Nevada next week, for
15 the stakeholders at the Nevada Test Site.
16 What we ask you to do is either raise
17 your hand, step up to the microphone, otherwise ask
18 to be recognized this evening. When you begin
19 speaking, we ask that you state your name clearly,
20 simply because this is being taken down for the
21 record.
22 If you have any written materials
23 that you want to submit this evening, you can also
24 give those to me at that time. If not, those can
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1 be sent in separately. As I say, this is being
2 transcribed, so what you say will be an the record
3 anyhow.
4 The comments, questions that we have
5 here tonight will be compiled into a responsiveness
6 summary, and that will be provided to everyone who
7 has signed in here tonight. We will also put a
8 copy of that in the Public Environmental
9 Information Center as soon as it is ready, and that
10 will probably be within two to three weeks after
11 the end of the public comment period, which again
12 ends on May 18th. With that, we would ask that
13 whoever wants to speak — I think, Lisa, you had
14 asked to speak early, so please proceed.
15 MS. CRAWFORD: I need to leave right
16 away.
17 MR. STEGNER: I understand.
18 MS. CRAWFORD: Quickly, you've all
19 heard my comments on many other occasions, but to
20 kind of put them in a nutshell tonight is I just
21 want to say that we live in a society of less is
22 better, as we all know, and reduce, reuse, recycle
23 are terms that are stressed at every turn these
24 days. So with that, three times the waste load is
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1 a little bit mind boggling for me, and it's a
2 little hard for me to comprehend, and the fact that
3 we are sending three times the amount of waste to
4 somebody else's backyard seems a little bit unfair,
5 and it really seems technologically wrong to me.
6 Three times the amount of waste also equals three
7 times the amount of shipments in trucks and, again,
8 those shipments will be traveling on highways and
9 byways across this country.
10 The waste form in a cement waste
11 form, and I call it solidification, it's cement,
12 sorry, but that's what it is, is not near as
13 protective, in my opinion, as vitrification is.
14 I've not seen a tremendous difference in the cost
15 values. They pretty much look the same to me. I
16 think when we add in some of the possible advance
17 wastewater treatment facility activities, that
18 could possibly bring them in line together.
19 Some of us have seen and heard the
20 horror stories from around the DOE complexes on the
21 cement issues, and they're not pretty. They can
22 tell me some work, and that's fine, but I've also
23 seen some that don't work, so that's a little scary
24 for us.
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1 The last thing I want to add is if
2 chemical stabilization is chosen, which it pretty
3 much seems like that's what it's going to be, that
4 I want to encourage everybody involved here that
5 you look very, very hard for ways to lower the
6 waste volumes and to possibly lower those truck
7 shipments. There's new technologies at every turn.
8 every time you turn around there's a new technology
9 out there and old technologies are made better and
10 better, and we would just encourage you to be very
11 watchful of the new technologies as they come down
12 the pike. And that's it.
13 MR. STEGNER: Thank you. JoAnne.
14 MS. WILSON: My name is JoAnne
15 Wilson. I'm from Fairfield, Ohio, and I would like
16 to make the following comments.
17 Some of this will go back to 1995,
18 because I think there are many people in this room
19 who were at meetings at that time, and I think it's
20 very, very important that you realize some of the
21 advances that have been made since that time. In
22 1995, when it was announced that there was all this
23 radium in the silos, and many scientists and
24 doctors came to see collectively what might be done
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1 to preserve this for medical research. However, at
2 that time this was just a — it was just talk as to
3 what was possible.
4 I would like to be able to report
5 today in 2000 that Dr.David Scheinberg, who was
6 here at that time and announced a new method of
7 treatment and possible cure, it will take time to
8 see whether it's an absolute cure, of using one of
9 the isotopes that would come from radium, namely
10 bismuth 213, married or connected with an antibody
11 which will target a specific type of leukemia or
12 non-Hodgkin's lymphoma and will carry this tiny
13 Alpha-admitting particle to the cancer cell and
14 will kill it wherever it is in the body. If it has
15 traveled from the site, it will get it. They're
16 called smart bullets, and they have a seek and
17 destroy ability.
18 The reason I bring this up is that
19 the Sloan Kettering Memorial Institute, Cancer
20 Institute, has been conducting since 1995 various
21 trials, I believe they're at least in phase two,
22 they may be going into phase three. The bismuth
23 213 has proved to be an excellent cancer killer.
24 It has mated with a number of these antibodies, and
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1 it is treating people who are desperately ill with
2 this. Dr. Scheinberg, whom I have spoken with, has
3 chosen the sickest of the patients to treat. Both
4 of these diseases are hard to treat, and he has
5 figured if he can treat and possibly cure these
6 people, then people who are lesser sick can also
7 benefit.
8 This is not the only type of cancer
9 that is being treated. The only reason I bring
10 this up so strongly is Dr. Scheinberg was here.
11 There's been nothing in the paper as to how
12 successful this has been. There are other people
13 who are working with medical isotopes in the same
14 manner using specific isotopes, and they are
15 working on treatment of ovarian cancer, prostate
16 cancer, lung cancer, brain cancer, and some other
17 noncancerous things such as heart and even the
18 possibility of AIDS treatment. This is a new type
19 of thing. Instead of irradiating the body with
20 radioactive material, you send bits and pieces in.
21 The body is subjected to less, much less trauma,
22 there's no hair loss, there's no nausea, it can
23 even be treated on an outpatient basis.
24 The reason that I bring this up, too,
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1 is because contained in the radium which is in the
2 two silos are two very important isotopes, medical
3 isotopes which are in short supply and of which the
4 radium which we have here is the largest known
5 supply all over the world. Bismuth 213 and
6 actinium 225 are both very, very valuable, and I
7 would like to speak on the alternative of trying to
8 preserve this radium. Both of these methods, the
9 vitrification and the chemical stabilization, will
10 put this 10 pounds of radium out of use of the
11 medical community. It will be gone, it cannot be
12 used. Some people say that you can take the glass
13 capsules, crush them down and treat them. The
14 cost, from what I've been able to gather, would be
15 extremely prohibitive. The same way, I think the
16 chemical stabilization is even worse in possible
17 retrieval later on, if at all.
18 I think that the radium here is
19 extremely valuable. I think your presentations
20 tonight have been very, very good and they
21 certainly have been honest ones in that there is no
22 real easy way to treat this material. We wish that
23 there was. Each one of them has a, its own
24 problems, complications, uncertainties I think you
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1 were careful to point out, and I think that honesty
2 is good to see.
3 I have, and I've come to this meeting
4 with an alternative, which I have discussed with
5 other people in the DOE, with scientists out in
6 Hanford, as a method of removing this material
7 completely from the neighborhood in a much less
8 complicated manner, and I would like the DOE and
9 the EPA and all the other involved agencies to
10 consider this. The biggest problem we have is
11 getting it out and my proposal is this: That the
12 contents of the silos be removed as they are with
13 no treatment here, and that in the process or
14 before this, of course, that some agency, some
15 site, some commercial company be either given or
16 sold this, however to take it out of our hands.
17 There are many companies in this
18 country and in Canada that are very competent in
19 processing radioactive material. They do it all
20 the time. They separate different things out.
21 It's no big deal to them. If this material could
22 be disposed of to such an entity, and I'm not
23 saying that they would be easy to find, I am
24 suggesting that we would, for example, try an
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1 entity in Canada. A number of years ago there was
2 a company called, I believe it was Rioalto —
3 Rioalgum, that's correct, who was interested in the
4 material, and as I understand it, they did the
5 problem with them is that they didn't have any
6 method of final disposal of the waste product after
7 they had taken the radium out. I think someone
8 said that they were just going to dump it
9 somewhere, if I remember. If we were able to give,
10 sell, dispose of the material in Canada, for
11 example, and I use Canada because there's a lot of
12 uranium mining being done there, and they know how
13 to care for and process radioactive material, it's
14 no big deal, it's their living. They could decide
15 on the method of separating put the radium from the
16 barium sulfate which is contained in this. If you
17 have to process it, barium sulfate is taken out and
18 then that has to be processed in order to get the
19 radium salts. But once this is done, the material,
20 the residue, the radium can go to a reactor and can
21 be changed into many, many valuable isotopes,
22 medical isotopes, and I stress that. This whole
23 area is just beginning, and I think we would be
24 proud, extremely proud if we could be the source of
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1 saving lives of people with various types of
2 cancer.
3 It may seem like an odd proposal, and
4 I realize that, but our biggest problem here is to
5 get rid of the material in the silos. And I know
6 that there are places that could take it. It's
7 just a question of working with -- finding them and
8 working with them. Perhaps it sounds too simple.
9 What we've heard has been very complicated, very
10 interesting, but very complicated.
11 So I offer this proposal. I am at
12 this time talking with different people, different
13 mining companies to find their interest, see if
14 there is any. However, I do not believe and, Gary,
15 correct me if you have any different information, I
16 do not believe at this time that the DOE has put
17 out any type of requests for comments or proposals
18 to, for this type of treatment or disposal of the
19 material.
20 I would also like to end this by
21 saying that the Department of Energy as well as
22 its — what is it called here — its Isotope
23 Production and Distribution Division has funded a
24 great deal of money into Dr. Scheinberg's clinical
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1 trials and in his work, and so the DOE must have
2 some confidence in what he's doing that is being a
3 great contribution to cancer treatments. I would
4 offer the alternative, and I would also think that
5 we should keep in mind what a valuable amount of
6 radium that we had. If we send it to Nevada, it's
7 gone forever, and people with lymphomas, leukemias,
8 non-Hodgkin's disease, for example, and if you
9 remember, this is what King Hussein, Jacqueline
10 Kennedy, and Tom Landry of the Dallas Cowboys all
11 died of, and I think that we should use this
12 radium, find a way to use it and keep it and not
13 dump it. Thank you very much.
14 MR. STEGNER: Thank you, JoAnne.
15 MS. SCHROER: My name is Carol
16 Schroer, and if what I'm going to read makes no
17 sense to everybody, it's because I haven't been
18 able to hear very well tonight.
19 We knew the silos would be a big part
20 of the Fernald cleanup, and we knew they would be a
21 real challenge. And when vitrification was
22 suggested, it seemed to be our answer to the low
23 volume storage plus the transportation. But when
24 the VIT pilot plant ran into major problems, like
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1 square fittings into round holes, I knew we were in
2 trouble. I still know in my heart that to vitrify
3 is really the best way to go, but we must move on
4 and we must get to the silos and get them taken
5 care of, and my one prayer is that it be done with
6 every precaution and that it be done correctly. We
7 live here, and we want to be sure that we're still
8 here when the silos aren't.
9 MR. STEGNER: Thank you, Carol.
10 MS. YOCUM: I'm Edwa Yocum, and as a
11 resident living one and a half miles south of the
12 Fernald site, which is also a disposal and storage
13 site, and it contaminated the environment, I really
14 prefer the vitrification process for its reduction
15 of the toxicity, the mobility, and the low volume
16 of treated waste and less volume for shipping. But
17 when I think about the workers and their safety, I
18 have to select chemical stabilization. Because,
19 yes, it's easier possibly to implement than what
20 vitrification is right at this time, but who knows
21 what can happen to the vitrification technology in
22 another four years. But still we must move on and
23 get this job done. So I will accept chemical
24 stabilization, but also I would like to add too, as
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1 treated silos 1 and 2 waste must not remain on the
2 Fernald site or be placed in the on-site disposal
3 facility if NTS's doors close, Thank you.
4 MR. STEGNER: Anyone else?
5 MR. DAVIS: Douglas Davis. I want
6 to take an opportunity to be very brief, you've
7 been very gracious to our company in the past in
8 allowing us in discussion, and I'm very impressed
9 with the level of consideration that's come into
10 this whole problem. I think this is amazing. I
11 might like it if it were shifted a bit, but that's
12 not the point.
13 I did want to say just a couple of
14 things about glass, though, I think it gets into
15 your soul a little bit when you work on glass
16 developments for months. In terms of safety I have
17 to say that I feel better about thinking about a
18 durable glass at a site where, even if our
19 infrastructure is totally gone and even if it's no
20 longer an arid area, the radon, the radioactivity,
21 the lead, is still contained and can't wander off.
22 The other thing that several times
23 we've talked about, and I think perhaps we haven't
24 given it as much emphasis as we might, is to the
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1 large commercial glass industry that operates all
2 around the world, not with our radioactive
3 hazardous waste glasses, but many of these issues.
4 I think it's wonderful that we've gone and
5 considered the opinions of the workers, that's very
6 important. Surprisingly that's not done very
7 much. But a slightly increased inherent risk in a
8 process does not always result in more injury
9 because you can build in, and I think the glass
10 industry is a good example, they have built in the
11 structure to be a very safe industry. Even in
12 parts of the world where they don't even have the
13 infrastructure that we have.
14 In talking about greater
15 implementability, you know, our company, one of the
16 things we do is build large float glass plants, and
17 one of the demands that's often put on us is, okay,
18 here's an order, we would like to have glass
19 running out in sheet form in two years. That's
20 very common. So, you know, through construction
21 planning and engineering planning you can put
22 together complex projects very quickly, and it's
23 still with good quality control.
24 And I guess under the question of
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1 operability, again I would just mention some of
2 these plants that are run commercially, we commonly
3 as part of our contracts to a customer, now these
4 are not radioactive waste raw materials, but part
5 of our warranty is that day after day these operate
6 with less than two or three defects per ton of
7 glass. So, the commercial industry sits there and
8 runs, it's very operable. Just want to make sure
9 we just think about that, and I appreciate your
10 consideration.
11 MR. STEGNER: Thank you, sir.
12 MR. GELS: My name is Jerry Gels.
13 I'm a health physicist. I've been coming to a lot
14 of these meetings and was about to go on the record
15 as saying that I thought that cementation was the
16 better alternative of the two because if those are
17 our choices, I felt that, as Ms. Wilson pointed
18 out, that the retrievability would be better than
19 that, although I think she said that it wouldn't,
20 so I don't know how to feel about that. But I do
21 feel that the radium 226 that we have in those
22 silos is a resource. We've been looking at it as a
23 waste, and it is very true in a lot of short-term
24 viewpoints, it can be considered a waste. If you
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1 look at the long term, as she's pointed out it
2 could be considered a resource, and this is a
3 resource that of all the atoms of radium 226 that
4 there are in this country, most of them are in two
5 silos out by Paddy's Run Creek, and they are,
6 depending on the medical results, which I've been
7 trying to find out about for some years now, how
8 that is doing, but depending on those results, they
9 can be a resource of tremendous value to the world,
10 and I think that should be considered in the long
11 run as what we do on that basis, whether we do
12 something that will put those atoms in a form that
13 cannot be easily retrieved or whether we separate
14 them out. And they can be chemically separated, it
15 is possible to do. Marie Curie did it a hundred
16 years ago. It's possible to do it. I don't know
17 if we've looked at doing that, but I think it's
18 something that we ought to look at. Thank you.
19 MR. STEGNER: Anyone else? Going
20 once, twice. Thank you all for coming.
21 - - -
22 MEETING CONCLUDED AT 8:20 P.M.
23 - - -
24
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CERTIFIED COPY
ATTACHMENT B.II
1 UNITED STATES OF AMERICA
2 DEPARTMENT OF ENERGY
3
4
5
6 PUBLIC MEETING
7 PROPOSED PLAN FOR
8 REMEDIAL ACTIONS
9 AT SILOS 1 & 2
10
11
12 WEDNESDAY, MAY 3, 2000
13 NORTH LAS VEGAS, NEVADA
14 4:35 PM
15
16 REPORTER'S TRANSCRIPT OF PROCEEDINGS
17
18
19
20
21
22
23
24 Reported by: MARK I. BRICKMAN, CSR, RPR, CCR
Nevada License No. 605
25
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1 APPEARANCES
2 FOR THE DEPARTMENT OF ENERGY: Moderator - GARY STEGNER
3 TERRY HAGEN
4
5 Formal Comments: Page 43
6
7
8
9
10
11 BE IT REMEMBERED that, pursuant to notice of
12 the Public Meeting, and on Wednesday, May 3, 2000, at the hour
13 of 4:35 PM, at 232 Energy Way, North Las Vegas, Nevada, before
14 me, MARK I. BRICKMAN, CCR No. 605, State of Nevada, there
15 commenced a public meeting.
16
17 oOo
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21
22
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1 MR. STEGNER: Good afternoon, everyone. My name
2 is Gary Stegner. I work in Public Affairs for the Department
3 of Energy at Fernald. I want to thank you all for coming here
4 this afternoon.
5 With me are Nina Aksunduz. She is the Silos
6 Project Manager for the Department of Energy - Fernald. Gene
7 Jablonowski. He is Region 5 EPA, Fernald Program Manager for
8 US-EPA there.
9 Terry Hagen, for Fernald and also Dennis Nixon.
10 Since Nevada stakeholders could potentially be
11 impacted by the course of action we choose to remediate Fernald
12 silos, we figured we would provide the same public involvement
13 opportunities for you as we did for our own stakeholders last
14 week.
15 What we did then we hope to do tonight is two
16 distinct segments of a -- a meeting.
17 First is an informal review of the program that
18 we're proposing, and that will be followed by informal question
19 an answer session, which combined should take about thirty
2 0 minutes.
21 We would ask you to hold your questions until the
22 presentations are over. That will be -- consist of a video,
23 which you guys have requested we produce, which we have done,
24 and also a short presentation by Terry.
25 Then that will be, as I say, followed by the
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1 informal question and answer session.
2 If you want clarification on any aspect of the
3 project, that's the time to raise your questions at that time.
4 That will be followed by a formal public hearing
5 where we will be exclusively in a listening mode. We will not
6 be responding to anything at that time. We will simply be
7 taking your comments on the Revised Proposed Plan Silo Project.
8 Your comments will be transcribed and be part of
9 the official public record on the silos project.
10 We will respond to any and all comments received
11 by Nevada stakeholders through formal responsiveness summary
12 document which will be provided to all commenters and will also
13 be placed in your public reading room and public information
14 center. Those will be placed here and also at Fernald.
15 If you would rather submit your comments in
16 writing to me, you can certainly do that. You don't have to
17 speak on the record tonight. Those comments should be
18 postmarked by May 18th if you want them to be included in the
19 formal record.
20 As I said, the project overview will be presented
21 in a video form which was prepared by request of the Nevada
22 stakeholders, and following the video, Terry will offer a short
23 briefing, after which you can ask your questions.
24 At the conclusion of the question and answer
25 period, then we will go into the formal public comment period.
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1 So with that, if you could queue the video and
2 we'll get started.
3 (Videotape is being shown at this time).
4 MR. HAGEN: What I'd like to do is move this
5 clip down. So to briefly summarize and supplement the data in
6 the video against the criteria that EPA mandates for
7 consideration when you make a decision in the CERCLA, and
8 they're the same ones that were -- that were presented in the
9 video.
10 I apologize for the font size there. I know it's
11 a little hard to read, but you've got it in your handouts.
12 Maybe you can follow along.
13 We'll talk about all nine of these, and real
14 quickly, you see the bottom two don't have an assessment;
15 rather we felt that there was a favoring for vitrification and
16 chemical stabilization, either/or.
17 The state acceptance and community acceptance,
18 that's evaluated based on the results of these public
19 involvement forums, so actually I'll be talking about seven of
20 the nine.
21 The first criteria is called overall protection
22 of human health and the environment, and this is what's called
23 a threshold criteria under CERCLA, which means that the EPA
24 requires that before you can select a remedy, you must
25 demonstrate that it adequately -- again I apologize. We were
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1 trying to make this readable. That it adequately addresses
2 this particular criterion.
3 What we concluded is that both stabilization and
4 vitrification do pass this threshold. The protection is
5 provided by a combination of removal at Fernald, treatment to
6 address the RCRA metals in the waste and also treatment to meet
7 Nevada Test Site waste acceptance criteria and performance
8 assessment requirements and long-term stable disposal at the
9 test site.
10 The second threshold criteria is called
11 compliance with applicable or relevant and appropriate
12 requirements.
13 Our conclusion again was that both technology
14 families met this threshold criteria.
15 The primary ARARs that we're concerned about --
16 we're concerned with all of them and we have to meet all of
17 those, but the ones that really drove the analysis, number one,
18 are the NESHAP sub-part 2 radon flux limitations, and what we
19 found is is that both technologies when combined with their
20 packaging met this ARAR, and then second, of course, are all
21 the Department of Transportation requirements for
22 transportation.
23 Again the analysis — and we'll talk a little bit
24 more about those Department of Transportation requirements, but
25 our analysis is that both alternative families, technology
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1 families meet this threshold criteria.
2 What that means under CERCLA is that once you
3 screen your potential alternatives against the threshold
4 criteria, some get screened out.
5 Those that -- that pass through that screening
6 are then eligible for a comparative analysis against five
7 balancing criteria. Those are the next five that we're going
8 to go through.
9 The first one is long-term effectiveness and
10 permanence. Our evaluation along with US-EPA was that both
11 technology alternatives performed at approximately the same and
12 performed adequately.
13 The basis for saying that both provided adequate
14 long-term effectiveness and permanence is really the same
15 argument that went with the first threshold criteria; that is,
16 removing at Fernald, treatment to meet regulatory requirements
17 for the leachable -- RCRA leachable materials in there, also to
18 meet the waste acceptance criteria at the test site and
19 performance assessment requirements and then stable disposal,
20 long-term disposal at the test site.
21 Again, equal -- equal and adequate performance by
22 both technology families.
23 The next of the balancing criteria is called
24 reduction of toxicity, mobility or volume through treatment.
25 In this criteria, it was our assessment that
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1 there was a distinct advantage to the vitrification technology,
2 and that primarily relates to the treated waste volume, and at
3 the end of the presentation, I'm going to present a couple of
4 slides that are intended to directly address some questions we
5 got from the Transportation Subcommittee of the CAB, and
6 there's also another one coming up here in just a second that
7 show those volumes, but there's — there's a lot more volume
8 associated with chemical stabilization than vitrification, and
9 that's the primary basis. We'll cover all of these sub-
10 components.
11 Basically chemical stabilization produces about
12 three times the amount of waste than vitrification, and hence
13 the basis for the advantage to vitrification.
14 About 12 to 1,300 -- depending on which
15 particular iteration of the chemical stabilization technology,
16 between 12 and 1,300 cubic yards -- cubic feet -- I'm sorry.
17 It's -- it's 1,300,000 cubic feet -- sorry -- of material that
18 would require disposal at the test site versus 3 to 400,000 for
19 vitrification.
20 For secondary waste volumes, you'll see those
21 were approximately equal. The secondary waste associated with
22 vitrification are a little bit more difficult to deal with than
23 those associated with chemical solidification. Some of them
24 are mixed waste.
25 Also because of the nature of the high
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1 temperature operation, it tends to drive off more gas type
2 materials and more gaseous emissions that have to be dealt
3 with.
4 So we do believe there's a slight advantage to
5 chemical stabilization relative to secondary waste, but not
6 enough to undo the significant increased volume there for
7 chemical stabilization.
8 Short-term effectiveness is the next balancing
9 criteria. Short-term effectiveness basically consists of a
10 couple of subcomponents.
11 Worker risk, risk to the workers associated with
12 actually removing the material and treating it as well as the
13 workers involved in transportation, and then again those
14 workers also at the test site who would be involved in
15 disposing of these materials, and then the -- the last
16 subcomponent is how long it takes to complete the remedy, time
17 to protectiveness.
18 Our evaluation here was that there was an
19 advantage for chemical stabilization, primarily driven by the
20 worker risk issue, and we'll talk about each of these sub-
21 components here.
22 Relative to radiological dose, which is what a
23 lot of people have — have historically assumed would drive the
24 worker risk, that's about the same for the different
25 alternatives.
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1 The difference comes in the fact that — and
2 we've got an overhead here coming up to demonstrate those
3 hours, but there are a lot higher number of working hours
4 required to complete the project under vitrification than for
5 chemical stabilization, and statistically what that results in
6 is a higher probability of some kind of accident for the
7 workers in implementing that technology.
8 Also, vitrification is a high temperature, high
9 power, high voltage operation which has some inherent risk to
10 workers associated with those issues versus chemical
11 stabilization, which is an ambient temperature batch type, room
12 temperature batch type operation.
13 And then finally both of these technology
14 families would be implemented remotely, but for maintenance of
15 the system, that would be done by contact; in other words,
16 workers going in and actually maintaining, fixing, et cetera,
17 and again for some of the reasons associated with the high
18 power, high temperature, we think there's a greater risk to
19 workers during maintenance operations.
20 Relative to transportation risk, there is an
21 advantage to vitrification, and that links directly back to
22 what I talked about a while ago; that is, there's three times
23 the volume of material to be handled, to be dis -- to be
24 transported and be disposed for chemical stabilization.
25 Statistically that equates to about three times
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1 the transportation risk.
2 Now, a couple of points to be made: One is is
3 while there is a clear advantage to vitrification, CERCLA/
4 US-EPA requires us to do a number of evaluations of what are
5 the risks associated with transporting this material under an
6 accident free scenario, but also what are the risks associated
7 with this material in the event of an accident to the general
8 public, response workers, et cetera.
9 What we found was that those calculations were
10 well within what the CERCLA process, at least, considers to be
11 acceptable risk to the public, transportation workers, both
12 under routine circumstances and in an accident scenario.
13 And then the second element of that evaluation
14 was that there actually were higher -- acceptable, but higher
15 risk to emergency response workers through the vitrification
16 technology.
17 The reason being is vitrification basically
18 concentrates the waste, whereas the -- the clearest way to
19 state it for chemical stabilization is by adding the — the
20 various things that bind the contaminants together, you're
21 diluting the waste, you're diluting that radioactive source.
22 So there's actually a higher source term because
23 of the concentration of the waste with vitrification than
24 chemical stabilization. So that's the basis of the -- of the
25 last conclusion.
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1 The other issue — I don't have an overhead for
2 it -- was time to protectiveness.
3 Based on data that we received from the vendors
4 that were involved in the proof of principle testing that was
5 referenced in the video, that data said that we could implement
6 chemical stabilization approximately a year quicker than
7 vitrification.
8 So that coupled with the increased worker risk
9 was the basis of saying there was a — an advantage to chemical
10 stabilization in this balancing criteria.
11 The next balancing criteria is implementability,
12 which is pretty much what it sounds like, your ability to
13 successfully with a reasonable degree of certainty implement
14 this technology.
15 It was our conclusion that there was an advantage
16 to chemical stabilization. Again we'll talk about some of
17 these things.
18 The first one is scale-up. We rated that
19 neutral. The reason we rated that neutral — in other words,
20 no advantage in one direction or the other — is is that there
21 are examples, albeit very, very limited for vitrification that
22 we're going to discuss in a second.
23 There are examples for both technology families,
24 however, of -- of facilities operating at the scale that we
25 would require at Fernald to complete this project in a timely
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1 basis. So we rated that neutral.
2 From this point forward, we feel -- for the
3 reasons I'll go into here in a second — that there is an
4 advantage to chemical stabilization.
5 The first one is commercial demonstration which
6 EPA requires us to look at. If you go out, which we did, and
7 look at hazardous and radiological contaminated sites
8 throughout not only the United States, but also the world, we
9 found many, over a hundred instances to where chemical
10 stabilization had been selected and selec -- successfully
11 implemented to manage waste under CERCLA sites through CERCLA
12 records of decision, through NRC response actions, in some
13 instances through corrective actions under RCRA.
14 There was a very, very limited database of -- of
15 applications of vitrification, and what that translates to is
16 not that vitrification won't work. It translates to it's just
17 not proven to the same degree of chemical stabilization, which
18 is a factor that again EPA requires us to look at.
19 The second aspect is operability. The video
20 basically talked about the differences in the technology, and
21 what this boils down to is the number and the complexity of
22 unit operations.
23 To successfully implement vitrification requires
24 a number of steps, technical steps -- again, as briefly
25 discussed in the video — that are more numerous and more
13
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1 technically challenging than chemical stabilization, which is
2 basically an ambient, fairly low-tech operation.
3 That's not to say there aren't challenges since
4 we have to do this remotely, because there are. It's not a
5 slam dunk we're going to go in and do that successfully.
6 The point is that it is a simpler operation, and
7 that's fundamentally the basis of our conclusion that there was
8 an advantage for chemical stabilization.
9 The other thing that you saw up there was two
10 other points, contractibility, which links directly to what we
11 just talked about.
12 We show an advantage for chemical stabilization
13 because there are more unit operations, more complex equipment
14 to put in, and in particular the melter itself with its
15 refractory lining, it's something that has to be done to very
16 tight tolerances and has to be done at the site. It's just
17 harder to build, hence an advantage for chemical stabilization.
18 The other one is something we called ease of
19 acceleration. I think the — the best way to show that is —
20 is to reference the number of hours we talked about a little
21 earlier in the presentation that it requires the number of --
22 of unit operation hours that each technology family would
23 require to finish this project in three years, which is
24 arbitrary, but for illustration purposes, it shows a
25 significant difference.
14
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1 You're talking about anywhere from 7 to 10,000
2 operation hours for chemical stabilization depending on which
3 specific tweak of the technology you use versus 16,000.
4 That means it's just a lot harder to get done
5 quicker with vitrification.
6 It also introduces more possibility for equipment
7 failure just through routine wear and tear and things of that
8 nature. Again the basis of the conclusion under ease of
9 acceleration that proves an advantage for chemical
10 stabilization.
11 The last of the balancing criteria is cost; not a
12 big difference. CERCLA requires that this stage in the
13 process, the feasibility study phase of the process before you
14 go into de -- detailed design that you develop cost estimate --
15 cost estimates for these technologies to an accuracy of plus
16 50, minus 30.
17 We think we're a lot tighter than that, and what
18 it shows is is there is a slight advantage for chemical
19 stabilization, maybe a ten percent difference between the two,
20 which within that range of accuracy that I talked about isn't
21 particularly meaningful.
22 So, again, very slight advantage for chemical
23 stabilization, but not a real driver in our mind for the
24 decision. Important, but not a differentiator between the two.
25 The other two criteria -- again, state acceptance
15
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1 and community acceptance — will be based on these forms with
2 you all, the public hearing that we had in Ohio as well as
3 comments from the Ohio Environmental Protection Agency.
4 That really wraps up the comparative summary
5 among -- against the two alternatives.
6 What I want to do is give a couple of additional
7 pieces of information, and this is based on questions that came
8 out from the transportation subcommittee of the CAB last week.
9 Some of our people were here talking to them.
10 Wanted to know a little bit more information
11 about transportation, which presumably is the primary concern
12 of -- of this group of people. I don't want to presume too
13 much, but we'll just get to this point.
14 Silos 1 and 2 material are LSA or low specific
15 activity II solid material, and what that means is we have to
16 use a particular type of container, which I'll get to on the
17 next slide, and there's also limitations on the rad field that
18 can emanate from the material shipments, and you see what they
19 are here.
20 200 millirem per hour on contact with the
21 container at conveyance, 10 millirem at 2 meters from
22 conveyance, 2 millirem an hour to the driver, and just to put
23 it in perspective, what is the untreated field coming off the
24 silos material? Up to 900 millirem per hour.
25 With packaging, both technology families perform
16
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1 about the same, and that is approximately 50 millirem per hour
2 on contact with the container or about four times less than
3 what the regulatory limit allows and conversely about four
4 times under these other limits, as well.
5 Relative to the package itself that we will be
6 obligated to use, the container has to be the Department of
7 Transportation 7A type A container, which means that it has to
8 be certified, and it has to be certified using these tests.
9 The water spray test which basically is water
10 can't get in or can't get out, to put it at its simplest. The
11 drop test, three foot drop test in a manner that causes the
12 maximum damage.
13 That's to simulate what happens to it in an
14 accident scenario and it's got to maintain its integrity and
15 its ability to hold the material in there.
16 Penetration test, also looking to judge the
17 stability of the container in a particular type of accident
18 scenario. Compression test the same.
19 We have a certified container that — when I say
20 "we," I'm talking about Fluor Fernald at the site, and I'll put
21 up an overhead about it here in a minute.
22 Whenever we do this project, it is the current
23 intent to give the vendor the ability to propose a specific
24 kind of container.
25 So it could be different than the one we've got,
17
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1 but if it is different than the one we've got, they're going to
2 have to certify it and they're going to have to certify it
3 against these particular tests.
4 Another question is relative to the total volume
5 of material being generated from the Fernald cleanup, how much
6 is coming here, how much is staying there, and I presented this
7 to — to some of you I think in December.
8 Three-quarters of the material being generated
9 from the Fernald cleanup are staying at Fernald in a — in an
10 on-site disposal facility. Roughly two and a half million
11 cubic yards of material.
12 About sixteen percent of the materials according
13 to current plan will go to Envirocare.
14 For those of you who have been to Fernald before,
15 that's primarily our waste pits project, about 700,000 cubic
16 yards -- actually a little less than that, but on that order.
17 Eight percent of the total material to be
18 generated by the Fernald cleanup will come to the Nevada Test
19 Site.
20 Now of that eight percent -- you see that this
21 goes back to 1985. Of the eight percent of our total volume,
22 about seventy-five percent of that material is already here,
23 okay. It's already here and in the ground.
24 So the remaining waste stream to come to the
25 Nevada Test Site is primarily what we've been talking about
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1 tonight. Most of our legacy waste is already out of Fernald
2 and safely at the site.
3 One last point. It is the current proposed plan
4 that the treated materials from Silos 1 and 2 come to the
5 Nevada Test Site.
6 That is because right now there is no commercial
7 disposal facility that has the disposal capability and/or is
8 permitted to take this particular type of material.
9 Envirocare has voiced a number of times — for
10 those of you who are familiar with that commercial disposal
11 facility up in Utah, that they are going to be pursuing some, I
12 guess, liberalization — that's my own word — of their permit
13 that might allow these materials to go to Envirocare.
14 If that's the case, it -- it would be our intent
15 to explore that option, or if any other commercial disposal
16 facility became available to us, we would explore that option,
17 too, and if it was safe and cost-effective, we'd go there, and
18 what's the probability of it being cost-effective compared to
19 NTS?
20 Right now it's cheaper for us to send the
21 material to Envirocare because we've got the ability to send it
22 door to door by unit rail train.
23 Of course, that capability is not test for the
24 test site so we've got to send it in individual trucks.
25 My point is if -- if we ever have the ability to
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1 go somewhere like the Envirocare, in all likelihood, we will.
2 I apologize. I probably got this a little bit
3 out of order, and I'm going to — I think I get most of it.
4 I mentioned earlier that we do have a container
5 right now that is certified, and we got it from the SEG
6 Corporation.
7 This is — this is that container, and our
8 baseline, our current plan assumes use of this concrete
9 container for transportation of the stabilized material to the
10 test site.
11 Again, we will give other vendors the opportunity
12 to optimize design of this box, this container, but if they
13 don't use this one, they're going to have to certify it
14 according to the standards that I mentioned on the previous
15 slide.
16 That sums up my presentation. I'm going to waltz
17 back to the back table and we're open to take any questions
18 that you might have prior to the formal public hearing.
19 MR. STEGNER: If you have any questions right
20 now, we'll take those and answer them prior to the formal
21 comment period. Once we start taking your formal comments,
22 we'll sit and listen.
23 AUDIENCE PARTICIPANT: With regard to the last
24 statement you just made, the gentleman here, you have the
25 certified container.
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1 To whom — what certified it?
2 MR. NIXON: It's the Department of
3 Transportation.
4 AUDIENCE PARTICIPANT: It's not certified by the
5 NEPA or any other agency?
6 MR. NIXON: It's not.
7 MR. STEGNER: Terry put up a slide on the
8 Department of Transportation it's a 7A type container and
9 what's required to certify that through the Department of
10 Transportation. That's the material.
11 AUDIENCE PARTICIPANT: Can you tell me who makes
12 it again?
13 MR. NIXON: It's a commercial container that was
14 developed by SEG for commercial use.
15 MR. HAGEN: The answer to the second part is
16 yes.
17 AUDIENCE PARTICIPANT: Do you have to have a
18 special vehicle to haul these? Are you going to have any kind
19 of markings on the trailer on the outside?
20 MR. NIXON: It would be placard
21 MR. HAGEN: LSA material. Yes, sir.
22 MR. CLAIRE: Don, would you use your mic so we
23 can all hear and we won't ask the same question a second time?
24 AUDIENCE PARTICIPANT: Can you hear me?
25 I've got several other questions, two or three.
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1 Okay. So we have the certified container going
2 down the highway assume like flatbed trailer, two of these
3 containers per tractor trailer.
4 It is parked by some McDonald's and the driver
5 wants to get a hamburger or something. If you took a rad meter
6 and went out and surveyed that -- the outside casing of that,
7 what type of radiation amount would we get on the —
8 MR. NIXON: In contact with the container?
9 AUDIENCE PARTICIPANT: What are we talking
10 about? How many millirems?
11 MR. NIXON: 70 millirem per hour is what we
12 designed the process that's proposed for -- the chemical
13 stabilization process would be -- result in about 70 millirem
14 per hour on contact with the package.
15 AUDIENCE PARTICIPANT: That's the two containers
16 together?
17 MR. NIXON: That's direct contact on the
18 container itself. As you go away from it — from the
19 container, it would be significantly less.
20 AUDIENCE PARTICIPANT: All right.
21 MR. NIXON: And Terry put up a slide which had
22 the require -- what the Department of Transportation
23 requirements are.
24 It's based on 200 millirem per hour on contact
25 with the container.
22
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1 Our design is — is much less than that at 70
2 millirem per hour. So it would be very conservative.
3 AUDIENCE PARTICIPANT: My next question, other
4 than the nuclear test site, what other avenues of disposal has
5 Fernald looked into?
6 MR. HAGEN: We've looked at number one,
7 commercial disposal, and there is no commercial disposal
8 available at this time that is within the constraints of the
9 license that have the ability to take this material, number
10 one.
11 Number two, we looked at leaving it at Fernald.
12 We do have an on-site disposal facility that our stakeholders
13 and regulators agreed to.
14 There were waste acceptance criteria established
15 for that material based on the fact that their sole source of
16 drinking water for Cincinnati is the aquifer underneath of the
17 on-site disposal facility and created a number of contaminant
18 specific waste acceptance criteria, and this material is
19 significantly above the waste acceptance criteria for the on-
20 site disposal facility.
21 So that ruled out on-site disposal at Fernald,
22 and again, no off-site commercial disposal facility that has
23 the — the licensing in place right now to take this material.
24 Our Silo 3 material, which was referenced at the
25 beginning of the video, is going to — in all likelihood will
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1 go to Envirocare, because that is material that is within the
2 constraints of that license.
3 AUDIENCE PARTICIPANT: In New Mexico, that
4 hasn't been —
5 MR. HAGEN: Are you talking about WIPP?
6 AUDIENCE PARTICIPANT: Yes.
7 MR. HAGEN: This is low-level material. WIPP as
8 I understand it -- I'm not terribly familiar with the internal
9 workings of WIPP, but that's for transuranic storage and other
10 materials. A low-level waste is not technically envisioned for
11 disposal at wipp and this is a low-level waste.
12 AUDIENCE PARTICIPANT: Okay. That concludes my
13 questions. Thank you.
14 MR. HAGEN: Thank you.
15 AUDIENCE PARTICIPANT: I have a couple of
16 comments and then a couple questions.
17 Firstly, from the standpoint of Nevada, you know,
18 the cost difference between your two alternatives is minimal,
19 especially within the kind of, you know, estimates that we're
20 talking about today, and if you use vitrification as opposed to
21 chemical stabilization, we're going to have less volume of junk
22 coming to our state, number one.
23 We're going to have less of a problem
24 transporting because there's less volume, right? You said that
25 yourself.
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1 I guess that makes a problem for me. Why should
2 we take your waste when you have an alternative which is not
3 going to cost that much more for you, but might be costly to
4 us?
5 My other comment, I used to live in Tennessee and
6 worked at Oak Ridge. We were working on vitrification in the
7 1950s.
8 Do you mean to tell me — I heard you say, "We
9 don't know enough about it."
10 How could you not know enough about it? How can
11 you not know anything about it at this point in time? That's
12 forty years ago.
13 Those are my comments.
14 Question: What happens -- I assume you're using
15 filter presence, right?
16 MR. NIXON: Yes.
17 AUDIENCE PARTICIPANT: What happens to the
18 filtrate? Number one question.
19 MR. NIXON: Treated on-site.
20 AUDIENCE PARTICIPANT: How? That's going to be
21 really concentrated. You're going to have to do something with
22 that. That's going to be another probably worst waste than you
23 have in the solids, possibly, anyway.
24 MR. NIXON: Well, it's going to go through
25 wastewater treatment at the site and then we have an advanced
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1 wastewater treatment before it's discharged to the -- to the
2 river for radium.
3 Primarily we will be removing the radium at the
4 processing facility.
5 Now how -- how that will be designed will be
6 again dependent on the vendor to design on how they propose to
7 deal with that aspect of it. That has not been --
8 AUDIENCE PARTICIPANT: That can be -- that could
9 be a real problem in terms of wastewater treatment. You're
10 going to have some real problems getting rid of those heavy
11 metals in a way that doesn't affect the environment, so to
12 speak. Some river. Cincinnati, Ohio.
13 The other thing is I guess it bothered me that
14 you're going to use either an oxide or some metal, iron — I
15 don't know what your precipitous is going to be. You're either
16 using iron, aloe, lime, whatever. Those are all going to
17 result in a higher pH; that is, your solid matrix.
18 If you bury that in the ground according to all
19 the nuts, the environmentalists, you're going to have more and
20 more acid rain, right? As acid rain filters down through the
21 ground, what happens to all these metals?
22 I know what's going to happen to them. If, in
23 fact, that happens, and we do have some rain here — not like
24 Cincinnati, but there's a little bit of rain here.
25 Is -- is that a concern?
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1 MR. NIXON: It certainly is a concern. The
2 process that is proposed here using a trisodium phosphate as
3 the stabilizing agent for the lead compound to make the lead
4 compound immobile.
5 AUDIENCE PARTICIPANT: Yeah, but it's still tied
6 up with a high pH environment.
7 MR. NIXON: Exactly.
8 And then after the lead is stabilized with the
9 trisodium phosphate, then cement and in one paste fly ash would
10 be stabilized or solidified with the cement in the fly ash for
11 final disposal.
12 Now the waste acceptance criteria at the Nevada
13 Test Site is based on the TCLP analysis where we actually take
14 the stabilized waste and we grind it up and we do this
15 analysis, and the analysis is meant to essentially mock what
16 happens in the environment under infiltration of acid rain.
17 It's counteracted with an acidic solution over
18 time, and then that solution is analyzed for its constituents,
19 and that's how we meet — demonstrate that we meet your waste
20 acceptance criteria through that testing.
21 So it's essentially the test. The TCLP analysis
22 is there to mock up exactly what you had defined, the
23 infiltration into a landfill of acid rain.
24 So if we meet that TCLP analysis or meet the --
25 the leachate is below the TC limits, the regulatory limits,
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1 then theoretically that would no longer be an issue in nature.
2 AUDIENCE PARTICIPANT: The bottom line of my
3 question or comment is that from the standpoint of Nevada, we
4 would recommend — I would recommend — and I'm a registered
5 engineer. I would recommend using -- using vitrification.
6 I know it will cost you ten million dollars more
7 dollars in Fernald, but using that much waste coming into our
8 state, why not? Well?
9 MR. HAGEN: Do you want a response or is that
10 a --
11 AUDIENCE PARTICIPANT: I want to ask you a
12 question that's relative to that.
13 AUDIENCE PARTICIPANT: Let him respond first.
14 AUDIENCE PARTICIPANT: Well --
15 AUDIENCE PARTICIPANT: Let him respond to the
16 question. I want to hear his response.
17 MR. HAGEN: Okay. One thing I probably should
18 have spent more time with, you know, relative to your comment
19 about you've been working with vitrification since the ^50s.
20 The simple fact is for waste streams like this,
21 nobody has gone out and done it very successfully.
22 There are a couple of instances to where it's
23 been done, Savannah River. I got a feeling you know as much
24 about it than I or more.
25 Nowhere with the technology that we're talking
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1 about in a radioactive remote environment has it been done, not
2 once at the scale we would require for Fernald, and where it
3 has been done at lower scale, significantly lower scale, the
4 fact is is that it was very difficult to get where they were.
5 I think there's one or two instances in the world
6 where there have been what you would call a successful
7 application of vitrification for this type of waste stream. It
8 was at a lot lower scale than we need, and they went through
9 hell to get to where they eventually got to.
10 So from our perspective -- I understand your
11 comment, but to answer from our perspective, yeah, there's a
12 10, 20 million dollar difference in the cost estimate, but the
13 data that we have got from industry tells us that we're going
14 to have a very, very difficult time implementing vitrification
15 if we can do it successfully at all.
16 We've already had one less than optimal
17 experience with vitrification at Fernald. We look at what's
18 happened at Savannah River. We look at what's happening at
19 Paducah and more recently with DNFL at Hanford.
20 It's just not a technology that we feel certain
21 that we can go implement in a cost-effective, timely manner.
22 I understand, and please welcome the formal
23 comment period what you said, but that's -- that's from our
24 perspective why we're going with chemical stabilization.
25 All those other advantages are only hypothetical
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1 if you can't do it, and the simple fact is is that we're a lot
2 more confident in our ability to get it done with chemical
3 stabilization.
4 AUDIENCE PARTICIPANT: Thank you.
5 AUDIENCE PARTICIPANT: Yeah. The reason I
6 wanted to make a comment and ask a question was to compliment
7 Peter's concerns because this is the first time at least I have
8 heard a positive evaluation of vitrification.
9 All up to now has been exactly parallel to what
10 you've been saying, which I suppose leads to the question of
11 why do you even present the vitrification in a positive sense
12 when you do not have the technology or the capability?
13 Because if you don't have the capability, you
14 don't have the knowledge, you don't have an alternative.
15 MR. HAGEN: Yeah. My answer to that is is that
16 we evaluated this -- we, the Department of Energy and the
17 Fernald site back in the early '90s where it was --
18 notwithstanding the comment that the technology has been around
19 for a long time.
20 The technology is applied to environmental
21 cleanup was kind of the rage in the early '90s, and so we went
22 through the initial evaluation frankly with -- with a lot of
23 literature-type data, lab scale-type data and we made an over-
24 optimistic assessment of that technology relative to our
25 ability to go do it, at least at the Fernald site.
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1 So with that done, whenever we got into the
2 situation of needing to re-evaluate the technologies, our
3 stakeholders in Ohio felt very strongly that that needed to
4 stay on the table for those comparative evaluation.
5 AUDIENCE PARTICIPANT: Well. I'm -- I'm
6 perfectly satisfied with your remedial action choice. My only
7 point was I'm not even sure that vitrification should have been
8 given consideration, and that's your business.
9 AUDIENCE PARTICIPANT: I was -- I was pleased to
10 see that you had a chart that showed the radon flux at silos 1
11 and 2, and so I assume from that that you had some measurements
12 of the production of radon gas in those — the vicinity of
13 those two silos.
14 And then I further assume that with that kind of
15 information, you made an estimate of the kind of contribution
16 of radon gas in the Nevada environment, your disposal is going
17 to make.
18 Did anybody do that?
19 MR. NIXON: Yeah. As part of -- in looking at
20 the -- the way that the waste would be disposed, obviously you
21 can see from the chart that the waste itself does not meet the
22 regulatory requirements, which is basically 20 picocuries per
23 meter -- square meter per sec -- per second.
24 But once packaged, it would meet the NESHAP
25 requirements; not only for interim storage, but for long-term
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1 disposal. Combined with the disposal facility.
2 When we ultimately do the performance assessment
3 for the final disposal of this waste in its final form, that
4 will be one of the key parameters that's evaluated for the
5 disposal configuration to be sure that the waste itself, even
6 after the package is possibly compromised over time, would
7 still meet the radon flux limits on the top of the disposal —
8 disposal cell itself.
9 AUDIENCE PARTICIPANT: I just have one more
10 question. I was wondering about the possibility of instead of
11 putting all of that good shielding in the ground, I thought
12 maybe you could design some kind of a shell that went over each
13 container, and then after it's offloaded, return those shells
14 back to Fernald.
15 MR. NIXON: That was evaluated. That certainly
16 was evaluated, and let me tell you the main reason we --
17 there's two reasons, really.
18 One is worker risk. Putting the waste after it's
19 treated into an unshielded container is going to require us to
20 handle both at Fernald and at Nevada.
21 So there's a significant worker risk issue before
22 it gets into the shielded container for shipment.
23 Secondly, you have the shipment that is not
24 dedicated two-way trans -- transport. It's dedicated to the
25 NTS site itself.
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1 We would have to pay to have the container
2 delivered back to the Fernald site at a significant cost to the
3 project.
4 Really from our standpoint it's worker risk, we
5 want the waste to go directly into the shielded container and
6 have the waste shielded for the workers both putting it in the
7 container and dealing with that at Fernald and offloading it
8 here and putting it into the disposal cell.
9 AUDIENCE PARTICIPANT: Thank you.
10 I've got a couple questions. Is this a NEPA
11 process?
12 MR. NIXON: Yes, yes.
13 AUDIENCE PARTICIPANT: The NEPA process requires
14 that energy consumption be a consideration. I don't see that
15 as one of your criteria.
16 We are importing over fifty-five percent of our
17 energy. The Department of Energy has a responsibility for this
18 area, and it is an issue which should be kept before the
19 forefront of the public.
20 MR. NIXON: The feasibility study that led up to
21 this proposed plan that we're presenting tonight was a full
22 environmental impact statement when it was originally done. As
23 revised, it's — we did a supplemental analysis to our original
24 Environmental Impact Statement.
25 So yes, those things are evaluated in the -- in
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1 the detailed document, the feasibility study. They're not
2 presented to you here.
3 AUDIENCE PARTICIPANT: In regard to energy
4 consumption, we got process of transportation and disposal.
5 What alternative has the least energy consumed?
6 MR. NIXON: I'm not sure I can answer that.
7 AUDIENCE PARTICIPANT: It's an important
8 question.
9 MR. NIXON: Yes, it is.
10 AUDIENCE PARTICIPANT: You folks should be able
11 to answer that.
12 MR. NIXON: I would have to -- I would have
13 to -- I don't have the information here in front of me.
14 AUDIENCE PARTICIPANT: We spend probably a
15 hundred or 200 million dollars protecting our foreign oil
16 resources with a military force and our energy consumption is
17 increasing.
18 So this is a very major national issue and also a
19 national security issue. Most people don't think about it.
20 MR. HAGEN: The exact numbers I can't quote. It
21 was -- obviously it was significantly higher for the
22 transportation element for chemical stabilization just because
23 of the shear, you know, increased number of shipments.
24 As far as the on-site treatment aspect of it, it
25 was significantly higher vitrification because of the — the
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1 high power requirements for that technology. I can't quote the
2 numbers. I apologize.
3 AUDIENCE PARTICIPANT: Just for a point of
4 information, in Europe, country of France, the vitrification
5 process is quite sometime.
6 As a matter of fact in 1998 and 1996, the power
7 plants in Europe were sent the waste vitrification and
8 particularly in Germany, by rail car back to Germany for
9 storage and all kinds.
10 Are you aware of that?
11 MR. HAGEN: Yes. In fact, I didn't get to --
12 the boss got the glory trip, but we actually went to La Havre.
13 in France and also to Britain where they're doing
14 vitrification.
15 Basically they are doing it, but on a very
16 different waste stream. So we didn't think it was --
17 MR. NIXON: We evaluated those facilities under
18 commercial demonstration. They're on much smaller scales, but
19 homogenous, high-level — specifically on high-level waste.
20 Never on low-level waste.
21 MR. HAGEN: Our boss actually went there and
22 actually looked at these facilities.
23 MR. NIXON: These same facilities, the low-level
24 waste or a portion of the waste that they have on-site is also
25 being chemically stabilized, as well, or similar process.
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1 AUDIENCE PARTICIPANT: What type of cement is
2 going to be used in the --
3 MR. HAGEN: Cement is a generic term. I'm
4 sorry.
5 AUDIENCE PARTICIPANT: That's okay.
6 MR. HAGEN: You know, cement stabilization is
7 kind of a generic term that applies. What is more likely in my
8 opinion -- not that a successful vendor couldn't use straight
9 cement — is they're going to have their own little proprietary
10 version of some pozzolanic based additive.
11 So it will be some tweak, their own little
12 proprietary tweak, and it will probably have the basics of
13 cement in it, but it will have other things in it, too.
14 MR. NIXON: These are all type A cement with the
15 stabilizing agents in it:
16 AUDIENCE PARTICIPANT: They got some good state
17 of the art material.
18 MR. HAGEN: Yes.
19 MR. NIXON: And that very well will come into
20 play with a competitive environment that vendors will be asked
21 to engage in.
22 AUDIENCE PARTICIPANT: What I'd like to --
23 rather rude. I'd — I'd like to really — want to thank you
24 all for having the public hearing out here and also for the
25 meeting you had last week.
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1 I found you responded to our questions and we had
2 a number of them and I thought there was a good demonstration
3 of interaction among sites, which I hope can happen with other
4 sites.
5 One -- one question I had. You indicated the
6 majority of the waste has actually arrived at the test site.
7 And how does that compare with the material
8 you've already shipped? How does it compare with the material
9 you're proposing to ship from the silo program as far as risk?
10 Just ballpark or if you're able to do that.
11 MR. HAGEN: As far as a calculated number, I
12 can't do it, but in terms of a type of material, most of it
13 does not -- most of the material coming does not have the same
14 degree of radium content within the radon generation, which is
15 really a primary issue during waste transportation.
16 Most of the material would have fallen into the
17 LSA-1 category versus the LSA-2.
18 AUDIENCE PARTICIPANT: The prior material?
19 MR. HAGEN: Yeah.
20 So, you know, all low-level waste, all — you
21 know, what I would say within the same order of magnitude of
22 risk, although what's unique about this particular waste --
23 waste form relative to transportation issues, we'll probably do
24 that radium content.
25 MR. NIXON: We've shipped similar compact dose
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1 rates on the container that didn't require this level of
2 shielding to get to those levels, to that 50 to 70 millirem per
3 hour.
4 AUDIENCE PARTICIPANT: Thanks.
5 AUDIENCE PARTICIPANT: I've got a couple
6 questions. Just kind of help me understand this.
7 On this sheet that you have here, you've got
8 volumes.
9 MR. HAGEN: Yes.
10 AUDIENCE PARTICIPANT: Is this just the waste or
11 does that include the containers alone?
12 MR. HAGEN: It's the container -- it's the
13 entire waste volume that would go into the ground including the
14 container.
15 AUDIENCE PARTICIPANT: Just roughly figure the
16 loads out, how many loads are in --
17 MR. HAGEN: That's about 6,000 containers and
18 3,000 shipments.
19 AUDIENCE PARTICIPANT: On each line or total? I
20 mean —
21 MR. NIXON: We're talking about the chemical
22 stabilization one.
23 AUDIENCE PARTICIPANT: Each of them. That's
24 what I —
25 MR. NIXON: If you look at the tallest one,
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1 which would be M-l, which was our cement base chemical
2 stabilization, that is equivalent to 3,000 shipments.
3 AUDIENCE PARTICIPANT: Okay.
4 MR. NIXON: Two containers per shipment.
5 AUDIENCE PARTICIPANT: I just kind of wanted to
6 have an idea.
7 On this box, is this a picture of the actual box
8 that -- basically or is it something different?
9 MR. NIXON: That's a picture of a box that was
10 used in the evaluation. As Terry said earlier, the vendor who
11 ultimately performs this design construct and operate the plant
12 may decide to select a different package.
13 AUDIENCE PARTICIPANT: Okay.
14 MR. NIXON: That would be optimized to his
15 particular process.
16 AUDIENCE PARTICIPANT: I was just trying to
17 understand how would you fasten the lid on.
18 MR. NIXON: There again, it would have to be
19 designed, certified in the manner that we talked about.
20 That particular container is in connection with a
21 gas, a neoprene gasket, but that is not necessarily the package
22 that would be used.
23 AUDIENCE PARTICIPANT: Okay. These silos --
24 you're emptying silos; is that correct?
25 MR. NIXON: Yes.
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1 AUDIENCE PARTICIPANT: Are you going to reuse
2 the silos or they look like they were kind of getting pretty
3 well --
4 MR. NIXON: They'll be demolished.
5 AUDIENCE PARTICIPANT: Are they being hauled out
6 here, too, or someone else or do you have your own -- where
7 does that material go when you demolish those?
8 MR. HAGEN: Silos 4 will go to our on-site
9 disposal facility. Silo 3 will go to our on-site disposal
10 facility. Silo 1 and 2 rubble will come to the test site.
11 AUDIENCE PARTICIPANT: Is this in this volume
12 here or not?
13 MR. NIXON: It's in that volume. It's in our
14 cost estimate, yes, here, but it's also in our low-level waste
15 shipment estimates in our waste management program.
16 AUDIENCE PARTICIPANT: Okay.
17 MR. NIXON: It's already covered under the waste
18 management program that your cost and communication.
19 AUDIENCE PARTICIPANT: I think you've got a
20 couple more questions.
21 AUDIENCE PARTICIPANT: That actually inspired
22 during your discussion.
23 What's the speed of operation for this
24 chemical -- in other words, how many little boxes will you put
25 out a day? Are you going to stack up a thousand a day or one
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1 every two weeks or how is it going to happen that way? Can you
2 tell me?
3 MR. NIXON: Yeah. I think that based on our
4 calculations, we're looking at up to fourteen containers per
5 day.
6 AUDIENCE PARTICIPANT: Per day.
7 MR. NIXON: Per day, but it's probably going to
8 be something less than that. That's what we think our maximum
9 production.
10 AUDIENCE PARTICIPANT: But your shipping rate
11 may not be that high.
12 MR. NIXON: That's correct.
13 AUDIENCE PARTICIPANT: There was a concern about
14 constriction of shipments at portals of entry where we have —
15 MR. NIXON: Exactly.
16 AUDIENCE PARTICIPANT: We have stacks of total
17 boxes here.
18 MR. NIXON: I thought we had a slide on that.
19 MR. HAGEN: We do.
20 MR. NIXON: Yeah. The proposed shipments are
21 three shipments per day for the chemical stabilization, so that
22 would be six containers per day normal shipping program.
23 MR. HAGEN: For three years.
24 MR. NIXON: For three years.
25 AUDIENCE PARTICIPANT: That wouldn't jam us up.
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1 MR. NIXON: It would accelerate the process. If
2 we were able to increase the shipments, we could potentially
3 accelerate the project. But that would be something that could
4 be worked out.
5 AUDIENCE PARTICIPANT: Thank you.
6 AUDIENCE PARTICIPANT: Did I not hear you say
7 you're going to drop these containers from three feet?
8 MR. HAGEN: The certification requires a test of
9 dropping it three feet.
10 AUDIENCE PARTICIPANT: You know, the shear
11 stress of concrete is 33 psi.
12 Do you know what's going to happen in three feet?
13 There would be nothing left of it.
14 MR. NIXON: This package that we're using, the
15 SEG container was tested under those conditions. It was
16 dropped on a corner from that one meter height.
17 You know, you got to remember that you were --
18 you're exactly right on concrete, but this SEG container is
19 primarily steel.
20 MR. HAGEN: It's got a lot of rebar in it.
21 AUDIENCE PARTICIPANT: That's not on here at
22 all. That's why I couldn't figure it out.
23 MR. NIXON: They use — they use almost a steel
24 wool type reinforcement that's packed into the concrete.
25 AUDIENCE PARTICIPANT: But it says concrete.
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1 MR. NIXON: It's reinforced concrete.
2 AUDIENCE PARTICIPANT: Very reinforced concrete.
3 FORMAL COMMENTS
4 MR. CLAIRE: Any other questions, guys?
5 MR. STEGNER: If there are no other questions,
6 we can proceed to the formal public comments period. We'll
7 take them at this time.
8 All we would ask is simply you say your name for
9 purposes of the court reporter before offering your comments or
10 questions, and then as I said, we will go into our silent mode
11 now and simply listen to your comments, take them and we will
12 respond to them in the formal responsiveness summary that we
13 will provide to you.
14 Yes, sir.
15 AUDIENCE PARTICIPANT: Can't you surmise from
16 our questions?
17 MR. STEGNER: You don't have to say anything, as
18 I said. We can — if you do want something responded to
19 formally or you do want to go on the record formally.
20 MR. CLAIRE: Why don't we go ahead. If nobody
21 else has got anything to say. Why don't we let some of the
22 guests --
23 AUDIENCE PARTICIPANT: I've got just one item.
24 I think it's important to consider energy consumption for the
25 national interest.
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1 MR. BECHTEL: My comments are as a citizen. The
2 Community Advisory Board may be commenting, so for the record,
3 my name is Dennis Bechtel, 319 Encima Court, Henderson, Nevada,
4 and a few items, and I'm going to read part of it and I'm just
5 going to paraphrase part of it, and I have a copy for you.
6 There were several references in the -- in the
7 documents that I had about, you know, the rural environment or
8 the sparse population of Nevada, and, you know, the total
9 program is going to be involved with — you know, the disposal
10 of the waste and the transport of the waste.
11 So my concern as a Nevadan is that southern
12 Nevada is experiencing some fairly rapid growth, you know, over
13 the last several decades, and I think that that will probably
14 continue over the next — who knows, until we run another of
15 water, I guess.
16 But the concern I have is that the area is
17 isolated now, and of course the test site will probably
18 continue to be isolated, although parts of it are transitioning
19 to other uses, that it's not — it's kind of misleading to make
20 statements like that in justifying, you know, say the project,
21 I think the project needs to stand on its own merits.
22 The fact that although it's an isolated site,
23 there's some concern about contaminants going off or, you know,
24 at least migrating from where it was originally intended for
25 the nuclear testing.
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1 So I think — I think the disposal needs to —
2 the citizens of Nevada need to be assured that -- that the
3 concrete containers, which I also have some — maybe some
4 personal concern about over the long-term, that -- that the
5 waste is able to is -- be isolated from the -- from the
6 accessible environment or from the public.
7 And as a justification, I think you need to make
8 that case -- I know I get a number of volumes of material.
9 Maybe you did make it and I missed it, but I think that needs
10 to be the -- the point that the waste is -- that the public is
11 protected, both from the transportation of the waste, but also
12 long-term because the material could be dangerous for a long
13 period of time. So I want to make that item -- case.
14 The second, with regard to the preferred
15 alternative — and I think I spoke to this when you all came
16 out here -- that yes, chemical stabilization probably has a
17 longer history. It is easier to make.
18 There's been some problems of vitrification, but
19 I think, you know, the — there has been — there has been that
20 type of alternatives that have failed, and I'm thinking of the
21 pondcrete at Rocky Flats.
22 I know you spoke to this. Each site is
23 different, but it's very much something that needs process
24 control, and I am certain that -- well, I guess the concern I
25 have is that this is going to take place over time.
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1 People are going to leave, and that a process
2 control that's institutionalized in our operation so we don't
3 run into another pondcrete situation, and the fact that there
4 is a -- I also agree. I think vitrification, despite the fact
5 it may not have the history, is probably a bit more stable
6 form.
7 So that's -- not saying that chemical
8 stabilization doesn't work, because it obviously works, too,
9 but just so we don't run into situations like pondcrete.
10 I also have concern about the number of
11 shipments. You indicated at our meeting last week that's
12 pretty much the number of shipments are equivalent to
13 historical shipments that you've had out to the test site.
14 One thing that sort of gets lost, though, is the
15 fact that Nevada Test Site is -- will be the disposal site.
16 It's a disposal option for -- for all the sites
17 in DOE complexes as I understand it, and not that everything's
18 going to come here, but you will just be one of a number of
19 waste streams.
20 So I think — this isn't really your fault, but I
21 think DOE nationally needs to look at the cumulative effects
22 since we're the end of the funnel, so it's more than just your
23 shipments. There will be other stuff coming, too.
24 Personally, and because I live in the Las Vegas
25 Valley, I guess, but I'm gratified with your encouraging
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1 shippers, your northern/southern option.
2 A little unclear on what the time frames are
3 between the north and — whether you transition to the southern
4 shipment. I guess depends on the weather, but I think the
5 point of -- of concern I have as a citizen is that risk could
6 be less risk, and it's my personal opinion that -- that we can
7 debate about the danger of the material, but the fact that DOE
8 should -- and apparently is -- Fernald, at least, considering
9 that you shouldn't put the shipments into places where there's
10 an opportunity for accidents.
11 I think — I think we all recognize that Murphy's
12 law, I know it's alive and we'll and I think that it's my
13 personal opinion that a more rural option is the way to prevent
14 potential impact, particularly in our area. That's growing
15 fairly rapidly.
16 So I'm glad to see that. We still have in the
17 Las Vegas Valley, we're marking out our growth, and one of the
18 areas that is growing is the southwestern section of the valley
19 which coincides with the 160 route, and that's probably a split
20 with the 160 and 127 route in California.
21 I do think there needs to be some sort of hazard
22 analysis. Currently I don't -- 160 is a -- it's going to be
23 better than it is maybe three or four years from now when some
24 of those other developments get on-line. There's going to be a
25 lot more construction traffic.
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1 I mentioned routing.
2 The last item, state acceptance and community
3 acceptance I think is very important. It's a little unclear in
4 the documents.
5 You kind of mush everything together, and I know
6 that's one of the -- I guess the ancillary alternatives, but I
7 think nonetheless, there are — all these other items are
8 important, but we are the community -- southern Nevada is a
9 community that's going to have to live with this.
10 So I think — and your response here is good.
11 I'm glad to see it, but -- and I hope you'll take our -- our
12 concerns and questions into consideration because, you know,
13 again, it's a -- it's a long-term commitment for folks in the
14 area.
15 So those are my comments, and I have more formal,
16 but --
17 MR. STEGNER: If you can give me those, also.
18 MR. BECHTEL: Sure.
19 MR. CLAIRE: Anyone else want to say anything?
20 Any one of the guests want to come forward and say anything?
21 Come on up to a mic here.
22 MR. SHUDY: Dale Shudy. I live out in Pahrump.
23 I had one question right off the bat.
24 Did you -- in your transportation costs, did you
25 consider using intermodal or not?
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1 And then while your testing of the containers
2 sounds fairly good, I would assume at 50 miles an hour on a
3 highway, that a collision would probably rupture the container.
4 I would just like to state for the record that
5 Nye County as it sits now is not really prepared to handle that
6 type of an accident.
7 I guess that's really all I have to say.
8 MR. CLAIRE: Anyone else want to make any
9 comments or statements?
10 John. Go ahead.
11 MR. PHILLIPS: Just recently we had hearings
12 about the workers that had their health impacted adversely and
13 the Federal Government's going to reimburse them, and my
14 concern is we've said that there's the health and safety issue
15 and we just need to feel a little more comfortable that we're
16 not going to repeat history by having ten, twenty years from
17 now the same thing, a hearing where people are saying that
18 their health was impacted.
19 So I think that we need to specifically learn
20 from history and make sure we're not going to have a repeat
21 situation and we're getting into robotics.
22 Maybe that may be something that needs to be
23 looked at where we minimize the environmental impact on the
24 human beings and that robotics -- robots get involved in this
25 at the beginning and at the end of this shipment. That may be
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1 an area that you might want to look at.
2 MR. CLAIRE: Okay. Anybody else? Comments?
3 Don, do you want to say something?
4 MR. CLOQUET: Yes.
5 On behalf of the Native Americans, I would like
6 to state that the Western Shoshone and their individual nations
7 within the Great Basin region are opposed to all high-level and
8 low-level nuclear waste issues, particularly the Yucca Mountain
9 Project, which has been stated numerous times by my dear
10 friend, Corbin Harney, who's a Western Shoshone Indian.
11 And I don't see him here today, but I certainly
12 have a lot of respect for his thought and wisdom and foresight,
13 and also I've also known the area myself, and I predict that
14 the nuclear test site, 1,380 square miles, we're talking about
15 various entities up there.
16 We have the proposed Kistler Aerospace
17 Corporation that's going to be located up on that mesa. We
18 have low-level nuclear waste areas of the test site already
19 that we get from various entities like Oak Ridge and other
20 areas, perhaps from Idaho and Hanford, perhaps and other areas
21 cause low-level nuclear waste coming in daily, and I'd like to
22 repeat my friend Dennis that this is a tremendously growing
23 area here in Las Vegas and I don't know if you — if you want
24 to go down to Spaghetti Bowl as I see at this moment, you're
25 probably going about 3 miles an hour.
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1 The population of Las Vegas is 1,300,000 people
2 and there are estimated 17,000 Native Americans that are
3 residing in this area.
4 We all have really concerns of the transportation
5 of low-level and high-level nuclear waste if it ever comes to
6 southern Nevada here, and we have the Native Americans. Just
7 for point of information, we have our own agenda with regard to
8 this issue.
9 Thank you.
10 MR. CLAIRE: Dale, did you want to add
11 something?
12 MR. SHUDY: It's not on the proposal. It's
13 basically on the public hearing process.
14 As you may notice, I'm the only one here from Nye
15 County. One of the only reasons for this appears to be that we
16 received notice that the CAB meeting itself was canceled for
17 this month.
18 Then a notice came out about a little over a week
19 ago stating that this meeting would be February — or Mar —
20 May 5th, which is this Friday, and it wasn't until yesterday
21 that I actually learned this meeting is today.
22 That's kind of a short response period for people
23 who live out in Nye County to get into a public hearing like
24 this.
25 I hope that next time that we'll get a lot more
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1 warning of a public hearing.
2 Thank you.
3 MR. CLAIRE: Okay. Well, we're pretty well on
4 schedule here.
5 MR. STEGNER: We thank you very much.
6 MR. HAGEN: We appreciate you coming out.
7 (The meeting concluded at 5:52 PM).
8
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10
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12
13
14
15
16
17
18
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1 STATE OF NEVADA ]
2 COUNTY OF CLARK ]
3 I, the undersigned, hereby certify that the foregoing
4 proceeding was by me stenographically reported and that I have
5 accurately and truthfully subscribed to time and place; that
6 the foregoing proceeding is a full, true and complete record of
7 said testimony; and that the subject or subjects of this
8 transcript were given an opportunity to read and correct said
9 transcript and to subscribe the same.
10 I further certify that I am not of counsel, attorney
11 nor associated with either or any of the parties in the
12 foregoing caption named, or in any way interested in the
13 outcome of the cause discussed in said action.
14
15
IN WITNESS WHEREOF, I have
16 ,
hereunto sen my iptand this
17
18
19
7
21
22
23
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ATTACHMENT B.III
WRITTEN COMMENTS RECEIVED ON THE
PROPOSED PLAN FOR REMEDIAL ACTIONS AT
SILOS 1 AND 2
B-lll-1
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Joanne Wilson
43 Carousel Circle
Fairfield, Ohio 45014
April 21, 2000
Mr. Gary Stegner
Department of Energy
PO Box 53705
Cincinnati, Ohio 445253-8705
Fax 1-513-648-3073
RE: The proposed disposal of the contents of the K-65 silos at
Fernald Facility, Ross, Ohio.
Dear Mr. Stegner:
We have talked several times concerning the issues of recycling
the product material in the K-65 silos so in s that the radium
contained in them can produce four alpha emitting isotopes now needed
in new and successful treatment of cancer, such as leukemia and
non-Hodgkin's lymphoma.
We also spoke of several alternate recycling methods. One was
the removal of the waste product material completely from the site
without site processing. This would involve the search for a facility
and/or commercial company familiar with separation and processing of
radioactive material to receive this material and process it to
produce the isotopes.
This alternative would avoid the vitrification or chemical
stabilization, cement-based process, now planned by the Department of
Energy and would save the taxpayers many millions of dollars by
avoiding these very expensive processes.
I feel this question of alternatives should be raised at this
time, in light of the need and present use, by the medical community,
for the four isotopes, namely Bismuth 213, Bismuth 212, Actinium 220
and Actinium 225, which can be produced from the radium 226 in the
silo material.
Is the Department of Energy doing anything to preserve,
retrieve, and recycle the approximately 10 pounds of valuable Radium
226 the in the K-65 silos?
I believe that the Fernald radium can provide isotope material
for treating thousands of cancer patients and that this matter is so
important that the Department of Energy arid other involved agencies
should be exploring ways of recycling this radium instead of
disposing of it in Nevada.
B-lll-2
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It is understandable that five years ago, in 1995, the great
contribution that the Fernald radium would be able to make to the
treatment of cancer was just beginning to be known. Now, it is known,
and I believe that the Department of Energy and other agencies must
make the retrieval and recycling of this radium a top priority,
regardless of past plans or ideas.
I urge the Department of Energy and all other agencies to
actively consider and pursue this matter.
Joanne Wilson
B-lll-3
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To:
Company:
Department:
Telephone:
FAX:
Date: 05-18-00
Gary Stegner
U.S. Dept. of Energy
Public Information
(513)648-3153
(513)648-3073
Time: 02:20 am
From: Gerald L. Gels
Company: Prof. Radiological Service
Telephone: (513)661-9457
FAX: (513)661-8654
Pages (incl. Cover): 2
Gary:
Attached are my comments fnr the Proposed Plan for Silos 1 & 2 Remedial Actions.
(' Lyt/iJ,
Gerald ETGeLs
261 OMooirgdale Ci
Cincinnati, OH 45211
B-lll-4
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Comments on Revised Feasibility Study/Proposed Plan for Silos 1 & 2 Remedial Actions
SPECIFIC COMMENT: In the "Revised Proposed Plan for Remedial Actions at Silos 1 and 2," March 2000,
the Comparative Analysis Summary, Figure 7.2-1, contains two (of the 7 evaluated) parameters that seem, on the
surface at least, to have a bias toward chemical stabilization. The category of "Long-Term Effectiveness and
Permanence" is rated as "neutral." And the category of "Short-Term Effectiveness" is rated as favoring chemical
stabilization.
In the "Long-Term" category, considering the long half-life of tire 226Ra (1600 years), vitrification seems
to be clearly favored. The immobilization of the radioactive constituents, particularly 226Ra and 222Rn, seems to
definitely favor the vitrification option. In the "thousands of years" time frame, glass material should experience
very little degradation, while the same cannot be said for cement products.
In the category of "Short-Term Effectiveness," the rating favors chemical stabilization, presumably due to
the shorter projected time schedule for chemical stabilization. The radon release from either process will be very
close to 100%. Note that the recommended method of removal of radon from drinking water supplies is aeration.
While the vitrification alternative will result in a longer-term period of (potential) radon release, the lower amount
of material handled per day should result in a lower daily dose to workers and nearby residents. Because of the
reduced effectiveness for radon retention, the chemical stabilization alternative would not be favored in the short
term, as the processing is carried out. This category seems to slightly favor vitrification or, at a minimum, be rated
neutral.
GENERAL COMMENT: While the preceding specific comments may seem to favor the vitrification the
philosophy of remedial actions for the K-65 residues should be examined. Up to 80% of the 226Ra available for
scientific and/or medical use in this country is contained in the two K-65 Silos. Vitrification would tie up those
radium atoms in a glass matrix from which they would be very difficult to retrieve. While separation and
concentration of the radium (approximately 4000 curies, equal to about 10 pounds of 226Ra) from the bulk of the
residues would be a difficult and expensive technological task, it is not at all beyond present day capabilities. The
advantages of this approach are enormous, and certainly worthy of consideration. First, the radium would be
available for use into the future. From a potential medical perspective alone, this 10 Ib. of material could become
an invaluable resource in the near future - a resource that we currently have no alternative for. Vitrification (or
chemical stabilization, to a lesser extent) would make that material much more difficult to access. Second, the most
radiologically dangerous nuclide in the K-65 Silos is 226Ra. Concentrating and removing this radionuclide from the
remaining residues will allow the disposal of those materials with much less concern for the release and possible
pathway to the population for 226Ra which has a very long biological and radiological half-life along with emission
of alpha particle radiation. It could also possibly allow for recovery of the gold from the residues in a relatively
uncontaminated state. Third, the removal of 226Ra would take a large fraction of the gamma ray emitting radionuclides
with it (214Bi and 214Pb). These gamma-emitting nuclides are the immediate progeny of 226Ra and 222Rn, and have
relatively very short half-lives. So, all three of the major hazards in the K-65 Silos are associated with the 10 Ib. of
226Ra distributed through the contents of Silos 1 and 2. The possible intake of 226Ra (with its extremely low Annual
Limit), the direct radiation from radium and its short-lived progeny, and the seemingly uncontrollable release of
222Rn will all be removed from the remaining residues and will be concentrated (and will thus be controllable) with
the 10 Ib. of 226Ra.
GENERAL COMMENT: The remediation of the K-65 Silos, by whatever method is selected, needs to include
environmental health physics analysis focusing on all the K-65 radionuclides, but particularly on 22eRa and releases
of 222Rn. Current real-time radon data from FEMP and Ohio EPA indicate that off-site radon concentrations - at
the west fence of the FEMP and at Crosby School, 2 miles away - are significantly greater than background. These
concentrations have yet to be acknowledged as being different than natural background, although September 1999
outdoor concentrations at a distance of 2 miles from the K-65 Silos averaged 1.3 pCi/L, with many individual
hour-long averages at concentrations equal to or greater than 3 pCi/L. The level of 3 pCi/L is ten times higher than
the average background radon concentration expected for this part of the country, and the average for the month is
more than four times the expected background concentration. The failure to recognize and address this issue
indicates the possibility that proposed radon control measures for Silos 1-3 removal and Accelerated Waste
Retrieval may need re-evaluation by experts in those areas. To date, neither the Critical Analysis Team (CAT) nor
Fernald engineers have demonstrated sensitivity to these issues.
Gerald L. Gels, CHP
2610MorningdaleCt.
Cincinnati, OH 45211
(513)661-9457
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FERNALD
Mr. Kenneth A. Moore 1 H P
4470 Classic Drive LU b
Cincinnati Ohio 45241 HflT J7
(513)489-4470
e-mail-kmoore2@cinci.rr.com ZTff p.
LIBRARYi
May 11,2000
U. S. Department of Energy
% Mr. Gary Stegner
DOE-FEMP Public Affairs Officer ^
P.O. Box 538705 °jDs
Cincinnati, Ohio 45253-8705 ^
RE: Silos 1 & 2 Public Hearing
As a member of the Fernald Citizens Advisory Board I was invited to attend a Public Hearing on April 25,
2000 conducted by the U. S. Department of Energy (DOE) to receive comments pertaining to the Silos
1 and 2 proj ect. There were two speakers at the hearing, Dr. Joanne Wilson, Physician and Mr. Jerry Gels,
Health Physicist, who presented information about the possible positive health benefits of the radium stored
within Silos 1 and 2, the largest single source of radium in the world. They presented information that
indicated studies are currently being conducted and funded by U. S. Government, using radium which might
lead to a treatment for certain types of cancer with reduced side effects. They indicated that the proposed
treatment of the Silos 1 and 2 materials would render the radium useless for future bio-medical purposes.
The DOE has an opportunity and a responsibility to mankind to fully evaluate and fund research into the
bio-medical benefits of radium before the Silos 1 and 2 materials are permanently lost for that purpose. Jf
we fail to act in a responsible manner and dispose of the radium and then discover that radium is a
bio-medical asset, the costs, both monetary and environmental would be significantly higher for new radium
production and would far outweigh the cost of storing the existing radium in a form that would not degrade
it for bio-medical purposes.
Everyone involved with the Fernald Environmental Management Project has a mission of remediation for
the site through decontamination and dismantlement. However, we should not have such a narrow view as
to overlook the possible bio-medical benefits of radium, which could provide significant health benefits for
society. Will the legacy of Fernald be forty years of cold war activities and fifteen years of cleanup costing
billions of dollars or the use of cold war radium for world wide bio-medical cancer treatment in the 21st
century?
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How can the radium be extracted for bio-medical purposes while maintaining a realistic timetable for the
safe removal of the other Silos 1 & 2 materials? It is being proposed that the Silos 1 & 2 materials be
moved to a Transfer Tank Area and placed into metal storage tanks prior to the recommended chemical
stabilization-cement alternative. The November 1999 Silos Report indicates that there is as much as four
and one-half years (54 months) available for extraction of radium prior to the start of operations. It would
appear that a private commercial organization could implement a radium extraction process within that time
frame. Even if the time frame for commencing operations was extended by a year or two, the benefits
would far outweigh the incremental time lost.
The single most responsible action that DOE should take would be to fully evaluate the use of Radium from
silos 1 & 2 for bio-medical purposes prior to implementing the Revised Proposed Plan for Remedial
Actions at Operable Unit 4 (Silos 1 & 2). This would include preplanning to identify private commercial
operations.
The intent of this letter is to assist others who are actively trying to identify radium as a treatment for cancer
and to save a vital resource for that treatment.
Sincerely,
Kenneth A. Moore
B-lll-7
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3686 Cincinnati-Brookville Road
Hamilton, Ohio 45013-9011
FILE:J[£M,5H
n v
May5, 2000 LIBRAKT:
Mr. Gary Stegner
U. S. Department of Energy
Fernald Environmental Management Project
P.O. Box 538705
Cincinnati, Ohio 45253-8705
SUBJECT: PUBLIC COMMENTS ON PROPOSED PLAN (CHEMICAL
STABILIZATION VS. VITRIFICATION) FOR REMEDIAL ACTIONS
AT SILOS 1 AND 2, DOE-FEMP DUE MAY 18, 2000
Dear Mr. Stegner:
We conclude that chemical stabilization of subject toxic materials should be the
preferred treatment alternative because it meets the threshold criteria and provides the
best overall balance of tradeoffs compared to vitrification.
The above conclusion was influenced by information from the following three sources:
1. Silos update meeting on April 25, 2000 (6:30-8:30 p.m.) at the Alpha
Building, Room 0,10967 Hamilton-Cleves Highway, Harrison, Ohio.
2. Revised proposed plan for remedial actions at Silos 1 and 2, Report
#40700-PL-0001 DOE-FEMP dated March, 2000.
3. Executive Summary Revised Feasibility Study for Silos 1 and 2, Report
#40730-RP-0001.
Because there is no natural safety barrier which would prevent toxic particulates,
fumes, gases or vapors from being quickly transported from FEMP operations by
average 9 MPH wind speed to its nearest residential neighbors in a matter of minutes,
engineering controls must be designed and maintained to prevent any off-site migration
of toxic chemicals. Negative air pressure engineering enclosures should be employed
and maintained to assure that people on and off site do not breathe in any dust or toxic
chemicals. Safety and health of the FEMP workers and the public must not be
compromised.
Sincerely, f
~'
Walter
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REVISED PROPOSED PLAN FOR REMEDIAL
ACTIONS AT
SILOS 1 AND 2 (40700-PL-001)
Statement of Dennis Bechtel
319 Encima Court
Henderson, Nevada
May 3, 2000
B-lll-9
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REVISED PROPOSED PLAN FOR REMEDIAL ACTIONS AT
SILOS 1 AND 2 (40700-PL-001)
Statement of Dennis Bechtel
Resident of Henderson, Nevada
My name is Dennis Bechtel. I am a resident of Henderson, Nevada. Although I am a member
of the Nevada Test Site-Community Advisory Board my comments are as an individual and
don't represent the views of the Nevada Test Site Community Advisory Board. I appreciate
the fact that Fernald is holding a public hearing in Nevada on this issue. Too often public
hearings and the review of public documents do not include all parties that would be
impacted by a project. In this case there is a site being remediated and a site that is accepting
the waste. Both parties should be party to reviewing the proposed plan.
1. The Nevada Test Site (NTS) setting. The Proposed Plan notes that the Nevada Test
Site is located "in a sparsely populated, arid environment with a low potential for
leachate generation . . . migration, . . .". On the bottom of Page 7-6 of the Summary
Proposed Plan it also alludes to the isolation of Southern Nevada as being a reason in
the event of long-term degradation of engineered features or loss of institutional
controls . . . ensure the protectiveness of human health and the environment is
maintained.
Southern Nevada has, of course, experienced rapid growth over the past several decades, a
trend that it appears will continue in the future. Because the County is becoming increasingly
urbanized, however, it should be noted that the communities that could be affected by issues
such as the transportation of the nuclear waste are no longer small and isolated. Clark
County, for example, has a population that exceeds 1.4 million.
Accordingly, the increasing numbers of Southern Nevadans in the future and the potential
risk involved could make comments such as these inaccurate. Likewise, recent monitoring
information seems to provide evidence that the
B-lll-10
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migration of radioactivity from areas of weapons testing may be more extensive then
previously thought.
The rationale for storage of radioactive waste at the NTS should not be supported
because of the isolation of Southern Nevada (which is changing rapidly) but rather
because the disposal facility will be designed to ensure that the resident population
potentially impacted will be protected.
2. The Preferred Treatment Alternative. Chemical Stabilization (CS) is the preferred
treatment alternative for treatment and disposal of the Silos 1 and 2 wastes. The CS
alternative (CS, as we understand it, is now one alternative) is preferred to the
Vitrification (VT) alternatives for a number of reasons including experience in use,
lower cost, lower toxicity, health and safety concerns, and lower O & M costs. While
the rationale presented seems reasonable we're aware, however, that a similarly
stabilized waste material, Pondcrete [sic] at the Rocky Flats Department of Energy
(DOE) facility experienced problems in maintaining integrity. Vitrification although
more complex in development seems to demonstrate more long-term integrity.
The Plan shoulddocument how the Chemical Stabilizationprocessproposedat Fernald
will, if selected, avoid the degradation that occurred at the Rocky Flats facility? Will it
maintain its integrity over the life of the risk to the public and environment. Also, it is
uncertain in the documents whether the CS material meet the State of Nevada Waste
Acceptance Criteria?.
3. Number of shipments. The number of shipments for the preferred CS alternative is
considerably higher than that for the VT option. At a recent meeting DOE/Fernald
personnel noted that the proposed Silo shipments to the NTS are equivalent to current
shipment levels. The NTS, however, was recently named as one of two sites that can
receive low-level and mixed low-level radioactive waste from all DOE sites throughout
the
B-lll-11
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Complex. Fernald thus will be only one of many sites transporting waste to the NTS. As
a number of DOE plans this avoids discussion of cumulative impacts- e.g., the Fernald
shipments plus those from other sites using the NTS.
Since the majority of Fernald shipments may occur during the same time frame as
shipments from other sites, DOE needs to evaluate these shipments in a cumulative
sense. In addition to listing shipments from Fernald, DOE must provide information to
enable the public to understand the totality of shipments from DOE sites to the NTS to
enable the public and governments to understand how these shipments add to the risk.
4. Routing of nuclear waste shipments. Transportation information in the Planning
documents indicated that truck shipments carrying Silos 1 and 2 wastes will continue to
utilize the Northern and Southern routing options described in the Proposed Plan.
DOE/Fernald continues to be responsive to the concerns of Southern Nevadans
associated with transporting the Silos waste through a rapidly growing area with
congestion and, therefore, a greater potential for accident.
While it appears that DOE/Fernald is actively involved in encouraging certain routes
for the transportation of the waste to be used, it is unclear why, based on the experience
of the Waste Isolation Pilot Project (WIPP) with the transportation of waste, that routes
can be specified in contracts. Also needing to be noted is how DOE/Fernald intends on
monitoring the shipments to ensure that their carriers comply with the routing
designations and Department of Transportation criteria. Tourism is, of course,
Nevada's bread and butter. Given the fact that rightly or wrongly the public does not
distinguish between types of low-level radioactive waste, it is important that DOE avoid
situations that could potentially adversely impact our economy and quality of life.
B-lll-12
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5. State Acceptance/Community Acceptance. The Program Planning document needs to
describe how the State Acceptance and Community Acceptance criteria are defined,
analyzed and weighted by DOE in selecting a preferred alternative.
Community acceptance, of course, should be more than the statements of those
attending public hearings. It should be the total record of meetings with communities
and stakeholders. The record of community acceptance should be derived from a
number of sources and not merely the results of one hearing.
Thank you again for convening the meeting in Southern Nevada. We look forward to Fernald
and the Nevada Operations office to considering my comments.
B-lll-13
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2437 LOSEE ROAD
NORTH LAS VEGAS, NV 89030
PH: 702/633-5300, EXT. 232
FAX: 702/633-5200
E-MAIL: NTSCAB@aol.com
COMMUNITY
ADVISORY BOARD
Fax
To:
Gary Stegner
From:
Phil Claire
Pages:
Date:
Re:
05/18/00
Comments on Revised Proposed Plan
for Remedial Actions at Silos 1 and 2
cc:
Herewith is the Comments from the Nevada Community Advisory Board and the Low-Level Waste
Committee on the Revised Proposed Plan for Remedial Actions at Silos 1 and 2 (40700-PL-001) - Fernald,
Ohio.
If there are any questions, please contact us.
Regards,
Phil Claire
Chair, NTS CAB
B-lll-14
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^
•Community Advisory Board
•v <$* A Site-Specific Environmental Management Advisory Board
ft? Chartered Under the U.S. Department of Energy
Phillip Claire, CAB Chair
Cynthia Ortiz, CAB Vice Chair
Dennis Bechtel, Chair
Transportation/LLW Committee
Kent English
Dr. Peter Krenkel, Chair
Program/Public Outreach
Committee
Stephanie Lawton
Richard Nielsen, Chair
Environmental Management
Committee
Richard Nocria, Chair
Stewardship/Future Land Use
Committee
Cynthia Ortiz, Chair
Budget Committee
Diversification Committee
Frank Overbey. Jr.
John Pawlak
Dr. Darrell Pepper
John Phillips
Kenneth Reim
Paul Ruttan
Connie Simkins
Michael Williams
David Wise
Ex-Officio Members
Carl Gertz
U.S. Department of Energy,
Nevada Operations Office
Dave Bedsun
Defense Threat Reduction
Agency
Paul Liebendorfer
Sfafe of Nevada Division of
Environmental Protection
Dan Simmons
A/ye County Nuclear Waste
Repository Office
Frank Tussing
Nevada Allaince for Defenes
Energy and Business
Technica! Advisor
Earle Dixon
Support Staff
Jin Gorman
Kay Planamento
May 18, 2000
Mr. Gary Stegner
U.S. Department of Energy
Fernald Area Office
P.O. Box 398705
Cincinnati, OH 45239-8705
Subject: Comments from the (CAB, LLW Committee) on the Revised Proposed Plan
for Remedial Actions at Silos 1 and 2 (40700-PL-001) - Fernald, Ohio
Dear Mr. Stegner;
Attached are comments from the Nevada Test Site Community Advisory Board (NTS-CAB)
to the Revised Proposed Plan for Remedial Actions at Silos 1 and 2 (40700-PL-001)
developed by the Department of Energy (DOE) for remediation activities at the Fernald
Environmental Management Project (FEMP) in Ohio.
We have appreciated the opportunity to comment on the Revised Proposed Plan and the
efforts expended by the Femald project office staff to meet with NTS-CAB members and
public on issues associated with the Plan. The NTS-CAB and Nevada community and Fernald
personnel, of course, have collaborated on issues of mutual concern over the past several
years. We hope that this relationship and dialogue will continue on future issues.
Thank you again for the opportunity to respond. If there are questions please contact us.
Sincerely,
Phil Claire, Chair
Nevada Test Site Community Advisory Board
(Chair LLW/Transportation Subcommittee)
cc:
Carl Gertz
Kevin Rohrer
CAB - Fernald
2437 Losee Road
North Las Vegas, NV 89030-4233
Phone: 702/633-5300 Ext. 232
Fax: 702/633-5200
B-lll-15
E-mail: NTSCAB@aol.com
Home Page: http://www.univedu/Colleges/
Urban/cab/cabmain num
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Comments of the
Nevada Test Site Community Advisory Board (or Low-Level
Radioactive Waste Transportation Committee) to the
Revised Proposed Plan for Remedial Actions at Silos 1 and 2
(40700-PL-001) - Fernald, Ohio
The following are comments by the Nevada Test Site Community Advisory Board to the Revised
Proposed Plan for Remedial Actions at Silos 1 and 2 (40700-PL-001)
1. The Nevada Test Site (NTS) setting. The Revised Proposed Plan notes that the NTS is
located "in a sparsely populated, arid environment with a low potential for leachate
generation., [and pollutant] migration, ..." . On the bottom of Page 7-6 of the Summary of the
Revised Proposed Plan it is also noted that the isolation of Southern Nevada as being a reason
to select the NTS location " in the event of long-term degradation of engineered features or
loss of institutional controls . . . [that the isolation would] ensure [that] the protectiveness
of human health and the environment is maintained''
What is not apparent in reading the document is that Southern Nevada has become a major
population center. Rapid growth in Southern Nevada has been experienced over the past several
decades, a trend that is projected to continue well into the future. The Amargosa Valley and
Pahrump in Nye County adjacent to the NTS are experiencing unprecedented growth. The
population of Clark County, through which of many shipments of radioactive waste from Fernald
over the years, is projected to grow from 1.3 million in 1999 to an estimated 2.5 million in 2020.
The potential risk to increasing numbers of Southern Nevadans from all activities associated with
the project, including the transport of the waste, needs to be better described in the report.
The storage of radioactive waste at the NTS should not be justified because of the isolation
of the sire but, rather, because the disposal facility has been designed to ensure that
contaminants will not impact residents and the environment in Southern Nevada
2. The Preferred Treatment Alternative. Chemical Stabilization (CS) is the preferred treatment
alternative for Silos 1 and 2 wastes for a number of reasons including experience in use, lower
cost, lower toxicity to workers as well as lower operations and maintenance costs. While there is
a rationale to justify its selection, we are also aware that there have been problems with premature
degradation from similarly stabilized materials.
The Proposed Revised Plan should include documentation describing how the Chemical
Stabilization process proposed would avoid degradation. Related questions would include
B-lll-16
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how the CS would compare to VT in maintaining its integrity over the period of danger of
the waste (on-site) and as a result of a highway accident. It is also unclear in the Plan
whether the CS material will meet the DOE/NV Waste Acceptance Criteria (WAC).
3. Number of shipments. The total number of shipments specified for the preferred CS alternative
are almost double the number noted for the VT option. With the greater number of shipments the
potential exists for more accidents with the CS alternative and more risk potential to the public.
While a case has been made that CS is safer for workers than the VT alternative, one could
also be made that twice the number of shipments on the highway would increase the risk to
the public adjacent to transportation routes. More shipments provide the potential for
additional accidents, as an example. While the NTS CAB obviously supports minimal risk to
Fernald residents and workers we also must consider minimizing risk to Nevada residents
and visitors as well. The VT alternative with fewer shipments will from a transportation
perspective provide lower risk not just to Nevadans but others on transportation routes. We
understand that several stakeholders at the Fernald site were also supportive of the VT
alternative for similar reasons. There is no discussion of the use of rail in the Plan. Is this an
option as well? The use of rail could reduce the total number of shipments and thereby also
present lesser risk.
4. Cumulative impacts. The NTS was recently named as one of two sites eligible to receive
low-level and mixed low-level radioactive waste from all DOE sites being remediated. Fernald will,
therefore, be only one of many DOE sites transporting radioactive waste to the NTS.
Fernald will be transporting waste at the same time that other DOE sites will be shipping
to the NTS. While not necessarily Fernalds problem this further substantiates why DOE
needs to evaluate the potential cumulative affects of shipments from all sites being
remediated. While Nevada's, citizens and communities, at the "end of the funnel" for these
shipments, will be offered the potential of experiencing more impacts, this, also will be a
nationwide issue.
5. Routing of nuclear waste shipments. The Proposed Revised Plan notes that truck shipments
carrying Silos 1 and 2 wastes will continue to utilize the "Northern" and "Southern" routes
currently being utilized. DOE/Fernald, therefore, continues to be responsive to the concerns of
Southern Nevadans regarding the transportation of the Silos waste through our rapidly growing
communities. Avoiding congestion and the greater potential for accident would be in the interest
of DOE as well as Nevada's citizens..
While it appears that DOE/Fernald is actively involved in encouraging certain routes for the
transportation of the waste to be used, it is unclear why, based on the experience of the
Waste Isolation Pilot Project (WIPP) with the transportation of its waste, routes cannot be
B-lll-17
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specified by DOE to shippers. The plan should also express how DOE/Fernald intends on
monitoring on-going and future shipments to ensure that carriers are actually complying
with Department of Transportation routing regulations.
6. State Acceptance/Community Acceptance. The Proposed Revised Plan needs a description
of how the State Acceptance and Community Acceptance criteria are defined, analyzed and
weighted by DOE in selecting a preferred alternative.
Community acceptance should include the history of meetings, correspondence, interactions
with stakeholders conducted by DOE on this topic and not be solely from the public
hearings.
1. Equity. The naming of the NTS as one of two sites eligible for accepting low-level and mixed
low-level radioactive waste, as noted earlier, also raises a number of equity-related questions.
Nevada, by accepting waste is improving the health, safety and environment of residents and
workers at other DOE sites. This also provides evidence of Nevada's further service to the nation
on an important nuclear issue. In addition to the benefit to the nation in providing this service, there
is also the added burden of stewardship and the associated future costs.
Fernald, and other sites, in remediating their sites adds to the burden of the NTS and
Nevadans. To restore equity as well as to ensure that future stewardship costs are defrayed,
it is important that cost savings at sites being remediated be made available to the NTS to
defray future stewardship costs.
8. Energy Consuption. Analyses of energy consumption for the various project alternatives is
required under the National Environmental Policy Act of 1969. In selecting the disposal alternative
and transportation mode (truck and/or rail) and routing, the alternative with the minimum energy
consumption must seriously be considered by the U.S. Department of Energy, U.S. Department
of Transportation, and carrier(s) as the preferred alternative.
B-lll-18
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Public Meeting Evaluation/Comment Card
Silos 1 & 2 Proposed Plan for Remedial Actions
May 3, 2000
The U.S. Department of Energy and Fluor Fernald would like your feedback about this meeting. Please
complete this evaluation form to help us better serve your needs. Thank you.
1. The level of information presented tonight was:
Not detailed enough
Adequate
Too detailed
Please explain:
2. The presentation made use of a video explaining the Proposed Plan. Was this approach:
Very useful
y Somewhat useful
Not helpful at all
Please explain:
3. I better understand the Proposed Plan for Remedial Actions at Silos 1 and 2 after hearing this
presentation.
Strongly Agree
V^ Agree
Disagree
Please explain:
4. Please list specific questions or concerns you have about die SHos 1 and 2 Proposed Plan for
Remedial Actions:
B-lll-19
-------
5. Please provide other comments about this meeting:
,
4- -
Questioa/Concera
For more information about the Silos Project, please visit DOE's Public Environmental Information
Center, 10995 Hamflton-Cleves Highway, Harrison, Ohio, 45030 or visit our Web site at
www.fernald.gov.
B-lll-20
-------
Public Meeting Evaluation/Comment Card
Silos 1 & 2 Proposed Plan for Remedial Actions
May 3, 2000
The U.S. Department of Energy and Fluor Fernald would like your feedback about this meeting. Please
complete this evaluation form to help us better serve your needs. Thank you.
1. The level of information presented tonight was:
Not detailed enough
j£ Adequate
Too detailed
Please explain: l/ft/w/
T
2. The presentation made use of a video explaining the Proposed Plan. Was this approach:
Very useful
-------
5. Please provide other comments about this meeting:
AM - &JLAL ~zA* Ate
&bJL
6. If you would like a Fernald representative to contact you to clarify information presented tonight
please provide the following information:
Name:
Affiliation:
Daytime Phone:
Question/Concern
For more information, about the Silos Project, please visit DOE's Public Environmental Information
Center, 10995 Hamflton-Cleyes Highway, Harrison, Ohio, 4S030 or visit our Web site at
www.fernald.gov.
B-lll-22
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Public Meeting Evaluation/Comment Card
Silos 1 & 2 Proposed Plan for Remedial Actions
May 3, 2000
The U.S. Department of Energy and Fluor Fernald would like your feedback about this meeting. Please
complete this evaluation form to help us better serve your needs. Thank you.
1. The level of information presented tonight was:
. Not detailed enough
V Adequate
._ Too detailed
Please explain:.
2. The presentation made use of a video explaining the Proposed Plan. Was this approach:
V Very useful
Somewhat useful
Not helpful at all
Please explain:
3. I better understand the Proposed Plan for Remedial Actions at Silos 1 and 2 after hearing this
presentation.
Strongly Agree
Agree
Disagree
Please explain:
4. Please list specific questions or concerns you have about the Silos 1 and 2 Proposed Plan for
Remedial Actions:
Contimied.0n.?eYerse.side-
B-lll-23
-------
5. Please provide other comments about this meeting:
6. If you would like a Fernald representative to contact you to clarify information presented tonight
please provide the following information:
Name:
Affiliation:
Daytime Phone:
Question/Concern^
For more information about the Silos Project, please visit DOE's Public Environmental Information
Center, 10995 Hamflton-CIeves Highway, Harrison, Ohio, 45030 or visit our Web site at
www.fernald.gov.
B-lll-24
-------
Public Meeting Evaluation/Comment Card
Silos 1 & 2 Proposed Plan for Remedial Actions
May 3, 2000
The U.S. Department of Energy and Fluor Fernald would like your feedback about this meeting. Please
complete this evaluation form to help us better serve your needs. Thank you.
1 . The level of information presented tonight was:
Adequate
Toodetafled
Please explain: l ?P » C OwTV O*
P«*
2. The presentation made use of a video explaining the Proposed Plan. Was mis approach:
Very useful
Somewhat usciiu
t
Not helpful at an
Please explain:
3. I better understand the Proposed Plan for Remedial Actions at Silos 1 and 2 after hearing this
presentation,
* Strongly Agree
Agree
Disagree
Please explain:
4. Please list specific questions or concerns you have about the SHos 1 and 2 Proposed Plan for
Remedial Actions:
Continued on reverse side-
B-lll-25
-------
5. Please provide other comments about this meeting:
6. If you would life a Fernald representative to contact you to clarify information presented tonight
please provide the following information:
Name:.-
Affiliation:
Daytime Pnone:
Question/Concern
For more information about the Silos Project, please visit DOE's Public Environmental Information
Center, 10995 Hamflton-Cleves Highway, Harrison, Ohio, 45030 or visit our Web site at
www.fernald.sov.
B-lll-26
-------
Public Meeting Evaluation/Comment Card
Silos 1 & 2 Proposed Plan for Remedial Actions
May 3, 2000
The U.S. Department of Energy and Fluor Fernald would like your feedback about this meeting. Please
complete this evaluation form to help us better serve your needs. Thank you.
1. The level of information presented tonight was:
Not detailed enough
/*
"_ Adequate
Too detailed
Please explain:
2. The presentation, made use of a video explaining the Proposed Plan. Was this approach:
/ Very useful
Somewhat useful
Not helpful at all
Please explain:
3. I better understand the Proposed Plan for Remedial Actions at Silos 1 and 2 after hearing mis
presentation.
Strongly Agree
y Agree
Disagree
Please explain:
4. Please list specific questions or concerns you have about the SQos I and 2 Proposed Plan; for
Remedial Actions:
Connmied on reverse side-
B-lll-27
-------
5. Please provide other comments about this meeting:
6. If you would like a Fernald representative to contact you to clarify information presented tonight
please provide me following information:
Name:
Affiliation: _^
Daytime Phone:
Question/Concern,
For more information about the Silos Project, please visit DOE's Public Environmental Information
Center, 10995 Hainflton-CIeves Highway, Harrison, Ohio, 45030 or visit our Web site at
www.fernald.gov.
B-lll-28
-------
Public Meeting Evaluation/Comment Card
Silos 1 & 2 Proposed Plan for Remedial Actions
May 3, 2000
The U.S. Department of Energy and Fluor Fernald would like your feedback about this meeting. Please
complete this evaluation form to help us better serve your needs. Thank you.
1. The level of information presented tonight was:
Not detailed enough
Adequate
Too detailed
Please explain:
2. The presentation made use of a video explaining the Proposed Plan. Was this approach:
Very useful
i/ Somewhat useful
Not helpful at all
Please explain:
3. I better understand me Proposed Plan for Remedial Actions at Sflos 1 and 2 after hearing this
presentation.
Strongly Agree
Agree
Disagree
Please explain:
4. Please list specific questions or concerns you have about the Silos I and 2 Proposed Plan for
Remedial Actions:
^_^ . _, ^
B-lll-29
-------
5. Please provide other comments about mis meeting:
Ca-uvJLj
6. . If you would like a Feniald representative to contact you to clarify information presented tonight
please provide the following information:
Name:
v_ Q *. >!L Jl or
Affiliation:
Daytime Phone:
Question/Concern,
For more information about the Silos Project, please visit DOE's Public Environmental Mormation
Center, 10995 Hamilton-Cleves Highway, Harrison, Ohio, 45030 or visit our Web site at
www.fernald.gov.
B-lll-30
-------
Public Meeting Evaluation/Comment Card
Silos 1 & 2 Proposed Plan for Remedial Actions
April 25, 2000
The U.S. Department of Energy and Fluor Fernald would like your feedback about this meeting. Please
complete this evaluation form to help us better serve your needs. Thank you.
1. The level of information presented tonight was:
>\ Not detailed enough
\*4 Adequate
X Too detailed
Please explain:
2. The presentation made use of a video explaining the Proposed PlanT Was" this approach:
•>y Very useful
X Somewhat useful
£=* Not helpful at all
Please explain:
3. I better understand me Proposed Plan for Remedial Actions at SHos 1 and 2 after hearing this
presentation.
Strongly Agree
Agree
/*• Disagree
Please explain:
4. Please list specific questions or concerns you have about me Silos 1 and 2 Proposed Plan for
Remedial Actions:
Contnmed on reverse side-
B-lll-31
-------
5. Please provide other comments about this meeting:
6. If you would like a Fernald representative to contact you to clarify information presented tonight
please provide the following information:
Affiliation:
Daytime Phone:
Question/Concern
For more information, about the Silos. Project, please visit DOE's Public Environmental Information
Center, 10995 Hamflton-Cleves Highway,'Harrison, Ohio, 45030 or visit our Web site at
www.iernald.gov.
B-lll-32
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B-lll-34
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TECO
INTERNATIONAL Glass Plant Engineers & Contractors
May 17, 2000
Mr. Gary Stegner
U.S. Department of Energy, Fernald Area Office
P.O. Box 538705
Cincinnati, OH 45253-8705
Subject: Comment on PDF Proposed Plan/Feasibility Study for Remedial Actions at Silos 1 and 2
We appreciate the opportunity to comment on the Proposed Plan and Feasibility Study for Remedial
Actions at Silos 1 and 2. Although we have concerns about the choice of technology, we have been
impressed with the effort to inform your stakeholders and to elicit comment.
We feel that the data and the analysis do not support the decision for Chemical Stabilization as the
preferred treatment. Both the strengths of vitrification and the problems with chemical stabilization seem
to have been understated. These concerns primarily focus on the following issues:
4 The placing of reliance on the disposal container and the disposal site for protection of human health
and the environment from the chemically stabilized waste, rather than the properties of the
wasteform itself.
4 The understating of difficulties experienced with the chemical stabilization technologies under the
controlled conditions of the POPT demonstration, yet giving a favorable assessment of chemical
stabilization based on extrapolated, undemonstrated, "results".
4 The lack of optimization of the container scenario for the "VTT 1 technology which reduces the
benefit of its inherent volume reduction.
4 The favoring of chemical stabilization in the areas of process flexibility and schedule attainment while
disregarding the commercial experience in glass furnace design, construction and operation of the
VTT1 vendor.
4 The favoring of chemical stabilization technologies based on experience on dissimilar waste
materials, while disregarding the extensive commercial
Toledo Engineering Co., Inc.
2-iCO Executive Parkway
3 0. 3ox 2927
~;ecc. Ohic -3606-0927 U.S.A. B-lll-35
">=5ci-,cre: -"9-537-3~"
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TECO
INTERNATIONAL
May 17, 2000
Mr. Gary Stegner
Fluor Daniel Fernald
Page 2
experience in glass furnace design, construction, and operation on non-waste, but more similar,
materials by the VTT1 vendor.
1. Overall Protection of Human Health and the Environment:
The Feasibility Study places heavy reliance on the packaging of the chemically stabilized wasteform
and management of the storage site, especially when the stored waste is considered to require
controlled storage for 1000 years. For cases of surface disposal (versus HLW repository disposal
where protection is ensured by depth of disposal), long-term management and/or control cannot be
guaranteed. The actual waste performance under such conditions should be a significant
discriminator between the two technologies. The vitrified product possesses greater long-term
durability and radon mitigation (106 times better) compared to the cement-stabilized product itself.
The potential to provide longer protection to health and the environment seems to have been
ignored.
2. Reduction of Toxicity, Mobility, or Volume through Treatment:
a) The large volume reduction offered by the "VTT1 process should have been given more weight. The
packaged disposal volume from VTT1 represented only 24-26% of the volume predicted for the
Chemical Stabilization technologies.
In spite of the greatest volume reduction, VTT1 ended up with more shipments than the fritted waste
form of "VTT2. Had FDF worked with us in optimizing our disposal/shipment package, we likewise
would have had the fewest packages shipped. Instead, we continued under the expressed desire by
FDF to minimize the wasteform volume. VTT1 should be reconsidered assuming use of the simpler,
less expensive fritting.
The VTT1 technology excelled in this area based on the perceived desire by FDF to minimize the
wasteform produced. Based on the success in reducing the volume of treated waste, and the
demonstrated performance of the wastes, the vitrification technologies should be 'Strongly
Favored'.
B-lll-36
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TECO
INTERNATIONAL
May 17, 2000
Mr. Gary Stegner
Fluor Daniel Fernald
Page 3
b) The amount of secondary waste generated by vitrification technologies is very similar to that from
the chemical stabilization. These differences are insignificant in terms of the total waste generated,
and do not justify a 'Favorable' rating for the stabilization technologies.
3) Short-term Effectiveness- Worker Risk:
The down rating of VTT1 due to potential risk of electrical shock and from working at heights
ignores Toledo Engineering's experience in providing systems to the glass industry with exemplary
safety records. Our glassmaking systems are risk-engineered to force personnel safety. While we
applaud making your work force a part of your decision-making process, it is important that
something not be considered "risky" just because it is not typical of the DOE processes. Certainly
the excellent safety record at Fernald while working with the pervasive danger of radioactivity
exposure is a testament that potential risk can be controlled and does not necessarily translate into
injuries.
4) Short-term Effectiveness - Time to Achieve Protectiveness:
The time to completion assigned by FDF for "VTT1 is 3 times that proposed by Envitco and is far
too conservative. The length of time to operation start is governed by assets applied and project
management; not strictly by complexity of the task or system, and should be the same as for the
cement-based system. Toledo Engineering is a commercial design and build firm serving the
commercial glass industry and is used to increasingly fast-track projects.
Treatment time could reduced by increasing the melter size and such an increase would have
minimal effect on the total project cost. However, this approach was proposed to FDF, who
refused any efforts to provide added capacity to shorten the treatment time. In the end, the
perceived 'lack' of capacity and ability to accelerate schedule was considered a deficiency for
VTT1.
B-lll-37
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TECO
INTERNATIONAL
May 17, 2000
Mr. Gary Stegner
Fluor Daniel Fernald
Page 4
5) Long-term Effectiveness:
The Feasibility Study places heavy dependence on the packaging of the chemically stabilized
wasteform and management/maintenance of the storage to accomplish the long-term effectiveness.
This should not be a acceptable basis for control, considering the long-term risks associated with
the wasteform (long half-life radionuclides, long-term dose, continued radon emanation). Control of
the storage site was stated by PDF as required for 1000 years. This seems quite unlikely to be
possible.
The vitrified wasteform possesses much greater long-term durability and radon mitigation 105 to 106
times better than the actual cement-stabilized product.
6) Implementability:
Judgement of the VTT1 implementability should be based on the in-depth commercial experience of
Toledo Engineering in addition to hazardous and radioactive glass experience. Use of high-level
radio active waste vitrification examples should not be compared as analogous to low-level grout
examples. Worldwide, hundreds of production glass furnaces run 24 hours/day, 7 days/week for 5
to 15 years without a shutdown. Evaluation of VTT implementability based on high-level waste
demonstrations, versus evaluation of grout implementability for low level and hazardous waste
demonstrations is unfair, and biases the evaluation to down-rate vitrification. The inappropriateness
of the argument as presented is best exemplified at the Hartford DOE site, where grout stabilization
was canceled and replaced with vitrification, due to confidence in the process and wasteform.
Operability and controllability of the melter were questioned since some of the important properties
of the glasses were not measured directly during operation. The model for glass composition and
melter performance developed during initial operation and refined during operation allows accurate
prediction of all properties and operating variables. This has been demonstrated very effectively at
Savannah River and at the West Valley Demonstration Project.
B-lll-38
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TECO
INTERNATIONAL
May 17, 2000
Mr. Gary Stegner
Fluor Daniel Fernald
Page 5
7) Process Robustness/Reliability.
Cement stabilization was shown to have a narrow window for acceptability without significant
sacrifice in waste loading, as demonstrated by the failure of 11 of 12 formulations tested. These
failures were both in leaching and compression strength. These factors are critical to process
implementation, and these failures have been understated in evaluation of the process robustness,
implementability, rework quantities, long-term protection, process control, and numerous other
areas throughout the Feasibility Study.
Product Rework was taken to be 1% of the product produced for all four technologies. This is not
a valid assumption based on the actual 1/12 acceptable formulations of the Cement-Stabilization
POPT demonstration. This low level of rework was not demonstrated, and it is doubtful that it can
be achieved.
The results of the Chemical Stabilization - Cement tests (page G 3-16, Line 20-25) show an
increase in the cement content from 8.42 wt% to 12.11 wt.% increased the TCLP leaching from
0.0144 ppm to 301 ppm lead. Based on this, the Stabilization-Cement process should not be
deemed capable, considering expected variation in the waste, the water content, the analytical
methods, and in the weighing of material additions.
The robustness of the VIT1 process, even at 90% waste loading, was demonstrated by the number
and breadth of glass formulations that were developed and still met the TCLP requirements.
Significant variations in waste, or in process variation, could be accepted by the VTT process
without significantly affecting product performance.
8) Process Control:
Process control for vitrification is based on qualification of the waste prior to melting, and
verification of performance. These activities are in-process hold points, or near-process feedback
points. Off-spec product is unlikely, and can be corrected quickly. None was produced during the
extended POPT demonstration of VTT 1.
B-lll-39
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TECO
INTERNATIONAL
May 17, 2000
Mr. Gary Stegner
Fluor Daniel Fernald
Page 6
With the grout, determination of defective product cannot be made for a minimum of a week due to
curing. Detection of process deviation or performance problems cannot be detected until the
wasteform is fully cured, during which time numerous batches have been processed. This raises the
question of whether the chemical stabilization process can operate within the very small-required
working region, both in terms of chemical durability and processability.
Several other problems were identified with the Chemical Stabilization processes in Section G.3.
This was particularly prevalent with the cement-based stabilization, including flow characteristics,
curing/hardening time and unbound water in the product. All of these indicate poor process control,
giving unacceptable product. Based on the POPT data presented, the stabilization-cement
technology did not demonstrate process capability and should be significantly down-rated.
Further difficulties were experienced with the chemical stabilization technologies (particularly
cement) with meeting the TCLP leaching requirements. The FS suggested that the mix could be
'tuned' to match the TCLP No. 2 leachant, i.e. so the pH of the TCLP tests will approach the
minimum solubility of lead. This approach is a severe circumvention of the intent of the TCLP
testing process. These conditions are not likely in the NTS disposal cell and the waste may be
exposed to lower or higher pH conditions that result in rapid degradation and/or leaching of the
wasteform. Such "tuning" does not serve the long-term protection of the environment.
9) Transportation-Shielding Optimization.
The VIT1 evaluation should be reassessed to include an optimized container and associated
changes such as fritting as favored by the optimization. The VTT 1 design approach submitted by
Envitco relied on a qualified container design by SEG as described in the POPT report. This
container design was utilized at the suggestion of FDF. and Envitco understood that all technology
providers would utilize this container.
B-lll-40
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TECO
INTERNATIONAL
May 17, 2000
Mr. Gary Stegner
Fluor Daniel Fernald
Page 7
However, as reported in the Feasibility Study, the shipping and disposal containers for the other
three technologies were specified following a container optimization exercise by PDF. The
container design for VIT1 was not optimized, and provided approximately 155% the shielding that
is required. The difference is significant in terms of waste per container, number of containers
required, and ultimately a significantly increased number of shipments. This approach unfairly skews
the transport costs, since the volume transported is 270% of the actual glass volume (i.e. packaging
-170% of vitrified waste volume, 153% of the vitrified waste mass).
The SEG container used by VTT1 was a qualified container meeting drop test requirements while
the containers selected after optimization for the remaining three technologies were unqualified. If
unqualified packaging is acceptable at this phase of the study, then PDF should re-assess the
packaging for the "VTT 1 wasteform. This would include optimization of the wall thickness to meet
the 70 mrem/hr requirement, and re-assessing the transport volume, costs and risks. It is not
equitable to assess one technology based on an unoptimized, yet qualified container, while the other
technologies utilize unqualified, though dimensionally optimized containers.
10) Cost:
The cost data appearing in the FS for VTT1 was significantly different than that presented in the
Public Workshop in November 1999. VTT 1 costs increased by over 25%, primarily due to cost of
money and O&M costs. This magnitude of change did not appear in the cost assessments for the
other technologies. It was not obvious to us why this would differ for the different technologies.
VTT1 should be evaluated on the basis of at least 85-90% on-line time. The vitrification
technologies were penalized for 24 hr/day, 7 day/week schedules, although this is not critical to the
operation of either technology. This has, however, been identified as an increased risk, increased
cost, inability to recover schedule, inability to accelerate schedule, and various other negatives in the
assessment. The vitrification technologies focused on 70% utilization, a
B-lll-41
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TECO
INTERNATIONAL
May 17, 2000
Mr. Gary Stegner
Fluor Daniel Fernald
Page 8
utilization rate that is significantly lower than commercial glassmaking processes. It would be more
accurate to consider the higher demonstrated utilization of the vitrification processes based on
commercial history.
VTT1 should be evaluated on the basis of supplying an initial 30 ton/day melter. The size of the
Joule-heated melter presented in the conceptual design was based on requirements set in the
contract by PDF, which called for a three-year treatment schedule, and a 70% maximum utilization.
An advantage was awarded to Chemical Stabilization due to their ability to add capacity. This
award does not seem justifiable. The VTT1 evaluation should be adjusted to include construction of
a larger melter. There is no constraint on the size of the melter — the VTT 1 team has built
commercial Joule-heated melters as large as 250 TPD. Construction of a 30 TPD melter to allow
accelerated cleanup or allows for "catch up" can be done without a proportional increase in cost.
There is no justification in requiring a second melter when assessing the need for additional
capacity. A second melter is not required for additional capacity. A single 30 TPD melter could be
designed and constructed at the start of operations and provide the same flexibility, reduced
operating manpower, and accelerated treatment flexibility as has been deemed an advantage for the
Chemical Stabilization technologies.
We appreciate your consideration of our concerns.
Dr, Dcmglm H. Davis
r. Glass Technologies
• Co.,
& ";
fau.
Mr, David Benaert
President
Innavatedi Services, Inc.
E-lll-42
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Geo
2952 George Washington Way, Richland, WA 99352-1615
Corporation
Advanced Vitrification
Solutions International
(509) 375-0710 (v) (509) 375-7721 (f)
E-Mail: geosafe@owt.com
Home Page: www.geomelt.com
-n =3=:
May 16, 2000
Mr. Gary Stegner
US DEPARTMENT OF ENERGY
Fernald Area Office
P.O. Box 398705
Cincinnati, OH 45239-8705
Mr. James A. Saric
US EPA, 5HRE 8J
77 W. Jackson Blvd.
Chicago, IL 60604
ro
to
GEOSAFE CORPORATION COMMENT ON TFffi REVISED PROPOSED PLAN FOR
REMEDIAL ACTIONS AT SILOS 1 AND 2
Dear Messrs. Stegner and Saric:
Geosafe Corporation herein submits its comments on the Revised Proposed Plan for Remedial
Actions at Silos 1 and 2, in response to DOE's call for public comments. Our comments are based
on a detailed review of the Revised Feasibility Study Report for Silos 1 and 2, our close monitoring
of the Silos 1 and 2 project over the past three years, and significant familiarity with the technologies
involved in the project.
Our primary comment is that the ROD should NOT be changed to identify chemical
stabilization as the preferred treatment remedy in lieu of vitrification. This comment is based
on the fact that the Revised Feasibility Study is flawed and gives erroneous results, for the following
reasons:
1) It fails to recognize the superiority of vitrified waste over chemically stabilized waste relative
to the most important threshold criteria of overall protection of human health and the
environment. To conclude that both vitrification and chemical stabilization technologies are
equivalent relative to the threshold criteria is technically indefensible. The TCLP test
employed for this comparison is artificially biased toward chemical stabilization due to the
high pH of the wasteform and the resulting leachate, and the dilution of contaminants that
resulted from the 5-fold bulking up of the wasteform. The evaluation also fails to recognize
the significant differences in life expectancy between the wasteforms, and the impact of life
expectancy on long-term protection of human health and the environment.
B-lll-43
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Messrs. Stegner and Saric
May 11,2000
Page 2
2) It establishes preference for chemical stabilization based on evaluation against the five primary
balancing criteria. This is not appropriate in that the specific vitrification technologies evaluated
are not representative of vitrification technologies that have been specifically developed for
treating earthen waste materials such as are in Silos 1 and 2. Thus the cost, implementability,
short-term effectiveness, and related performance factors developed are not representative of
this technology class, and the balancing criteria evaluation is inadequate.
Given these flaws, the Revised Proposed Plan appears to be an attempt to select a lesser remedy as an
expedient to resolve the prior failure of the Silo 1 and 2 vitrification program. Geosafe recognizes the
difficulties posed by that failure, but comments that the Revised Proposed Plan is not an acceptable
way to resolve the problem. Geosafe suggests that the vitrification aspect of the current ROD is
acceptable as it stands. The errors of the prior vitrification program lie in the specific technology,
equipment and management that was employed, and should not be used to condemn the whole class of
vitrification technologies and to justify a less effective remedy.
Geosafe recognizes the political need for DOE and EPA to identify an alternative to vitrification due to
the past failure of the vitrification program at Fernald. As noted above, it would be an even greater
failure if vitrification is excluded from future consideration. If DOE must identify an alternative, then
Geosafe suggests that chemical stabilization be included in the revised ROD as a lesser contingent
remedy: but it certainly should not replace the vitrification alternative as the primary remedy. Such
replacement would be an injustice relative to the environment, and would result in an unfair restriction of
commercial competition. We are aware that the use of contingent remedies within a ROD are an
acceptable CERCLA practice.
Geosafe also believes that inadequate consideration has been given to the possibility of offsite treatment
of the waste by commercial vendors. We believe that such offsite treatment capability either presently
exists, or will shortly. In any case, such offsite capability can be established at far less cost than is
projected for a temporary facility at Fernald which will be destroyed at the end of the project.
Establishment of commercial facilities would also benefit the Government and the public through their
availability for continued use, and their lower overall cost to this project. The Revised Feasibility Study
produced estimates of total project costs exceeding $20,000 per ton of waste treated. That is an
exorbitant cost for a waste that can be treated by vitrification for direct vendor costs of less than $1000
per ton. Geosafe very strongly suggests that the ROD additionally revised to allow offsite treatment by
commercial vendors as an acceptable alternative.
DOE should define a performance specification consistent with the capabilities of best available
technology, and then should procure remediation of the Silos 1 and 2 waste on an open competition
basis. As a vendor of vitrification services, Geosafe would be pleased to compete in a procurement for
remediation of Silos 1 and 2 waste, at either an onsite or offsite facility. The GeoMelt technology has
been demonstrated to be effective on this type of waste and it does not require the same constraints that
led to the failures of the prior vitrification program. It can also be applied more cost effectively.
B-lll-44
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Messrs. Stegner and Saric
May 11,2000
Page 3
Geosafe's comments relative to specific errors and omissions in the Revised Proposed Plan are
attached. Please contact me if I can provide clarification of these comments.
Sincerely,
GEOSAPE CORPORATION
James 1. (Jim) Hansen, President
B-lll-45
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DETAILED COMMENTS BY GEOSAFE CORPORATION
ON THE REVISED PROPOSED PLAN FOR
REMEDIAL ACTIONS AT SILOS 1 AND 2
Page 2-16. line 14 - The basis for development of alternatives is said to have included, "commercial
and DOE-complex experience...". It is obvious from the Revised Feasibility Study and the Revised
Proposed Plan that this statement is not true relative to vitrification technologies. Geosafe has provided
information on its GeoMelt vitrification technology to DOE and Fluor Daniel Fernald (FDF) several
times; and it is apparent that this technology has been ignored by the studies. This technology has been
used commercially on hazardous and radioactive waste more than any other vitrification technology.
Page 6-1. line 10 - The two vitrification technologies selected for Proof-of-Principle (POP) testing are
judged to be "representative" of the class of vitrification technologies. The two technologies tested are
certainly not representative of available vitrification technologies. There are vitrification technologies
better suited for treatment of earthen materials such as the Silos 1 and 2 waste. One such superior
technology is the GeoMelt vitrification technology.
Page 7- 1. lines 21-23 - The Proposed Plan states here and several other places that "equivalent
processes" may exist and "are not precluded from consideration...". In fact equivalent and even
superior systems are being excluded from further consideration by not having been appropriately
considered in the Revised Feasibility Study or the Revised Proposed Plan.
Page 7-3. lines 14-15 - The statement that "both vitrification and chemical stabilization provide overall
protection of human health and the environment" is very misleading. In fact they may both meet or
exceed a minimum threshold value relative to leaching resistance, for instance; however, there are major
differences in the level of performance relative to this criterion. Additional comments below relate to this
position.
Page 7-5. lines 4-7 - The erroneous implication in these statements is that both technology classes are
equivalent relative to leaching resistance, even when the "original wasteform is degraded". It is well
known by DOE and EPA that vitrified waste has superior long-term leaching resistance to chemically
stabilized waste. It is also known by these parties that the TCLP test produces positively biased results
for chemically stabilized waste in that the presence of alkali materials in the waste buffers the acid used
in the TCLP testing. This is evidenced by the TCLP results for the POP-tested technologies. The
leachate from the chemical stabilization wasteform testing was highly basic, whereas it started out
acidic. It is known that once the alkali is "spent", the leaching resistance of chemically stabilized waste
falls off dramatically when exposed to acidic conditions.
The TCLP results are also biased due to dilution of contaminants that occurs due to the bulking (volume
increase) of the chemical stabilization wasteform. A volume increase of nearly 500% has been used to
dilute these wastes; and then the diluted waste's TCLP performance is compared to that of the vitrified
wasteforms which did not dilute, but rather concentrated the waste. For this reason it is not appropriate
to say the four wasteforms were equivalent on the TCLP basis.
B-IIM6
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It is also known that the estimated life expectancy of chemically stabilized product falls in the range of
10 to 100 years; whereas vitrified waste has a life expectancy of thousands to millions of years. It is
certainly misleading to state that the two technology classes are equivalent in terms of leaching
resistance over the long term.
Page 7-7. lines 6-7 - The statement that chemical stabilization ensures "long-term protectiveness of
human health and the environment..." is very misleading. It is only a matter of time and the chemically
stabilized waste will fail and become a risk to human health and the environment. The comments in the
item above apply here also.
Page 7-10. lines 27-28 - The statement regarding generation of waste streams may be true for the
vitrification technologies that were POP tested; however, this is not true for all vitrification technologies.
For instance, the GeoMelt vitrification technology consumes its own secondary waste, by recycling
back to subsequent melts, and substantially reduces the total amount of waste generated compared to
the alternative technologies.
Page 7-11. lines 26-27'. continuing on Page 7-13. lines 1-2 - The statements relative to radon release
are true; however, they omit recognition that the overall amount of radon released from the vitrified
wasteform throughout its lifetime will be far less than that released by the chemically stabilized
wasteform. Vitrification results in essentially stopping the release of radon to the environment. Chemical
stabilization temporarily slows the release; and at some time in the future, when the product is
degraded, radon emanation and release to the environment will return to high levels. This is another
benefit of vitrification that relates to long-term protection of human health and the environment.
Page 7-11. lines 18-15. and Table 7.2-1 - The text cites an "occupational hazard analysis" which
"evaluated the potential physical and chemical hazards to the workers...". The logic used resulted in
vitrification being rated lower than chemical stabilization. The analysis missed the point that due to
greater intrinsic hazard (i.e., high temperature and high voltage), the vitrification industry has taken steps
to ensure worker safety. A more appropriate comparison would have been to compare the actual
safety records of the two technology classes on a manhours worked basis. In the 20+ years that the
GeoMelt technology has been under development and in commercial use, there has not been a single
worker lost time injury associated with the technology. The analysis used in this evaluation was
inappropriate relative to what really counts ... actual personnel safety.
Page 7-14. lines 1 through 14 and Table 7.2 -3 - The analysis and conclusions presented here are an
example of error resulting from the assumption that the POP-tested vitrification technologies are
representative of the class. "The time period between the approval of the ROD amendment and the
initiation of treatment operations..." specified for vitrification technologies is far longer than would be
required for the GeoMelt technology. In addition, the 8-month requirement for performance of "Proof
of Process" testing for vitrification is unnecessary for technologies such as the GeoMelt vitrification
technology. More than 25,000 tons of waste and debris have been commercially processed by the
GeoMelt technology. This amount is far more than the combined total of all the other vitrification
technologies under consideration by DOE. It would not be necessary to perform such testing on the
GeoMelt technology. This technology has been demonstrated several times before on behalf of DOE.
For example, a 300-ton demonstration
2
B-lll-47
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melt, performed on mixed waste-contaminated soil and debris, was performed for DOE at LANL in
April, 2000. The technology has also been demonstrated capable of treating simulated Silos 1 and 2
waste without difficulty.
Page 7-16 lines 1-2 and Table 7.2-4 - The comparison of operating times is misleading due to
differences in scale between the technologies being compared. The vitrification alternative can be made
to operate at higher rates if desired. See further comments regarding scale below.
Page 7-16. lines 1-11 and Figure 7.2-5 - The implementability evaluation may be correct for the
POP-tested vitrification technologies, but unfairly judges others, like the GeoMelt technology. As noted
above, the GeoMelt technology has excellent commercial experience and has no uncertainty relative to
successful implementation. The analysis is clearly biased toward chemical stabilization, particularly in the
areas of commercial demonstration, ease of acceleration, and constructability.
Page 7-19. lines 2-14 - The section on scaleup fails to recognize vitrification technologies beyond those
that were POP-tested GeoMelt vitrification, which involves joule heating, but does not use a
refractory-lined melter vessel such as the POP-tested technologies, has been demonstrated and used
commercially many times before on radioactive and hazardous materials at rates far exceeding the
15-tpd scaleup size evaluated in the Revised Proposed Plan. GeoMelt capacity to 150 tpd exists, and
many thousands of tons of materials have been treated in the range of 30 to 80 tpd. On an 80 tpd basis,
the hours required for GeoMelting would be less than half those required for the Chem 1 alternative
(reference Table 7.2-4). Scaleup risk is not a concern for the GeoMelt technology. This scale of
equipment can be provided at lower capital cost than that of the POP-tested alternatives. Similarly,
there is no need to scaleup the off-gas treatment technology that would be employed with the GeoMelt
technology.
Page 7-19. lines 20-25 - The Plan states that joule-heated vitrification has not been used on material
"reasonably similar to Silos 1 and 2 material at the scale being proposed by the POP contractors ". As
noted above, that is an erroneous statement. The GeoMelt technology has been used to treat actual
simulated Silos 1 and 2 material (unpublished data provided to Fluor Daniel Fernald and DOE in
1997); and that material behaved during processing in a manner very similar to the great majority of the
>25,000 tons of earthen materials processed to date.
Page 7-20. lines 15-21 - The statements made are true for the vitrification technology cited; however,
they are misleading relative to vitrification as a class. The GeoMelt vitrification technology, including its
off-gas treatment system and other equipment, has been judged by EPA and DOE as highly reliable
(reference EPA/540/R-94/520). The comparison regarding reliability is misleading.
Page 7-20. lines 22-28 - Vitrification can easily equal chemical stabilization relative to schedule
acceleration/recovery by simply employing a larger scale of equipment. It is apparent that the two
technologies being compared are "apples and oranges" relative to processing scale (refer to discussion
above for page 7-19, lines 2-14).
Page 7-2 1. lines 1-2 - Not all vitrification technologies require the installation of custom refractory. The
GeoMelt technology would rate more favorably relative to constructability.
B-lll-48
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Page 7-23. Table 7.2-2 - The vitrification cost estimates are not representative of all vitrification
technologies. The GeoMelt technology could be applied at significantly lower cost than all the
technologies evaluated.
The summary cost data points out in a glaring way the need to consider offsite treatment as opposed to
onsite treatment of the waste. The logic of building a $55-69 million facility for three years of use, and
then to spend $24-25 million to decommission (destroy) it should be subject to serious evaluation.
These are costs that would be better spent on behalf of the Government, public and industry if they
were instead invested in commercial waste treatment capacity. In addition, commercial offsite treatment
would greatly reduce or nearly eliminate other costs associated with project management and the cost
of money.
Page 7-25. lines 7-20 - The capital and operating costs cited for vitrification are again not
representative. GeoMelt vitrification capital costs are typically less than half of melter-based
technologies. As noted earlier, neither an 8 month testing period of expensive spare parts nor refractory
replacement are necessary for GeoMelt vitrification.
Page 8-1. lines 21-27 - The comparative evaluation against the five primary balancing criteria is not
appropriate because the vitrification technologies evaluated are not representative. The evaluation does
not appear to give adequate importance to the superior environmental properties and life expectancy of
the vitrified product compared to the chemically stabilized product.
Page 8-5. lines 17-28 - These summary statements regarding vitrification are in error as indicated in the
comments above.
Page 8-7. -lines 7-8 - It should be noted that the GeoMelt vitrification technology is capable of
processing soils and debris related to the OU-4 remediation project. The use of this process at the site
for the Silos 1 and 2 waste could have subsequent benefit to DOE for completion d the OU-4 cleanup.
Page 8-10. line 4 - Whereas the remedy may be permanent as far as the Fernald facility is concerned,
the chemical stabilization alternative is certainly not a permanent solution for the waste itself. The
problem will have been moved to another location and the public will once again have the opportunity
to spend further resources on its ultimate treatment at a future time. It is inappropriate to call the
Proposed Plan a permanent remedy.
B-lll-49
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GeoMelt Vitrification Advantages Relative
to Melter-Based Vitrification
3. Simpler technology
• No melter vessel
• No waste pretreatment requirement
• No additive requirement
No feeding equipment
No withdrawal equipment
4. Lower cost
• Capital
- less expensive construction
Operating
- larger scale
- longer equipment life expectancy
- lower personnel requirement
- no need to purchase additives
- less material to treat due to absence of additives
- less product to ship due to absence of additives and higher volume reduction
- less product to landfill due to lesser volume
5. More robust technology
• Larger scale
• Higher melting temperature
Unconstrained by melt temperature
Tolerance of heterogeneity, waste and debris
6. Superior vitrified product
• Higher metals retention in melt
Greater leaching resistance
7. Greater experience
• More than 25,000 tons processed
• EPA SITE Program demonstrated
• EPA permitted for treatment of PCBs
DOE demonstrated several times
• Seven scales of equipment to 150 tpd
• Prior treatment of surrogate Silos 1 and 2 waste
Experience treating far more hazardous/radioactive waste than Silos 1 and 2 waste
B-lll-50
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ATTACHMENT B.IV
NOTICES OF PUBLIC COMMENT PERIOD AND
HEARINGS PLACED IN MAJOR LOCAL
NEWSPAPERS
B-IV-1
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March 29, 2000
Harrison Press
Page 4A
"Notice of Availability and Notification of Public Meeting"
NOTICE OF AVAILABILITY AND
NOTIFICATION OF PUBLIC MEETING
FEASIBILITY STUDY/PROPOSED PLAN
FOR
REMEDIAL ACTIONS AT SILOS 1 AND 2
Fernald Environmental Management Project
The United State Department if Energy (DOE) announces the availability of a
Proposed Plan for remediation of Silos 1 and 2, a component of Operable Unit 4
at the Fernald Environmental Project. The Proposed Plan identifies a preferred
alternative as well as the other alternatives considered, for public comment.
The December 1994 Record of Decision tor Remedial Actions at Operable Unit
4 identified removal of the material and treatment by vitrification followed by
off-site disposal at the Nevada Test site as the remedy for Silos 1 and 2. In the
Revised Feasibility Study for Silos 1 and 2, DOE reevaluated vitrification and
other potential technologies fortreatment of the Silos 1 and 2 material. A
detailed evaluation of vitrification and chemical stabilization was conducted.
Based upon available information, the preferred alternative proposed for the
public comment is removal, treatment of the Silos 1 and 2 material by chemical
stabilization, and off-site disposal at the NTS. Although this is the Preferred
Alternative at the present time, DOE welcome as the comments from the public
on both alternatives. The formal public comment period begins on April 3 and
ends on May 18, 2000. DOE will select the final remedy, with the concurrence of
the United States Environmental Protection Agency and the Ohio Environmental
Protection Agency, after the end of the public comment.
DOE will hold a public meeting to discuss the Proposed Plan and accept oral or
written public comments an April 25, 2000. from6:30-8:30p.m., at this Alpha
Building, Classroom D, 10967 Hamilton-Cleves Highway, Harrison, Ohio.
Copies of the Feasibility Study/Proposed Plan for Silos 1 and 2, and other
supporting information are available at:
Public Environmental Information Center
10995 Hamilton-Cleves Highway
Harrison, Ohio. 45030
(513)648-7480
For further information or to submit written comments, please contact:
Mr. Gary Stegner
U.S. Dept of Energy
Fernald Environmental Management Project
PO. Box 538705
Cincinnati, Ohio 45253-8705
(513)648-3153
B-IV-2
-------
March 30, 2000
Journal-News
Page A4
"Notice of Availability and Notification of Public Meeting"
of1
NOTICE OF AVAILABILITY AND
NOTIFICATION OF PUBLIC MEETING
FEASIBILITY STUDY/PROPOSED PLAN
FOR REMEDIAL ACTIONS AT SILOS 1 AND 2
Fernald Environmental Management Project
The United States Department of Energy (DOE) announces the availability of a Proposed
Plan for remediation of Silos 1 and 2 a component of Operable Unit 4, at the Fernald
Environmental Management Project. The Proposed Plan identifies a preferred alternative,
as well as the other alternatives considered, for public comment.
The December 1994 Record of Decision for Remedial Actions at Operable Unit 4
Identified removal of the material and treatment by vitrification followed by off-site
disposal at the Nevada Test Site as the remedy for Silos 1 and 2. In the Revised
Feasibility Study for Silos 1 and 2, DOE reevaluated vitrification and other potential
technologies for treatment of the Silos 1 and 2 material. A detailed evaluation of
vitrification and chemical stabilization was conducted.
Based upon available information, the preferred alternative proposed for public comment
is removal, treatment of the Silos 1 and 2 material by chemical stabilization, and off-site
disposal at the NTS. Although this is the Preferred Alternative at the present time, DOE
welcomes the comments from the public on both alternatives. The formal public
comment period begins on April 3 and ends on May 18, 2000. DOE will select the final
remedy, with the concurrence of the United States Environmental Protection Agency
and the Ohio Environmental Protection Agency, after the end of the public comment
period.
DOE will hold a public meeting to discuss the Proposed Plan and accept oral or written
public comments on April 25, 2000, from 6:30 - 8:30 p.m., at the Alpha Building,
Classroom D, 10967 Hamilton-Cleves Highway, Harrison, Ohio.
Copies of the Feasibility Study/Proposed Plan for Silos 1 and 2, and other supporting
information are available at
Public Environmental Information Center
10995 Hamilton-Cleves Highway
Harrison, OH 45030
Phone: (513)648-7480
For further Information or to submit written comments, please contact:
Mr. Gary Stegner
U.S. Department of Energy
Fernald Environmental Management Project
P.O. Box 538705
Cincinnati, Ohio 45253-8705
Phone (513) 648-3153
B-IV-3
-------
April 2, 2000
Cincinnati Enquirer
Page C5
"Notice of Availability and Notification of Public Meeting"
of1
NOTICE OF AVAILABILITY AND NOTIFICATION OF PUBLIC
MEETING
REVISED PROPOSED PLAN FOR
REMEDIAL ACTIONS AT SILOS 1 AND 2
Fernald Environmental Management Project
The United States Department of Energy (DOE) announces the
availability of a revised Proposed Plan for remediation of Silos 1 and 2,
a component of Operable Unit 4, at the Fernald Environmental
Management Project. The Proposed Plan identifies a preferred
alternative, as well as the other alternatives considered, for public
comment.
Based upon available information, the preferred alternative proposed for
public comment is removal, treatment of the Silos 1 and 2 material by
chemical stabilization, and off-site disposal at the NTS. Although this
is the Preferred Alternative at the present time, DOE welcomes the
comments from the public on other alternatives. The formal public
comment period begins on April 3 and ends on May 18, 2000. DOE
will select the final remedy, with the concurrence of the United State
Environmental Protection Agency and the Ohio Environmental
Protection Agency, after the end of the public comment period. Either
alternative may be selected after consideration of public comments.
DOE will hold a public meeting to discuss the Proposed Plan and
accept oral or written public comments on April 25, 2000, from 6:30-
8:30p.m., at the Alpha Building, Classroom 0,10967 Hamilton-Cleves
Highway, Harrison, Ohio.
Copies of the Proposed Plan, the Revised Feasibility Study for Silos 1
and 2, and other supporting information are available at:
Public Environment Information Center
10995 Hamilton-Cleves Highway
Harrison, OH 45030
Phone:(513)648-7480
For further information or to submit written comments, please contact:
Mr. Gary Stegner
U.S. Department of Energy
Fernald Environmental Management Project
P.O. Box 538705
Cincinnati, Ohio. 45253-8705
Phone:(513)648-3153
B-IV-4
-------
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Saturday, April 1, 2000/Las Vegas Review-Journal/SB
NOTICE OF AVAILABILITY AND NOTIFICATION OF PUBLIC MEETING
FEASIBILITY STUDY/PROPOSED PLAN
FOR
REMEDIAL ACTIONS AT SILOS 1 AND 2
Fernald Environmental Management Project
The United States Department of Energy (DOE) announces the availability of a Proposed Plan for
remediation of Silos 1 and 2, a component of Operable Unit 4, at the Fernald Environmental Management
Project. The Proposed Plan identifies a preferred alternative as well as the other alternatives considered,
for public comment.
The December 1994 Record of Decision for Remedial Actions at Operable Unit 4 identified removal of the
material and treatment by vitrification followed by off-site disposal at the Nevada Test Site as the remedy
for Silos 1 and 2. In the Revised Feasibility Study for Silos 1 and 2, DOE reevaluated vitrification and
other potential technologies for treatment of the Silos 1 and 2 material. A detailed evaluation of
vitrification and chemical stabilization was conducted.
Based upon available information, the preferred alternative proposed for public comment is removal,
treatment of Silos 1 and 2 material by chemical stabilization, and off-site disposal at the NTS. Although
this is the Preferred Alternative at the present time, DOE welcomes comments from the public on both
alternatives. The formal public comment period begins on April 3 and ends on May 18, 2000. DOE will
select the final remedy, with the concurrence of the United States Environmental Protection Agency and
the Ohio Environmental Protection Agency, after the end of the public comment period.
DOE will hold a public meeting to discuss the Proposed Plan and accept oral or written public comments
on May 3, 2000, from 4:30-6:00 p.m., in the Sedan Conference Room at the Department of Energy's
Nevada Support Facility, 232 Energy Way (just off Losee Rd.), in North Las Vegas. Written public
comments can be submitted throughout the entirety of the public comment period.
Copies of the Feasibility Study/Proposed Plan for Silos 1 and 2, and other supporting information are
available at these locations:
Public Environmental Information Center DOE Public Reading Room
10995 Hamilton-Cleves Highway 2621 Losee Rd., Bldg. B-3
Harrison, OH 45030 Las Vegas, NV 89030
Phone: (513) 648-7480 Phone: (702) 295-1628
For further information or to submit written comments, please contact:
Mr. Gary Stegner, Public Affairs Officer
U.S. Department of Energy
Fernald Environmental Management Project
P.O. Box 538705
Cincinnati, Ohio 45253-8705
Phone:(513)648-3153
B-IV-6
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