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DOE/ID-10719
Revision 2
Final Comprehensive
Record of Decision
Central Facilities Area
Operable Unit 4-13
Published July 2000
Idaho National Engineering and Environmental Laboratory
Idaho Falls, Idaho
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U.S. DEPARTMENT OF ENERGY IDAHO OPERATIONS OFFICE
SIGNATURE SHEET
Signature sheet for the Record of Decision for OU 4-13, located in Waste Area Group 4, the
Central Facilities Area, of the Idaho National Engineering and Environmental Laboratory, between the
U.S. Department of Energy and the Environmental Protection Agency, with concurrence by the Idaho
Department of Health and Welfare.
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U.S. ENVIRONMENTAL PROTECTION AGENCY
SIGNATURE SHEET
Signature sheet for the Record of Decision for OU 4-13, located in Waste Area Group 4, Central
Facilities Area, of the Idaho National Engineering and Environmental Laboratory, between the U.S.
Department of Energy and the Environmental Protection Agency, with concurrence by the Idaho Department of
Health and Welfare.
Chuck Clarke, Regional Adminfetraior
gion 10
US. Environmental Protection Agency
Date
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IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY
SIGNATURE SHEET
Signature sheet for the Record of Decision for OU 4-13, located in Waste Area Group 4, the Central
Facilities Area, of the Idaho National Engineering and Environmental Laboratory, between the U.S.
Department of Energy and the Environmental Protection Agency, with concurrence by the Idaho Department of
Environmental Quality.
, Director
Department of Environmental Quality
Date
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U.S. DEPARTMENT OF ENERGY IDAHO OPERATIONS OFFICE
SIGNATURE SHEET
Signature sheet for the Record of Decision for OU 4-13, located in Waste Area Group 4, the Central
Facilities Area, of the Idaho National Engineering and Environmental Laboratory, between the U.S.
Department of Energy and the Environmental Protection Agency, with concurrence by the Idaho Department of
Health and Welfare.
Beverly A. Cook, Manager Date
U.S. Department of Energy Idaho Operations Office
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U.S. ENVIRONMENTAL PROTECTION AGENCY
SIGNATURE SHEET
Signature sheet for the Record of Decision for OU 4-13, located in Waste Area Group 4, Central
Facilities Area, of the Idaho National Engineering and Environmental Laboratory, between the U.S.
Department of Energy and the Environmental Protection Agency, with concurrence by the Idaho Department of
Health and Welfare.
Chuck Clarke, Regional Administrator Date
Region 10
U.S. Environmental Protection Agency
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IDAHO DEPARTMENT OF HEALTH AND WELFARE
SIGNATURE SHEET
Signature sheet for the Record of Decision for OU 4-13, located in Waste Area Group 4, the Central
Facilities Area, of the Idaho National Engineering and Environmental Laboratory, between the U.S.
Department of Energy and the Environmental Protection Agency, with concurrence by the Idaho Department of
Health and Welfare.
C. Stephen Allred, Administrator Date
Division of Environmental Quality
Idaho Department of Health and Welfare
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PART I—DECLARATION OF THE RECORD OF DECISION
Site Names and Location
Central Facilities Area
Waste Area Group 4 Comprehensive Remedial Investigation/Feasibility Study, Operable Unit 4-13
Incorporating 52 individual sites in Operable Units 4-1 through 4-13
Idaho National Engineering and Environmental Laboratory
CERCLIS ID No. 4890008952; CERCLA Site ID No. 1000305
Idaho Falls, Idaho
Statement of Basis and Purpose
This Record of Decision (ROD) presents the selected remedy for Waste Area Group (WAG) 4 at the
Idaho National Engineering and Environmental Laboratory (INEEL). The selected remedy comprises remedial
action at three individual sites and outlines limited action institutional controls that will be implemented at one
of the remediated sites and one other site. Components of the selected remedy were selected in accordance
with the requirements of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (42 USC 9601, et
seq.) of 1980 as amended by the Superfund Amendments andReauthorization Act of 1986. All
documentation to support the decisions finalized in this ROD is contained in the Administrative Record for
WAG 4. The selected remedy is intended to be the final action at WAG 4, the Central Facilities Area (CFA).
The U.S. Department of Energy Idaho Operations Office (DOE-ID) is lead agency for the
decision. The U.S. Environmental Protection Agency (EPA), Region 10 and Idaho Department of Health
and Welfare (IDHW) Division of Environmental Quality participated in the evaluation and selection of the
remedial actions. The EPA approves and IDHW concurs with the selected remedy for WAG 4.
Although no unacceptable risks via groundwater were identified in the Comprehensive Remedial
Investigation/Feasibility Study for the Central Facilities Area Operable Unit 4-13 (RI/FS) (DOE-ID
1999a), a subsequent report for the Operable Unit (OU) 4-12 Post-ROD monitoring program identified
that nitrate in two wells at WAG 4 was above a federal drinking water maximum contaminant level
(MCL) of 10 mg/L. On this basis, the Agencies initially decided to separate OU 4-13 into two actions: OU
4-13 A, which was designated an Interim Action ROD, and OU 4-13B, which was designated as the
groundwater RI/FS. Therefore, the proposed plan for OU 4-13 was retitled the OU 4-13A Interim Action
Proposed Plan when it was issued in August 1999.
Subsequent to this decision, information was gathered regarding the likely source and extent of
nitrate in the wells. The most likely source has been identified as the CFA-08 Sewage Plant Drainfield.
Additionally, because the nitrate levels are expected to drop below the MCL during the time period that
DOE operates the facility, a higher allowable level under 40 CFR 141.11 for nitrate (20 mg/L) is
protective during the DOE operational period. The average nitrate concentration in one of the subject
wells is equal to the MCL; nitrate concentrations in the other well is less than the 20 mg/L allowable level
and shows a downward trend. On that basis, the agencies decided to eliminate the OU 4-13B RI/FS and
maintain the original name, the OU 4-13 Comprehensive ROD. Groundwater will continue to be evaluated
under the Post-ROD monitoring program
111
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Assessment of the Site
The response action selected in this ROD is necessary to protect the public health or welfare or the
environment from actual or threatened releases of hazardous substances into the environment. Such release
or threat of release may present an imminent and substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedies
The Federal Facility Agreement and Consent Order (FFA/CO) (DOE-ID 1991) was developed to
provide a framework and schedule for implementing CERCLA activities at the INEEL. The FFA/CO was
signed by DOE-ID, EPA Region 10, and the IDHW. To facilitate the implementation of CERCLA at INEEL,
the INEEL was divided into 10 WAGs. This ROD documents remedies selected for contaminated sites at
WAG 4.
WAG 4 consists of 52 surface sites grouped into 13 operable unit (OUs). As designated in the
FFA/CO, OU 4-13 is the Comprehensive Remedial Investigation/Feasibility Study for the Central Facilities
Area Operable Unit 4-13 (DOE-ID 1999a). An estimate of cumulative risk associated with all 52 surface
sites and an evaluation of appropriate actions for those sites posing unacceptable risk was included in the OU
4-13 RI/FS. Forty-seven of these sites were determined to be no action or no further action sites (this
includes a no action portion of one site, CFA-08). The selected remedies for WAG 4 comprise three remedial
actions to mitigate the risk associated with three sites (one of which will require continuing institutional
controls). Also limited action is required at the no further action site, CFA-07, and three previously covered
sites, CFA-01, -02, and -03, to implement and continue institutional controls. Monitoring of groundwater is
required to assess the downward trend of nitrate. The sites that require remedial action are the CFA-04 Pond,
the CFA-08 Sewage Plant Drainfield, and CFA-10 Transformer Yard (formerly known as the Transformer
Yard Oil Spills Site).
CFA-04 Pond
The CFA-04 Pond was determined to pose a threat to human health and the environment from
mercury contamination. The hazard indices are 80 for human (future resident with subsistence farming) and
up to 30,000 for ecological receptors (screening level). The volume of mercury-contaminated soil is
estimated to be 6,338 m3 (8,290 yd3). This estimate is based on the depth to basalt in the pond bottom
(max=2.4 m [8 ft]), the windblown area, and the pipeline. The remedial action selected to mitigate the threat
to human health and the environment for the CFA-04 Pond is excavation and on-INEEL disposal at the
proposed INEEL CERCLA Disposal Facility (ICDF). Given the volume of contaminated soil, the cost of
retrieval and associated cost of disposal is more cost effective than a more intensive analysis. This remedy
will consist of the following actions:
1. Characterizing the site and excavating soil from CFA-04 that exceeds the mercury final
remediation goal (FRG) of 0.50 mg/kg. Soil contaminated at concentrations above the FRG will
be excavated to basalt or 3m (10ft) below ground surface (bgs). No basalt will be excavated.
2. Transporting and disposing soil that exceeds the mercury FRG to the ICDF.
3. Stabilizing soil as necessary to meet ICDF Waste Acceptance Criteria.
IV
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4. Performing verification sampling to ensure that soil exceeding the FRG of 0.50 mg/kg
mercury has been removed.
5. Backfilling the pond, and adjacent areas that have been excavated with uncontaminated soil
to grade. All excavations will be contoured to match the surrounding terrain and revegetated.
The preamble of the NCP states that when noncontiguous facilities are reasonably close to one
another, and wastes at the sites are compatible for a selected treatment or disposal approach, CERCLA
section 104(d)(4) allows the lead agency to treat these related facilities as one site for response purposes;
and, therefore, allows the lead agency to manage waste transferred between such noncontiguous facilities
without having to obtain a permit. CFA and Idaho Nuclear Technology and Engineering Center (INTEC) will
be treated as one site for response purposes because of the reasonably close proximity of the facilities and
because of the compatibility of the disposal approach. Both facilities are part of INEEL. INTEC is located just
two miles north of CFA and the facilities are connected by a road limited only to badged personnel. The
ICDF is being designed to safely consolidate INTEC CERCLA waste and will accept CERCLA waste from
other areas within INEEL. The ICDF complex will include an engineered facility meeting Resource
Conservation and Recovery Act Subtitle C, Idaho Hazardous Waste Management Act and polychlorinated
biphenyl landfill design and construction requirements.
CFA-08 Sewage Plant Drainfield
The CFA-08 Sewage Plant Drainfield was determined to pose a threat to humans from cesium-137
contamination. The risk to the future residential receptor from cesium-137 is 4E-04. No environmental risks
were identified. The volume of cesium-137 contaminated soil is estimated to be 56,634 m3 (74,074 yd3).
Radioactive decay will reduce the cesium-137 concentration to below the 1E-04 (future resident) risk-based
level of 2.3 pCi/g in 189 years. The remedial action selected to mitigate the threat to human health for the
CFA-08 Sewage Plant Drainfield is containment of the contaminated soil area using an engineered cover. The
cover will be designed to isolate low-level radioactive contaminants from human and biotic intrusion and to
provide radiation shielding for a period of 189 years. Short-term remedial actions to be performed at the site
include:
1. Constructing an engineered Evapotransperation (ET) cover, using clean native soil for fill
material as needed
2. Contouring and grading the surrounding terrain to direct the surface water runoff away from
the cover.
The continued effectiveness of the remedy will be evaluated by monitoring soil cover integrity and
performing above ground radiological surveys. Because contamination is to be left in place, institutional
controls are necessary for CFA-08 to restrict access until the land can be released for unrestricted use.
Institutional controls (Section 12) to be implemented at CFA-08 include:
1. Restricting access using signs and permanent markers
2. Establishing and publishing surveyed boundaries
3. Controlling activities
4. Land use controls in land leasing and property transfers.
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CFA-10 Transformer Yard
Due to lead contamination, CFA-10 Transformer Yard was determined to pose a threat to human
health and the environment. Lead was detected in soil at a maximum concentration of 5,560 mg/kg, which
exceeds the EPA residential screening criterion of 400 mg/kg and the ecological risk level of 10 times
backgound (170 mg/kg). The relatively small volume of lead-contaminated soil is estimated at 122 m3 (160
yd3). The remedial action selected to mitigate the threat to human health and the environment for the CFA-10
Transformer Yard site is excavation and off-INEEL disposal at a permitted Treatment, Storage, and Disposal
Facility (TSDF). This remedy will consist of the following actions:
1. Characterizing the site and excavating soil from CFA-10 (OU4-09) that exceeds the lead
FRG of 400 mg/kg.
2. Performing verification sampling in the excavated area to verify that soil exceeding the FRG
of 400 mg/kg for lead, has been removed.
3. Stabilizing in cement, soil as necessary to ensure LDRs are met.
4. Transporting and disposing of excavated and stabilized soil to a permitted off-INEEL TSDF.
5. Backfilling areas that have been excavated with uncontaminated soil to grade. All
excavations will be contoured to match the surrounding terrain and revegetated.
Statutory Determination
Statutory Requirements
The selected remedies for the CFA-04 Pond, CFA-08 Sewage Drainfield, CFA-10 Transformer Yard,
No Action and No Further Action sites have been determined to protect human health and the environment,
comply with federal and state requirements that are legally applicable or relevant and appropriate, and are
cost-effective. These remedies use permanent solutions and alternative treatment technologies to the maximum
extent practicable.
Statutory Preference for Treatment
The statutory preference for a remedy to reduce the toxicity, mobility, or volume of materials through
treatment is met by the selected remedies for CFA-04 and CFA-10. Treatment will be performed by stabilizing
excavated, contaminated soil as appropriate to meet the ICDF Waste Acceptance Criteria for CFA 04 and the
LDRs for CFA 10.
The Agencies have decided to implement engineering controls in cases where treatment is impractical
or where sites pose relatively low long-term risk. Treating contaminated soils at CFA-08 is not practical due to
the large volume of soil contaminated with relatively low levels of cesium-137. The selected remedial action at
CFA-08 does not meet the preference for treatment as a principal element. However, the selected remedies
fulfill the Agencies preference for engineered controls in lieu of treatment.
Institutional Controls
Institutional controls (1C) or land use/access restriction will be maintained by DOE at any INEEL
CERCLA site where residual contamination levels are not protective for unrestricted exposure and unlimited
land use according to EPA Region 10 Policy (EPA 1999a). ICs may be discontinued if
VI
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contaminant conditions or potential risk levels are determined to be protective which will be documented
during CERCLA five-year reviews.
Five-Year Review Requirements
Statutory comprehensive five-year reviews are required at sites where contamination left in place
precludes unrestricted exposure and unlimited land use. Reviews will evaluate factors such as
contaminant migration from sites, effective use of institutional controls, and the overall effectiveness of
remedial actions. Also, reviews will assess the need for future long-term environmental monitoring and
administrative/institutional controls.
Vll
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RECORD OF DECISION DATA CERTIFICATION CHECKLIST
Based on Section 6.2.6 of A Guide to Preparing Superfund Proposed Plans, Records of Decision, and
Other Remedy Selection Decision Documents (EPA 1999b), the following information is included in the
Decision Summary (Part II) of this ROD:
• Contaminants of concern (COCs) and their respective concentrations
• Baseline risk assessment of the COCs
• Cleanup levels established for the COCs and the basis for the levels
• Information about principal threat wastes is not included because source materials constituting
principal threats were not encountered
• Current and future land- and groundwater-use assumptions used in the baseline risk assessment
and ROD
• Land and groundwater use that will be available at the Site as a result of the selected remedies
• Estimated costs for capital, operation and maintenance, and total net present value; discount rate;
and the number of years over which the remedy estimates are projected
• Decisive factors that led to selecting the remedies (i.e., how the selected remedies provide the
best balance of tradeoffs relative to the balancing and modifying criteria).
Supporting information on the decision process can be found in the Administrative Record for WAG
Vlll
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CONTENTS
PART I. DECLARATION OF THE RECORD OF DECISION iii
Site Names and Location iii
Statement of Basis and Purpose iii
Assessment of the Site iv
Description of the Selected Remedies iv
Statutory Determination vi
RECORD OF DECISION DATA CERTIFICATION CHECKLIST viii
U.S. DEPARTMENT OF ENERGY IDAHO OPERATIONS OFFICE SIGNATURE
SHEET ix
U.S. ENVIRONMENTAL PROTECTION AGENCY SIGNATURE SHEET xi
IDAHO DEPARTMENT OF HEALTH AND WELFARE SIGNATURE SHEET xiii
ACRONYMS xxiii
PART II—DECISION SUMMARY 1-1
1. SITE NAME, LOCATION, AND BRIEF DESCRIPTION 1-1
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2.1 INEEL History 2-1
2.2 CFA History 2-1
2.3 WAG 4 Enforcement Activities 2-1
2.3.1 CERCLA Actions 2-2
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION 3-1
4. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 4-1
4.1 Remedial Action Sites 4-1
4.2 No Action and No Further Action Sites 4-1
4.3 Groundwater 4-4
5. SITE CHARACTERISTICS 5-1
xv
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5.1 Physical Characteristics 5-1
5.2 Climate 5-2
5.3 Flora and Fauna 5-2
5.4 Demography 5-3
5.5 Cultural Resources 5-3
5.6 Conceptual Site Models 5-5
6. CURRENT AND POTENTIAL SITE AND RESOURCE USES 6-1
6.1 Current Land Use 6-1
6.2 Future Land Use 6-1
6.3 Groundwater Use 6-3
6.4 Groundwater Classification and Basis 6-3
7. BASELINE RISK ASSESSMENT METHODOLOGY 7-1
7.1 Human Health Risk Evaluation Summary 7-1
7. 1.1 Data Evaluation 7-1
7.1.2 Exposure Assessment 7-2
7.1.3 Toxicity Assessment 7-4
7.1.4 Risk Characterization 7-5
7.1.5 Qualitative Uncertainty Analysis 7-7
7.2 Ecological Risk Evaluation Summary 7-12
7.2.1 Problem Formulation 7-12
7.2.2 Analysis 7-12
7.2.3 Risk Characterization 7-15
7.2.4 Transition to the INEEL-Wide Ecological Risk Assessment 7-16
7.3 Risk Assessment Summary 7-16
8. CONTAMINATED SOIL SITES CFA-04, CFA-08, AND CFA-10 8-1
8.1 CFA-04 Pond (OU 4-05) 8-1
xvi
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8.1.1 Site Investigations 8-1
8.1.2 Nature and Extent of Contamination 8-2
8.1.3 Summary of Site Risks 8-2
8.2 CFA-08 Sewage Plant Drainfield (OU 4-08) 8-4
8.2.1 Site Investigations 8-4
8.2.2 Nature and Extent of Contamination 8-6
8.2.3 Summary of Site Risks 8-6
8.3 CFA-10 Transformer Yard (OU 4-09) 8-7
8.3.1 Site Investigations 8-7
8.3.2 Nature and Extent of Contamination 8-7
8.3.3 Summary of Site Risks 8-7
9. REMEDIAL ACTION OBJECTIVES AND FINAL REMEDIATION GOALS 9-1
9.1 Remedial Action Objectives 9-1
9.2 Final Remediation Goals for the Selected Alternatives 9-1
10. DESCRIPTION OF ALTERNATIVES 10-1
10.1 Alternative 1—No Action (With Monitoring) 10-1
10.2 Alternative 2—Limited Action 10-1
10.3 Alternative 3—Excavation, Treatment, and Disposal 10-2
10.3.1 Alternative 3a—Removal, On-INEEL Treatment, and Disposal 10-2
10.3.2 Alternative 3b—Removal, Treatment, and Disposal Off-INEEL 10-3
10.4 Alternative 4—Containment and Institutional Controls 10-4
11. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 11-1
11.1 Threshold Criteria 11-1
11.1.1 Overall Protection of Human Health and the Environment 11-1
11.1.2 Compliance with Applicable or Relevant and Appropriate Requirements .... 11-2
11.2 Balancing Criteria 11-3
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11.2.1 Long-Term Effectiveness and Permanence 11-3
11.2.2 Reduction of Toxicity, Mobility, or Volume Through Treatment 11-3
11.2.3 Short-Term Effectiveness 11-4
11.2.4 Implementability 11-4
11.2.5 Cost 11-5
11.3 Modifying Criteria 11-5
11.3.1 State Acceptance 11-5
11.3.2 Community Acceptance 11-6
12. SELECTED REMEDY 12-1
12.1 Description of Selected Remedy 12-1
12.1.1 CFA-04 Pond (OU 4-05) 12-1
12.1.2 CFA-08 Sewage Plant Drainfield (OU 4-08) 12-2
12.1.3 CFA-10 Transformer Yard (OU4-09) 12-3
12.2 Institutional Controls 12-4
12.3 Estimated Costs for the Selected Remedies 12-6
13. STATUTORY DETERMINATIONS 13-1
13.1 CFA-04 Pond 13-1
13.1.1 Protection of Human Health and the Environment 13-1
13.1.2 Cost-Effectiveness 13-1
13.1.3 Use of Permanent Solutions and Alternative Treatment Technologies 13-1
13.1.4 Preference for Treatment as a Principal Element 13-1
13.1.5 Five-Year Reviews 13-4
13.2 CFA-08 Sewage Plant Drainfield (OU 4-08) 13-4
13.2.1 Protection of Human Health and the Environment 13-4
13.2.2 Cost-Effectiveness 13-4
13.2.3 Use of Permanent Solutions and Alternative Treatment Technologies 13-4
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13.2.4 Preference for Treatment as a Principal Element 13-5
13.2.5 Five-Year Reviews 13-5
13.3 CFA-10 Transformer Yard (OU 4-09) 13-5
13.3.1 Protection of Human Health and the Environment 13-5
13.3.2 Cost-Effectiveness 13-5
13.3.3 Use of Permanent Solutions and Alternative Treatment Technologies 13-5
13.3.4 Preference for Treatment as a Principal Element 13-6
13.3.5 Five-Year Reviews 13-6
14. DOCUMENTATION OF SIGNIFICANT CHANGES 14-1
14.1 Modification of the Preferred Alternative for CFA-08 14-1
14.2 CFA-04 Information 14-1
14.3 OU 4-13A Interim Action Proposed Plan 14-1
14.4 Ecological Sites and Risks 14-2
15. REFERENCES 15-1
Part III. RESPONSIVENESS SUMMARY III-l-l
Appendix A—Oral and Written Public Comments
FIGURES
1-1. Location of WAG 4 at the INEEL 1-2
1-2. CERCLA sites and groundwater monitoring wells at WAG 4 1-3
5-1. Counties surrounding the INEEL 5-4
5-2. Conceptual site model for contaminated soil sites at CFA 5-6
5-3. Conceptual site model for underground storage tanks and buried waste sites at CFA 5-7
5-4. Conceptual site model for liquid discharge sites at CFA 5-8
5-5. Complete conceptual site model for ecological receptors at WAG 4 5-9
6-1. Land ownership distribution in the vicinity of the INEEL and on-INEEL
areas open for permitted grazing 6-2
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8-1. Pond (CFA-04) 8-3
8-2. Sewage Plant Drainfield (CFA-08) 8-5
8-3. The Transformer Yard site (CFA-10) 8-8
TABLES
4-1
7-1.
7-2.
7-3.
7-4.
8-1.
8-2
8-3.
9-1.
11-1.
11-2.
12-1
12-2
12-3.
Summary of WAG 4 Sites
BRA human health assessment uncertainty factors
Summary of source-term uncertainties site with selected remedies
Sources and effects of uncertainties in the ecological risk assessment
Summary of major risks and hazard quotients at individual sites and
contaminants of concern that are addressed by the selected remedy for WAG 4 . .
Summary data for the human health and ecological COC at the CFA-04 Pond . . . .
Summary of data for human health COCs at the CFA-08 drainfield
Summary of data for the human health and ecological COCs at the CFA-10
Transformer Yard
Final Remediation Goals for sites with selected alternatives
Relative ranking of alternatives evaluated for the three WAG 4 OU 4-13
sites of concern.3
Costs for the alternatives considered for CFA-04, CFA-08, and CFA-10
Institutional control evaluation for WAG 4 sites
Institutional control requirements for WAG 4 remediated sites
Cost estimate summary for selected remedy at OU 4-13: Pond (CFA-04),
4-2
7-8
.. 7-11
. . 7-17
. . 7-18
8-2
8-6
8-9
9-2
. . 11-2
. . 11-6
12-8
12-18
SP Drainfield (CFA-08), and Transformer Yard (CFA-10) 12-22
13-1. ARARs and TBCs for the selected remedies for CFA-04, CFA-08, and CFA-10 13-2
xx
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ACRONYMS
ALARA
AR
ARAR
ASA
bgs
BLM
BRA
CAB
CEL
CERCLA
CERCLIS
CFA
CFLUP
CFR
COC
COPC
DOE
DOE-ID
EPA
ERA
FFA/CO
FRG
GFE
ffl
as low as reasonably achievable
Administrative Record
applicable or relevant and appropriate requirements
Auditable Safety Analysis
below ground surface
U.S. Bureau of Land Management
baseline risk assessment
Citizen's Advisory Board
Chemical Engineering Laboratory
Comprehensive Environmental Response,
Compensation, and Liability Act
CERCLA Information System
Central Facilities Area
Comprehensive Facility Land Use Plan
Code of Federal Regulations
contaminant of concern
contaminant of potential concern
U.S. Department of Energy
U.S. Department of Energy Idaho Operations Office
U.S. Environmental Protection Agency
ecological risk assessment
Federal Facility Agreement and Consent Order
final remediation goals
government furnished equipment
hazard index
xxi
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HQ
HSP
1C
ICDF
ICP
IDAPA
IDHW
INEL
INEEL
INTEC
IRIS
LOAEL
MCL
NCP
NOAEL
NPL
NPV
NRTS
UCL
O&M
OU
PCB
RAO
RBC
hazard quotient
Health and Safety Plan
Institutional control
INEEL CERCLA Disposal Facility
Institutional Control Plan
Idaho Administrative Procedures Act
Idaho Department of Health and Welfare
Idaho National Engineering Laboratory
Idaho National Engineering and Environmental
Laboratory
Idaho National Technical and Engineering Center
Integrated Risk Information System
lowest observed adverse effects level
maximum contaminant level
National Oil and Hazardous Substances Pollution
Contingency Plan
no observed adverse effects level
National Priorities List
net present value
National Reactor Testing Station
upper confidence limits
operation and maintenance
operable unit
polychlorinated biphenyl
remedial action objective
risk based concentration
xxii
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RCRA Resource Conservation and Recovery Act
RD/RA remedial design/remedial action
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
SF slope factor
SGS segmented gate separation
SP sewage plant
SRPA Snake River Plain Aquifer
TBC to-be-considered
TCLP Toxicity Characteristic Leaching Procedure
TRV toxicity reference value
TSDF Treatment, Storage, and Disposal Facility
UCL upper confidence limit
UST underground storage tank
VOC volatile organic compound
WAG Waste Area Group
xxin
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XXIV
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PART II—DECISION SUMMARY
1. SITE NAME, LOCATION, AND BRIEF DESCRIPTION
Waste Area Group (WAG) 4 is designated as one of 10 WAGs located at the Idaho National
Engineering and Environmental Laboratory (INEEL). The INEEL has conducted nuclear reactor research and
testing for the U.S. Government since 1949. It is managed by the U.S. Department of Energy Idaho
Operations Office (DOE-ID) and occupies an area of approximately 2,305 km2 (890 mi2) in southeastern
Idaho. WAG 4 comprises the Central Facilities Area (CFA), located in the south-central portion of the INEEL
(see Figure 1-1).
A Federal Facility Agreement/Consent Order (FFA/CO) (DOE-ID 1991) between the U.S.
Environmental Protection Agency (EPA) Region 10, the State of Idaho Department of Health and Welfare
(IDHW), and the DOE-ID is the procedural framework for administering the INEEL's 10-WAGs for
environmental restoration activities. The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) (42USC 9601, et seq.) site identification number for the INEEL is 1000305.
The CFA has been used since 1949 to house many of the support services for all of the operations at
the INEEL, including laboratories, security, fire protection, medical, communication systems, warehouses, a
cafeteria, vehicle and equipment pools, bus system, and laundry facilities. The FFA/CO identified 52 potential
release sites at WAG 4 (see Figure 1-2). The types of CERCLA sites at WAG 4 include landfills, underground
storage tanks, above ground storage tanks, drywells, disposal ponds, soil contamination sites, and a sewage
plant. Each of these sites was placed into one of 13 operable units (OUs) within the WAG based on similarity
of contaminants, environmental release pathways, and/or investigations.
DOE-ID is the lead agency for the decisions presented in this Record of Decision (ROD). The EPA
Region 10 and the IDHW participated in the evaluation and selection of remedies at WAG 4. The EPA
approves decisions and IDHW concurs with the selected remedies. Both EPA and IDHW participated in the
evaluation and selection of remedies for WAG 4.
Part II 1-1
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Ts Sgtawi Te Outssit
Snake raver Plan
Aquifer and
Slles
Navot Reactors
FcciFity
Test Reactw Area 7jdaho NucJ
Argarm? Naliond
Mr
Engbnring Center
(f) Waste Area Groups
mm. i
8
iioRK T5!fi
llr m
Experfmental Breeder
SoK'ng Water Reactor Experiment
j
Hadiaactlvti Waste
Management Camples
Figure 1-1. Location of WAG 4 at the INEEL.
Part II 1-2
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CFA- 01
CFA- O4
. OS
CFA-
-------
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 INEEL History
Parts of the current INEEL site were first used as gunnery and bombing ranges during World War II
by the U.S. Navy and U.S. Army Air Corps. The site was established in 1949 as the National Reactor Testing
Station by the U.S. Atomic Energy Commission and was historically devoted to energy research and related
activities. The National Reactor Testing Station was renamed in 1974 to the Idaho National Engineering
Laboratory (INEL) to reflect a broader scope of engineering activities. In 1997, the name was changed to
INEEL to reflect a growing emphasis on environmental remediation and research. Historically, facilities at
INEEL were dedicated to the development and testing of peaceful applications of nuclear power. Waste
disposal practices from these operations resulted in contamination of some facilities and the surrounding
environment.
Throughout the 50 years of INEEL operations, disposal practices have been implemented in
compliance with state and federal regulations and policies established by DOE and its predecessors. Some of
these practices are not acceptable by contemporary standards and have been discontinued. Contaminated
structures and environmental media, such as soil and water, are the legacy of some historical disposals.
Occasional accidental releases have also occurred over time. In keeping with the contemporary emphasis on
environmental issues, INEEL research is now focused an environmental restoration to address these
contaminated media and waste management issues to minimize additional contamination from current and
future operations. Spent nuclear fuel management, hazardous and mixed waste management and
minimization, cultural resources preservation, and environmental engineering, protection, and remediation are
challenges addressed by current INEEL activities (DOE-ID 1996).
2.2 CFA History
The original buildings at CFA, built in the 1940s and 1950s, housed Navy gunnery range personnel,
administration, shops, and warehouse space. The facilities have been modified over the years to fit changing
needs and now provide four major types of functional space: (1) craft (2) office, (3) service, and (4)
laboratory. Approximately 1,028 people work at CFA. Public access to INEEL is strictly controlled through
the use of security personnel and security measures such as fences around sensitive facilities.
2.3 WAG 4 Enforcement Activities
In January 1984, hazardous waste disposal sites within the INEEL that could pose an unacceptable
risk to human health and safety or the environment were identified (EG&G 1984). The sites were ranked
using either the EPA hazard ranking system for sites with chemical contamination or the DOE modified
hazard ranking system for sites with radiological contamination. Based on the results of the hazard ranking,
DOE-ID) entered into a Consent Order and Compliance Agreement with Region 10 (COCA 1987), which
regulates the generation, transportation, treatment, storage, and disposal of hazardous waste. A hazard
ranking score of 28.5 or higher qualifies a site for the National Priorities List (54 FR 48184) as amended by
CERCLA (42 USC 9601 et seq.). Because the Test Reactor Area (WAG 2) received a score in excess of
28.5, the entire reservation became a candidate for the National Priorities List.
On November 15, 1989, the EPA added INEEL to the National Priorities List under CERCLA (42 USC
9601 et seq.). An FFA/CO and Action Plan (DOE-ID 1991) were negotiated and signed by DOE-ID, EPA,
and the IDHW in December 1991, to implement the rededication of the INEEL under
Part II 2-1
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CERCLA. Effective December 9, 1991, the FFA/CO superseded the corrective action elements of the
Consent Order and Compliance Agreement (COCA 1987).
The goals of the FFA/CO are two-fold: (1) ensure that potential or actual INEEL releases of
contaminants to the environment are thoroughly investigated in accordance with the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) (40 Code of Federal Regulations [CFR] 300), and
(2) appropriate response actions are taken to protect human health and the environment. The FFA/CO
established the procedural framework and schedule for developing, prioritizing, implementing, and monitoring
response actions at the INEEL in accordance with CERCLA and RCRA legislation and the Idaho Hazardous
Waste Management Act (Institutional control [1C] § 39-4401). The FFA/CO is consistent with a general
approach approved by the EPA and DOE in which agreements with states as full partners would allow site
investigation and cleanup to proceed using a single road map to minimize conflicting requirements and
maximize limited rededication resources. For management purposes, the FFA/CO divided INEEL into 10
WAGs.
The Secretary of Energy's Policy Statement (DOE 1994) on the National Environmental Policy Act
(42 USC 4321 et seq.) stipulates that DOE will rely on the CERCLA process for review of actions to be taken
under CERCLA. The policy statement also requires that DOE address National Environmental Policy Act
values and public involvement procedures by incorporating such values, to the extent practicable, in
documents and public involvement activities generated under CERCLA.
The OU 4-13 comprehensive remedial investigation /feasibility study (RI/FS) is the final investigation
for WAG 4 identified in the FFA/CO. Actions conducted under the authority of CERCLA are summarized
below.
2.3.1 CERCLA Actions
Two RODs, three time-critical removal actions, and four nontime-critical removal actions have been
performed at WAG 4. The first ROD for WAG 4 was for the OU 4-11 Motor Pool Pond and was signed on
December 31, 1992 (DOE-ID 1992a). ROD 4-11 resulted in no action with further evaluation of potential risk
via the groundwater pathway in the OU 4-13 Comprehensive RI/FS (DOE-ID) 1999a).
A second ROD was issued on October 10, 1995, for the OU 4-03 Underground Storage Tank sites
and OU 4-12 Landfills I, II and III (DOE-ID 1995). This ROD resulted in 19 No Further Action
determinations for the underground storage tanks and installation of compacted native soil covers over the
three landfills as a presumptive remedy. The ROD also called for cover and groundwater monitoring along
with institutional controls. Groundwater monitoring wells were installed in 1995 and 1996. The landfill covers
and monitoring systems were emplaced in 1997. Groundwater monitoring at WAG 4 was carried out under
the OU 4-12 Post-ROD Monitoring Work Plan (DOE-ID 1997a). The monitoring commenced in 1996 and
will continue until 2026, unless a five-year review alters that decision. A monitoring report has been published
that summarizes data from the first two years of monitoring (DOE-ID 2000a, draft).
Three time-critical removal actions were performed at WAG 4 for the CFA-04 Pond, CFA-06 and -43
Lead Sites, and CFA-42 Tank Farm Spills. Approximately 218 m3(285 yd3) of mercury-contaminated soil and
calcine material were removed from the pond periphery and treated in an on-INEEL retort unit. Analytical
data collected after the removal action indicated that mercury-contaminated soil remained in the pond bottom,
a windblown area and along a pipeline that discharged to the pond. As a result the site was investigated
further in the OU 4-13 RI/FS (DOE-ID 1999a).
A time-critical removal action was conducted in 1996 at CFA-06 Lead Shop and CFA-43 Lead
Storage Area, which resulted in the excavation of approximately 457 m3 (600 yd3) of lead- and arsenic-
Part II 2-2
-------
contaminated soil. Soil was shipped to an off-INEEL disposal facility. No further action was required per
confirmation sampling.(DOE-ID 1999a).
During time-critical removal actions in 1996 and 1997, approximately 6,718 m3 (8,787 yd3) of
petroleum-contaminated soil was removed from the CFA-42 Tank Farm Spills site. The tanks and associated
pumping and piping systems were removed and soil was excavated to basalt. Potential risk remaining from
the site was evaluated in the OU 4-13 RI/FS (DOE-ID 1999a).
Three nontime-critical removal actions were performed in 1997 at CFA-13, -15, -17 and -47. CFA-13
was a sewer clean out that received waste from Building CFA-640. The cleanout was excavated and disposed
at the CFA Bulk Waste Landfarm. Potential risk from the soil surrounding the cleanout was evaluated in the
OU 4-13 RI/FS (DOE-ID 1999a). The CFA-15 dry well was a concrete pipe 0.61 m (2 ft) in diameter by
2.44 m (8 ft) deep that received waste from Building CFA-674, i.e., discharged to the CFA-04 Pond.
Potential risk from the soil surrounding the dry well was evaluated in the OU 4-13 RI/FS (DOE-ID 1999a).
One nontime-critical removal action was performed for sites CFA-17 and CFA-47, bermed fire pits
and associated asphalt pad and an adjacent fire station chemical disposal area. A total of 4,051 m3 (5,298 yd
3) were removed from the two areas. Soil was excavated to basalt. Potential risk from the sites was evaluated
in the OU 4-13 RI/FS (DOE-ID 1999a).
It should be noted that the FFA/CO identified sites CFA-09 and CFA-11 as sites for which Interim
Actions were planned as part of the OU 10-05 Ordnance Sites Interim Action ROD. However, geophysical
investigations revealed no evidence of ordnance material at CFA-09 or CFA-11 and they were designated as
no action sites in the OU 10-05 Ordnance Sites Interim Action ROD (DOE-ID 1992b).
Part II 2-3
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3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
In accordance with CERCLA §113(k)(2)(b)(i-v) and §17, a series of opportunities for public
information and participation in the WAG 4 Comprehensive OU 4-13 RI/FS and decision-making process was
provided to the public between June 1997 and October 1999. The opportunities to obtain information and
provide input included a "kick-off fact sheet, INEEL Reporter newsletter articles (a publication of the
INEEL's Environmental Restoration Program), three Citizen's Guide supplemental updates, one "update" fact
sheet, a proposed plan, briefings and presentations to interested groups, and public meetings.
In June 1997, a "kick-off'fact sheet concerning the WAG 4 Comprehensive OU 4-13 RI/FS was sent
to about 600 individuals from the general public and INEEL employees on the Community Relations Plan
mailing list. Included with the fact sheet was a postage-paid return mailer comment form. No comments
were received. This fact sheet also offered technical briefings to those interested in the WAG 4
comprehensive remedial investigation. This was the initial opportunity for public input in the RI process.
Initially, no technical briefings were requested, but briefings were provided later in the RI process.
Bimonthly issues of the INEEL Reporter, which provided status of the investigation, were regularly
sent out to individuals on the mailing lists, Reports also appeared in three issues of a Citizen's Guide to
Environmental Restoration at the INEEL (a supplement to the INEEL Reporter) in early 1997, 1998, and late
June 1999.
In May 1999, an "update" fact sheet was distributed to approximately 600 citizens on the INEEL
Community Relations Plan mailing list. The purpose of the document was to keep citizens apprised of
developments that occurred during the OU 4-13 RI/FS and to announce the approximate dates of future
public meetings. The fact sheet offered technical briefings to those interested in the WAG 4 RI/FS.
The final WAG 4 Proposed Plan for remedial action at WAG 4 was mailed to about 600 members of
the public on the INEEL Community Relations Plan mailing list during the week of July 26, 1999. The public
comment period for the WAG 4 Proposed Plan began August 5 and was planned to end on September 4,
1999. However, at the request of the public, the comment period was extended 30 days to October 4, 1999.
During the week of August 2, 1999, personal calls were made to Idaho stakeholders in various Idaho
communities. The purpose of the telephone calls was to inform individuals of upcoming public meetings and
assess if a technical briefing was desired. As a result, technical briefings were held August 13, 1999, with
Coalition 21. Coalition 21 is an organization of retired INEEL employees. The following week of August 16,
1999, another technical briefing was held with a member of an environmental group.
Also during the week of August 2, 1999, DOE-ID issued a news release to more than 100 media
contacts concerning the beginning of a 30-day public comment period pertaining to the WAG 4 Proposed
Plan. Many of the news releases resulted in short notes in community calendar sections of newspapers and in
public service announcements on radio stations. The news release gave notice to the public that supportive
WAG 4 investigation documentation was available in the Administrative Record (AR) section of the INEEL
Information Repositories located in the INEEL Technical Library in Idaho Falls, Albertson Library on the
campus of Boise State University, and the University of Idaho Library in Moscow, Idaho. During the week of
August 2, 1999, display advertisements announcing the availability of the Proposed Plan and the locations of
public meetings appeared in regional newspapers in Idaho Falls, Boise,
Part II 3-1
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Moscow, Arco, Fort Hall, Pocatello, and Twin Falls, Idaho. Large display advertisements appeared in the
following newspapers: (1) the Post Register (Idaho Falls); (2) the Arco Advertiser (Arco); (3) The Sho-Ban
News (Fort Hall), (4) The Idaho State Journal (Pocatello); (5) The Times-News (Twin Falls); (6) the Idaho
Statesman (Boise); and (7) the Moscow-Pullman Daily News (Moscow). A follow-up advertisement ran in
newspapers approximately four days before the public meetings in Idaho Falls, Boise, and Moscow. Post
cards were mailed to approximately 5,400 citizens an the INEEL mailing list informing them of the availability
of the WAG 4 Proposed Plan, the duration of the comment period, and the times and locations of upcoming
public meetings. An electronic note was sent to all INEEL employees providing this information.
DOE-ID gave two briefings on the WAG 4 Proposed Plan to the INEEL Citizen's Advisory Board
(CAB) and its Environmental Restoration Program Subcommittee. The advisory board is a group of 15
individuals, representing the citizens of Idaho, who make recommendations to DOE, EPA, and the State of
Idaho regarding environmental restoration activities at the INEEL. On September 21, 1999, members of the
CAB toured the three CFA contaminated-soil sites proposed for remediation. On September 22, 1999, the
INEEL CAB met to finalize and submit their formal recommendations on the proposed plan to DOE.
For the general public, participation in the decision-making process included receiving the Proposed
Plan, attending availability sessions before public meetings to informally discuss issues, attending public
meetings, and submitting verbal and written comments to the Agencies during the 30-day public comment
period. Citizens were urged to comment on the proposed plan and to attend public meetings. Public meetings
were held in Idaho Falls on August 17, Boise on August 18, and Moscow on August 19, 1999. Prior to public
meetings in each location, an availability session took place from 6 to 7 p.m. Public meetings began at 7 p.m.
Approximately 30 people not associated with the WAG 4 project attended the public meetings.
Written comment forms (including a postage-paid, business-reply form) were made available to those
attending the public meetings. The forms were used to submit written comments either at the meeting or by
mail. The reverse side of the meeting agenda contained a form for the public to use in evaluating the
effectiveness of the meetings. A court reporter was present at each meeting to record transcripts of
discussions and public comments. The meeting transcripts were placed in the AR section for the WAG 4,
CFA, and OU 4-13 in three INEEL Information Repositories. For those who could not attend the public
meetings, but wanted to make formal written comments, a postage-paid written comment form was attached
to the WAG 4 Proposed Plan.
Overall, 13 groups or members of the public provided formal comments; five citizens provided verbal
comments at the public meetings and eight provided written comments. All comments received on the WAG
4 Proposed Plan were considered during the development of this ROD. The decision, finalized in this ROD, is
based on the information in the AR for OU 4-13.
Part III of this ROD, the Responsiveness Summary, includes responses to all formal verbal comments
presented at the public meetings and all written comments received on the WAG 4 Proposed Plan.
Transcripts of oral comments and scanned versions of written comments are provided in Appendix A in their
entirety. The oral and written comments are also included in the AR for WAG 4.
Part II 3-2
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4. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
OU 4-13 Comprehensive RI/FS is the culmination of all of the CERCLA evaluations performed for
WAG 4 at CFA. Table 4-1 presents a summary of all the affected WAG 4 sites, their OU, and the decisions
made per this OU 4-13 ROD. According to the FFA/CO, the boundary of WAG 4 encompasses the facility
locations and all surface and subsurface areas presently or historically used within the CFA area, as well as
adjacent areas where waste activities may have taken place. The issuance of the ROD for OU 4-13, marks
the beginning of final remedial activities. As specified in the action plan attached to the FFA/CO (DOE-ID
1991), post-ROD activities will include remedial design/remedial action (RD/RA) phases. The RD/RA will
commence with the development of a scope of work to identify and establish deadlines for submitting other
documents and outline the overall strategy for managing the RD/RA. A draft scope of work will be submitted
to EPA and IDHW for review within 21 days of the issuance of the ROD. Substantial continuous physical
remedial action within WAG 4 will commence within 15 months of the issuance of the ROD.
No principal threats have been identified at WAG 4. A principal threat is defined by EPA as source
material considered to be highly toxic or highly mobile that generally cannot be contained in a reliable manner
or would present a significant risk to human health or the environment should exposure occur (EPA 1999b).
4.1 Remedial Action Sites
Remedial actions at WAG 4 protect human health and the environment. Three actions will be
implemented to mitigate the unacceptable risks to human or ecological receptors associated with the three
specific sites identified in the WAG 4 Comprehensive RI/FS (DOE-ID 1999a) and Proposed Plan (DOE-ID
1999b).
The first remedial action addresses the risk associated with mercury at the CFA-04 Pond.
Mercury-contaminated soil in the pond bottom, the adjacent windblown area, and the pipeline will be
excavated, treated as required, and disposed to the INEEL CERCLA Disposal Facility (ICDF). Treatment will
include stabilization with cement of that portion of the soil with mercury concentrations in excess of the
RCRA characteristic hazardous waste level.
The second action will be implemented to mitigate the risk posed by soil in the CFA-08 Sewage Plant
Drainfield. Cesium-137 contaminated soil in the drainfield will be contained with an engineered barrier.
Long-term monitoring and institutional controls will be implemented as part of the remedy.
The third action mitigates risk associated with lead-contaminated soil at the CFA-10 Transformer Yard
site. Soil will be excavated, treated as required, and disposed of to an off-INEEL disposal facility. The
decision to use an off-site facility is based on a comparative cost analysis of managing this relatively small
volume of waste in the ICDF. Treatment will include stabilizing that portion of the soil with lead
concentrations in excess of the RCRA characteristic hazardous waste levels using cement.
4.2 No Action and No Further Action Sites
Per this ROD, a no action site is a site that has no contaminant source or has a minor contaminant
source with an acceptable risk level under a current residential exposure scenario, i.e., the risk is less than 1 x
104 or the hazard quotient is less than 1. A no further action site is a site that is not available for unrestricted
exposure and unlimited use. For WAG 4, there is one reason for a site to be a no further action site:
Part II 4-1
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Table 4-1. Summary of WAG 4 Sites.
Operable
Unit
4-01
4-02
4-03
Site Code
CFA-09
CFA-11
CFA-13
CFA-14
CFA-15
CFA-16
CFA-18
CFA-19
CFA-20
CFA-21
CFA-22
CFA-23
CFA-24
CFA-25
CFA-27
CFA-28
CFA-29
CFA-30
CFA-31
CFA-32
CFA-33
CFA-34
CFA-35
Site Name
Central Gravel Pit
French Drain (containing a 5 -in. shell
north of CFA-663)
Dry Well (south of CFA-640)
Two Dry Wells (CFA-665)
Dry Well
(CFA-674)
Dry Well
(south of CFA-682 pumphouse)
Fire Department Training Area, Oil
Storage Tanks
Gasoline Tanks (2) East of CFA-606
Fuel Oil Tank at CFA-609
(CFA-732)
Fuel Tank at Nevada Circle 1
(South by CFA-629)
Fuel Oil at CFA-640
Fuel Oil Tank at CFA-641
Fuel Tank at Nevada Circle 2
(South by CFA-629)
Fuel Oil Tank at CFA-656 (North Side)
Fuel Oil Tank at CFA-669
(CFA-740)
Fuel Oil Tank at CFA-674 (West)
Waste Oil Tank at
CFA-664
Waste Oil Tank at
CFA-665, active
Waste Oil Tank at
CFA-754, active
Fuel Tank at CFA-667 (North Side)
Fuel Tank at CFA-667 (South Side)
Diesel Tank at CFA-674 (South)
Sulfuric Acid Tank at CFA-674
(West Side)
No Further Action-
Institutional Controls
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
No Action
Part II 4-2
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Table 4-1.
Operable
Unit
4-04
4-05
4-06
4-08
4-09
(continued).
Site Code
CFA-36
CFA-37
CFA-38
CFA-45
CFA-39
CFA-40
CFA-41
CFA-04
CFA-17
CFA-47
CFA-50
CFA-06
CFA-43
CFA-44
CFA-07
CFA-12
CFA-48
CFA-08
CFA-49
CFA-10
CFA-26
CFA-42
CFA-46
Site Name
Gasoline Tank at
CFA-680
Diesel Tank at CFA-681 (South Side)
Fuel Oil Tank,
CFA-683
Underground Storage Tank
Drum Dock
(CFA-771)
Returnable Drum Storage- South of
CFA-601
Excess Drum Storage-south of CFA-
674
Pond
Fire Department Training Area, bermed
Fire Station Chemical Disposal
Shallow Well East of
CFA-654
Lead Shop
(outside areas)
Lead Storage Area
Spray Paint Booth Drain
French Drains E/S
(CFA-663)
French Drains (2)
(CFA-690)
Chemical Washout South of CFA-663
Sewage Plant
Pipeline
Sewage Plant Drainfield
Hot Laundry Drain Pipe
Transformer Yard
CFA-760 Pump Station Fuel Spill
Tank Farm Pump Station Fuel Spills
Cafeteria Oil Tank Spill (CFA-721)
No Further Action-
Institutional Controls
No Action
No Action
No Action
No Action
No Action
No Action
No Action
Remedial Action
No Action
No Action
No Action
No Action
No Action
No Action
No Further Action-
Institutional Controls
No Action
No Action
No Action
No Action
Remedial Action
No Action
Remedial Action
No Action
No Action
No Action
Part II 4-3
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Table 4-1. (continued).
Operable
Unit
4-11
4-12
Site Code Site Name
CFA-05 Motor Pool Pond
CFA-01 Landfill I
No Further Action-
Institutional Controls
No Action
Addressed under the OU 4-12
ROD-continued operation,
maintenance, and monitoring
CFA-02 Landfill II
CFA-03 Landfill III
4-13a
CFA-51 Drywell at North End of CFA-640
No Action
a)
CFA-52 Diesel Fuel UST (CFA-730) at Bldg
CFA-613 Bunkhouse
OU 4-13 was amended April 1996 to include these two sites.
No Action
• It has a contaminant source at depths greater than 3 m (10 ft) below grade that might pose a risk
to human health if it was ever brought to the surface. Contaminants do not have an exposure
route (current residential exposure scenario) available under current site conditions.
The Agencies have determined that no action or no further action be taken under CERCLA at 46 sites
in WAG 4 (one additional site, CFA-08, has two no action portions, and a remedial action portion). A
summary of these determinations is included in Table 4-1. Fifteen of these sites plus on portion of the CFA-
08 site were determined to be no action during the R^aseline risk assessment (BRA) analysis for this ROD.
One additional site, CFA-07 (OU 4-07), French Drain, was determined to be a no further action site and will
have institutional controls until it is otherwise evaluated and documented in a CERCLA five-year review.
Additional details on these sites can be found in the AR.
The other 30 no action sites were determined to be no action for one of the following reasons:
• The site was a declared a no action site by the signing of a previous WAG 4 ROD.
• A source did mot exist at the site.
• Contamination at the site was determined to pose a risk less than 1E-06 or have a hazard quotient
less than 1 through a Track 1 or Track 2 evaluation.
4.3 Groundwater
No unacceptable risk were predicted via the groundwater pathway from sites at WAG 4 during the OU
4-13 Comprehensive RI/FS (DOE-ID 1999a). Additionally, groundwater monitoring for all wells at WAG 4
will be carried out under the Post-ROD Monitoring Work Plan. Please see Figure 1-2 for the monitoring well
locations. The OU 4-12 Post-ROD Monitoring Work Plan included a cost estimate for 30 years of
groundwater monitoring at WAG 4; the wells have monitored for four years to date. Monitoring will continue
until such time as the five-year reviews show, and the Agencies agree, that it is no longer necessary. A
monitoring report was prepared for this two year of quarterly monitoring
Part II 4-4
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from 1996 to 1998 that also shows no constituents in the groundwater at WAG 4 are above risk-based
concentrations (DOE-ID 2000a).
During the preparation of the OU 4-12 monitoring report, two constituents — lead and nitrate—were
identified at elevated concentrations. Although there is no federal MCL for lead, the EPA lead action level and
the State of Idaho groundwater quality standard is 15 ug/L, unless site-specific situations are taken into
account (IDAPA 16.01.11). Lead concentrations in one well, CFA-MON-A-003, have exceeded this
standard. Lead concentrations were below the quality standard during the first two sampling rounds in 1996,
began increasing to a peak concentration of 44.8 ug/L in mid-1997, and have been decreasing since that time.
The most recent sampling event reported a lead concentration of 19 ug/L in April 1999. Zinc and iron
concentrations followed a similar trend in CFA-MON-A-003, although no groundwater standards were
exceeded. Because this is an isolated occurrence and no lead sources were identified at CFA that could pose a
risk to groundwater, lead levels in CFA-MON-A-003 are thought to be a localized phenomenon and will
continue to be monitored.
Nitrate concentrations of approximately 20 mg/L and 10 mg/L were identified in two wells,
CFA-MON-A-002 and CFA-MON-A-003, respectively. Nitrate levels in CFA-MON-A-002 were inititally
measured at 21 mg/L in 1995 and have declined to 16 mg/L in the most recent sampling round in March
2000. Nitrate levels in CFA-MON-A-003 have been measured between 8.65 and 11 mg/L, with an average
concentration of 10 mg/L. Although these concentrations are below the calculated risk-based concentration
(58 mg/L), the concentration in CFA-MON-A-002 exceeds the MCL identified in the National Primary
Drinking Water Regulations (40 CFA 141). The MCL is 10 mg/L if the water is available to sensitive
populations, such as infants below 6 months of age (40 CFA 141.62); the higher allowable limit is 20 mg/L if
the water is not available to infants below 6 months of age or other sensitive populations (40 CFA 141.11).
One risk from nitrate is "blue baby" syndrome in which nitrate preferentially replaces hemoglobin in a baby's
bloodstream, causing the skin to turn blue.
The Agencies initially decided to perform a separate groundwater RI/FS to assess the occurrence of
nitrate in CFA-MON-A-002; that investigation was to be called OU 4-13B and the OU 4-13 RI/FS was
referred to as OU 4-13 A. On that basis, the Proposed Plan was issued in August 1999 as the OU 4-13 A
Proposed Plan and it summarized only the three remedial actions described previously.
Subsequent to the issuance of the Proposed Plan, trend analysis of the nitrate concentrations in
CFA-MON-A-002 was performed, isotopic analysis of groundwater samples was conducted, a likely source
was identified, and limited groundwater modeling was conducted (DOE-ID 2000b). The source was
identified as CFA-08 Sewage Treatment Plan grainfield, which has not been used since February 1995. Per
this ROD, the CFA-08 grainfield will be capped in 2002, thereby reducing subsurface infiltration. Modeling
showed the plume is now diminishing and regression analysis showed that nitrate concentrations at
CFA-MON-A-002 would likely go below the MCL of 10 mg/L in approximately 10 to 15 years. Nitrate
concentrations in CFA-MON-A-002 have been below 20 mg/L in the last four sampling rounds since the fall
of 1997. Regression analysis of nitrate data collected over a four-year period also showed a statistically
significant downward trend for nitrate in CFA-MON-A-002 (DOE-ED 2000b).
The ultimate goal and applicable or relevant and appropriate MCL requirement for nitrate is 10 mg/L,
which is predicted be achieved within 15 years at CFA-MON-A-002. Because CFA-MON-A-002 is a
monitoring well that is presently located on the INEEL which is under DOE institutional control, the Agencies
agreed that the groundwater is currently protective under this land use scenario. On that basis, further
investigation of nitrate is not required. Nitrate concentrations will be determined annually at
CFA-MON-A-002, and CFA-MON-A-003 per the Post-ROD Monitoring Work Plan that addresses
groundwater monitoring at WAG 4 (DOE-ED 1997a). The State of Idaho and EPA
Part II 4-5
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will be notified of the concentrations annually as required by 40 CFA 141.11. Additionally, nitrate
concentrations and trends will be evaluated during the five-year reviews planned for WAG 4. If deviations to
the predicted trend are noted the approach described herein will be re-evaluated by the Agencies, which may
require a ROD amendment for active rededication. After the nitrate concentration falls below the MCL of 10
mg/L, annual reporting to the State and EPA will cease but the wells will continue to be monitored as
necessary based on five-year reviews.
As a result of this evaluation DOE requested and the Agencies concurred that the OU 4-13B
investigation should be discontinued and that this ROD become the Comprehensive OU 4-13 ROD for WAG
4 (DOE-ID 2000c).
Part II 4-6
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5. SITE CHARACTERISTICS
5.1 Physical Characteristics
The INEEL is located on the Eastern Snake River Plain, a large topographic depression extending
from the Oregon border across Idaho to Yellowstone National Park and northwestern Wyoming. The surface
of the INEEL, in general, is covered by basalt flows and intermittent, discontinuous pockets of sediment.
Surface hydrology includes water from three streams that flow intermittently onto INEEL and local
runoff caused by precipitation and melting snow. No ponds and streams are within WAG 4 except very
briefly in conjunction with spring runoff. The Big Lost River is the nearest surface water feature and is not
influenced by activities at WAG 4.
The vadose zone is the unsaturated region extending from land surface down to the water table, and
varies in thickness from approximately 61m (200 ft) thick in the northern part of INEEL to more than 274 in
(900 ft) in southern portions of the Site (Irving 1993). The vadose zone is a complex series of heterogeneous
basalt flows with thin layers of interbedded sediments. The basalt flows consist of thick dense intervals as
well as large void spaces resulting from rubble zones, lava tubes, undulatory basalt-flow surfaces, and
fractures. Sediment interbeds in the vadose zone consist of sand, silt, and clay and are generally thin and
discontinuous. The vadose zone is approximately 146 m (480 ft) thick beneath CFA.
The Snake River Plain Aquifer (SRPA) underlies most of INEEL. The aquifer, defined as the
saturated region beneath the vadose zone, arcs approximately 325 km (200 mi) through the eastern Idaho
subsurface and varies in width from approximately 80 to 112 km (50 to 70 mi). The total area is about
25,000 km2 (9,600 mi2) . The SRPA discharges approximately 8.8E+09 m3 (7.1 million acre/ft) of water
annually to springs and rivers (EG&G 1993). The aquifer contains thick sequences of numerous, relatively
thin basalt flows extending to depths of 1,067 in (3,500 ft) below ground surface (bgs). 7he SRPA also
contains sediment interbeds within the basalt flows that are typically discontinuous. The aquifer has an
estimated capacity of 2.5E+12 m3 (8.8E+13 ft3) of water (EG&G 1986).
The SRPA is recharged primarily by infiltration from precipitation and deep percolation of irrigation
water. Regional groundwater flows to the south-southwest; however, the flow direction can be affected
locally by recharge from rivers, surface water spreading areas, and heterogeneity in the aquifer. Locally at
CFA, the groundwater flow direction is to the south. Estimates of flow velocities within the aquifer range
from 1.5 to 6.1 m/day (5 to 20 ft/day) (EG&G 1993). Flow in the aquifer is primarily through fractures,
through interflow zones in the basalt, and in the highly permeable rubble zones located at the top of basalt
flows. The aquifer is considered heterogeneous and anisotropic (having properties that differ depending on
the direction of measurement) because of the permeability variations within the aquifer that are caused by
basalt irregularities, fractures, void spaces, rubble zones, and sediment interbeds. The heterogeneity of the
basalt bedrock results in a high variability in transmissivity values (measures of the ability of the aquifer to
transmit water). Transmissivity measurements in wells on the INEEL range from l.OE-01 to 1.1E+06 mVday
(1.1E+00 to 1.2E+07 ftVday) (INEEL 1995a). Concerns about groundwater contamination from INEEL
operations have prompted an extensive monitoring system over all of INEEL (EG&G 1993).
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5.2 Climate
Meteorological and climatological data for the INEEL and the surrounding region are collected and
compiled from several meteorological stations and three stations that are located at INEEL operated by the
National Oceanic and Atmospheric Administration field office in Idaho Falls, Idaho.
The region is classified as and to semiarid (DOE-ID 1989) with an annual average precipitation of
22.1 cm (8.7 in.). The rates of precipitation are highest during the months of May and June and lowest
during July. Normal winter snowfall occurs from November through April, though occasional snowstorms
occur in May, June, and October. Snowfall at the INEEL ranges from about 17.3 cm (6.8 in.) per year to
about 151.6 cm (59.7 in.) per year, and the annual average is 70.1 cm (27.6 in.) (DOE-ID 1989). The
INEEL is subject to severe weather episodes throughout the year. Thunderstorms are observed mostly during
spring and summer. An average of two to three thunderstorms occurs during each month from June through
August (EG&G 1981). Thunderstorms are often accompanied by strong gusty winds that may produce local
dust storms. Precipitation from thunderstorms at INEEL is generally light. Occasionally, however, rain
resulting from a single thunderstorm on INEEL exceeds the average monthly total precipitation (EG&G
1984).
The average summer daytime maximum temperature is 28 °C (83 °F), while the average winter
daytime maximum temperature is -0.6°C (31°F). Recorded temperature extremes at the INEEL vary from a
low of -44°C (47°F) in January to a high of 38°C (101 °F) in July (DOE-ID 1989). The relative humidity at
INEEL ranges from a monthly average minimum of 18% during the summer months to a monthly average
maximum of 55% during the winter. The relative humidity is directly related to diurnal temperature
fluctuations. Relative humidity reaches a maximum just before sunrise (the time of lowest daily temperature)
and a minimum in midafternoon (the time of maximum daily temperature) (DOE-ED 1989).
The INEEL is in the belt of prevailing westerly winds, which are channeled within the Eastern Snake
River Plain to produce a west-southwest or southwest wind approximately 40% of the time. The average
midspring windspeed recorded at a height of 6 m (20 ft) is 9.3 mph, while the average midwinter windspeed
is5.1mph(EG&G1993).
5.3 Flora and Fauna
Six broad vegetation categories representing nearly 20 distinct habitats have been identified on the
INEEL: (1) juniper-woodland, (2) native grassland, (3) shrub-steppe off lava, (4) shrub-steppe on lava (5)
modified, and (6) wetlands. Though small riparian and wetland regions exist along the Big Lost Rivet and
Birch Creek, nearly 90% of the site is covered by shrub-steppe vegetation. The most common varieties are
big sagebrush, saltbush, rabbitbrush, and native grasses.
The INEEL serves as a wildlife refuge because a large percentage of the Site is undeveloped and
human access is restricted. Grazing and hunting are prohibited in the central part of the site. Mostly
undeveloped, this tract may be the largest relatively undisturbed sagebrush steppe in the Intermountain West
outside of the national parklands (DOE-ID 1996). More than 270 vertebrate species including 43 mammalian,
210 avian, 11 reptilian, nine fish, and two amphibious species have been observed on the site. Hundreds of
birds of prey and thousands of pronghom antelope and sage grouse have often wintered on INEEL. Mule
deer and elk also reside at the Site. Observed predators include: bobcats, mountain lions, badgers, and
coyotes. Bald eagles, classified as a threatened species, are commonly observed on or near the site each
winter. Peregrine falcons, which are classified as endangered, have also been observed. In addition, other
species that are candidates for listing as threatened or endangered by the U.S. Fish and
Part II 5-2
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Wildlife Service may either inhabit or migrate through the area. Candidate species that may frequent the area
include ferruginous hawks, pygmy rabbits, Townsend's big-eared bats, burrowing owls, and loggerhead
shrikes.
The flora and fauna existing around CFA are representative of those found across the INEEL (Arthur
et al. 1984; Reynolds et al. 1986). Wildlife species present in and around the CFA include birds, mammals,
and reptiles that are associated with facilities, sagebrush-rabbitbrush, grasslands, and disturbed habitats,
deciduous trees and shrubs, and water (e.g., facility ponds and drainage areas). Both aquatic and terrestrial
species are potentially present. Sagebrush habitats in areas adjacent to facilities support a number of species
including sage grouse and pronghorn antelope (game species) and areas of grassland provide habitat for
species such as the western meadowlark (Sturnella neglectd) and mule deer (Odocoileus hemionus), also a
game species. Buildings, lawns, ornamental vegetation, and disposal/drainage ponds at WAG 4 are also used
by a number of species such as waterfowl, raptors, rabbits, mule deer, and bats. No areas of critical habitat
as defined in the 40 CFR Part 300 are known to exist in or around CFA.
5.4 Demography
The human populations potentially affected by INEEL activities include INEEL employees, ranchers
who graze livestock in areas on or near the INEEL, hunters on or near the site, residential populations in
neighboring communities, and highway travelers.
Nine separate facilities at INEEL, Figurel-1, include approximately 450 buildings and more than
2,000 other support facilities. Presently, the INEEL employs 8,348 contractor and government personnel.
Employee totals at INEEL locations include 250 at the Waste Management Facility; 1,049 at the CFA; 433 at
Test Area North; 511 at the Test Reactor Area; 622 at the Naval Reactors Facility; 1,201 at the Idaho Nuclear
Technology and Engineering Center; 732 at Argonne National Laboratory-West; and 193 within the remaining
site-wide areas, which include the Auxiliary Reactor Area. Approximately 3,231 INEEL employees occupy
numerous offices, research laboratories, and support facilities in Idaho Falls.
The INEEL is bordered by five counties: (1) Bingham, (2) Bonneville, (3) Butte, (4) Clark, and (5)
Jefferson (see Figure 5-1). The nearest communities to INEEL are Atomic City, located south of the INEEL
border on U.S. Highway 26; Arco, 11 km (7 mi) west of INEEL; Howe, west of INEEL on U.S. Highway
22/33; and Mud Lake and Terreton on the northeast border of INEEL. Other communities located near the
INEEL include Blackfoot and Shelley in Bingham County; Idaho Falls and Ammon in Bonneville County; Arco
in Butte County; and Rigby in Jefferson County.
5.5 Cultural Resources
Over the past two decades, detailed inventories of cultural resources at some parts of the INEEL
have been assembled. Initial surveys have been focused on areas within and around major operating facilities
at the Site. Proposed future construction areas also have been examined. As of January 1, 1998,
approximately 6.6% (37,681 acres) of the 2,305 km2 (890 mi2) comprising the INEEL has been
systematically surveyed for archaeological resources and 1,839 archaeological localities have been identified.
The inventory includes prehistoric resources representing a span of approximately 12,000 years, as well as
historic resources representing the last 150 years. Cultural resources on INEEL also include a number of
more recent buildings, structures, and objects that have made significant contributions to the broad patterns
of American history through the Site's association with World War II,
Part II 5-3
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Figure 5-1. Counties surrounding the INEEL.
Part II 5-4
-------
the Cold War, and important advances in nuclear science and technology. One INEEL facility, Experimental
Breeder Reactor I, is recognized as a national historic landmark.
Local Native American people, particularly the Shoshone-Bannock tribal members of Fort Hall,
Idaho, view all of the prehistoric sites on the INEEL as ancestral and of traditional cultural significance. A
variety of natural features are also important to Native Americans. Native American burial sites, though rare,
are of special concern on INEEL.
5.6 Conceptual Site Models
The conceptual site models used in the OU 4-13 Comprehensive RI/FS to evaluate potential risk from
surface soil, underground storage tanks and buried waste, and liquid discharge are shown in Figures 5-2
through 5-4. The models illustrate hypothetical exposure routes to current and future workers, future
residents, and ecological receptors. Future occupational and residential scenarios are assumed to begin in 100
years. The models are based on land-use assumptions and the exposure assessment conducted for the OU
4-13 RI/FS. The human health conceptual site models (Figures 5-2 through 5-4) are based on the following
land use assumptions:
• The INEEL will remain under government ownership and institutional control for at least the
next 100 years (i.e., until the year 2095, 100 years from the date the INEEL land-use
projections were established [DOE-ID 1996]).
• No residential development will occur within the INEEL boundaries within the institutional
control period.
The complete conceptual site model for the ecological risk assessment (Figure 5-5) reflects the
locations of contaminated media to which ecological receptors may be exposed. For a more detailed
conceptual site model, see Section 7 of the OU 4-13 Comprehensive RI/FS (DOE-ID 1999a).
Part II 5-5
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Primary
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Primary
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-------
Primajy
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5-3. Ctwiccplual si'*" model for underground MOCH^C lanks niul buije*! waste shes at f FA-
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Figure 5-4, Coiiceplunl iile mtxJel Tor liquid discharge- silcs
-------
Figure 5*5, Complete conceptual siic nuidcl fin- ccnlngical rcteplurs at WAO 4.
-------
6. CURRENT AND POTENTIAL SITE AND RESOURCE USES
The INEEL has an area of approximately 2,305 km2 (890 mi2) or (230,266 ha [569,000 acres]).
Approximately 98% of this land, has not been impacted by INEEL operations. The land use at the INEEL was
evaluated in the Comprehensive Facility and Land Use Plan (CFLUP) (DOE-ID 1996). Land use on the entire
INEEL is restricted. Though public highways traverse the INEEL, public access beyond the highway
right-of-way is not allowed. Access to facilities requires proper clearance, training, or escort. There are
specific controls in place to limit exposure to sites. Current and projected land use as described in the report
is summarized below.
6.1 Current Land Use
The land within INEEL is classified as industrial or mixed use by the U. S. Bureau of Land
Management (BLM) (DOE-ID 1996). The INEEL land use consists of wildlife management, government
industrial operations, and waste management. As shown in Figure 6-1, large tracts of land are reserved as
buffer and safety zones around the boundary of the INEEL. Operations are generally restricted to the INEEL
proper. Aside from the operational facilities, the land within INEEL proper is largely undeveloped and used
for environmental research, ecological preservation, and sociocultural preservation. No residential areas are
located within the INEEL boundaries.
The buffer surrounding INEEL consists of 1,295 km2 (500 mi2) of grazing land (DOE-ID 1996)
administered by the BLM. Grazing areas around the INEEL support cattle and sheep, especially during dry
conditions. Controlled hunts of game animals managed by the Idaho Department of Fish and Game are
permitted on INEEL and within the buffer zone during selected years (DOE-ID 1996). Hunters are allowed
access to an area that extends 0.8 km2 (0.5 mi) inside INEEL boundary on portions of the northeastern and
western borders of INEEL (DOE-ID 1996).
State Highways 22, 28, and 33 cross the northeastern portion of the Site. U.S. Highways 20 and 26
cross the southern portion (Figure 1-1). As much as 145 km (90 mi) of paved highways used by the general
public and 23 km (14 mi) of Union Pacific Railroad tracks traverse the southern portion of the Site (DOE-ID
1996). A government-owned railroad passes from the Union Pacific Railroad at the CFA to the Naval
Reactors Facility. An additional spur runs from the Union Pacific Railroad to the Radioactive Waste
Management Complex.
In the counties surrounding the INEEL, approximately 45% of the land is used for agriculture, 45%
is open land, and 10% is urban (DOE-ID 1996). Land use includes grazing, livestock production, and dairy
farming (EG&G 1984). Major crops produced on land surrounding INEEL are wheat, alfalfa, barley,
potatoes, oats, and corn. Sugar beets are grown within 64 km (40 mi) of INEEL in the vicinity of Rockford,
Idaho. The land surrounding the INEEL is owned by either private individuals or the U.S. Government. The
BLM administers the government land on INEEL (DOE-ID 1996).
6.2 Future Land Use
The future land use within the INEEL is projected to remain essentially the same as the current use:
research facilities within the INEEL boundaries, agriculture, and open land surrounding the INEEL (Figure 6-
1). The CFLUP was developed using a stakeholder process that involved a public participation forum, a
public comment period, and the INEEL CAB. The public participation forum included members from local
counties and cities, Shoshone-Bannock Tribes, BLM, DOE, U.S. Forest Service, U.S. National Park Service,
Idaho Department of Transportation, Idaho Fish and Game, and eight businesses, education,
Part II 6-1
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en
en
BUTBSU tA Land Manage merit {grazing}
National Fores! land
Private Sand [
Pdvati tad
State land
IN EEL bur 9: ±Q w (grazing)
3LM Sand managac by DOE-ID
:NEEL preferred devgfe"i6fit comdore
V I
MH.P*
Figure 6-1. Land ownership distribution in the vicinity of the INEEL and on-INEEL areas open for
permitted grazing.
Part II 6-2
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and citizen organizations. EPA and IDHW participated in an ex officio capacity. Following review and
comment by the public participation forum, the CFLUP underwent a 30-day public comment period and was
subsequently submitted to the INEEL CAB for review and recommendations. No recommendations for
residential use of any portions of the INEEL within the next 100 years have been received to date.
Land use projections are based on the following assumptions and factors:
• The INEEL will remain under government management and institutional control for at least
the next 100 years
• DOE projections for the future of its national laboratory research and development activities
and nuclear reactor programs
• The presence of active industrial and research facilities
• The presence of an industrial infrastructure
• The likely inability to "green field" (e.g., return to natural state with unrestricted land-use)
the industrial complex without total removal of waste
• No nonindustrial land use within the INEEL, other than grazing
• Recommendations from the INEEL CAB and other stakeholders about future use
assumptions.
Land use on the INEEL is anticipated to include unrestricted industrial uses, government-controlled
industrial uses, unrestricted areas, controlled areas for wildlife management and conservation, and waste
management areas. No residential development will be allowed within the INEEL boundaries, and no new
major private developments (residential or nonresidential) on public lands are expected in areas adjacent to the
Site. Grazing will be allowed to continue in the buffer area (DOE-ID 1996).
Regardless of the future use of the land now occupied by the INEEL, the federal government has an
obligation to provide adequate institutional controls (i.e., limited access) to areas that pose significant health
or safety risks until those risks diminish to acceptable levels (see Section 12.2). Fulfillment of this obligation
is contingent on the continued viability of the federal government and on congress appropriating sufficient
funds to maintain the institutional controls for as long as necessary.
6.3 Groundwater Use
Current use of SRPA groundwater at CFA is for drinking and irrigation. Groundwater is extracted
from two production wells at CFA (CFA-1 and CFA-2). A drinking water program was initiated in 1988 to
monitor drinking water wells on the INEEL for compliance with drinking water system standards as
established by EPA, the State of Idaho, and applicable DOE orders.
6.4 Groundwater Classification and Basis
The eastern portion of the aquifer was granted sole source status by the EPA on October 7, 1991 (56
FR 50634). The definition of a sole source aquifer is that more than 50% of the people who live above the
water use it for beneficial use. Idaho water quality standards are dictated primarily by the
Part II 6-3
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recently promulgated Idaho Groundwater Quality Rule and the Idaho Water Quality Standards and
Wastewater Treatment Requirements. The National Primary Drinking Water Regulations can also apply
(IDAPA 16.01)
Three categories of protectiveness apply to the aquifer and its associated resources under Idaho
regulations: (1) Sensitive Resources; (2) General Resources; and (3) Other Resources. Because no previous
action to categorize the SRPA under Idaho regulations has occurred, the aquifer defaults to the "General
Resources" category. General Resource aquifers are protected to ensure that groundwater quality is not
jeopardized. Idaho's groundwater standards incorporate federal radiation exposure and drinking water
standards (10 CFR 20, 1999, Appendix B, Table 2; 40 CFR 141, 1998; and 143, 1998).
Part II 6-4
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7. BASELINE RISK ASSESSMENT METHODOLOGY
The Baseline Risk Assessment (BRA) developed for WAG 4 (DOE-ID 1999a) evaluated the risk
potential associated with contaminated media at CFA. The evaluation simulated a No Action alternative,
meaning that mitigative measures to reduce risk were not considered. Methodologies implemented to evaluate
the baseline human health and ecological risks are outlined below, followed by a summary of the results.
Three sites were found to pose unacceptable risk to human health and the environment. For those three sites,
components of the risks assessment specific to the selected remedies, such as contaminants of concern,
contaminant concentrations, and risk estimates, are presented in detail in Section 8.
7.1 Human Health Risk Evaluation Summary
The human health risk assessment approach used in the BRA was based on the EPA Risk Assessment
Guidance for Superfund (EPA 1989, 1992a), INEEL Track 2 Guidance (DOE-ID 1994), and the INEEL
cumulative risk assessment guidance protocol (INEEL 1995b). The tasks associated with development of the
human health risk assessment included the following:
• Data evaluation
• Exposure assessment
• Toxicity assessment
• Risk characterization
• Qualitative uncertainty analysis.
These tasks are described in the subsections below.
7.1.1 Data Evaluation
Data evaluation tasks that were completed as part of the BRA included site screening, contaminant
screening, and development of data sets for use in the-risk assessment. The screening processes were
designed to be conservative so that only sites and contaminants that clearly do not pose an unacceptable risk
to human health and the environment are eliminated.
Initial site screening consisted of a review of previous risk assessments conducted for WAG 4 sites
identified in the FFA/CO. As a result of the site screening, 19 of the individual sites, including the sites
identified in the FFA/CO, were retained for quantitative risk assessment in the comprehensive BRA. The
remaining sites either exhibited no risk potential (e.g., the site had no source of contamination) or a risk
potential sufficiently below threshold values to preclude a significant contribution to cumulative risk.
Individual sites with risk estimates greater than or equal to 1E-06 or hazard indices greater than or equal to 1
were retained.
Site screening also involved a CFA Facilities Analysis that evaluated all operating, abandoned and
demolished non-CERCLA facilities proximal or co-located to WAG 4 CERCLA sites. The analysis assessed
their potential impacts to cumulative risk estimates to ensure that all historical releases were identified and
assessed. The analysis included a review of past and present operational activities at CFA, existing facilities
and structures, and management control procedures for mitigating the effects of future
Part II 7-1
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environmental releases of contaminants. No facilities or structures were identified in the facilities analysis that
would affect the cumulative risk calculations at WAG 4.
Contaminant screening consisted of comparing maximum detected concentrations to INEEL
background concentrations (INEEL 1996a) and EPA risk-based concentrations (RBCs) (EPA 1995, 1997a).
The Risk Based Concentrations (RBC) used to screen contaminants were calculated using the soil ingestion,
soil inhalation, and external exposure pathways for a calculated lifetime cancer risk of 1E-06 or a Hazard
Quotient (HQ) of 1. The most restrictive RBC was compared to the maximum detected soil concentration of
each contaminant of concern. The most contaminants that exceeded the screening criteria were identified as
contaminants of potential concern and retained for quantitative analysis in the BRA. Potential exposure routes
were also identified in conjunction with contaminant screening using the conceptual site models (Section
5.6).
All sampling data collected at WAG 4 sites were evaluated to determine whether the data were
appropriate and adequate for use in the BRA. This evaluation was conducted generally in accordance with
EPA guidance (EPA 1992a). As a result of the screening process, 19 of the individual sites including the sites
identified in the FFA/CO, were retained for quantitative risk assessment in the BRA.
7.1.2 Exposure Assessment
The exposure assessment quantities the receptor intake of contaminants of potential concern for
those exposure pathways that may cause adverse effects. The assessment consists of estimating the
magnitude, frequency, duration, and exposure route of contaminants to receptors. The following parameters
are considered in estimating exposure assessment:
• Exposed populations
• Complete exposure pathways
• Contaminant concentrations at the points of exposure for the complete exposure pathways
• Intake rates
• Intake factors.
Both populations and exposure pathways evaluated in the WAG 4 comprehensive human health BRA
are illustrated in the conceptual site models (Figure 5-2 through 5-4). Land-use assumptions and projections
discussed in Section 6 were used to identify exposure scenarios, pathways, and routes.
• Exposure scenarios
Occupational
Residential intrusion
• Exposure pathways
Groundwater pathway (cumulative)
Air pathway (cumulative)
Soil pathway
Part II 7-2
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• Exposure routes
Soil ingestion
Inhalation of fugitive dust
Inhalation of volatiles
External radiation exposure
Dermal absorption from soil (organics and arsenic only)
Ground-water ingestion (residential scenario only)
Ingestion of homegrown produce (residential scenario only)
Dermal absorption of contaminants in groundwater (residential scenario only)
Inhalation of volatiles from indoor use of groundwater (residential scenario only).
Contaminant concentrations at the points of exposure for complete exposure pathways were
calculated using upper confidence limits (UCLs) derived from analytical data. If sufficient data were not
available for calculating UCL concentrations, the maximum detected concentration was used. For
radioactive contaminants, radioactive decay was incorporated into the intake calculations. No degradation
mechanisms for reducing the concentrations of organic or inorganic contaminants over time were
considered.
Groundwater fate and transport modeling was used to predict the maximum contaminant
concentrations that could occur in the aquifer from leaching and transport of nonradionuclide and
radionuclide contaminants at WAG 4. The GWSCREEN model was used to simulate the potential release
of contaminants from the release sites and the transport of the contaminants through the vadose zone to
the aquifer.
To calculate intake rates, default intake factors from the EPA guidance (EPA 1989, 1991, and
1992a) and Track 2 guidance for the INEEL (DOE-ID 1994) were used. In conjunction with conversion
factors and site-specific contaminant concentrations, these values were used to calculate contaminant
intakes. The specific exposure parameters used for each receptor and exposure pathway are given in the
OU 4-13 RI/FS (DOE-ID 1999a). Generally, occupational scenarios reflect workers exposed to
contaminants for 8 hours/day, 250 days/year for 25 years and residential scenarios reflect exposures to
contaminants for 24 hours/day, 350 days/year, for 30 years. Standard values were used to simulate the
human body (e.g., mass, skin area, inhalation rates, and soil ingestion rates).
To satisfy the objective of the comprehensive risk assessment, risks produced through the air
and groundwater exposure pathways were analyzed cumulatively. Cumulative risks were estimated by
calculating one risk number for each contaminant of potential concern (COPC) in air and groundwater
exposure routes (e.g., inhalation of fugitive dust and ingestion of groundwater) for each collection of
sites in close proximity to one another. Analyzing risks for the air and groundwater pathways in a
cumulative manner was necessary because contamination from all sites within an area can contribute to
local air and groundwater contaminant concentrations. Conversely, individual sites within a WAG are
typically isolated from one another relative to the soil pathway exposure routes (e.g., external exposure
and
Part II 7-3
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ingestion of soil). As a result, site-specific soil pathway exposures were analyzed. However, the BRA is
comprehensive because it evaluates risks from all known sites within WAG 4, and it is cumulative
because risks from multiple sites are evaluated in the air and groundwater exposure pathways.
7.1.3 Toxicity Assessment
The toxicity assessment evaluated the relationship between intake of a substance and incidence
of an adverse health effect in the exposed population. Toxicity assessments evaluate the results from
studies with laboratory animals or from human epidemiological studies. These evaluations were used to
extrapolate from high levels of exposure, for which adverse effects are known to occur, to low levels of
environmental exposures, for which effects could be postulated. Results of these extrapolations were
used to establish quantitative indicators of toxicity.
Health risks from all routes of exposure were characterized by combining the chemical intake
information with numerical indicators of toxicity (i.e., slope factors for carcinogens and reference doses
for noncarcinogens). Toxicity constants used in the BRA were obtained from several sources. The
primary source of information is the EPA online Integrated Risk Information System (IRIS) (EPA
1997b). The IRIS database contains only those toxicity constants that have been verified by EPA work
groups. The IRIS database is updated monthly and supersedes all other sources of toxicity information.
If the necessary data are not available in IRIS, EPA Health Effects Assessment Summary Tables (EPA
1994a) are used. The toxicity constant tables are published annually and updated approximately twice per
year. The Health Effects Assessment Summary Tables contain a comprehensive listing of provisional risk
assessment information that has been reviewed and accepted by individual EPA program offices, but has
not had enough review to be recognized as high-quality, agency-wide information (EPA 1994a). Toxicity
profiles for the contaminant of concern (COC) addressed in the selected remedies to mitigate
unacceptable risk are presented below.
7.1.3.1 Lead. Lead is classified as a metal. No critical effects due to exposures to lead have
been reported. However, many organs and systems are adversely affected by lead exposure. The major
target organs and systems are the central nervous system, the peripheral nerves, the kidney, the
gastrointestinal system, and the blood system (Sittig 1985). Anemia can be an early manifestation of lead
poisoning. Other early effects of lead poisoning can include decreased physical fitness, fatigue, sleep
disturbance, headache, aching bones and muscles, digestive symptoms, abdominal pains, and decreased
appetite. The major central nervous system effects can include dullness, irritability, headaches, muscular
tremors, inability to coordinate voluntary muscles, and loss of memory. The most sensitive effect for
adults in the general population may be hypertension (Amdur, Doull, and Klaassen 1991).
Ingestion and inhalation of lead have the same effects on the human body. Large amounts of lead
can result in severe convulsions, coma, delirium, and possibly death. A high incidence of residual
damage, similar to that following infections or traumatic damage or injury, has been observed from
sustained exposure to lead. Most of the body burden of lead can be in the bone (ATSDR 1990). Lead
effects in the peripheral nervous system are primarily manifested by weakness of the exterior muscles
and sensory disturbances. Lead also has been shown to adversely affect sperm and damage other parts
of the male reproductive system (ATSDR 1990). Dermal absorption of inorganic lead compounds was
reported to be much less significant than absorption by inhalation or oral routes of exposure (ATSDR
1990).
Behavioral effects of lead exposure are a major concern, particularly in children. Exposure to
lead can cause damage to the central nervous system, mental retardation, and hearing impairment in
children. Levels of exposure that may have little or no effect on adults can produce important
biochemical alterations in growing children that may be expressed as altered neuropsychological behavior
(Martin 1991).
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Though the ability of lead to cause cancer in humans has not been shown, EPA has classified
lead as a probable human carcinogen through both the ingestion and inhalation routes of exposure. Lead
classification was based on the available evidence of cancer from animal studies. Rats ingesting lead
demonstrated statistically increased incidence of kidney tumors (ATSDR 1990). According to some
epidemiological studies, lead workers have an increased incidence of cancer. Data used in these studies
are considered inadequate to demonstrate or refute the carcinogenicity of lead to humans. The EPA has
not established toxicity values for lead.
7.1.3.2 Cesium-137. The radioactive isotope Cesium-137 is a fission product produced by
nuclear reactors and nuclear weapons detonations. Cesium-137 is rapidly absorbed into the bloodstream
and is distributed throughout the active tissues of the body. Metabolically, cesium-137 behaves as an
analog of potassium and is distributed throughout the body. Its daughter, Barium-13 7m, an isomer, is an
energetic beta and gamma radiation source and emits a 0.662-megaelectron volt gamma ray. Absorbed
cesium-137 results in essentially whole-body irradiation (Amdur, Doull, and Klaassen 1991). The
radioactive half-life of cesium-137 is 30 years. Its biological half-life in adults is 50 to 150 days, and in
children is 44 days. The whole body is the critical organ for cesium-137 exposure.
7.1.3.3 Mercury. The chemistry of mercury in the environment is complex. It has various
oxidation states, biotic and abiotic methylation and demethylation processes, complexation with organic
and inorganic ligands, and differential solubility and volatility forms. Speciation is a major determinant of
the fate, bioavailability, absorption, and toxicologic characteristics of mercury compounds.
Although the generally more toxic organic forms of mercury, such as methylmercury, are
unlikely to persist in the environment, they may form in biotic tissues and are known to biomagnify
through ecosystems, particularly aquatic systems (Wren 1986, Scheuhammer 1987).
Because of its chemical stability and lipophilicity, methylmercury readily penetrates the blood-
brain barrier. Thus, the central nervous system is a major target organ in both mammals and birds.
However, adverse reproductive effects have been reported. Methylmercury can be converted to
inorganic mercury in muscle tissues. The homolytic cleavage of the mercury-carbon bond leads to
generation of reactive intermediates, e.g., methyl and metal radicals, which cause cellular damage (Wren
1986; Scheuhammer 1987; Manzo et al., 1992). The inhalation "no observed adverse effects level"
(NOAEL) and "lowest observed adverse effects level" (LOAEL) are 0.000 and 0.009 mg/m3,
respectively (EPA 1997a).
7.1.4 Risk Characterization
The characterization of risk involves combining results of the toxicity and exposure assessments
to estimate health risks. These estimates are either a comparison of exposure levels with appropriate
toxicity criteria for noncarcinogens or an estimate of the lifetime cancer risk associated with a particular
intake for carcinogens. The nature and weight of evidence supporting the risk estimate and the magnitude
of uncertainty surrounding the estimate are also considered in risk assessment.
To determine human health risks, contaminant intakes are compared to the applicable
contaminant toxicity data. The complete results of BRA risk characterization process, including risk
estimates for each of the retained sites, are presented in Appendix D of the RI/FS report (DOE-ID
1999a). The generalized equations for calculating carcinogenic risk and noncarcinogenic hazard quotients
from contaminant intake and toxicity information are provided in the following subsections.
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7.1.4.1 Carcinogenic Health Effects. The following equations are used to obtain numerical
estimates, (i.e., unitless probability) of lifetime cancer risks. The risk probability is the product of intake
and slope factor, as follows, in Equation (7-1):
Risk = Intake x SF (7-1)
where
Risk = potential lifetime cancer risk (unitless)
Intake = chemical intake (mg/kg/day), or radionuclide intake (pCi)
SF = slope factor, for chemicals (mg/kg/day)"1, or radionuclides (pCi)"1.
The linear low-dose equation shown in Equation (7-1) is valid at risk levels lower than 1E-02. In
accordance with EPA guidance (EPA 1989), risks that are greater than 1E-02 are calculated using the
following one-hit equation, Equation (7-2):
Risk = 1 - exp(-Intake x SF) (7-2)
where
Risk = potential lifetime cancer risk (unitless)
Intake = chemical intake (mg/kg/day), or radionuclide intake (pCi)
SF = slope factor: for chemicals (mg/kg/day)"1 or radionuclides (pCi)."1
To develop a total risk estimate for a given rate at a given site, cancer risks are summed across
all potential carcinogens at the site as shown in Equation (7-3):
(7-3)
where
Riskf = total cancer risk, expressed as a unitless probability for a given exposure and a given
route
Riskt = risk estimate for the i* contaminant for the route.
Similarly, risk values for each exposure route are summed to obtain the total cancer risk for
each site.
7.1.4.2 Noncarcinogenic Effects. Health risks associated with exposure to individual
noncarcinogenic compounds are evaluated by calculating the hazard quotient (HQ). The HQ is the ratio
of the intake rate to the reference dose, as shown in Equation (7-4):
HQ = Intake /RfD (7-4)
where
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HQ = noncarcinogenic hazard quotient (unitless)
Intake = chemical intake (mg/kg/day)
RfD = reference dose (mg/kg/day).
Hazard indices are calculated by summing hazard quotients for each chemical across all
exposure routes. If the hazard index for any contaminant of potential concern (COPC) exceeds unity,
potential health effects may be a concern from exposure to the contaminant of potential concern. The
hazard index is calculated using Equation (7-5):
T-, Intake
(7-5)
where
HI = hazard index for a given COPC (unitless)
Intake ,. = exposure level (intake) for the i* COPC (mg/kg/day)
RfD, = reference dose for the i* COPC (mg/kg/day).
In Equation (7-5), intake and reference doses are expressed in the same units and represent the
same exposure time period. Hazard indices may be summed across multiple contaminants to develop a
total hazard index for a site.
7.1.5 Qualitative Uncertainty Analysis
Risk assessment results depend on the methodologies applied to develop risk estimates. These
analysis methods were developed over a period of several years by INEEL risk management and risk
assessment professionals to provide realistic, yet conservative estimates of human health risks.
Nonetheless, if different risk assessment methods had been used, the BRA would have likely produced
different risk assessment results. To ensure the risk estimates are conservative (i.e., generate
upper-bound risk estimates), health protective assumptions that tend to bound the plausible upper limits
of human health risks were applied throughout the BRA. Therefore, risk estimates that may be calculated
by other risk assessment methods are not likely to be significantly higher than estimates developed for the
OU 4-13 RI/FS.
Uncertainty factors are present in all four stages of risk analysis (i.e., data collection and
evaluation, exposure assessment, toxicity assessment, and risk characterization). Uncertainties associated
with parameters used in the risk assessment are listed in Table 7-1. The conservative assumptions and
uncertainties in risk estimates for the three sites identified for remediation are summarized in Table 7-2.
Qualitative consideration of the collective impact of all the assumptions indicates that risks are more likely
to be overestimated than underestimated.
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Table 7-1. BRA human health assessment uncertainty factors.
Uncertainty factor
Effect of uncertainty
Comments and Assumptions
Source term assumptions
Natural infiltration rate
Moisture content
Water table fluctuations
Mass of contaminants in soils is
estimated by assuming a uniform
contamination concentration in the
source zone
Plug flow assumption in groundwater
transport
May overestimate risk
May overestimate risk
May overestimate or underestimate risk
May slightly overestimate or
underestimate risk
May overestimate or underestimate risk
Could overestimate or underestimate risk
All infiltration into WAG 4 is assumed
to occur through the contaminated sites
No migration of contaminants from the
soil source prior to 1994
Contaminant source terms assumed to
be lognormally distributed
Will overestimate risk
Could overestimate or underestimate risk
Could overestimate risk
All contaminants are assumed to be completely available for transportation away from
the source zone. In reality, some contaminants may be chemically or physically bound to
the source zone and unavailable for transport.
A conservative value of 10 cm/year was used for this parameter.
Soil moisture contents vary seasonally in the upper vadose zone and may be subject to
measurement error.
The average value used is expected to be representative of the depth over the 30-year
exposure period.
There is a possibility that most of the mass of a contaminant at a site may exist in a
hotspot that was not detected by sampling. If this condition existed, the mass of the
contaminant used in the analysis might be underestimated. However, 95% UCLs or
maximum detected contamination were used for all mass calculations, and these
concentrations are assumed to exist at every point in each waste site; therefore, the mass
of contaminants used in the analysis is probably overestimated.
Plug flow groundwater models will likely estimate a greater mass of contaminants will
be transported to the aquifer than would occur under natural conditions, with respect to
concentrations because dispersion is neglected, and mass fluxes from the source to the
aquifer differ only by the time delay in the unsaturated zone (the magnitude of the flux
remains unchanged). For nonradiological contaminants, the plug flow assumption is
conservative because dispersion as completed in the models is now allowed to dilute the
contaminant groundwater concentrations. For radionuclides, the plug flow assumption
may or may not be conservative. Based on actual travel time, the radionuclide
groundwater concentrations could be overestimated or underestimated because a longer
travel time allows for more decay. If the concentration decreases because the travel time
delay is larger than the neglected dilution from dispersion, the model will not be
conservative.
Infiltration that normally occurs between contaminated sites is assumed to be
concentrated on contaminated sites. This assumption results on a probable overestimate
of risk because more water is available in the model calculations to carry contaminants to
the aquifer.
The effect of not modeling contaminant migration from the soil before 1994 is dependent
on the contaminant half-life, radioactive in growth, and mobility characteristics.
If sampling data at a given site fits a normal distribution rather than a lognormal
distribution, the 95% UCL of the near concentrations calculated for the site could be as
much as 50% too high.
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Table 7-1. (continued).
Uncertainty factor
Effect of uncertainty
Comments and Assumptions
Chemical form assumptions
Exposure scenario assumptions
Could overestimate or underestimate risk
May overestimate risk
Exposure parameter assumptions
Receptor locations
May overestimate risk
May overestimate risk
May overestimate or underestimate risk
For the groundwater pathway analysis,
all contaminants are assumed to be
homogeneously distributed in a large
mass of soil
The entire inventory of each contaminant May overestimate risk
is assumed to be available for transport
along each pathway
Exposure duration
May overestimate risk
Noncontaminant-specific constants (not May overestimate risk
dependent on contaminant properties)
In general, the methods and inputs used in contaminant migration calculations, including
assumptions made about the chemical forms of contaminants, were chosen to err on the
protective side. All contaminant concentration and mass are assumed available for
transport. This assumption results in a probable overestimate of risk.
The likelihood of future scenarios has been qualitatively evaluated as follows: resident -
improbable; industrial - credible. The likelihood of future on-INEEL residential
development is small. If future residential use of this site does not occur, then the risk
estimates calculated for future on-INEEL residents are likely to overestimate the true risk
associated with future use of this site.
Assumptions regarding media intake, population characteristics, and exposure patterns
may not characterize actual exposures.
Groundwater ingestion risks are calculated for a point at the downgradient edge of an
equivalent rectangular area. The groundwater risk at this point is assumed to be the risk
from groundwater ingestion at every point within the WAG 4 boundaries. Changing the
receptor location will affect only the risks calculated for the groundwater pathway
because all other risks are site-specific or assumed constant at every point within the
WAG 4 boundaries.
The total mass of each COPC is assumed to be homogeneously distributed in the soil
volume beneath the WAG 4 retained sites. This assumption tends to maximize the
estimated groundwater concentrations produced by the contaminant inventories because
homogeneously distributed contaminants would not have to travel far to reach a
groundwater well drilled anywhere within the WAG 4 boundary. However groundwater
concentrations may be underestimated for a large mass of contamination located in a
small area with a groundwater well drilled directly downgradient.
Only a portion of each contaminant's inventory is actually transported by each pathway.
The assumption that an individual will work or reside at a contaminated site for 25 or 30
years is conservative. Short-term exposures involve comparison to subchronic toxicity
values, which are generally less restrictive than chronic values.
Conservative or upper limit values were used for all parameters incorporated into intake
calculations.
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Table 7-1. (continued).
Uncertainty factor
Effect of uncertainty
Comments and Assumptions
Exclusion of some hypothetical
pathways from the exposure scenarios
May underestimate risk
Poorly defined dermal absorption factor May underestimate risk
values for most WAG 4 contaminants
Model does not consider biotic decay May overestimate risk
Occupational intake value for inhalation Slightly overestimates risk
Use of cancer SFs
Toxicity values are derived primarily
from animal studies
Toxicity values are derived primarily
from high doses; most exposures are at
low doses
Toxicity values and classification of
carcinogens
Lack of SFs
Lack of RfDs
Risk/HQs are combined across
pathways
May overestimate risk
May overestimate or underestimate risk
Exposure pathways are considered for each scenario and estimated only if the pathway is
either incomplete or negligible compared to other evaluated pathways.
A lack of absorption factor values for most WAG 4 contaminants may mean that dermal
absorption risks are higher than expected. The possibility of unacceptable dermal
absorption from soil risks being produced by WAG 4 contaminants is considered to be
unlikely.
Biotic decay would tend to reduce contamination over time.
Standard exposure factors for inhalation have the same value for occupational as for
residential scenarios. The time of exposure is assumed to be the same in the risk
calculations for occupational workers as it is for residents.
Nonradionuclide SFs are associated with upper 95th percentile confidence limits and
radionuclide SFs are central estimates of cancer incidence per unit intake. They are
considered unlikely to underestimate true risk.
Extrapolation from animal to humans may induce error caused by differences in
absorption, pharmacokinetics, target organs, enzymes, and population variability.
May overestimate or underestimate risk Assumes linearity at low doses. Tends to have conservative exposure assumptions.
May overestimate or underestimate risk
May underestimate risk
May underestimate risk
May overestimate risk
Not all values represent the same degree of certainty. All are subject to change as new
evidence becomes available.
COPCs without SFs, may or may not be carcinogenic through the oral pathway.
COPCs without RfDs may or may not have noncarcinogenic adverse effects.
Not all of the COPC inventory will be available for exposure through all applicable
exposure pathways.
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Table 7-2. Summary of source-term uncertainties site with selected remedies.
ID No.
Release Sites
Source, Term Uncertainties and/or Assumptions
Pond (CFA-674)
CFA-04
Exposure point concentrations used for depth interval and volume-weighted concentrations are based
on the 95% UCL or maximum detected concentration, whichever is less, instead of average
(arithmetic mean) concentrations. The area of contamination is assumed to exist uniformly across the
site, even though only two of the six COPCs were detected in 100% of the site-wide samples. The
other COPCs were detected in at least 48.0% of the samples. The area of contamination is assumed to
exist uniformly across the site. Contamination is assumed to exist down to 5.5 m (18 ft), even though
positive detections of chemicals in the vadose zone are reported only to a depth of 2.4 m (8 ft bgs).
The depth of contamination is based on the assumption that mobility of dissolved phase chemicals in
the vadose zone (i.e., waste water) at CFA-04 is 3 m (10 ft). This assumption is made to ensure that
potential risks from exposures at CFA-04 are not underestimated (Section 8). These assumptions
may cause the calculated risks at the site to be overestimated.
CFA-08
Sewage Plant Drainfield
CFA-10
Transformer Yard
Exposure point concentrations used for depth interval and volume-weighted concentrations are based
on the 95% UCL or maximum detected concentration, whichever is less, instead of average
(arithmetic mean) concentrations. Of the nine calculated site-specific exposure point concentrations,
seven are based on the maximum detected concentration. The area of contamination is assumed to
exist uniformly across the drainfield, even though site-wide detection frequencies for each of the three
COPCs are no greater than 72.3%. Contamination is assumed to exist at 10 m (32 ft) bgs. The depth
to basalt is assumed to occur at 10 m (32 ft). It is assumed that COPCs will not migrate downward
beyond 10m (32 ft) due to the presence of basalt at 10 m (32 ft). These assumptions may cause the
calculated risks at the site to be overestimated.
Exposure point concentrations used for depth interval and volume-weighted concentrations are based
on the 95% UCL or maximum detected concentration, whichever is less, instead of average
(arithmetic mean) concentrations. The area of contamination is the area of the site based on process
knowledge that there was no specific pattern of waste disposal. The maximum depth of contamination
is 0.6 m (2 ft) bgs based on depths of measured concentrations. For purposes of evaluating
residential exposure pathways, contamination from 0 to 3.05 m (0 to 10 ft) soil interval is assumed.
This assumption is made to ensure that potential risks from exposures at CFA-10 are not
underestimated (Section 8). These assumptions may cause the calculated risks at the site to be
overestimated.
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7.2 Ecological Risk Evaluation Summary
Results of the WAG 4 ecological risk assessment (ERA) will be integrated into an INEEL-wide
evaluation of potential risks to ecological receptors as a component of the WAG 10 OU 10-04 ERA. The
WAG 4 ERA was conducted as outlined in the guidance for the INEEL.
An ecological site and contaminant screening was conducted to determine which sites and
contaminants would be subjected to further analysis in the comprehensive RI/FS. The screening was
completed and documented as part of the OU 4-13 Work Plan (DOE-ID 1997b). A site-by-site evaluation of
risks to ecological resources as a result of exposure to contaminants was developed in the RI/FS. The
evaluation included a review of screening completed in the Work Plan to ensure that sites or contaminants
were not inappropriately omitted from further evaluation. Complete details of the ERA are presented in
Sections 7 and 8 of the OU 4-13 RI/FS report (DOE-ID 1999a). The primary components of the ERA,
discussed below, include problem formulation, analysis, risk characterization, and transition to the
INEEL-wide ERA.
7.2.1 Problem Formulation
The goal of the problem formulation step is to investigate interactions between the stressor
characteristics (i.e., contaminant characteristics), the ecosystem potentially at risk, and potential ecological
effects (EPA 1992b). Site screening was conducted to identify the sites that could pose unacceptable risk.
Contaminant screening and data evaluation were conducted to identify COPCs and define exposure
point concentrations. For the most part, results of the data evaluation conducted for the human health BRA
were applied to the ERA. For those contaminants that were not retained for evaluation in the human health
risk assessment, additional data evaluation to support the completion of the ERA was performed.
Contaminant concentrations were compared to background concentrations and ecologically based screening
levels. All radioactive contaminants were eliminated on the basis of this comparison.
Site-specific data characterizing contaminant concentration in biota for the INEEL ERAs are sparse.
Consequently, the definition of assessment and measurement endpoints (i.e., ecological receptors) is primarily
based on pathway and exposure analyses. Pathway and exposure models for contaminated surface and
subsurface media were combined with a food web analysis to characterize the potential risks illustrated in the
complete ERA conceptual site model (see Figure 5-2).
7.2.2 Analysis
In the analysis component of the ERA, the likelihood and significance of an adverse reaction from
exposure to stressors were evaluated. Exposure assessment involved relating contaminant migration to
exposure pathways for ecological receptors. The behavior and fate of contaminants of potential concern in
the terrestrial environment were presented in a general manner because formal fate and transport modeling
was not conducted for the WAG ERA. The ecological effects assessment consisted of a hazard evaluation
and a dose-response assessment. The hazard evaluation involved a comprehensive review of toxicity data for
contaminants to identify the nature and severity of toxic properties. The doses from multiple media (surface
and subsurface soil) identified at WAG 4 were developed and used to assess potential risk to receptors.
Because dose-based toxicological criteria exist for few ecological receptors, it was necessary to develop
appropriate toxicity reference values (TRVs) for contaminants and functional groups at INEEL. A
semiquantitative analysis was used, augmented by qualitative information and professional judgment as
necessary.
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Exposures for each functional group, threatened or endangered species, and sensitive species were
estimated based on site-specific life history and when possible, feeding habits. Quantification of group and
individual exposures incorporated species-specific numerical exposure factors including body weight,
ingestion rate, and the fraction of diet composed of vegetation or prey, and soil consumed from the affected
area. Parameters used to model contaminant intakes by functional groups were derived from a combination
of parameters that produced the most conservative overall exposure for the group. Parameter values and
associated information sources are discussed in further detail in the RI/FS (DOE-ID 1999a). The
development of TRVs for those contaminants targeted for remediation based on unacceptable ecological risks
is described in the following subsections.
7.22.1 Lead. Lead is a ubiquitous trace constituent in rocks, soil, plants, water, and air. The
average concentration of lead in the earth's crust is 16 mg/kg (Eisler 1988). Lead has four stable isotopes
with the following percentages of occurrence: Pb-204 (1.5%), Pb-206 (23.6%), Pb-207 (22.6%), and
Pb-208 (52.3%). Lead occurs in four valence states: (1) elemental (Pb), (2) monovalent (Pb+), (3) divalent
(Pb+2), and (4) tetravalent (Pb+4). In nature, lead occurs mainly as Pb+2 and is oxidized to Pb.+4 Metallic lead
is relatively insoluble in hard water; some lead salts are somewhat soluble in water. Of the organoleads,
tetraethyllead and tetramethyllead are the most stable and are highly soluble in many organic solvents but are
fairly insoluble in water. Both undergo photochemical degradation in the atmosphere to elemental lead and
free organic radicals. Organolead compounds are primarily anthropogenic (Eisler 1988).
Lead is neither essential nor beneficial to living organisms. Lead affects the kidneys, blood, bone, and
the central nervous system. The effects of lead on the nervous system are both functional and structural.
Lead toxicity varies widely with the form and dose of administered lead. In general, organolead compounds
are more toxic than inorganic lead. A significant cause of mortality among regulatory waterfowl is ingestion
of lead shot.
Hatchlings of chickens, quail, and pheasants are relatively tolerant to moderate lead exposure (Eisler
1988). Dietary levels of 500 mg/kg had no effect on hatchling growth of these species, and levels at 2,000
mg/kg of lead had no effect on survival (Hoffman et al. 1985 as cited in Eisler 1988). For avian herbivores, a
TRV was estimated using a study of mallards (Dieter and Finley 1978). Altricial species are generally more
sensitive to lead than precocial species (Eisler 1988) of avian insectivores. An oral study using European
starlings (Osborn, Eney, and Bull 1983) was used to generate a TRV for trimethyllead chloride. Because
organic lead compounds are generally more toxic than inorganic lead, the toxicity quotients generated using
this TRV should be interpreted with caution. American kestrels (Falco sparverius) exposed to 50 mg/kg/day
of metallic lead in diets exhibited no effects on survival or reproductive success (Colle et al. 1980). Using
these studies, TRVs were developed for avian functional groups.
Studies of rats administered lead in drinking water (Kimmel et al. 1980), lead toxicity of calves
(Zmudzki et al. 1983), and lead toxicity of dogs (DeMayo et al. 1982) were used to develop TRVs for
mammalian receptors. A critical concentration of 2,000 mg/kg of lead in food on a dry weight basis for
reproduction was reported in a study on the toxicity of lead nitrate to the isopod (Porcellio scaber).
The recommended screening benchmark concentration for phytotoxicity in soil for lead of 50 mg/kg
was used as the TRV for terrestrial plants (Suter, Will, and Evans 1993).
7.2.2.2 Mercury. Mercury exists in the environment in three oxidation states: the elemental state,
+1 (mercurous) state, and +2 (mercuric) state. The factors that affect the predominant oxidation state in an
environment are the oxidation-reduction potential and the pH of the system. Particle-bound mercury can be
converted to insoluble mercury sulfide, which can be bioconverted into more soluble or volatile
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forms that may reenter the atmosphere or be taken up by biota and bioaccumulated in the terrestrial food
chain. Mercury forms many stable organic complexes that generally are more soluble in organic matter than
in water. Inorganic and organic particles strongly sorb mercury. Mercury can be transformed in the
environment by biotic and abiotic oxidation and reduction, bioconversion of organic and inorganic forms, and
photolysis. Mercury can be strongly concentrated by living organisms (Callahan et al. 1979). The chemistry
of mercury in the environment is complex, not only because of its various oxidation states, but also because
of biotic and abiotic methylation and demethylation processes, complexation with organic and inorganic
ligands, and the differential solubility and volatility of various forms. Because speciation is a major
determinant of the fate, bioavailability, absorption, and toxicological characteristics of mercury compounds,
lack of knowledge of the state of the mercury in INEEL soil is a large source of uncertainty in both exposure
assessment and TRV development.
Though the generally more toxic organic forms of mercury are unlikely to persist in the environment,
they (in particular, methylmercury) may be formed in biotic tissues and are known to biomagnify through
ecosystems, particularly aquatic systems (Wren 1986; Scheuhammer 1987). Thus, to ensure that mercury
TRVs for WAG ERAs are protective of receptors at all levels of ecological organization, TRVs are developed
from studies of the toxic effects of organic mercury. This measure is highly conservative and tends to result
in an overestimate of risks for receptors lower in the food web because the majority of mercury in soil and
plants (i.e., the majority of exposures to plants and soil-dwelling and herbivorous animals) is expected to be
inorganic.
Because of its chemical stability and lipophilicity, methylmercury readily penetrates the blood-brain
barrier. Therefore, the central nervous system is a major target organ in both mammals and birds. However,
reproductive effects have been reported at even lower doses. Methylmercury can be converted to inorganic
mercury in tissues. The homolytic cleavage of the mercury-carbon bond leads to generation of reactive
intermediates (e.g., methyl and metal radicals, which cause cellular damage) (Wren 1986; Scheuhammer
1987; Manzo et al. 1992).
The effects of mercury on avian herbivores, insectivores, and carnivores were evaluated. For
herbivores, the effects of organic mercury compounds on galliformes (e.g., domestic chickens, quail, and
pheasants) have been investigated by several groups. However, no study was reviewed that identified a
NOAEL. The LOAEL for relevant endpoints (i.e., reproductive success) of several similar studies was found
in a study of the effects of mercury on birds (Fimreite 1979). Reduced egg production, shell thickness, and
hatchability in pheasants that were fed seed, treated with organomercurial fungicide, were observed. This
study was selected over others because of its use of a wild species and lower dose levels. A TRV was
derived from this study.
Three goshawks were fed a diet of chickens that had eaten wheat dressed with an organomercurial
fungicide (Borg et al. 1970). Their tissues contained 10 to 40 ppm of mercury, mostly as methylmercury.
The hawks died after 30 to 47 days, and their total mercury intake was about 20 mg/bird.
Two studies examined the effects of subchronic methylmercury exposure on the reproductive
competence of male and female rats (Khera and Tabacova 1973; Khera 1973). The NOAEL identified for
both sexes was 0.25 mg/kg/day. Much less information is available about methylmercury toxicity to
herbivores. In a study of acute methylmercury toxicity in mule deer (Odocoileus hemionus), 17.88 mg/kg
was said to be the lethal dose of 50% of the exposed organisms (Eisler 1987). A number of studies have
examined the effects of chronic methylmercury ingestion on carnivorous mammals, particularly house cats
(e.g., Albanus et al. 1972; Charbonneau et al. 1976; Eaton, Secord, and Hewitt 1980) and mink (e.g.,
Aulerich, Ringer, and Iwamoto 1974; Wobeser, Neilson, and Schiefer 1976; Wren et al. 1987). The study of
the chronic toxicity of house cats was considered superior to other available studies because of its long
duration (two years), use of relatively large group sizes, detailed examination of endpoints,
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identification of both no-effect and effect levels, and administration of mercury via both contaminated fish
and addition to diet (Charbonneau et al. 1976).
A TRV of 0.3 mg/kg was assigned for mercury for terrestrial plants based on the toxicological
benchmark (Suter, Will, and Evans 1993).
7.2.3 Risk Characterization
Risk characterization is the final step of the ERA process. The risk evaluation determines whether
risk is indicated from the contaminant concentrations and the calculated dose for the INEEL functional
groups, threatened or endangered species, and species of concern. The risk characterization considers the
uncertainty inherent in the assessment. For a WAG ERA, the risk characterization step has two components:
a description of estimation of risk, and a summary of results.
Risk is estimated by comparing the calculated dose to the TRV. If the dose from the contaminant
does not exceed its TRV (i.e., if the HQ is less than 1.0 for nonradiological contaminants), adverse effects to
ecological receptors from exposure to that contaminant are not expected and no further evaluation of that
contaminant is required. Hence, the HQ is an indicator of potential risk. Hazard quotients are calculated using
Equation (7-6):
Dose
HQ - — (7-6)
where
HQ = hazard quotient (unitless)
Dose = from all media (mg/kg/day)
TRV = toxicity reference value (mg/kg/day).
HQs were derived for all contaminants, functional groups, threatened or endangered species, and
species of concern identified in WAG 4 for each site of concern. When information is not available to derive
a TRV, then an HQ cannot be developed for that particular contaminant and functional group or species
combination.
An HQ greater than the threshold value indicates that exposure to a given contaminant, at the
concentrations and for the duration and frequencies of exposure estimated in the exposure assessment, may
cause adverse health effects in exposed populations. However, the level of concern associated with exposure
may not increase linearly as the HQ values exceed the threshold value. Therefore, the HQs cannot be used to
represent a probability or a percentage because an HQ of 10 does not necessarily indicate that adverse effects
are 10 times more likely to occur than an HQ of 1. It is only possible to infer that the greater the HQ, the
greater the concern about potential adverse effects to ecological receptors.
In general, the significance of a HQ exceeding 1 depends on: (a) the perceived "value" (i.e.,
ecological, social, or political) of the receptor (or species represented by that receptor), (b) the nature of the
endpoint measured, and (c) the degree of uncertainty associated with the process as a whole. Therefore, the
decision to take no further action, order corrective action, or perform additional assessment must be
determined on a site-, chemical-, and species-specific basis. With the exception of threatened or endangered
species (EPA 1992b), the unit of concern in ERA is usually the population as opposed to the
Part II 7-15
-------
individual. Therefore, exceeding conservative screening criteria does not necessarily mean that significant
adverse effects to populations of receptors are likely.
Three sites, CFA-04, CFA-08, and CFA-10, with ecological HQs up to 30,000, 30, and 5,000
respectively, were retained for evaluation of remedial alternatives in the Comprehensive Feasibility Study
(DOE-ID 1999a). These sites also pose an unacceptable risk to human health. Six other sites will be evaluated
for ecological risk as part of the WAG 10 Sitewide assessment. These sites are CFA-01, CFA-02, CFA-05,
CFA-13, CFA-41, and CFA-43.
Principal sources of uncertainty apply to the use of data not specifically collected for ERA and in the
development of exposure assessment. Uncertainties inherent in exposure assessment are associated with
estimated receptor ingestion rates, selected acceptable HQs, estimated site usage, and estimated risk
assessment parameters (e.g., plant uptake factors and bioaccumulation factors). Additional uncertainties are
associated with the depicted site characteristics, the determined nature and extent of contamination, and the
derived TRVs. A large area of uncertainty is the inability to evaluate risk to many receptors because of the
lack of appropriate toxicity data for many chemicals. This is especially a problem for certain receptors such
as reptiles. In addition, because of the conservative nature of assumptions made to compensate for the lack
of site-specific uptake and bioaccumulation factors, ecologically based screening levels for some chemicals
are lower than their sample quantitation and detection limits. In WAG-4 analysis, this occurs for metals,
polychlorinated biphenyls (PCBs), and some other organics. All of these uncertainties likely influence risk
estimates. Major sources and effects of uncertainties in the ERA are reviewed in Table 7-3.
7.2.4 Transition to the INEEL-Wide Ecological Risk Assessment
The third phase of the ERA process is WAG 10 (OU 10-04) ERA, which will integrate WAG ERAs
to evaluate risk to the INEEL-wide ecological resources. This assessment will evaluate effects resulting from
past contamination, and their potential for adversely impacting the INEEL-wide ecological resources including
residual impacts from completed remedial actions.
Sites identified in the WAG 4 ERA with an HQ greater than 10, and a concentration greater than 10
times the background concentration, will be considered in the INEEL-wide ecological risk assessment. The
INEEL-wide ERA will be conducted as a component of the comprehensive RI/FS for OU 10-04. The WAG
10 comprehensive investigation will be referenced during the five-year review process for WAG 4 to
determine if the decisions implemented by WAG 4 are still protective of the environment. If the OU 10-04
ERA determines that those WAG 4 sites screened at greater than 10 times background, or HQ greater than
10, require further action, it will be determined during the WAG 4, five-year review. Future remediation may
be necessary if the WAG 10 INEEL-wide assessment indicates that a cumulative ecological risk is exceeded
for a population of receptors or if land-use changes.
7.3 Risk Assessment Summary
The human health and ERA results are summarized in Table 7-4. The risks and HQ for the three sites
and their COCs selected for remedial action are shown.
At the CFA-04 Pond, risk assessment calculations indicate that mercury poses a potential
unacceptable risk to future residential receptors via ingestion of homegrown produce. The calculated hazard
index for this exposure route is 80. Cancer risk at CFA-04 was less than 1E-04. Mercury was detected at
depths to 0.6 m (2 ft) below pond bottom. Mercury also poses an ecological risk at CFA-04.
Part II 7-16
-------
Table 7-3. Sources and effects of uncertainties in the ecological risk assessment.
Uncertainty Factor
Effect of Uncertainty
(Level of Magnitude)
Comment
Estimation of ingestion
rates (soil and food)
Estimation of
bioaccumulation and
plant uptake factors
Use of human health
exposure concentrations
Estimation of toxicity
reference values
Use of functional
grouping
Site use factor
May overestimate or
underestimate risk
(moderate)
May overestimate or
underestimate risk and the
magnitude of error cannot
be quantified (high)
May overestimate (high)
risk
May overestimate (high) or
underestimate (moderate)
risk
May overestimate (high)
risk
May overestimate (high) or
underestimate (moderate)
risk
Few intake (ingestion) estimates used for terrestrial
receptors are based on data in the scientific literature
(preferably site-specific) when available. Food
ingestion rates are calculated by using allometric
equations available in the literature (Nagy 1987). Soil
ingestion values are generally from (Beyer et al. 1994).
Few bioaccumulation factors or Plant Uptake Factors
are available in the literature because they must be
both contaminant- and receptor-specific. In the
absence of more specific information, Plant Uptake
Factors and bioaccumulation factors for metals and
elements are obtained from (Baes et al. 1994), and for
organic compounds from (Travis and Arms 1988).
Exposure concentrations were derived from data
obtained as a product of biased sampling of WAG 4
sites. Samples were generally obtained from areas
where contamination was believed the greatest.
To compensate for potential uncertainties in the
exposure assessment, various adjustment factors are
incorporated to extrapolate toxicity from the test
organism to other species.
Functional groups were designed as an assessment
tool that would ensure that the ERA would address all
species potentially present at the facility. A
hypothetical species is developed using input values
to the exposure assessment that represents the
greatest exposure of the combined functional group
members.
Site use factor is a percentage of the site of concern
compared to the home range. This is extrapolated from
literature values and allometric equations and may
vary from season to season and year to year
depending on environmental conditions. It is highly
uncertain.
Part II 7-17
-------
Table 7-4. Summary of major risks and hazard quotients at individual sites and contaminants of concern that are
addressed by the selected remedy for WAG 4.
Hazard
Risk Quotient
Site
coc
Exposure Pathway
Future Residential Exposure Scenario
CFA-04 Mercury Ingestion of homegrown produce
CFA-08 Cesium-137 External radiation exposure
CFA-10 Lead Ingestion of soil
Current Occupational Scenario
CFA-04 Mercury Ingestion of soil
CFA-08 Cesium-137 External radiation exposure
CFA-10 Lead Ingestion of soil
Future Occupational Scenario
CFA-04 Mercury Ingestion of soil
External radiation exposure
Ingestion of soil
CFA-08 Cesium-137
CFA-10 Lead
Ecological Risk Assessment
CFA-04 Mercury
CFA-10 Lead
CFA-10 Copper
a. " '
b
4E-04
a
b
2E-03
a
b
2E-04
a
80
NAd
a
0.3
NAd
a
0.3
NAd
a
b.
c.
d.
Ecological exposure <1 to 30,000
Ecological exposure <1 to 5,000
Ecological exposure <1 to 70°
Risks and hazard quotients could not be estimated for lead because human health toxicity data are not available.
However, concentrations in excess of the EPA screening level of 400 mg/kg (EPA 1994b) will be remediated.
Risk is less than 1E-04
Copper contamination exists in the surface soil and any remedial action for lead contamination is expected to also
remove copper.
NA-Not Applicable
The carcinogenic risks at the CFA-08 Drainfield are greater than 1E-04 for external radiation
exposure to current and future occupational workers and future residents to cesium-137. The
noncarcinogenic HI at CFA-08 is less than one. Cesium-137 was detected from ground surface to between
1.2 m (4 ft) and 2.4 m (8 ft) bgs. Concentrations of cesium-137 are highest in the top 0.9 m (3 ft) of soil.
Lead was detected in surface soil between 0 to 0.6 m (0 to 2 ft) bgs at the CFA-10 Transformer
Yard site. There are no toxicity data available for lead. Five samples reported concentrations above the 400
mg/kg EPA screening level. Lead also poses a risk to ecological receptors at CFA-10.
Groundwater risks were evaluated for 26 COCs identified in the OU 4-13 RI/FS (DOE-ID 1999a).
The GWSCREEN modeling results indicate that WAG 4 does not contain sources of contamination that have
the potential to produce risk greater than 1E-04 or an HQ greater than 1 for those COCs via the groundwater
pathways (e.g., groundwater ingestion). No collection of sites showed risks in the air and groundwater
residential scenarios greater than threshold values.
Part II 7-18
-------
8. CONTAMINATED SOIL SITES CFA-04, CFA-08, AND CFA-10
Remedial actions are required for three soil sites: (1) the CFA-04 Pond, (2) the CFA-08 Drainfield,
and (3) the CFA-10 Transformer Yard site. Sections 8.1 through 8.3 address each of the sites, including the
nature and extent of contamination and BRA results. More detailed information about the contaminated soil
sites may be found in the OU 4-13 RI/FS report (DOE-ID 1999a).
8.1 CFA-04 Pond (OU 4-05)
The CFA-04 pond will be remediated to address the threat to human health and ecological receptors
from mercury in soil. A summary of the site history, site investigations, nature and extent of contamination
and estimated risks are presented below.
The CFA-04 Pond is a shallow, unlined surface depression that was originally a borrow pit for
construction activities at the CFA. It is approximately 152 x 46 m (500 x 150 ft) and roughly 2 to 2.4 m (7 to
8 ft) deep; basalt outcrops are present within and immediately adjacent to the pond. It received laboratory
wastes from the Chemical Engineering Laboratory (CEL) in Building CFA-674 between 1953 and 1969. The
CEL was used to conduct calcine experiments on simulated nuclear wastes. (The calcining process was later
used on actual nuclear wastes at the INEEL to change them from a liquid to a solid and to effect an overall
volume reducton.) The CEL experiments used mercury to dissolve simulated aluminum fuel cladding as well
as radioisotope tracers in the calcining process. The primary waste streams discharged to the pond from the
CEL included approximately 76.5 m3 (100 yd3) of mercury-contaminated calcine that contained low-level
radioactive wastes and liquid effluent from the laboratory experiments. Additionally, there is approximately
382 m3 (500 yd3) of rubble, consisting of laboratory bottles, asphalt and asbestos roofing materials,
reinforced concrete and construction and demolition debris. The pond received runoff from the CFA site
periodically between 1953 and 1995.
8.1.1 Site Investigations
The CFA-04 Pond was identified as a Track 2 investigation site in the FFA/CO (DOE-ID 1991).
Visual inspections in 1994 revealed the presence of calcine on the bermed areas around the periphery of the
pond. Following surface and subsurface soil data collection from the calcine and the pond berm in early and
mid-1994, a time-critical removal action in September 1994 excavated approximately 218 m3 (285 yd3) of
calcine and calcine-contaminated soil and a small amount of asbestos from the bermed area. The soil was
remediated at a portable retort set up northeast of the pond. Verification soil sampling conducted after the
removal action showed that the bermed areas had residual mercury concentration up to 233 mg/kg (DOE-ID
1999a).
During the 1995 Track 2 investigation, additional soil samples were collected from the pond inlet area
as well as a deeper area of the pond near the inlet where laboratory effluent may have collected. The results
of the 1994 and 1995 soil investigations revealed that concentrations of the following constituents exceeded
background concentrations for the INEEL: aluminum, arsenic, barium, cadmium, calcium, chromium,
cobalt, lead, magnesium, mercury, nickel, cesium-137, paladium-234m, strontium-90, thorium-234,
uranium-234, uranium-235 and uranium-238. Aroclor-1254 was also detected at low levels. Preliminary risk
screening indicated that the following constituents detected at the pond posed potential human health risks:
aroclor-1254, arsenic, mercury, cesium-137, uranium-234, uranium-235, and uranium-238. On this basis, the
site was recommended for further characterization in the OU 4-13 RI/FS (INEEL 1996b).
Additional soil samples were collected for the OU 4-13 RI/FS during 1997 and 1998 at four areas
Part II 8-1
-------
along the length of the pipe connecting the CEL to the pond, in the area northeast of the pond known as the
windblown area, and from the pond bottom. Data from these investigations confirmed the presence of
mercury in these areas at concentrations up to 439 mg/kg (DOE-ID 1999a). Four of 88 samples exceeded
the mercury RCRA characteristic hazardous waste level of 0.2 mg/L. Three of the four samples were in
close proximity to one another in the pond and the fourth was an isolated occurrence in the windblown area
and was eliminated. A contour line was drawn around the three closely spaced samples and the area was
estimated. The depth of soil in the pond was conservatively estimated to be 2.4 m (8 ft) in the pond bottom
and 0.15 m (0.5 ft) in the wind blown area, indicating that approximately 612 m3 (800 yd3) of soil is
potentially characteristic waste per RCRA and is subject to Land Disposal Restrictions upon excavation.
8.1.2 Nature and Extent of Contamination
The only contaminant that poses an unacceptable risk to human health and the environment is
mercury. Mercury-contaminated soil is present in the pond bottom, around the pond periphery in the berms,
along the pipe connecting the CEL to the pond, and in the area northeast of the pond as a result of windblown
contamination, an area encompassing approximately 183 x 91 m (600 x 300 ft) (Figure 8-1). The OU 4-13
RI/FS conservatively estimated the volume of mercury-contaminated soil to be approximately 6,338 m3
(8,290 yd3), based on the dimensions of the pond bottoms, wind blown area and pipeline at depths of 2.4 m
(8 ft), 0.15 m (0.5 ft), and 1.8m (6 ft) respectively.
8.1.3 Summary of Site Risks
The CFA-04 Pond was retained for quantitative risk analysis in the OU 4-13 RI/FS to evaluate human
health risks from aroclor-1254, arsenic, mercury, cesium-137, Ra-226, U-234, U-235, U-238; and ecological
risks from arsenic, barium, cadmium, chromium-Ill, cobalt, copper, lead, mercury, nickel, nitrate, silver and
vanadium. Refer to the OU 4-13 RI/FS (DOE 1999a) for the details of the risk assessment process.
8.1.3.1 Human Health Risk Assessment. Mercury was identified as the only contaminant that
poses an unacceptable risk to human health at CFA-04 with a noncarcinogenic HQ of 80. Table 8-1
summarizes the data for mercury at the CFA-04 Pond.
The estimated total risk for the current and future occupational worker is less than 1E-04. The
noncarcinogenic hazard index for both current and future occupational scenarios is less than 1.
The total excess cancer risk, from the BRA, for the future residential scenario is 4E-05 (4 in
100,000). The estimated HQ for future residential scenario is 80. The majority of the noncancer risk is from
mercury (97%) and the exposure route is ingestion of homegrown produce.
8.1.3.2 Ecological Risk Assessment. Mercury is the only contaminant that poses an unacceptable
risk to ecological receptors. The maximum concentration of 439 mg/kg results in a hazard quotient of 30,000
(DOE-ID 1999a).
Table 8-1. Summary data for the human health and ecological COC at the CFA-04 Pond.
Contaminant
of Concern
Human Health
Mercury
Ecology
Mercury
Units
mg/kg
mg/kg
Number
of
Samples
267
267
Number
of
Detections
247
247
Minimum
Detected
0.9
0.9
Maximum
Detected
439
439
Exposure
Point
Concentration
146b
439C
INEEL
Background
Concentration*
0.05
0.05
a. The background value for composited samples from INEEL 1996a.
b. Volume weighted average 95% UCL concentrations.
c. Maximum concentration detected.
Part II 8-2
-------
Cher-pica] Engineering
Laboratory (CFA-674.}
Windblown
ccntcminaFfon
arocj
0 )6O
480 F
Surveyecf Area
| \ Con tam inn red Sail
L J LJncon!amfnoted Soi;
j_ J V/indbiown Soil
600 Feet
. , conform jnqnan
-,,-:>,' • ' -{Death - O-6"
Figure 8-1. Pond (CFA-04).
Part II 8-3
-------
8.2 CFA-08 Sewage Plant Drainfield (OU 4-08)
The CFA-08 (SP) Drainfield will be remediated to address the threat to human health from external
radiological exposure from cesium-137 in soil. A summary of the site history, site investigations, nature and
extent of contamination, and estimated risks are presented in this subsection.
The Navy first operated a sewage treatment facility at CFA from 1944 through 1953. This system
consisted of a septic tank (CFA-716), a sludge drying bed, and two distribution areas. In 1953, a new system
was constructed that utilized the original septic tank, a new sludge drying bed, and an expanded drainfield
with additional distribution areas equipped with trickling filters, digesters, and two clarifiers. This system
operated, with some modifications, until February 1995. It received effluent from sewage waste lines from
chemical laboratories, craft shops, warehouses, photographic services, vehicle services, a medical
dispensary, a maintenance repair shop and laundry facilities that processed low-level radiologically
contaminated clothing. Average flow through the SP ranged between 416,350 L (110,000 gal) to 662,375 L
(175,000 gal)/day (INEEL 1995c).
The CFA-08 site comprises three components in the FFA/CO (DOE-ID 1991): the SP building
(CFA-691), the septic tank inside the SP (CFA-716) and the drainfield (Figure 8-2). Potential releases from
the SP, the septic tank and associated piping/pipelines were investigated during decontamination and
dismantlement activities that commenced in 1996. Those data were evaluated in the BRA portion of the OU
4-13 RI/FS (DOE-ID 1999a). The BRA concluded that concentrations of metals, radionuclides, herbicides,
PCBs, volatile organic compound (VOCs), and SVOCs at the SP and the pipeline between the SP and the
drainfield do not pose an unacceptable risk to human health and the environment. Those portions of the
CFA-08 site require no further action.
The CFA-08 drainfield is approximately 61 x 305 m (200 x 1000 ft) with linear trenches that are
approximately 1.8 m (6 ft) deep. It contains five distribution areas, each with 20 concrete drain pipes
approximately l.lm (3.5 ft) bgs. The distribution pipes are surrounded by screened gravel in linear trenches
0.76 m (2.5 ft) wide, 1.8 m (6 ft) deep, and 61 m (200 ft) long. Basalt bedrock is encountered between 20
and 32 ft bgs in the vicinity of the drainfield. A sedimentary interbed was encountered at depths of
approximately 102 ft bgs in two borings drilled adjacent to the drainfield (INEEL 1995c).
8.2.1 Site Investigations
The 1993 Track 2 investigation focused only on delineating potential releases from the drainfield
because the SP, septic tank, and associated building piping were to be addressed under Decontamination and
Deactivation activities (INEEL 1995d). Soil samples were collected from eight borings inside the drainfield,
two borings outside the drainfield, and the Naval sludge drying bed. Perched water samples were obtained
from two shallow wells within the drainfield and one well outside the drainfield at 102 ft bgs. Additionally, a
radiological survey was performed over the soil surface downwind of the drainfield. Soil and water samples
were analyzed for Contract Lab Program metals, VOCs, semi-volatile organic compounds, PCBs, tritium, and
alpha, beta, and gamma-emitting radionuclides.
Concentrations of contaminants detected in the Naval sludge drying bed do not pose an unacceptable
risk to human health or the environment. No windblown radiologic contamination above background levels
was detected in surface soils downwind of the drainfield. Low levels of arsenic, barium, manganese, zinc and
radionuclides were detected in the perched water samples. However, the perched water zones dissipated
shortly after the SP ceased operation in 1995 (DOE-ID 1999a). The Track 2 preliminary scoping identified
the following contaminants of concern for the CFA-09 drainfield: aroclor-1254, aroclor-1260, beryllium,
cobalt-60, cesium-137, europium-152, europium-154, U-234, U-238, and Pu-239/240.
Part II 8-4
-------
fioitoad trocb
-Arao
0 50O
C3
Site OU 4-08, CFA-03 Sewage Treatment Plant DrctnHeld
Figure 8-2. Sewage Plant Drainfield (CFA-08).
Part II 8-5
-------
The OU 4-13 RI/FS investigation at the CFA-08 drainfield focused on collecting additional soil samples
inside the drainfield and determining the lateral extent of contamination outside of the drainfield. The
contaminant screening process retained aroclor-1254, cesium-137, Pu-239/240, and U-235 for evaluation of
human health risks in the BRA.
8.2.2 Nature and Extent of Contamination
The nature and extent of contamination was estimated in the OU 4-13 RI/FS to be defined by the
perimeter of the drainfield and estimated to be to a depth of 3.1 m (10 ft) bgs. The total volume is
approximately 56,577 m3 (74,000 yd3).
8.2.3 Summary of Site Risks
The CFA-08 drainfield was retained for quantitative risk analysis in the BRA to evaluate human health
risks from aroclor-1254, cesium-137, plutonium-239/240, and uranium-235. Ecological risks were evaluated
for chloromethane, chromium-Ill, copper, lead, mercury, nickel, selenium, aroclor-1254, benzo(a)pyrene,
and silver. Please refer to the OU 4-13 RI/FS (DOE 1999a) for the details of the risk assessment process.
Refer to the OU 4-13 RI/FS (DOE 1999a) for the details of the risk assessment process.
8.2.3.1 Human Health Risk Assessment. Cesium-137 is the only contaminant at the CFA-08
drainfield that poses an unacceptable risk to human health. The maximum concentration of cesium-137 is 180
pCi/g and the exposure route is external exposure. Table 8-2 summarizes the cesium-137 data.
The total excess cancer risk for the current occupational work is 2E-03 (2 in 1,000). The majority of
this risk (99%) is from external exposure to radiation from cesium-137 in soil. The noncarcinogenic hazard
index is less than 1.
The total excess cancer risk for the future occupational work is 2E-04 (2 in 10,000). The major
contributor is external exposure to radiation from cesium-137 in soil. The noncarcinogenic hazard index is
less than 1.
The total excess cancer risk for the future residential scenario is 4E-04 (4 in 10,000). The majority of
the risk (99%) is attributable to external radiation exposure to cesium-137 in soil. The noncarcinogenic
hazard index is less than 1.
8.2.3.2 Ecological Risk Assessment. The ecological risk assessment determined that no
contaminants pose an unacceptable risk to ecological receptors.
Table 8-2. Summary data for the human health COC at the CFA-08 drainfield.
Contaminant
of
Concern
Human Health
Cesium-137
Units
pCi/g
Number
of
Samples
65
Number
of
Detections
47
Minimum
Detected
0.08
Maximum
Detected
180
Exposure
Point
Concentration
88.9b
INEEL
Background
Concentration3
1.28
a. The background value for composited samples (INEEL 1996a.)
b. Volume weighted average 95% UCL concentrations.
Part II 8-6
-------
8.3 CFA-10 Transformer Yard (OU 4-09)
The CFA-10 site will be remediated to address the threat to human health and ecological receptors
posed by lead-contaminated soil. A summary of the site investigations, nature and extent of contamination,
and estimated risks are presented below.
The Transformer Yard site (see Figure 8-3) is an area approximately 19.8m x 42 m. The building and
yard area were used for welding and metalworking between approximately 1958 and 1985 (INEEL 1996a).
From 1985 to 1990, electrical transformers were stored on the concrete pad. Process knowledge indicates
that the yard was not used for waste disposal, but accidental spills may have occurred at the site. Potential
contaminants were identified as metals and PCBs in the Track 2 scoping process.
8.3.1 Site Investigations
The CFA-10 Transformer Yard site was identified as a Track 2 investigation site in the FFA/CO
(DOE-ID 1991). Six surface soil samples were collected in the Track 2 investigation for PCB analyses and
four samples were analyzed for metals. Two of seven possible PCBs were detected: aroclor-1254 and
aroclor-1260 with maximum concentrations of 1.4 and 1.3 mg/kg, respectively. The Track 2 investigation
identified arsenic, lead, aroclor-1254 and aroclor-1260 as COPCs, and the site was carried forward to the OU
4-13 RI/FS.
As part of the OU 4-13 RI/FS investigation, soil samples were collected at four additional locations for
lead analyses. At each location, samples were collected at the surface and at depths of 0.3 m (1 ft) and 0.6 m
(2 ft) bgs. The average lead concentration for the surface soil, soil at 0.3 m (1 ft) bgs, and soil at 0.6 m (2 ft)
bgs is 1,848, 64, and 18 mg/kg, respectively. Only the average lead concentration for the surface soil
exceeds the EPA residential lead screening level of 400 mg/kg. Additionally, samples collected from the three
depths at the four locations were analyzed by the TCLP for lead; two samples exceeded the toxicity
characteristic level for lead. Aroclor-1254 and aroclor-1260 were retained for evaluation of human health
risk; lead was evaluated against the EPA screening criterion.
8.3.2 Nature and Extent of Contamination
The extent of contamination at the CFA-10 Transformer Yard encompasses the dimensions of the yard
to a depth of 0.15 m (0.5 ft). The volume of lead-contaminated soil is estimated to be 123 m3 (160 yd3).
Subsurface data indicate that lead concentrations above 400 mg/kg are confined to the upper 0.15 m (0.5 ft)
of the yard.
8.3.3 Summary of Site Risks
Because there are no toxicity data for lead, lead concentrations were compared to the EPA
screening criterion. Aroclor-1254 and aroclor-1260 were evaluated for potential risk to human health in the
BRA. Antimony, arsenic, cadmium, chromium III, cobalt, copper, lead, manganese, mercury, nickel, zinc,
and aroclor-1254 were evaluated for potential risks to ecological receptors. Please refer to the OU 4-13 RI/FS
for the details of the risk assessment process.
Part II 8-7
-------
Iron iformer Yard
Map View
Rood sand buildingi
60 120 1BO 240 Fast
Surveyed Area
t^l\ ContaminaledSoil
I I Uncontaminated
0-0.5
T4i Fsef
Figure 8-3. The Transformer Yard (CFA-10).
Part II 8-8
-------
8.3.3.1 Human Health Risk Assessment Lead is the only contaminant that poses an
unacceptable risk to human health at CFA-10. Concentrations in the top 0.5 ft of soil exceed the EPA
residential screening level of 400 mg/kg. Lead also poses an unacceptable ecological risk above 10 times
background (170 mg/kg), in the top 0.15 m (0.5 ft) of soil. Data for lead at CFA-04 are summarized in Table
8-3.
The total excess cancer risk for the current and future occupational scenarios is less than 1E-04. The
noncarcinogenic hazard quotient is less than 1 for both the current and future occupational scenarios.
8.3.3.2 Ecological Risk Assessment. Lead and copper were identified as a contaminant that
poses unacceptable risks to ecological receptors at CFA-10. The exposure point concentration of 5,560
mg/kg for lead has a calculated hazard quotient of 5,000. The maximum copper concentration of 259 mg/kg
is only slightly above the 10 background criteria of 220 mg/kg in one sample of four detected samples. Data
for lead and copper are summarized in Table 8-3.
Table 8-3. Summary of data for the human health and ecological COC at the CFA-10 Transformer
Yard.
Contaminant
of
Concern
Human Health
Lead
Ecological
Lead
Copper0
Units
mg/kg
mg/kg
mg/kg
Number
of
Samples
17
17
4
Number
of
Detections
17
17
4
Minimum
Detected
16.5
16.5
36
Maximum
Detected
5,560
5,560C
259
Exposure
Point
Concentration
305b
5,560
259
INEEL
Background
Concentration3
17
17
22
a. The background value for composited samples from INEEL 1996a.
b. Volume weighted average 95% UCL concentrations
c. Copper contamination was detected at the same depth of surface soil where lead contamination is and a remedial action for
lead contamination is expected to also remediate the copper. Therefore, copper will not be evaluated as a COPC in the FS.
Part II 8-9
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9. REMEDIAL ACTION OBJECTIVES AND
FINAL REMEDIATION GOALS
The remedial action objectives (RAOs) and final remediation goals (FRGs) for sites CFA-04, CFA-08,
and CFA-10 are discussed below. The remedial alternatives were evaluated collectively in the Feasibility
Study, and are presented similarly in this ROD. Sections 9 through 11 address the remedial alternatives for
each of the three sites. The remedial alternatives, a comparison of these alternatives, and the selected
remedies are presented.
9.1 Remedial Action Objectives
These RAOs are based on the results of both human health and ecological risk assessments and are
specific to the COCs and exposure pathways for each of the three sites.
The RAOs were developed in accordance with the NCP and CERCLA RI/FS guidance (EPA 1988) and
refined through discussions among the Agencies (IDHW, EPA Region 10, and DOE-ID). During development
of the RAOs it was assumed that CFA would serve as the primary area at INEEL for technical service and
support functions for the next 100 years with access restrictions and other administrative and physical
security controls.
Based on these assumptions the RAOs are to:
• Prevent direct exposure to radionuclide COCs that would result in a total excess cancer risk greater
than 1 in 10,000
• Prevent ingestion and inhalation of radionuclide and nonradionuclide COCs that would result in a
total excess cancer risk greater than 1 in 10,000, or a total of hazard index greater than 1.0
• Prevent exposure to lead at concentrations over 400 mg/kg, the EPA residential screening level for
lead
• Prevent exposure of ecological receptors to contaminated soil with concentrations greater than or
equal to a screening level of 10 times background values that result in a hazard quotient greater
than or equal to 10.
• Monitor the groundwater at WAG 4 until the nitrate level falls below the MCL of 10 mg/L.
9.2 Final Remediation Goals for the Selected Alternatives
The FRGs developed in the OU 4-13 RI/FS (DOE-ID 1999a) are based on risk-specific doses,
applicable or relevant and appropriate requirements (ARARs), or EPA guidance and are summarized in Table
9-1. For sites, CFA-04 and CFA-10, the FRGs are based on screening level goals rather than further intensive
analysis and the additional cost of further study, which would be necessary to refine the FRGs.
Part II 9-1
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Table 9-1. Final Remediation Goals for sites with selected alternatives.
Site Contaminant FRG Basis
CFA-04-Pond Mercury 0.50mg/kg Ecological goal based on ten times
average background concentration for
composited samples.3
CFA-08 Sewage Plant Cesium-137 2.3pCi/gb Human health goal. See Footnote b.
Drainfield
CFA-10 Transformer Yard Lead 400mg/kg EPA residential screening level (400
mg/kg)
Ecological goal is lower than human health goal of 1.27 mg/kg.
The maximum cesium-137 concentration at the CFA-08 drainfield (180 pCi/g) will naturally decay to 23 pCi/g
in the 100-year 1C period for the INEEL. However, the ultimate goal for unrestricted access is 2.3 pCi/g, the
1E-04 future residential risk-based concentration. That concentration will be achieved in an additional 89
years through continued natural decay. Note that 23 pCi/g is not a true "remediation goal" in that soil is not
being removed to this level; it will be achieved through radioactive decay. Confirmatory soil sampling to
demonstrate that this level is achieved in 100 years will not be performed under this remedy, because the
known radioactive half-life for cesium-137 is 30 years (Benedict et al. 1981).
Part II 9-2
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10. DESCRIPTION OF ALTERNATIVES
The alternatives listed below were developed to meet the RAOs for contaminated materials at sites
CFA-04, -08, and -10.
1. No Action (with monitoring)
2. Limited Action
3. Excavation, treatment by stabilization, and disposal
a. On-INEEL disposal
b. Off-INEEL disposal
4. Containment.
A brief description of each alternative is presented in the sections below.
10.1 Alternative 1—No Action (With Monitoring)
The NCP [40 CFR 300.430(e)(6)] requires consideration of a No Action alternative to serve as a
baseline for evaluation of other remedial alternatives. The primary elements of Alternative 1 are:
• No remedial actions would be taken.
• No land-use restriction, controls, or active remedial measures would be implemented at the
site.
• Environmental monitoring may be warranted if contamination is left in place under this
alternative. Monitoring would enable detection of contaminant migration within
environmental media (air, groundwater, and soil) or other changes in site conditions that
warrant future remedial actions. Monitoring would remain in effect for at least 100 years.
For the sites in this ROD, environmental monitoring would consist of radiological surveys in
appropriate areas, groundwater, and air monitoring. Any required air monitoring would be.
performed as part of the INEEL air-monitoring program. The frequency and locations of all
air monitoring activities would be determined during the remedial design.
10.2 Alternative 2—Limited Action
A Limited Action alternative was developed that consists of:
• Institutional controls (ICs) include property transfer restrictions in perpetuity. These
restrictions would limit use of property if it is transferred from government control to
private ownership. If the property is ever transferred to private ownership, the information
required under Section 120(h) of CERCLA would be transferred with it. The property
transfer documentation would provide notification to the new property owner disclosing
former waste management and disposal activities that occurred on the site. It would limit
property use to activities that would prevent human health risks from exceeding allowable
levels. These restrictions may take the form of restrictive covenants or easements
established in perpetuity.
Part II 10-1
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• Access restrictions would be maintained during the institutional control period using fences
and signs. Routine site inspections and monitoring for animal burrows, erosion, or
subsidence also will be performed to assess maintenance requirements.
• Surface water would be controlled to minimize the potential for surface water accumulation
at the site. This management would include inspection and maintenance of site drainage.
• Environmental monitoring may be warranted if contamination is left in place under this
alternative. Monitoring would enable detection of contaminant migration within
environmental media (air, groundwater, and soil) or other changes in site conditions that
warrant future remedial actions. Monitoring would remain in effect for at least 100 years.
For the sites in this ROD, environmental monitoring would consist of radiological surveys in
appropriate areas and groundwater monitoring. Any required air monitoring would be
performed as part of the INEEL air-monitoring program. The frequency and locations of all
air monitoring activities would be determined during the remedial design.
10.3 Alternative 3—Excavation, Treatment, and Disposal
Remedial alternatives incorporating treatment were developed to meet ARARs and EPA's preference
for treatment. Treatment may be required to dispose contaminated media removed from a site. Alternatives
incorporating treatment were developed to allow risk managers to determine the relative cost-effectiveness
and practicability. Excavation, treatment, and disposal alternatives could be applied to any of the three
remediation sites.
10.3. 1 Alternative 3a—Excavation, On-INEEL Treatment, and Disposal
CFA-04. This alternative would consist of the actions listed below. No ICs would be required for the
CFA-04 Pond after completing the remediation, providing soil exceeding the FRG is removed.
• Characterizing the site and excavating soil and sediments from the pond exceeding FRG. Soil
contaminated at concentrations above the FRG will be excavated to a maximum depth of 3
m (10 ft) bgs or to basalt. No basalt will be excavated.
• Transporting excavated soil exceeding the FRG to the ICDF.
• Stabilizing soil exceeding the RCRA characteristic hazardous waste levels for mercury with
cement.
• Disposing treated and nontreated soil at the ICDF.
• Performing verification sampling to ensure that there is no identified contamination
remaining at the site exceeding the FRG.
• Backfilling the pond and any adjacent excavations with uncontaminated soil to grade. All
excavations will be contoured to match the surrounding terrain and revegetated.
CFA-08. This alternative would consist of the actions listed below. No ICs are necessary at CFA-08
provided that soil exceeding the FRG is removed from the site. Note that in this instance the FRG for
excavation would be 2.3 pCi/g for cesium-137; that concentration is the 1E-04 risk-based concentration for
the future residential scenario for unrestricted access.
Part II 10-2
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• Characterizing soil and excavating soil and sediments from the drainfield exceeding FRG.
Soil contaminated at concentrations above the FRG will be excavated to a maximum depth
of 3 m (10 ft) bgs or to basalt. No basalt will be excavated.
• Allowing sludges remaining in drainfield feeder lines to drain into soil during excavation.
• Transporting soil exceeding the FRG to the ICDF
• Performing verification sampling to ensure that there is no identified contamination
remaining at the site exceeding the FRG.
• Returning soil contaminated at less than FRG to the excavation.
• Backfilling the excavation with uncontaminated native soil, creating final slopes that will
divert water, and revegetating the site.
This alternative originally used soil separation as the treatment technology. However, a pilot-scale
treatability study performed by WAG 5 in 1999 (INEEL 1999) concluded that this technology is not cost
effective for this type of soil contamination. Therefore, soil separation was eliminated from the alternative.
Soil excavated that exceeds the FRG would be disposed of at the ICDF.
CFA-10. This alternative would consist of the actions listed below. No ICs are necessary at CFA-10
provided that soil exceeding the FRG is removed from the site.
• Characterizing soil and excavating soil exceeding FRG. Soil contaminated at concentrations
above the FRG will be excavated to a maximum depth of 3 m (10 ft) bgs or to basalt. No
basalt will be excavated.
• Performing verification sampling to ensure that there is no identified contamination
remaining at the site exceeding the FRG.
• Transporting soil contaminated above the FRG to the ICDF.
• Stabilizing soil that exhibits the RCRA toxicity characteristic for lead, and disposing of
treated and nontreated soils to the ICDF.
• Returning soil contaminated at less than the FRG to the excavation.
• Backfilling the excavation with uncontaminated soil to grade. The excavation will be
contoured to match the surrounding terrain and revegetated.
10.3.2 Alternative 3b—Excavation, Treatment, and Disposal Off-INEEL
CFA-04. This alternative would consist of the actions described in Section 10.3.1, Alternative 3a,
for this site, except that soils exceeding the FRG would be treated, transported to, and disposed of at an
off-INEEL TSDF.
CFA-08. This alternative would consist of the actions listed in Section 10.3.1, Alternative 3 a, for
this site, except that soils contaminated at levels exceeding the FRG would be transported to an off-INEEL
low-level waste landfill for disposal.
Part II 10-3
-------
CFA-10. This alternative would consist of the actions described in Section 10.3.1, Alternative 3a,
for this site, except that soils exceeding the FRGs would be treated, transported to, and disposed of at an
off-INEEL TSDF.
10.4 Alternative A—Containment and Institutional Controls
The alternatives developed for containing contamination are based on capping technologies. These
alternatives would be designed to meet RAOs by eliminating exposure pathways identified in the BRA. The
cap must be designed to maintain integrity for the period of time that unacceptable exposure risks will be
present. The functional life of a particular cover is dependent on how long failure mechanisms such as
erosion, subsidence, geosynthetic failure, infiltration, biotic and human intrusion can be delayed. The human
health risks due to cesium-137 contamination at CFA-08 will decline to acceptable levels for unrestricted
access within 189 years through natural radioactive decay. Human health and ecological risks due to toxic
metals at CFA-04 and -10 will not decrease due to time.
For CFA-04 and CFA-10, the cap would also be required to meet RCRA 40 CFR 264.310(a)(l-5),
which would be an ARAR for those sites. This regulation specifies that the cap must meet the following
functional requirements:
• Provide long-term minimization of infiltration
• Function with minimum maintenance
• Promote drainage and minimize erosion or abrasion of the cover
• Accommodate settling and subsidence so that the cover's integrity is maintained
• Maintain permeability less than or equal to the permeability of any bottom liner system or
natural subsoil present.
An engineered C-ET barrier was determined to best meet the functional requirements and was
selected as the representative capping technology for Alternative 4 for all three.
Institutional controls, as described for Alternative 2, would be implemented. The cap would be
maintained during the entire 100-year 1C period. Long-term maintenance and inspection requirements would
include reestablishing vegetation as necessary, repairing any subsidence, erosion furrows and animal
burrows, and removing undesirable plants. Long-term monitoring requirements would include visual
inspections and radiation surveys.
Part II 10-4
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11. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives discussed in Section 10 were evaluated for each site using the nine evaluation criteria
required under CERCLA (40 CFR 300.430[f][5][I]). The purpose of these comparisons is to identify the
relative advantages and disadvantages of each alternative. Each criterion is described below and the
alternatives are presented in decreasing order from the most to least advantageous. Table 11-1 provides a
summary of the evaluation criteria for the alternatives and a ranking of alternatives for each criterion and each
site.
11.1 Threshold Criteria
The selected remedial action must meet the threshold criteria of overall protection of human health
and the environment, and compliance with ARARs.
11.1.1 Overall Protection of Human Health and the Environment
This criterion addresses the degree to which a remedy provides adequate protection of human health
and the environment. Risks posed by the COCs at the site may be eliminated, reduced, or controlled through
removal, treatment, engineering controls, or ICs. Long-term risk calculations in the BRA and short-term
health effects associated with construction work in the field must be considered for this criterion.
• Alternatives 3 a and 3b are the most protective, since contaminated soil above FRGs would
be removed from WAG 4.
• Alternative 4 meets human health and ecological RAOs; however, it is less effective than
Alternatives 3a and 3b, since contamination would remain at the sites. Mercury and lead
would remain indefinitely at CFA-04 and CFA-10, respectively, while cesium-137 at
CFA-08 would decay to allowable residential levels within 189 years.
• Alternative 2 does not meet the criterion at CFA-04, CFA-08, or CFA-10. Contamination
remaining at CFA-04 and CFA-10 would exceed human health remediation goals.
Contamination remaining at CFA-08 after 100 years of institutional control would exceed
the human health unrestricted release criterion of 2.3 pCi/g cesium-137.
• Alternative 1 does not satisfy the criterion for any of these three sites, because site access
and contact with the contaminated media are not prevented, and potential risks are not
reduced. The no action alternative does not meet RAOs for protection of human health and
the environment.
Part II 11-1
-------
Table 11-1. Relative ranking of alternatives evaluated for the three WAG 4 OU 4-13 sites of concern.3
Evaluation Criteria
CFA-08
CFA-04
CFA-10
Overall protection of
human health and the
environment
Compliance with
ARARs
1 and 2 do not meet the 1 and 2 do not meet the
criterion. criterion.
(3a, 3b, 4)
1 and 2 do not meet the
criterion.
Long-term effectiveness (3a, 3b), 4
and permanence
Reduction of toxicity,
mobility or volume
through treatment
(3a, 3b), 4
(3a, 3b, 4)
1 and 2 do not meet the
criterion.
(3a, 3b), 4
(3a, 3b), 4
(3b, 3a), 4 (3a, 3b), 4 (3a, 3b), 4
1 and 2 do not meet the
criterion.
(3a, 3b, 4)
1 and 2 do not meet the
criterion.
(3a, 3b), 4
(3a, 3b), 4
4, (3a, 3b)
4, 3b, 3a
3a, 3b, 4
a. Ranking is from highest to lowest, except for costs, which are ranked from lowest to highest in net present value.
() =No significant difference between alternatives with respect to the criterion.
Alternative 1: No Action with monitoring.
Alternative 2: Institutional Controls.
Alternative 3a: Excavate, Treat, and ICDF Disposal
Alternative 3b: Excavate, Treat and Off-INEEL TSDF Disposal
Alternative 4: Containment with an engineered cover and Institutional Controls.
Short-term
effectiveness
Implementability
Cost
4, (3a,3b)
4, 3b, 3a
4, 3a, 3b
4, (3a, 31
4, 3b, 3a
3a, 4, 3b
11.1.2 Compliance with Applicable or Relevant and Appropriate Requirements
Evaluation of compliance with ARARs for all alternatives is included in Table 11-1 and summarized
below. A complete list of ARARs for selected remedies are provided in Section 13, Table 13-1.
Alternatives 3a, 3b, and 4 meet all ARARs identified in Section 13, Table 13-1 for CFA-04,
CFA-08, and CFA-10.
• The RAOs for CFA-04 and CFA-08 would be met under Alternative 4 since contaminated
soil would be capped and the exposure pathway eliminated. The engineered cover could
meet the to-be-considered (TBC) requirements of DOE orders for low-level waste disposal
for CFA-08 and would meet RCRA Subtitle C requirements of cap performance for CFA-04
and CFA-10.
Part II 11-2
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• Alternative 2 would not meet (DOE Order 5400.5) for a period of 89 years after the
100-year institutional control period at CFA-08. Because hazardous constituents would be
left in place, Alternative 2 would not meet RCRA Subtitle C standards for landfill closure and
post-closure at CFA-04 and CFA- 10.
Alternative 1 would not meet (DOE Order 5400.5) for 189 years at CFA-08. Alternative 1
would not meet RCRA Subtitle C standards for landfill closure and post-closure at CFA-04
and CFA- 10.
11.2 Balancing Criteria
The balancing criteria used in refining the selection of the candidate alternatives for the site include:
(1) long-term effectiveness and permanence; (2) reduction in toxicity, mobility, or volume through treatment;
(3) short-term effectiveness; (4) implementability; and (5) cost. Only alternatives 3a, 3b, and 4 are evaluated
against balancing criteria because 1 and 2 do not fulfill the threshold criteria.
11.2.1 Long-Term Effectiveness and Permanence
This criterion includes consideration of residual risk that will remain on-INEEL following remedial
action. The adequacy and reliability of controls are also considered.
• Alternatives 3 a and 3b would achieve the highest level of long-term effectiveness and
permanence because contaminated soil and debris would be completely removed from the
sites. Solid waste generated would be managed in accordance with ARARs. The ICDF will
be required to meet substantive requirements for a TSDF under the Hazardous Waste
Management Act and RCRA. Institutional controls would ensure effectiveness of the remedy
at any site where contaminated soil above FRGs was allowed to remain below 3 in (10
ft)bgs
• Alternative 4 would be highly effective at achieving long-term effectiveness and permanence
at CFA-08. The effectiveness of the containment option is greater at the CFA-08 Drainfield
than at CFA-04 and CFA-10 because the cap integrity needs to be maintained for a shorter
period due to the radioactive decay of the COC. External exposure risks estimated for the
CFA-08 drainfield, due to cesium-137, decrease to 1E-04 in approximately 189 years.
However, human health and ecological risks from toxic metals at CFA-04 and CFA-10
would not decrease with time. Under Alternative 4, long-term effectiveness and permanence
at CFA-04 and CFA-10 depends on the durability of the cap. Cap integrity monitoring, as
well as periodic removal of undesirable vegetation and burrowing animals (if necessary),
would be performed.
11.2.2 Reduction of Toxicity, Mobility, or Volume Through Treatment
This criterion addresses the statutory preference for selecting remedial actions that employ treatment
technologies that permanently result in reduction of toxicity, mobility, or volume of the hazardous substances
as their principal elements.
• No reduction in toxicity or volume would result from stabilization (Alternative 3) of
mercury- or lead-contaminated soils at CFA-04 and CFA-10, respectively. Volume increase
would likely be in the range of 200%. The overall mobility of lead and mercury would be
reduced through stabilization.
Part II 11-3
-------
• No reduction in volume through treatment would occur for Alternatives 3 a and 3b for site
CFA-08. These alternatives, as presented in the Proposed Plan (DOE-ID 1999b),
incorporated treatment by segmented gate separation (SGS) of cesium-137 contamination.
Application of this treatment at WAG 4 was contingent on acceptable results in a WAG 5
treatability study that investigated the viability of SGS on INEEL soils. The results of this
study indicate that the radiological components in contaminated soil could not be effectively
separated (INEEL 1999). The SGS system is, therefore, not considered further for CFA-08
for either of these alternatives.
• Alternative 4 does not include treatment.
11.2.3 Short-Term Effectiveness
The short-term effectiveness criterion addresses the time needed to implement remedies to reduce
any adverse impacts on human health and the environment. This criterion specifically refers to risks that may
be posed during the construction and implementation period of remedial action prior to achieving remedial
goals. For this criterion, the alternative that provides the least amount of disturbance to contaminated
materials ranks the highest in terms of short-term effectiveness because of the potential for worker exposure.
• Alternatives 3a and 3b provide a moderate degree of short-term effectiveness primarily due
to potential worker exposure. Health risks to workers during excavation would be minimized
to the extent possible. Potential exposures from removal and treatment of waste would be
mitigated using standard administrative and engineering controls. These controls could
include, but are not limited to dust suppression and appropriate personal protective
equipment. Other measures may include the use of excavation equipment modified with
positive-pressure ventilation systems and HEPA filters for use in contaminated areas.
Environmental impacts for Alternatives 3 a and 3b are minimal. No environmentally sensitive
archaeological or historical sites, wetlands, or critical habitat exist at WAG 4.
• Alternative 4 also provides a moderate degree of short-term effectiveness primarily due to
potential worker exposure. The possibility of direct radiation exposure of workers installing
a protective cover at CFA-08 would be minimized by first placing a foundation layer over
the contaminated soils. Emplacement of foundation material and the lowermost layer(s) of
the cover would add additional shielding sufficient to eliminate subsequent exposure risks
throughout the remainder of construction activities at CFA-08. Construction activities would
be performed in accordance with the as low as reasonably achievable (ALARA) approach to
radiation protection as required under (10 CFR 835). Inhalation and ingestion risks due to
toxic metals in soil at CFA-04 and -10 would be minimized by the use of appropriate
personal protective equipment, engineering controls, and adherence to health and safety
protocols. Environmental impacts resulting from excavation and construction activities
would be minimal.
11.2.4 Implementability
The implementability criterion addresses such factors as the availability of services and materials.
Coordination with other governmental entities is also considered.
• The implementability of Alternative 3a for CFA-04, CFA-08, and CFA-10 is considered
moderate. The technology to perform stabilization is readily implementable. Chemical
Part II 11-4
-------
stabilization of lead and mercury has been previously performed at the INEEL. The moderate
rating is primarily due to the uncertain availability of the ICDF, which is planned to begin
operations in 2004.
The implementability of Alternative 3b for site CFA-0.4 and -10 is considered high, due to
the ready availability of an off-INEEL disposal facility. The technology associated with
stabilization and disposal is also readily implementable. Off-INEEL disposal can be
implemented sooner because the ICDF may not be complete for several years. The
implementability of Alternative 3b for CFA-08 is high.
Alternative 4 is highly implementable for all three sites due to the availability of materials and
technology.
11.2.5 Cost
Table 11-2 presents a summary of the comparative costs of the alternatives for CFA-04, CFA-08,
and CFA- 10.
CFA-04. Of the three alternatives that meet the threshold criteria, the least costly alternative for
CFA-04 is Alternative 3 a, Excavation, Treatment and disposal at ICDF. Alternative 4 is the next lowest cost.
The operating and maintenance costs for Alternative 4 account for approximately 40% of the overall costs.
Alternative 3b has the highest cost, primarily due to the cost of shipping contaminated soils to an off-INEEL
facility.
CFA-08. Of the three alternatives that meet the threshold criteria, the least costly alternative for
CFA-08 is Alternative 4, Containment. Approximately 35% of this total cost is attributable to operating and
maintenance costs. Alternative 3a has the next lowest cost. The increase in costs for 3a is due to the
excavation of drainfield soils and on-INEEL disposal. The costs for Alternative 3b are highest due to the
additional cost of off-INEEL transport and disposal.
CFA-10. Of the three alternatives that meet the threshold criteria, the least costly alternative for
CFA-10 is Alternative 3 a, Excavate, Treat, and disposal at the ICDF. Alternative 3b has the next lowest cost.
The slightly higher cost of Alternative 3b in comparison to 3a is primarily due to the additional cost of
off-INEEL transport and disposal. Alternative 4, containment, has the highest cost. Approximately 55% of
these costs are attributed to long-term operations and maintenance of a cover.
11.3 Modifying Criteria
The modifying criteria—state and community acceptance—are used in the final evaluation of
remedial alternatives. Consideration in evaluating state and community acceptance includes elements of the
alternatives that are supported, unsupported, or strongly opposed.
11.3.1 State Acceptance
The IDHW has been involved in the development and review of the RI/FS report, the Proposed Plan,
and this ROD. All comments received from IDHW have been resolved and incorporated into these
documents. The IDHW has participated in public meetings where public comments and concerns have been
voiced and responses offered.
The IDHW concurs with the selected remedial alternatives.
Part II 11-5
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Table 11-2. Costs for the alternatives considered for CFA-04, CFA-08, and CFA- 10.
CFA-04
Capital cost
O&M
Total cost
CFA-08
Capital cost
O&M cost
Total cost
CFA- 10
Capital cost
O&M cost
Total Cost
Alternative 1
No Action
$0.9
H2
$1.1
$0..9
H2
$1.1
$0.8
N/A
$0.8
Alternative 3 a
on-INEEL
$4.8
N/A
$4.8*
$30.8
(L2
$31.0
$1.3
N/A
$1.3
Alternative 3b
off-INEEL
$12.6
0.2
$12.8
$36.5
(X2
$36.7
$1.4
N/A
$1.4
Alternative 4
containment
$4.8
3J.
$7.9
$7.3
$3.5
$10.8
$2.1
2.7
$4.8
Costs are in millions and net present value.
O&M costs are included in capital costs for CFA-10 alternatives 1, 3a and 3b.
N/A=Not Applicable
* These costs are lower than the S6.9M estimate presented in the Proposed Plan because the number of five-year reviews was
reduced by one and ICDF disposal costs to be borne by WAG 3 have been removed (DOE-ID 2000d).
11.3.2 Community Acceptance
Community participation in the remedy selection process includes participation in the public meetings held in August,
1999, and review of the Proposed Plan during the public comment period that began August 5 and ended October 4,1999. The
highlights of community participation are included in Section 3. The Responsiveness Summary (Part III) includes verbal and
written comments received from the public and the Agencies' responses to these comments.
Approximately 30 people not associated with the project attended the proposed plan public meetings. Overall, 12
people provided formal comments; of these, five people provided verbal comments, and seven provided written comments. All
comments received on the Proposed Plan were considered during the development of this ROD.
In general, the public was supportive of the preferred alternatives for the three sites to be remediated at WAG 4. Two
stakeholders questioned the need for cleanup and the cost estimates for the remedial projects. It was explained that the sites were
selected on the basis of CERCLA cleanup criteria, and that costs will be refined as the projects progress through the RD/RA
process. Please refer to the Responsiveness Summary in Part III for more details.
Part II 11-6
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12. SELECTED REMEDY
12.1 Description of Selected Remedy
12.1.1 CFA-04 Pond (OU 4-05)
12.1.1.1 Selected Remedy. The Agencies have selected Alternative 3a, Excavation, Treatment by
Stabilization, and on-INEEL Disposal for the CFA-04 Pond mercury-contaminated soil. The selected
alternative most cost-effectively meets the threshold and balancing criteria of the three alternatives
considered. Under this alternative, approximately 6,338 M3 (8,290 yd3) of contaminated soil will be
excavated. Soil with concentrations above the RCRA characteristic hazardous waste levels (estimated as 608
m3 [796 yd3]) will be stabilized with cement to comply with 40 CFR 268.49. The pond and adjacent
excavations will be backfilled with clean soil to grade. The ground surface will be contoured to match the
surrounding terrain or sloped to promote drainage and revegetated.
This remedy will consist of the following actions:
1. Characterizing the site and excavating soil from CFA-04 that exceeds the mercury FRG of
0.50 mg/kg. Soil contaminated at concentrations above the FRG will be excavated to 10 ft.
(bgs), or to basalt. No basalt will be excavated.
2. Transporting and disposing of soil that exceed the mercury FRG to the proposed ICDF.
3. Stabilizing soil with TCLP mercury concentrations greater than 0.2 mg/L using cement and
verification that all LDRs are met.
4. Performing verification sampling to ensure that soil exceeding the FRG of 0.50 mg/kg
mercury has been removed.
5. Backfilling the pond, and adjacent areas that have been excavated, with uncontaminated soil
to grade or sloped to promote drainage. All excavations will be contoured to match the
surrounding terrain and revegetated.
Long-term institutional controls are not anticipated for the CFA-04 Pond, but will be evaluated after
remediation.
12.1.1.2 Evaluation. Alternative 3a will protect human health and the environment and will comply with
ARARs. This alternative will be highly effective long-term because it removes the contamination. It will only
be moderately effective short-term because of the possibility of worker exposure during excavation,
transport, and disposal. Alternative 3 a will not reduce toxicity or volume through treatment, but will reduce
contaminant mobility through stabilization. Implementability of Alternative 3 a is moderate, because availability
of the disposal facility on the INEEL is uncertain.
Compared to the other alternatives that meet the threshold criteria (3b and 4), Alternative 3 a will be
as or more effective long-term, and equally effective short-term. Its ranking for reduction of toxicity,
mobility, or volume through treatment is the same or better. Its implementability is lower than for Alternatives
3b and 4, given the uncertain availability of the on-INEEL disposal facility; however, all other required
technologies and personnel are available. The estimated $4.8 million cost is the lowest of the three alternatives
that meet threshold criteria. Therefore, this alternative 3 a is the selected remedy.
Part II 12-1
-------
12.1.1.3 Performance Standards. Performance standards will be implemented to ensure that excavation.
treatment, and disposal activities will result in protection against direct exposure to mercury during
excavation and after disposal. The performance standards identified for this alternative include:
• Removing mercury contaminated soil where concentrations exceeding the FRG (0.5 mg/kg)
are detected.
• Sampling soil at the pond to confirm that the cleanup meets or exceeds FRGs.
• Sampling of contaminated soil removed from the pond to confirm that soil disposed to the
ICDF meets treatment standards for mercury and all underlying hazardous constituents (40
CFR 268.48). It must also meet the waste acceptance criteria of the ICDF. Soil meeting this
standard must be less than 0.2 mg/L using TCLP analysis. Contaminated soil that does not
meet treatment standards and requires treatment will be treated prior to disposal.
12.1.2 CFA-08 Sewage Plant Drainfield (OU 4-08)
12.12.1 Selected Remedy. The Agencies have selected Alternative 4, Containment, for the CFA-08 SP
Drainfield. The selected alternative most cost-effectively meets the threshold and balancing criteria, of the
three alternatives considered. Under this alternative, the contaminated site will be covered with an engineered
protective cover. This cover will be an engineered barrier, constructed of layers of rock and soil with a
vegetative cover. This barrier will isolate the waste and minimize water infiltration. The cover will be
designed to isolate the low-level radioactive contaminants from human and biotic intrusion and to provide
radiation shielding for a period of 189 years. The following remedial actions will be performed at the site:
1. Constructing an engineered ET cover. Clean native soil will be used for fill material as
needed.
2. Contouring and grading the surrounding terrain to direct the surface water runoff away
from the cover.
The continued effectiveness of this remedy will be evaluated through soil cover integrity monitoring
and above-ground radiological surveys. Because contamination is to be left in place, ICs are necessary for
CFA-08 to restrict access until the land can be released for unrestricted use. Institutional controls to be
implemented at CFA-08 include:
• Restricting access through the use of signs and permanent markers
• Controlling land use leasing and property transfers
• Establishing and publishing surveyed boundaries
• Controlling activities on the land.
12.1.2.2 Evaluation. Alternative 4 was selected for CFA-08 because it is protective of human health and
the environment and complies with ARARs. It will have high long-term effectiveness because it will eliminate
the direct exposure pathway and contain the contamination until the risks to human health posed by the
cesium-137 drop below threshold levels. In addition, it will eliminate the ecological risk exposure pathway to
the mercury. Short-term effectiveness will be moderate due to the possibility for worker
Part II 12-2
-------
exposure during construction. This alternative will not reduce toxicity, mobility, or volume through treatment.
Implementability of Alternative 4 is high, because the technology, personnel, and materials are readily
available. Institutional Controls are required for the selected option.
Compared to the other alternatives that meet the threshold criteria (3 a and 3b), Alternative 4 will
have the same or greater long-term effectiveness and implementability. Its short-term effectiveness is greater
than that for Alternatives 3a and 3b because of reduced worker exposure to site risks. Its ranking for
reduction of toxicity, mobility, or volume through treatment is the same as for Alternative 2, and is lower
than Alternatives 3a and 3b, because Alternative 4 involves no treatment. The estimated $9.9 million cost is
significantly lower than for Alternatives 3a and 3b. Therefore Alternative 4 is the selected remedy.
12.1.2.3 Performance Standards. The performance standards identified for Alternative 4 include the
following design requirements for the cover:
• Develop and implement surface monitoring and maintenance programs to detect cesium-137
and contain it within the site boundary.
• Institute restrictions limiting land use/access for at least 189 years. Institutional controls will
be maintained and transferred, as applicable, until cesium- 137 has decayed to an acceptable
risk level.
• Implement surface water controls to direct surface water away from the capped drainfield.
• Eliminate, to the extent practicable, the need for ongoing active maintenance following
construction so that only surveillance, monitoring, and minor custodial care are required.
• Design and construct an adequate cover to inhibit erosion by natural processes for the
specified design life of the cover.
• Incorporate features that will inhibit biotic intrusion into the contaminated drainfield.
12.1.3 CFA-10 Transformer Yard (OU 4-09)
12.1.3.1 Selected Remedy. The Agencies have selected Alternative 3b, Excavation, Treatment by
Stabilization, and Off-INEEL Disposal for CFA-10 Transformer Yard. The selected alternative most
cost-effectively meets the threshold and balancing criteria of the three alternatives considered. Under this
alternative, the contaminated soil (approximately 122 m3 [160 yd3) will be excavated. The soil will be
transported to an off-Site disposal facility and soil requiring treatment per 40 CFR 268.49 will be stabilized
before disposal; soil not requiring treatment will be disposed of directly. The excavation will be backfilled
with clean soil, contoured to match the surrounding terrain, sloped to divert water, and revegetated.
This remedy will consist of the following actions:
1. Characterizing the site and excavating soil from CFA-10 that exceeds the lead FRG of 400
mg/kg
2. Performing verification sampling in the excavated yard to ensure that soil exceeding the FRG
of 400 mg/kg for lead has been removed
Part II 12-3
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3. Stabilizing, with cement, soils with lead concentrations above the RCRA characteristic
hazardous waste level of 5 mg/L, if any, and sampling stabilized soil to meet LDRs
4. Transporting and disposing of excavated and stabilized soil to a permitted off-INEEL TSDF
5. Backfilling areas that have been excavated with uncontaminated soil to grade or sloping it to
promote drainage. All excavations will be contoured to match the surrounding terrain and
revegetated.
No long-term ICs are anticipated for the CFA-10 Transformer Yard site, but they will be evaluated
after remedial action.
12.1.3.2 Evaluation. At the CFA-10 site, Alternative 3b is protective of human health and the environment,
and complies with ARARs. The alternative will have high long-term effectiveness because it will remove the
contamination from the INEEL. Its short-term effectiveness will be moderate, because of the possibility for
worker exposure during excavation, transport, and disposal activities. Alternative 3b will not reduce toxicity
through treatment, but will reduce mobility through stabilization. The treatment with cement will increase
volume. Implementability of this alternative is high, because the technology, off-INEEL disposal facility, and
personnel are readily available.
Compared to the other alternatives that meet the threshold criteria (3a and 4), Alternative 3b will have
the same or greater long-term effectiveness and the same short-term effectiveness. It ranks the same or
better compared with the other alternatives for reduction of toxicity, mobility, or volume through treatment.
The implementability of Alternative 3b is greater than other alternatives. The estimated $1.4 million cost is
slightly more than for Alternative 3a but substantially lower than for Alternative 4. Alternative 3b, is relatively
equal in all other respects and was selected by the Agencies because it can be implemented more rapidly than
Alternatives 3 a or 4.
12.1.3.3 Performance Standards. Performance standards will be implemented to ensure that
excavation, treatment, and disposal activities will result in protection against direct exposure to lead during
excavation and after disposal. The performance standards identified for this alternative include:
• Removing lead contaminated soil where concentrations exceeding the FRGs (400 mg/kg) are
detected. Sampling of the stabilized soil to confirm that soil disposed meets treatment
standards for lead and all underlying hazardous constituents.
• Sampling the transformer yard soil to confirm that the cleanup meets or exceeds FRGs.
12.2 Institutional Controls
Institutional controls or land use restrictions will be maintained by DOE at any INEEL CERCLA site
where residual contamination precludes unrestricted land use per EPA Region 10 Policy (EPA 1999a). A site
is considered available for unrestricted land use if potential risks to a current resident are less than 1E-04. ICs
may be discontinued if contaminant conditions or potential risk levels change; if these situations occur, they
will be documented during CERCLA five-year reviews.
In accordance with CFLUP (DOE-ID 1996), DOE will provide ICs for sites subject to land-use
restrictions over the next 100 years unless a CERCLA five-year review concludes that unrestricted land use is
allowable. After 100 years, DOE may no longer manage INEEL activities but controls will remain in place in
the form of land-use restrictions. The Hall Amendment of the National Defense Authorization
Part II 12-4
-------
Act of 1994 (Public Law 103-160) requires concurrence from EPA on the lease of any site on the National
Priorities List (NPL) during the period of DOE-ID control. CERCLA (42 USC 9620 § 120[h]) requires that
the state be notified of a lease involving a site, where contaminants may be present. DOE-ID is also required
under CERCLA (42 USC 9620 § 120[h]) to indicate the presence of contamination and any restrictions at the
time of property transfer.
Table 12-1 summarizes the 1C evaluation for all sites at WAG 4. Long-term ICs are planned for four
sites that include the CFA-08 SP Drainfield and the CFA I, II, and III Landfills (OU 4-12). The Drainfield will
require ICs because of the residual risk from cesium-137 that will remain at the site for approximately 189
years. ICs were identified as part of the selected remedy for the Landfills in the OU 4-12 ROD to ensure that
future activities would not compromise the integrity of the covers (DOE-ID 1995). A description of ICs that
will be applied for these sites is provided in Table 12-2 and the estimated costs for ICs at CFA-0.8 are
included in Table 12-3.
Additional ICs are not planned for CFA-04 Pond and CFA-10 Transformer Yard prior to remediation
since there is only a residential use concern and INEEL has adequate land use controls in place to prevent
residential use during current DOE operations. Also these sites are being permanently fenced with locked
gates and require the approval of the ER WAG 4 Manager and the CFA Site Area Director to enter. Any soil
disturbance would require a Soil Disturbance Notification which requires Agency approval. One of the 47 no
action sites at WAG 4 also requires ICs. The CFA-07 French Drain has residual lead contamination above the
400 mg/kg screening level below 10 ft.
A comprehensive approach for establishing, implementing, enforcing, and monitoring institutional
controls will be developed in accordance with Environmental Protection Agency (EPA) "Region 10 Final
Policy on the Use of Institutional Controls at Federal Facilities" (EPA 1999b). The following elements for
WAG 4 institutional controls will be developed in the operation and maintenance (O&M) plan and will involve
a facility-wide land use plan and procedures for controlling activities as outlined in the policy:
• A comprehensive facility-wide list of all WAG 4 areas or locations covered by any and all
decision documents at the facility that have or should have institutional controls for
protection of human health or the environment. The information on this list will include, at a
minimum, the location of the area, the objectives of the restriction or control, the timeframe
that the restrictions apply, and the tools and procedures that the facility will use to implement
the restrictions or controls and to evaluate the effectiveness of the restrictions or controls.
• Cover, and legally bind where appropriate, all entities and persons, including, but not limited
to, employees, contractors, lessees, agents, licensees, and invitees. In areas where the
facility is aware of routine trespassing, trespassers will be covered.
• Cover all activities and reasonably anticipated future activities, including, but not limited to,
any future soil disturbance, routine and nonroutine utility work, well placement and drilling,
recreational activities, groundwater withdrawals, paving, training activities, construction,
renovation work on structures or other activities.
• A tracking mechanism that identifies all land areas under restriction or control.
Part II 12-5
-------
• A process to promptly notify both EPA and the State prior to any anticipated change in land
use designation, restriction, land users, or activity for any institutional control required by a
decision document.
Within 6 months of signature of this ROD, a monitoring report on the status of institutional controls
at WAG 4 will be submitted to the EPA and Idaho Department of Health and Welfare. An updated institutional
control monitoring report will be submitted to the EPA and Idaho Department of Health and Welfare at least
annually thereafter. After the facility's comprehensive facility-wide approach is well established and the
facility has demonstrated its effectiveness, the frequency of future monitoring reports may be modified
subject to approval by EPA and the State. The institutional control monitoring report will contain at a
minimum:
• A description of how DOE is meeting the facility-wide institutional control requirements
• A description of how DOE is meeting the WAG 4 specific objectives, including results of
visual field inspections of all areas subject to WAG 4 specific restrictions
• An evaluation of whether or not all the WAG specific and facility-wide institutional control
requirements are being met
• A description of any deficiencies and the efforts or measures that have been or will be taken
to correct problems.
EPA and State review of the institutional control monitoring report will follow existing procedures
for agency review of documents.
The DOE will notify EPA and the State immediately upon discovery of any activity that is
inconsistent with the WAG specific institutional control objectives, or of any change in the land use or land
use designation of a site addressed in the WAG 4 list of areas or locations covered by institutional controls.
DOE will work together with EPA and the State to determine a plan of action to rectify the situation except in
the case where DOE believes the activity creates an emergency situation, the DOE can respond to the
emergency immediately upon notification to EPA and the State and need not wait for EPA or State input to
determine a plan of action. DOE will identify a point of contact for implementing, maintaining, and monitoring
institutional controls. DOE will also identify what went wrong with the institutional control process, evaluate
how to correct the process to avoid future problems, and implement these changes after consulting with EPA
and the State.
DOE will notify EPA and the State at least 6 months prior to any transfer, sale or lease of any
property subject to institutional controls required by an EPA decision document so that EPA and the State can
be involved in discussions to ensure that appropriate provisions are included in the conveyance documents to
maintain effective institutional controls. DOE will not delete or terminate any institutional control unless EPA
and the State have concurred in the deletion or termination. If it is not possible for DOE to notify EPA and
the State at least 6 months prior to any transfer, sale or lease, then DOE will notify EPA and the State as soon
as possible but no later than 60 days prior to the transfer, sale, or lease of any property subject to institutional
controls.
12.3 Estimated Costs for the Selected Remedies
A summary of the estimated costs for each of the selected remedies for CFA-04, CFA-08 and
CFA-10 is presented in Table 12-3. All initial and future life-cycle costs are normalized to net present
Part II 12-6
-------
value (NPV). The NPV is the cumulative worth of all costs, as of the beginning of the first year of activities,
accounting for inflation of future costs. All NPV costs were estimated assuming variable annual inflation
factors for the first 10 years, per DOE guidance and cost estimating procedures. A constant 5% discount
rate is assumed. An O&M period of 100 years was assumed, consistent with the assumed 100 year
institutional control period. The estimates were prepared to meet the accuracy range of+50% to -30%
required by CERCLA.
It should be noted that the costs presented in Table 12-2 for CFA-04 differ from the costs presented
in the OU 4-13 RI/FS and the Proposed Plan. The revised cost estimate is $4.8 million NPV versus the
previous estimate of $6.9 million NPV. The cost estimate is lower because the five-year review costs have
been reduced and ICDF disposal costs that will be borne by WAG 3 have been eliminated. These
modifications are documented in (DOE-ID 2000d).
Part II 12-7
-------
Table 12-1. Institutional control evaluation for WAG 4 sites.
Site
Code
Site Name
FFA/CO
Classification
Institutional
controls
(Yes/No)
Basis for No Action or Institutional Controls
Description of Institutional
Controls
Evaluations of sites that have had or will have remedial actions.
CFA-01 Landfill I
CFA-02 Landfill II
CFA-03 Landfill III
CFA-04 Pond
OU 4-12 RI/FS
Yes
CFA-08
Sewage Plant
Drainfield
OU 4-05 Track 2
OU4-13 RI/FS
OU 4-08 Track 2
OU 4-13 RI/FS
No
Yes
CFA-10
Transformer
Yard
OU 4-03 Track 2
OU 4-13 RI/FS
No
Evaluation of no action and no further action sites.
CFA-05 Motor Pool OU 4-11 ROD No
Pond OU 4-13 RI/FS
Landfill waste was left in place after remediation
under the OU 4-12 ROD. Risks for all exposure
pathways are less than 1E-04. A groundwater
monitoring plan for the remaining 26 years out of 30
years is in place.
Future 100-year residential hazard index of 80 which
will be remediated per this ROD.
Current occupational risk is 2E-03. Future 100-year
residential risk is 4E-04. Contaminated soil will be
left in place after implementation of the remediation
prescribed in the ROD.
Lead concentration in excess of the EPA residential
screening level of 400 mg/kg will be remediated per
this ROD.
All human health risks are less than 1E-06 and the
hazard index is less than 1. This site was determined
to be a no action site in the OU 4-11 ROD, was
further evaluated and determined to be a no action
site in the OU 4-13 RI/FS.
Maintain land use controls and
re-evaluate at the five-year
review.
None
Maintain land use controls for
189 years to inhibit intrusion
into the buried waste. Restrict
residential land use until risk is
less than 1E-04 (2.3 pCi/g
cesium-13 7) or the released
based on the results of a five-
year review.
None
None
Part II 12-8
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Table 12-1. (continued).
Site
Code
CFA-06
CFA-07
CFA-08
CFA-09
Site Name
Lead Shop
(outside
areas)
French Drains
E/S
(CFA-633)
Sewage
Treatment
Plant
Pipeline
Central
Gravel Pit
FFA/CO
Classification
OU 4-06 Track 2,
Time Critical
Removal Action
OU 4-13 RI/FS
OU 4-07 Track 2
Non-time critical
removal action
OU4-13 RI/FS
OU 4-08 Track 2
OU 4-13 RI/FS
OU 4-08 Track 2
OU 4-13 RI/FS
OU 10-05
Interim Action
Institutional
controls
(Yes/No) Basis for No Action or Institutional Controls
No Lead and arsenic contaminated soil removed. Lead
concentrations are below the 400 mg/kg screening
level. Arsenic slightly above background, is naturally
occurring. No quantifiable risk or hazard was evident
after removal action. This site was determined to be
a no action site in the OU 4-13 RI/FS.
Yes French drains were removed. Total Risk is less than
1E-06. Total hazard index is less than 1 for
contaminants between the surface and 3 m (10 ft)
below grade. Suspected lead concentrations above
400 mg/kg and radionuclides at depths greater than 4
m (13 ft). This site is recommended as a no further
action site per this ROD.
No All risks are less than 1E-06 and the hazard index is
less than 1 . This site was determined to be a no
action site in the OU 4-13 RI/FS.
No No COCs. No quantifiable risk or hazard.
No Using geophysical techniques a suspected
ordnance shell was not located. No quantifiable
Description of Institutional
Controls
None
Limit land use at depths greater
than 3 m (10 ft) until otherwise
evaluated and documented in a
five-year review.
None
None
NA
ROD
risk or hazard was indicated. This site was
determined to be a no action site in OU 10 -05
Interim Action ROD.
Part II 12-9
-------
Table 12-1. (continued).
Site
Code
Site Name
FFA/CO
Classification
Institutional
controls
(Yes/No)
Basis for No Action or Institutional Controls
Description of Institutional
Controls
CFA-11 French Drain
OU 10-05 Interim
Action ROD
No Using geophysical techniques a suspected ordnance
shell was not located. No quantifiable risk or hazard.
This site was determined to be a no action site during
the OU 10-05 Interim Action ROD.
None
CFA-12
CFA-13
CFA-14
CFA-15
French Drains
(2)
(CFA-690)
Dry Well
(south of
CFA-640)
Two Dry
Wells
Dry Well
(CFA-674)
OU 4-07 Track 2
Time-critical
Removal Action
OU 4-13 RI/FS
OU 4-02 Track 1
Non-time Critical
Removal Action
OU 4-13 RI/FS
OU 4-02 Track 1
OU 4-02 Track 1
Non time Critical
Removal Action
OU 4-13 RI/FS.
No The dry wells were removed. Contamination
removed to basalt. All risks are less than 1E-06 and
the hazard index is less than 1. This site was
determined to be a no action in the OU 4-13 RI/FS.
No The dry well was removed. Total risk is less than
1E-06 for and current and future resident, after
elimination of naturally occurring Ra-226 and
arsenic. Total hazard index is less than 1 for current
and future resident. This site was determined to be a
no action site in the OU 4-13 RI/FS.
No Dry wells were never found after demolition of
Building CFA-665 in 1998. Original building plans
indicate they would have received rainwater from
roof drains. No quantifiable risk or hazard was found
at this site. This site was eliminated as a no action
site from the OU 4-13 RI/FS.
No The drywell was removed. Risk is less than 1E-06
for current and future resident after elimination of
naturally occurring Ra-226. This site was determined
to be a no action site in the OU 4-13 RI/FS.
None
None
None
None
Part II 12-10
-------
Table 12-1. (continued).
Site
Code
CFA-16
CFA-17
CFA-18
CFA-19
CFA-20
CFA-21
Site Name
Dry Well
(south of
CFA-682
pumphouse)
Fire
Department
Training
Area, bermed
Fire
Department
Training Area,
Oil Storage
Tanks
Gasoline
Tanks (2)
EastofCFA-
606
Fuel Oil Tank
at CFA-609
(CFA-732)
Fuel Tank at
Nevada
Circle 1
(South by
CFA-629)
FFA/CO
Classification
OU 4-02 Track 1
OU 4-05 Track 2
Non-time Critical
Removal Action
OU 4-13 RI/FS
OU 4-03 Track 1
OU 4-02 Track 1
OU 4-03/-12 ROD
OU 4-02 Track 1
OU 4-03/-12 ROD
OU 4-02 Track 1
OU 4-03/-12 ROD
Institutional
controls Description of Institutional
(Yes/No) Basis for No Action or Institutional Controls Controls
No The drywell was left in place. No quantifiable risk or
hazard to residential receptor was identified. This site
was eliminated as a no action site in the OU 4-13
RI/FS.
No Contaminated soil removed. All risks are less than
1E-06 and the hazard index is less than 1. This site was
determined to be a no action site in the OU 4-13
RI/FS.
No The tank was removed with no evidence of leakage.
No quantifiable risk or hazard. This site was
determined to be a no action site in the OU 4-03/-12
ROD.
No The former tank location was investigated with ground
penetrating radar; tanks were not located. No
quantifiable risk or hazard was found at this site. This
site was determined to be a no action site in the OU
4-03 /- 12 ROD and was not further evaluated in this
ROD.
No The tank was removed. No quantifiable risk or hazard
was found at this site. This site was determined to be a
no action site in the OU 4-03/12 ROD.
No The tank was removed. No contaminants were
detected that exceed 1E-06 risk-based concentrations.
This site was determined to be a no action site in the
OU 4-03/12 ROD and was not further evaluated in this
ROD.
None
None
None
None
None
None
Part II 12-11
-------
Table 12-1. (continued).
Site
Code
CFA-22
CFA-23
CFA-24
CFA-25
CFA-26
CFA-27
FFA/CO
Site Name Classification
Fuel Oil at OU 4-03 Track 2
CFA-640
Fuel Oil Tank OU 4-03 Track 1
at CFA-641
Fuel Oil Tank OU 4-03 Track 1
at Nevada OU 4-03/- 1 2 ROD
Circle 2
(South by
CFA-629)
Fuel Oil Tank OU 4-02 Track 1
at CFA-656 OU 4-03/-12 ROD
(North Side)
CFA-760 OU 4-09 Track 2
Pump Station
Fuel Spill
Fuel Oil Tank OU 4-03 Track 1
at CFA-669 OU 4-03/-12 ROD
(CFA-740)
Institutional
controls Description of Institutional
(Yes/No) Basis for No Action or Institutional Controls Controls
No The tank was removed. Contaminants in remaining soil
were analyzed and evaluated to have a risk less than
1E-06 and a hazard index less than 1. This site was
eliminated as a no action site in the OU 4-13 RI/FS.
No The tank was removed. No contaminants were
detected that exceed 1E-06 risk-based concentrations.
This site was determined to be a no action site in the
OU 4-03/-12 ROD.
No The tank was removed. No holes or signs of leakage
were observed. This site was determined to be a no
action site in the OU 4-03/-12 ROD.
No The tank was removed. No evidence of leakage
observed. No contaminants were detected that exceed
1E-06 risk-based concentrations. This site was
determined to be a no action site in the OU 4-03/-12
ROD.
No The tank was removed. All risks due to soil exposure
are less than 1E-06 and the hazard index is less than 1.
This site was determined to be a no action site in the
OU 4-13 RI/FS.
No The tank was removed. Contaminated soil was
removed. No contaminants were detected that exceed
1E-06 risk-based concentrations. This site was
determined to be a no action site in the OU 4-03/-12
ROD.
None
None
None
None
None
None
Part II 12-12
-------
Table 12-1. (continued).
Site
Code
CFA-28
CFA-29
CFA-30
CFA-31
CFA-32
CFA-33
FFA/CO
Site Name Classification
Fuel Oil Tank OU 4-03 Track 1
at CFA-674 OU 4-03/-12 ROD
(West)
Waste Oil OU 4-03 Track 2
Tank at CFA- OU 4-03/-12 ROD
664
Waste Oil OU 4-03 Track 2
Tank at CFA- OU 4-03/-12 ROD
665, active
Waste Oil OU 4-03 Track 1
Tank at CFA-
754, active
Fuel Oil Tank OU 4-03 Track 1
CFA-667 OU 4-03/-12 ROD
(North Side)
Fuel Tank at OU 4-03 Track 1
CFA-667 OU 4-03/-12 ROD
(South Side)
Institutional
controls Description of Institutional
(Yes/No) Basis for No Action or Institutional Controls Controls
No The tank was removed. No evidence of leakage was
found. No contaminants were detected that exceed
1E-06 risk-based concentrations. This site was
determined to be a no action site in the OU 4-03/-12
ROD.
No The tank was removed. Contaminated soil was
removed. No contaminants were detected that exceed
risk-based concentrations. This site was determined
to be a no action site in the OU 4-03/-12 ROD.
No The tank was removed. Contaminated soil was
removed. No contaminants were detected that exceed
1E-06 risk-based concentrations. No active
quantifiable risk or hazard was found. This site was
determined to be a no action site in the OU 4-03/-12
ROD.
No The tank was removed. Contaminated soil was
removed. No contaminants were detected that exceed
1E-06 risk-based concentrations. This site was
determined to be a no action site in the OU 4-03 1-12
ROD.
No The tank was removed. No evidence of leakage was
found. No contaminants were detected. This site was
determined to be a no action site in the OU 4-03/-12
ROD.
No The tank was removed. Contaminated soil near
filling post was removed. This site was determined
to be a no action site in the OU 4-03/-12 ROD.
None
None
None
None
None
None
Part II 12-13
-------
Table 12-1. (continued).
Site
Code
CFA-34
Site Name
Diesel Tank at
FFA/CO
Classification
OU 4-03 Track 1
Institutional
controls
(Yes/No)
No
Basis for No Action or Institutional Controls
The tank was removed. Contaminated soil was
Description of Institutional
Controls
None
CFA-35
CFA-674
(South)
Sulfuric Acid
Tank at
CFA-674
(West Side)
OU 4-03/-12 ROD
OU 4-03 Track 1
OU 4-03/-12 ROD
CFA-36 Gasoline Tank OU 4-03 Track 1
at CFA-680
OU 4-03/-12 ROD
CFA-37 Diesel Tank OU 4-03 Track 1
at CFA-681
(South Side) OU 4-03/-12 ROD
CFA-38 Fuel Oil
Tank,
CFA-683
CFA-39 Drum Dock
(CFA-771)
OU 4-04 Track 1
OU 4-03/-12 ROD
OU 4-03 Track 1
OU 4-03/-12 ROD
removed. This site was determined to be a no action
site in the OU 4-03/-12 ROD.
No The tank was removed. No evidence of leakage was
found. No contaminants were detected that exceed
1E-06 risk-based concentrations. This site was
determined to be a no action site in the OU 4-03/-12
ROD.
No The tank was removed. No evidence of leakage was
found. No contaminants were detected that exceed
1E-06 risk-based concentrations. This site was
determined to be a no action site in the OU 4-03/-12
ROD.
No The tank was removed. No evidence of leakage was
found. No contaminants were detected that exceed
1E-06 risk-based concentrations. No quantifiable risk
or hazard. This site was determined to be a no action
site in the OU 4-03/-12 ROD.
No The tank was removed. No contaminants were
detected that exceed is less than risk-based
concentrations. This site was determined to be a no
action site in the OU 4-03/-12 ROD.
No No source-term. This site was determined to be a no
action site in the OU 4-04 Track 1.
None
None
None
None
None
Part II 12-14
-------
Table 12-1. (continued).
Site
Code
CFA-40
CFA-41
CFA-42
CFA-43
CFA-44
CFA-45
Site Name
Returnable
Drum
Storage-South
ofCFA-601
Excess Drum
Storage —
south of
CFA-674
Tank Farm
Pump Station
Fuel Spills
Lead Storage
Area
Spray Paint
Booth Drain
Underground
Storage Tank
FFA/CO
Classification
OU 4-04 Track 1
OU 4-04 Track 1
OU 4-09 Track 2,
Non-time Critical
Removal Action
OU 4-13 RI/FS
OU 4-06 Track 2,
Time Critical
Removal Action
OU 4-13 RI/FS
OU 4-06 Track 2,
Time Critical
Removal Action
OU 4-13 RI/FS
OU 4-03 Track 2
Institutional
controls Description of Institutional
(Yes/No) Basis for No Action or Institutional Controls Controls
No No quantifiable risk or hazard was found. This site
was determined to be a no action site in the OU 4-04
Track 1.
No No contaminants were detected that exceed 1E-06
risk-based concentrations. This site was determined
to be a no action site in the OU 4-04 Track 1 .
No Petroleum contaminated soil was removed. All risks
are less than 1E-06 and the hazard index is less than
1 . This site was determined to be a no action site in
the OU 4-13 RI/FS.
No Lead and antimony contaminated soil was removed.
Lead and antimony concentrations are less than 400
mg/kg screening level and risk- based concentration
of 31, respectively. This site was determined to be a
no action site in the OU 4-13 RI/FS.
No Lead concentrations are less than 400 mg/kg
screening level. This site was determined to be a
no action site in the OU 4-13 RI/FS.
No No contaminants were detected that exceed 1E-06
risk-based concentrations. This site was eliminated as
None
None
None
None
None
None
a no action site in the OU 4-13 RI/FS.
Part II 12-15
-------
Table 12-1. (continued).
Site
Code
Site Name
FFA/CO
Classification
Institutional
controls
(Yes/No)
Basis for No Action or Institutional Controls
Description of Institutional
Controls
CFA-46 Cafeteria Oil
Tank Spill
(CFA-721)
CFA-47 Fire Station
Chemical
Disposal
CFA-48
Chemical
Washout South
of CFA-633
CFA-49 Hot Laundry
(Part of Drain Pipe
CFA-08
SP)
CFA-50 Shallow Well
East of
CFA-654
OU 4-09 Track 2
OU 4-13 RI/FS
OU 4-05 Track 2,
Non-time Critical
Removal Action
OU 4-13 RI/FS
OU 4-07 Track 2
OU 4-08 Track 2,
OU 4-13 RI/FS
OU 4-05 Track 2,
CFA-51 Drywellat OU 4-13 RI/FS
North End of
CFA-640
No All risks are less than 1E-06 and the hazard index is
less than 1. This site was determined to be a no
action site in the OU 4-13 RI/FS.
No Petroleum contaminated soil removed. Lead
concentrations are less than 400 mg/kg screening
level. Total risk is less than 1E-06 for current and
future resident. Total hazard index is less than 1 for
current and future resident. This site was determined
to be a no action site in the OU 4-13 RI/FS.
No No COCs identified, however mercury was detected.
Total risk is N/A. Total hazard index is less than 1
for current and future resident. This site was
eliminated as a no action site in the OU 4-13 RI/FS.
No No COCs identified. All risks are less than 1E-06
and the hazard index is less than 1. This site was
determined to be a no action site in the OU 4-13
RI/FS.
No No COCs identified. Lead concentrations are less
than 400 mg/kg. Risk - Not quantifiable, Total HI is
less than 1. This site was eliminated as a no action
site in the OU 4-13 RI/FS.
No No COCs identified. Lead concentrations are less
than 400 mg/kg. This site was determined to be a no
action site in the OU 4-13 RI/FS.
None
None
None
None
None
None
Part II 12-16
-------
Table 12-1. (continued).
Institutional
Site FFA/CO controls Description of Institutional
Code Site Name Classification (Yes/No) Basis for No Action or Institutional Controls Controls
CFA-52 Diesel Fuel OU 4-13 RI/FS No All risks are less than 1E-06 and the hazard index None
UST (CFA- less than 1. This site was determined to be a no
730) at Bldg action site in the OU 4-13 RI/FS.
CFA-613
Bunkhouse
Part II 12-17
-------
Table 12-1. Institutional control requirements for WAG 4 Remediated sites.
Timeframe
Land
Restriction3
Exposure
Concern
Objective
Controls
Regulatory Basis or Authority
Site CFA-01, CFA-02, CFA-03 Landfills I, II and III, respectively, (OU 4-12). Cumulative risk is less than 1E-04 for future resident. Covers
emplaced as presumptive remedies.
Current DOE
operations
Landfill— no
unauthorized
intrusion into
capped area
DOE control Landfill— no
post unauthorized
operations intrusion into
(i.e., after capped area
operations
cease)
Buried
waste
including
abestos
Buried
waste
including
abestos
Maintain
integrity of
soil cover
Maintain
integrity of
soil cover
1. Visible access restrictions
(warning signs and permanent
markers)
2. Control of activities (drilling or
excavating and drilling of
Federal Facility Agreement and Consent Order
(DOE-ID 1991)
National Oil and Hazardous Substances Pollution
Control Plan (40 CFR Part 300)
residential drinking water wells) CERLA [42 USC 9620 § 120(h)]
Publication of surveyed
boundaries and descriptions of
controls in the INEEL Land Use
Plan (DOE-ID 1996)
Visible access restrictions
(warning signs)
2. Control of activities (drilling or
excavating)
3. Property lease requirements
including control of land use
consistent with this ROD
4. Notice to affected stakeholders
(e.g., Bureau of Land
Management, Sho-Ban Tribal
Council, local county
governments, IDHW, and EPA)
for any change in land-use
designation, restriction, or land
users
Federal Facility Agreement and Consent Order
(DOE-ID 1991)
CERCLA [42 USC 9620 § 120(h)(5)]b
Hall Amendment of the National Defense
Authorization Actc (Public Law 103-160)
Property release restrictions (DOE Order 5400.5)
Part II 12-18
-------
Table 12-1. (continued)
Timeframe
Land
Restriction3
Exposure
Concern
Objective
Controls
Regulatory Basis or Authority
Post DOE Landfill—no Buried Maintain
control unauthorized waste integrity of
intrusion into including soil cover
capped area abestos
Property transfer requirements
including issuance of a finding of
suitability to transfer and control of
land use consistent with this ROD.
FFA/CO(DOE-LD1991)
CERLA [42 USC 9620 § 120(h)(3)]d
CERCLA [42 USC 9620 § 120(h)(3)(C)(ii)]c
CERCLA [42 USC 9620 § 120(h)(3)(A)(m)]f
CERCLA [42 USC 9620 § 120(h)(l)-(3)]g
CERCLA [42 USC 9620 § 120(h)(4)]h
Property relinquishment notification (43 CFR
Criteria for Bureau of Land Management
Excess property reporting requirements
Property release restrictions (DOE Order 5400.5)
CFA-08 Sewage Plant Drainfield. Subsurface radiological contamination to be remediated by capping in accordance with this ROD. Contaminant
of Concern cesium-137
Current DOE Industrial Radionucli
operations— des—extern
prior to al radiation
remediation
1. Visible access restrictions
(radioactivity barriers)
Prevent
exposure to
contaminate
d soil, except 2. Control of activities (drilling or
for approved excavating)
activities
pursuant to
the FF A/CO
FFA/CO(DOE-LD1991)
Worker protection (10 CFR 835)
National Oil and Hazardous Substances Pollution
Control Plan (40 CFR Part 300)
CERCLA [42 USC 9620 § 120(h)]
Radiation protection of the public and AL ARA
principles (DOE Order 5400.5)
Part II 12-19
-------
Table 12-1. (continued).
Timeframe
Land
Restriction*
Exposure
Concern
Objective
Controls
Regulatory Basis or Authority
Current DOE
operations
after
remediation
DOE control
post
operations
Landfill—no
unauthorized
intrusion into
capped area
Landfill—no
unauthorized
intrusion into
capped area
Exposure to Maintain
subsurface integrity of
soil and containment
buried waste barrier
Exposure to Maintain
subsurface integrity of
soil and containment
buried waste barrier
1. Visible access restrictions
(warning signs)
2. Control of activities (drilling or
excavating)
3. Publication of surveyed
boundaries and descriptions of
land-use controls in the INEEL
Land Use Plan (DOE-ID 1996)
1. Visible access restrictions
(warning signs)
2. Control of activities (drilling or
excavating)
3. Property lease requirements
including control of land-use
consistent with this RODs
FF A/CO (DOE-LD 1991)
Worker protection (10 CFR 835)
National Oil and Hazardous Substances Pollution
Control Plan (40 CFR Part 300)
CERCLA [42 USC 9620 § 120(h)]
Radiation protection of the public and AL ARA
principles (DOE Order 5400.5)
FF A/CO (DOE-LD 1991)
CERCLA [42 USC 9620 § 120(h)(5)]b
Hall Amendment of the National Defense
Authorization Act0 (Public Law 103-160)c
Property release restrictions (DOE Order 5400.5)
Post DOE
control
Landfill—no
unauthorized
intrusion into
capped area
Exposure to Maintain
subsurface integrity of
soil and containment
buried waste barrier
Property transfer requirements
including issuance of a finding of
suitability to transfer and control of
land use consistent with this ROD.
FF A/CO (DOE-LD 1991)
CERCLA [42 USC 9620 § 120(h)(3)]d
CERCLA [42 USC 9620 § 120(h)(3)(C)(ii)]e
CERCLA [42 USC 9620 § 120(h)(3)(A)(ih)]f
CERCLA [42 USC 9620 § 120(h)(l)-(3)]g
CERCLA [42 USC 9620 § 120(h)(4)]h
Property relinquishment notification (43 CFR
Criteria for Bureau of Land Management acceptance
Excess property reporting requirements
Property release restrictions (DOE Order 5400.5)
Part II 12-20
-------
Table 1 2-1 . (continued).
Timeframe
DOE control
post
operations
Land
Restriction3
Limited
residential
Exposure
Concern
Various-
minimal
concern
Objective
Limit
residential
land use for
depths greater
than 10 feet
Controls
1 . Visible access restrictions/ signs
2. Property lease requirements
including control of land-use
consistent with this ROD
Regulatory Basis or Authority
FFA/CO (DOE-ID 1991)
CERCLA [42 USC 9620 § 120(h)(5)]b
Hall Amendment of the National Defense Authorization
Post DOE
control
Limited
residential
Various- Limited Property transfer requirements
minimal residential including issuance of a finding of
concern land use suitability to transfer and control of
land use consistent with this ROD.
Act (Public Law 103-160)c
Property release restrictions (DOE Order 5400.5)
FFA/CO (DOE-ID 1991)
CERCLA [42 USC 9620 § 120(h)(3)]d
CERCLA [42 USC 9620 § 120(h)(3)(C)(ii)]e
CERCLA [42 USC 9620 § 120(h)(3)(A)(m)]f
CERCLA [42 USC 9620 § 120(h)(l)-(3)]g
CERCLA [42 USC 9620 § 120(h)(4)]h
Property relinquishment notification (43 CFR 2372-1)1
Criteria for Bureau of Land Management acceptance of
property 43 CFR 2374.2J
Excess property reporting requirements
(41 CFR 101-47.202-l,-2,-7)k
Property release restrictions (DOE Order 5400.5)
a. Institutional controls are applicable only to sites where hazardous substances, pollutants, or contaminants are present that preclude unlimited land use.
Surveillance will be conducted every 5 years to ensure that controls are in place.
b. Notification to states of leases involving contamination. Concurrence of the EPA is requested on leases of NPL (54 FR 48184) sites.
c. Consult with and request concurrence of EPA with proposed leases of sites that are on the NPL.
d. A statement that remedial action is complete is required in the deed.
e. If response action for which the federal government is responsible is not complete, restrictions, the response guarantee, the schedule for investigation and
completion of all necessary response actions, and budget assurances must be included in the deed.
f A clause allowing the U. S. government access to the property must be included in the deed.
g. A notice of information about hazardous substances present on the property must be included in the deed.
h. Uncontaminated parcels of land must be identified and concurred with by the EPA administrator before termination of operations.
i. A Notice of Intent with contamination information and protection needs is required to relinquish the property to the U. S. Department of Interior.
j. Transfer to the U.S. Department of Interior must indicate continuation of DOE responsibility, as applicable.
k. Report to the General Services Administration on contamination information and allowable land use for excess real property.
Part II 12-21
-------
Table 12-3. Cost estimate summary for selected remedy at OU
(CFA-08), AND Transformer Yard (CFA-10).
Planned Activity
FFA/CO management and oversite
Remedial action
Document preparation
RD/RASOW
RA work plan
Packaging, shipping, transportation documentation
Remedial action report
WAG- Wide RA — Five- Year Review
RD documentation preparation
Safety analysis documentation
(ASAandHSP)
Sampling and analysis plan
Prefinal inspection report
Remedial design
Added institutional controls - Five- Year Reviews
Title design construction document package
Remedial action — construction subcontract
Site characterization
Construction subcontract/GFE
Project/construction management allowance
Total Capital Costs
Operations (100-year Duration)
Program management
Continued/new construction CFA
caretaker/maintenance
Surveillance and monitoring
Total Operations Costs
4-13:Pond(CFA-04),
Pond
(CFA-04)
Alternative 3 a
$437,500
$54,000
$63,000
N/A
$48,000
$176,000
$100,500
$108,000
$7,500
$10,000
$85,000
$1,394,000
$1,245,059
$202,701
$3,931,260
N/A
N/A
N/A
0
SP Dramfield
Cost FY-99 (dollars)
SP Dramfield
(CFA-08)
Alternative 4
$312,500
$54,000
$63,000
N/A
$48,000
$811,000
$100,500
$108,000
$7,500
$200,000
$59,500
$248,000
$3,280,000
$534,000
$5,826,000
$3,385,000
$2,460,000
$420,000
$6,265,000
Transformer Yard
(CFA-10)
Alternative 3b
$219,000
$54,000
$63,000
$78,000
$48,000
N/A
$100,500
$108,000
$7,500
N/A
$60,000
$76,000
$322,000
$37,000
$1,173,000
N/A
N/A
N/A
0
Part II 12-22
-------
Table 12-3. (continued).
Planned Activity
Capital Cost Subtotal
Contingency @ 30%
Total Capital Cost in FY99 Dollars
Total Capital Cost in Net Present Value
O&M Cost Subtotal
Contingency @ 30%
Total O&M Cost in FY99 Dollars
Total O&M Cost in Net Present Value
Total Project Cost in FY 1999 Dollars
Total Project Cost in Net Present Value Dollars
Cost
Pond
(CFA-04)
Alternative 3 a
$3,931,260
$1,179,378
$5,110,638
$4,766,092
N/A
N/A
N/A
N/A
$5,110,638
$4,766,092
FY-99 (dollars)
SP Drainfield
(CFA-08)
Alternative 4
$5,826,000
$1,747,800
$7,573,800
$6,508,000
$6,265,000
$1,879,500
$8,144,500
$3,486,000
$15,718,300
$9,994,000
Transformer
Yard
(CFA-10)
Alternative 3b
$1,173,000
$351,900
$1,524,900
$1,442,000
N/A
N/A
N/A
N/A
$1,524,900
$1,442,000
ASA = Auditable Safety Analysis
HSP = Health and Safety Plan
GFE = government furnished equipment.
Part II 12-23
-------
13. STATUTORY DETERMINATIONS
13.1 CFA-04Pond
13.1.1 Protection of Human Health and the Environment
The selected remedy for CFA-04 Pond—excavation and disposal of mercury-contaminated soil to an
approved facility at INEEL—provides highly effective, long-term protection of human health and the
environment. The selected remedy most cost-effectively meets the threshold and balancing criteria of the
three remedies considered. The removal of the mercury-contaminated soil from CFA-04 will eliminate
potential short-term and long-tern human health and environmental threats. The ICDF will provide isolation of
the contaminated soil and prevent adverse effects to human health or the environment.
13.1.1.1 Compliance with ARARs. The selected remedy will be designed to comply with all
action-specific and location-specific federal and state ARARs as listed in Table 13-1. The selected remedial
design will achieve the FRG of 0.50 mg/kg for mercury. This represents 10 times the background
concentration of mercury. Available data indicate that approximately 612 m3 (800 yd3) of soil to be excavated
from CFA-04 contain levels of leachable mercury above the RCRA characteristic hazardous waste levels.
This soil will be treated prior to disposal to meet applicable RCRA land disposal restriction treatment
standards. All applicable emission control standards shown in Table 13-1 will be met during the excavation
and disposal of the soil. Applicable provisions of Department of Energy Order 5400.5, Radiation Protection
of the Public and the Environment will be met. The selected remedy will comply with all ARARs.
13.1.2 Cost-Effectiveness
Cost-effectiveness is a determination of whether the cost of a remedy is proportional to the overall
effectiveness of the remedy. The long-term effectiveness is rated as high because mercury-contaminated soil
will be permanently removed and disposed of to a RCRA-compliant facility. The portion of the soil that
exceeds RCRA characteristic hazardous waste levels will be treated by stabilization with cement to achieve
land disposal restrictions. A reduction in mobility for that portion of the contaminated soil will be achieved.
The short-term effectiveness is moderate because some workers may be exposed to contaminated soil during
excavation. Off-INEEL disposal could be implemented sooner than on-INEEL disposal. However, the costs
would almost double if off-site disposal is required. The selected remedy is the most cost-effective
alternative.
13.1.3 Use of Permanent Solutions and Alternative Treatment Technologies
The selected remedy uses a permanent solution to the maximum extent practicable. Treatment
through stabilization with cement will be used for that portion of the soil that exceeds the TCLP standard for
mercury. The mobility of mercury in CFA-04 soil above the FRG will be reduced by placement in an
approved disposal facility. Mercury-contaminated soil above the FRG will be permanently removed from the
CFA-04 Pond and disposed in an approved facility, thereby eliminating human and environmental exposure.
This alternative will prove to be very effective in the long term and provides the best balance between
long-term effectiveness and permanence.
13.1.4 Preference for Treatment as a Principal Element
Alternatives incorporating ex situ treatment of the mercury-contaminated soil do not significantly
increase the long-term effectiveness, permanence, or protection of human health and the environment-
Part II 13-1
-------
Table 13-1. ARARs and TBCs for the selected remedies for CFA-04, CFA-08, and CFA-10
Category
Citation
Reason
Relevancy3
Action Specific ARARs
Rules for the Control of Air
Pollution in Idaho
National Emission Standards for
Hazardous Air Pollutants
Resource Conservation and
Recovery Act— Standards
Applicable to Generators of
Hazardous Waste
Toxic Air Emissions
(IDAPA 16.01.01.585 and .586)
Fugitive Dust
(IDAPA 16.01.01.650 and .651)
Radionuclide Emissions from
DOE Facilities
(40CFR61.92)
Emission Monitoring
(40CFR61.93)
Hazardous Waste Determination
(IDAPA 16.01.05.006)
(40CFR262.il)
Temporary Units
IDAPA 16.01.05.008
(40 CFR 264.553)
Remediation waste stagging piles
IDAPA 16.01.05.008
(40 CFR 264.554)
Storm water discharge during
construction
40 CFR 122.26
Land disposal restrictions (LDR)
IDAPA 16.01.05.011
(40 CFR 268)
Alternative LDR treatment
standards for contaminated soils
IDAPA 16.01.05.011
(40 CFR 268.49)
The release of carcinogenic and noncarinogenic
contaminants into the air must be estimated before the start
of construction, controlled, if necessary, and monitored
during excavation and sorting of soil.
Requires control of dust during excavation and removal of
soil.
Limits exposure of radioactive contamination release to 10
mrem/year for the off-Site receptor and establishes
monitoring and compliance requirements.
A hazardous waste determination is required for the soil and
any secondary waste generated during remediation. Not an
ARAR for CFA-08.
Applies to temporary (<1 year) storage or treatment units.
Excavated soils can be temporarily stage prior to disposal.
Will be met during excavation and disposal through
engineering controls.
Applies only to soils that have triggered placement. Not for
CFA-08.
Applies only to soils that have triggered placement, not for
CFA-08.
A
A
A
A
A
A
A
A
A
Part II 13-2
-------
Table 13-1. (continued).
Category
Citation
Reason
Relevancy3
Chemical-specific
Location-Specific ARARs
National Historic Preservation
Act
Native American Graves
Protection and Repatriation Act
Closure and Post Closure Care of
Landfills
40CFR264.310(a)(l-5)
Hazardous waste characteristics
identification
IDAPA 16.01.05.005
(40 CFR 261.20-24)
Historic properties owned or
controlled by Federal Agencies (16
USC 4691.2)
Identifying Historic Properties (36
CFR 800.4)
Assessing Effects
(36 CFR 800.5)
Custody
(25 USC 3002)
Repatriation
(25 USC 3005)
(43 CFR 10.10)
To-be considered (TBC) guidance
Radiation protection of the (DOE Order 5400.5, Chapter II
Public and the Environment for [1] [a,b])
CFA-OS only
Although waste in CFA-08 is not RCRA hazardous, the
design and maintenance for soil cover will be followed
Applies if the soils are excavated and consolidated to
facilitate their management and for soils that are treated or
placed in a long-term storage unit.
The site must be surveyed for cultural and archeological
resources before construction and for appropriate actions
taken to protect any sensitive resources
The site must be surveyed for cultural and archeological
resources prior to construction and for appropriate actions
taken to protect any sensitive resources.
Limited the effective dose to the public from exposure to
radiation source and airborne releases.
a. Relevancy:
A = Applicable
B= TBCs are not classified as applicable or relevant and appropriate.
LDR - Land Disposal Restrictions
B
A
A
A
A
A
A
B
Part II 13-3
-------
than removal and disposal alone. These methods are also more expensive. Treatment is only required for the
portion of soil with mercury concentrations in excess of the RCRA characteristic hazardous waste levels for
land disposal. The statutory preference for treatment is achieved to the maximum extent practicable.
13.1.5 Five-Year Reviews
Because this remedy will remove hazardous substances and contaminants above levels that allow for
unlimited use and unrestricted exposure, five-year statutory reviews will not be required.
13.2 CFA-08 Sewage Plant Drainfield (OU 4-08)
13.2.1 Protection of Human Health and the Environment
The selected remedy for the CFA-08 SP Drainfield—containment of cesium-137- contaminated soil
through capping—provides effective, long-term protection of human health and the environment. The
selected remedy most cost-effectively meets the threshold and balancing criteria of the three remedies
considered. It effectively isolates the contaminated soil and breaks the external exposure pathway in both the
short- and long-term. Natural radioactive decay is projected to reduce the cesium-137 concentrations to
levels that do not pose an unacceptable risk to human health and the environment in 189 years.
13.2.1.1 Compliance with ARARs. The selected remedy will be designed to comply with all
action-specific and location-specific federal and state ARARs as listed in Table 13-1. Available data indicate
that no RCRA contaminated media are present at the CFA-08 drainfield. All applicable emission control
standards shown in Table 13-1 will be met during the construction. DOE Order 5400.5, "Radiation Protection
of the Public and the Environment," (DOE, 1990) will be met by implementing and enforcing applicable
provisions of that order. Therefore, the selected remedy will comply with all ARARs.
13.2.2 Cost-Effectiveness
Cost-effectiveness is a determination of whether the costs of a remedy are proportional to the overall
effectiveness of the remedy. The long-term effectiveness of capping the drainfield is rated as high because it
would break the external exposure pathway until the human health risks from cesium-137 fall below
threshold levels. The short-term effectiveness is moderate, because although the risks from direct exposure
will be reduced in the near future, some workers potentially will be exposed to contaminated soil during
construction. Although the containment remedy is approximately twice as expensive as the Limited Action
(institutional control) alternative, the long-term effectiveness is greater because capping will prevent external
exposure from cesium-137 during the calculated 189-year timeframe required for levels to fall below
acceptable risk levels. Therefore, the selected remedy is the most cost-effective alternative.
13.2.3 Use of Permanent Solutions and Alternative Treatment Technologies
This selected remedy uses a permanent solution to the maximum extent practicable. The engineered
cap is projected to be effective over the 189-year timeframe until natural radioactive decay of cesium-137
causes concentrations to fall below acceptable exposure levels. Therefore, this remedy achieves a high degree
of long-term effectiveness. After 189 years, the remedy can be considered to be permanent because radiation
from cesium-137 will no longer pose an unacceptable risk to human health.
Part II 13-4
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13.2.4 Preference for Treatment as a Principal Element
This remedy does not use treatment to reduce toxicity, mobility or volume for the following reasons.
Natural radioactive decay is the only means to reduce the toxicity of radionuclides. Reduction in mobility is
not applicable because the risk from the cesium-137 contaminated soil is from external exposure. Other
attempts to reduce the volume of radionuclide-contaminated soil through physical separation have not been
successful at the INEEL.
13.2.5 Five-Year Reviews
ICs consisting of monitoring, access restriction, and runoff-control technologies will be used as a part
of this remedy. Therefore, five-year statutory reviews will be required for this remedy.
13.3 CFA-10 Transformer Yard (OU 4-09)
13.3.1 Protection of Human Health and the Environment
The selected remedy for the CFA-10 Transformer Yard—excavation, treatment and disposal of
lead-contaminated soil at an off-site facility—provides highly effective, short- and long-term protection of
human health and the environment. The selected remedy most cost-effectively meets the threshold and
balancing criteria of the remedies considered. The removal of the lead-contaminated soil from CFA-10 will
eliminate potential short-term and long-term human health and environmental threats. A permitted off-site
disposal facility will provide isolation of the contaminated soil and prevent exposure to humans or the
environment.
13.3.1.1 Compliance with ARARs. This selected remedy will be designed to comply with all the
action-specific and location-specific federal and state ARARs listed in Table 13-1. The selected remedial
design will achieve the FRG of 400 mg/kg of lead in soil remaining on site. Excavated soil with lead
concentrations exceeding 5 mg/L TCLP will be stabilized with cement prior to disposal. All applicable
emission control standards will be met during the excavation and disposal of the soil (DOE-ID 1999a).
Therefore, the selected remedy will comply with all ARARs.
13.3.2 Cost-Effectiveness
Cost-effectiveness is a determination of whether the costs of a remedy are proportional to the overall
effectiveness of the remedy. The long-term effectiveness is rated as high because lead-contaminated soil will
be permanently removed and disposed to an approved, permitted off-INEEL facility. The short-term
effectiveness is moderate in that some workers potentially will be exposed to contaminated soil during
excavation. The selected remedy is slightly more expensive than the on-INEEL disposal alternative ($1.4
million vs. 1.3 million, respectively). However, off-INEEL disposal can be implemented sooner because the
ICDF will not be operational until 2004. Therefore, the selected remedy is the most cost-effective alternative.
13.3.3 Use of Permanent Solutions and Alternative Treatment Technologies.
This selected remedy uses a permanent solution to the maximum extent practicable. Treatment through
stabilization with cement, of CFA-10 soil with TCLP concentrations greater than 5mg/kg, will reduce the
mobility of lead. Lead-contaminated soil exceeding the FRG will be permanently removed from the CFA- 10
Transformer Yard and disposed of at an approved off-INEEL facility, thereby
Part II 13-5
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eliminating human and environmental exposure. This alternative will prove to be very effective in the
long-term and provides the best balance between long-term effectiveness and permanence.
13.3.4 Preference for Treatment as a Principal Element
The statutory preference for treatment through reduction in toxicity, mobility, or volume is met to the
maximum extent practicable with the selected remedy. Soil exceeding the lead FRG of 400 mg/kg and the
lead TCLP limit of 5 mg/L will be excavated, stabilized with cement to reduce mobility, and disposed of in an
off-INEEL facility. No treatment technologies exist to reduce the toxicity or volume of lead-contaminated
soil. Therefore, the statutory preference for treatment is achieved to the maximum extent practicable.
13.3.5 Five-Year Reviews
Because this remedy will remove hazardous substances and contaminants above levels that allow for
unlimited use and unrestricted exposure, five-year statutory reviews will not be required.
Part II 13-6
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14. DOCUMENTATION OF SIGNIFICANT CHANGES
14.1 Modification of the Preferred Alternative for CFA-08
Alternatives 3a and 3b for the CFA-08 Sewage Plant Drainfield use SGS as the treatment option in the
Proposed Plan. The SGS was proposed to reduce the volume of contaminated soil disposed to on- or off-
INEEL locations by ex situ separation. A treatability study on SGS was performed by WAG 5 in 1999
(DOE-ID 1999b). The results of the study indicate that cesium-137 contaminated soil at WAG 5 cannot be
successfully sorted to satisfy the 2.3 pCi/g FRG for cesium-137 with any volume reduction. As a result,
Alternatives 3a and 3b are shown without treatment and the preferred remedy is Alternative 4.
14.2 CFA-04 Information
Table 3 on page 11 and Table 7 on page 1 of the Proposed Plan indicate that the human health hazard
index for mercury is 62 at CFA-04. The calculated HQ is 80 as shown in Appendix D, Table D-46 of the
RI/FS (DOE-ID 1999a). The values in the Proposed Plan were taken from Section 7 of the RI/FS, which
was not updated to reflect the calculated risk values prior to finalization.
Table 3 also shows the FRG for mercury at CFA-04 is 0.74 mg/kg, when it is reported in this ROD as
0.5 mg/kg. The 0.5 mg/kg number represents the average background concentration for composited
samples, whereas 0.74 mg/kg is the average background for discrete samples. Because the samples will
be composited for analysis during remediation of the pond, 0.5 mg/kg is the appropriate FRG.
The cost estimate for the selected remedy at CFA-04 was $6.9 million NPV in the RI/FS and the
Proposed Plan, whereas the estimated cost in this ROD is shown in Table 12-3 as $4.8 million NPV. The cost
estimate in this ROD is lower because costs have been recalculated and ICDF disposal costs that will be
borne by WAG 3 have been eliminated from the CFA-04 cost estimate. (These modifications are documented
in DOE-ID 2000d.)
The Proposed Plan states that Alternative 3b, off-INEEL disposal would be the contingent remedy if
the ICDF is not operational. By remediating CFA-04 last (CY-03), it is believed that the ICDF will be
operational for disposal of the contaminated and stabilized soil.
14.3 OU 4-13A Interim Action Proposed Plan
The Proposed Plan for this ROD was titled the OU 4-13 A Interim Action Proposed Plan. The following
paragraphs explain the naming differences between the OU 4-13 RI/FS, the OU 4-13A Interim Action
Proposed Plan, and this OU 4-13 Comprehensive ROD. These changes are a logical outgrowth of the
Proposed Plan and other documents in the AR.
Although no unacceptable risks were identified in the OU 4-13 RI/FS via groundwater use at WAG 4, a
subsequent report for the OU 4-12 Post-ROD monitoring program identified that nitrate in two wells at WAG
4 was above a federal drinking water MCL of 10 mg/L. On this basis, the Agencies initially decided to
separate OU 4-13 into two investigations: OU 4-13A was designated as an Interim Action ROD, and OU
4-13B, which was planned as the groundwater RI/FS. Therefore, the Proposed Plan for the OU 4-13
investigation was retitled the OU 4-13A Interim Action Proposed Plan when it was issued in August 1999.
Subsequent to this decision, information was gathered regarding the likely source and extent of nitrate
in the wells. Additionally, a higher allowable level for nitrate was identified in the Federal Regulations that
apply when the water is not available to infants under 6 months of age. The average nitrate concentration in
one of the subject wells is equal to the MCL; nitrate concentrations in the other
Part II 14-1
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well are less than the allowable MCL and show a downward trend. On that basis, the Agencies decided to
eliminate the OU 4-13B RI/FS and maintain the original name, which is the OU 4-13 Comprehensive ROD.
Groundwater will continue to be evaluated under the OU 4-12 Post-ROD monitoring program.
14.4 Ecological Sites and Risks
On page 8 of the proposed plan, sites that were retained for cumulative site-wide investigation are listed
as CFA-01, CFA-02, CFA-05, CFA-13, CFA-17, CFA-21, CFA-26, CFA-41, CFA-43, and CFA-47. The sites
retained for further evaluation are CFA-01, CFA-02, CFA-05, CFA-13, CFA-41, and CFA-43, based on
further screening of contaminants with HQ less than 10.
On page 7 of the proposed plan, the maximum acceptable level of copper and lead for CFA-10 was
listed as 320 and 400 respectively. The maximum acceptable level, or 10 times background values, listed in
the RI/FS are 220 and 170 respectively.
Part II 14-2
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Part III—Responsiveness Summary
1. INTRODUCTION
The purpose of this Responsiveness Summary is to provide a clear and concise measure of: (1)
which aspects or elements of the alternatives for WAG 4 the community supports, opposes, or has
reservations about, and (2) general concerns about the sites and the CERCLA process at those sites. This
Responsiveness Summary identifies and responds to more than 40 statements of preferences, concerns,
comments, and questions received both as formal statements at three public meetings, held on August 17, 18,
and 19, 1999, and as written comments in more than 10 pages of materials from at least 12 individuals and
interested groups. All comments on the August 1999 Proposed Plan were considered in preparation of the
ROD and this Responsiveness Summary and are included verbatim in the Administrative Record for WAG 4.
The comments cover a wide range of issues, including:
1. The WAG 4 cleanup in general, specific CFA sites, and the proposed INEEL CERCLA
Disposal Facility (ICDF)
2. Past disposal practices
3. Goals for public participation and education
4. The criteria used to compare alternative remedies, identify feasible cleanup methods evaluate
technologies, and ensure long-term protection to human health and the environment
5. Uncertainties associated with the CERCLA process and WAG 4 contamination, specifically.
Written comments received and formal statements made at the public meetings showed that
community acceptance of the preferred alternatives, as presented in the Proposed Plan, ranges from support,
to support with reservations. As documented in this Responsiveness Summary:
1. The preferred alternative of Excavation, Treatment by Stabilization, and On-Site Disposal for
the Pond (CFA-04) was generally supported. Commenters asked for more details on aspects
of cost and technical implementation of the preferred alternative, and clarification of why
phytoremediation could not be considered for this site. This information has been provided
in Section 3.3.1 of this Responsiveness Summary.
2. The preferred alternative of Containment for the Sewage Treatment Plant Drainfield
(CFA-08) was not opposed in any comments received. At the request of several
commenters, additional information describing the contaminant of concern has been
provided in this Responsiveness Summary.
3. The preferred alternative of Excavation, Treatment by Stabilization, and Off-INEEL Disposal
for the Transformer Yard (CFA-10) was supported by public comment. Additional
information on the timing of the remedial action was requested and has been provided in
Section 3.3.2 of this Responsiveness Summary.
During the WAG 4 public comment period, additional questions were submitted on several subjects
not related to the WAG 4 remediation, such as questions about the Advanced Mixed Waste
Part III 1-1
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Treatment Facility. While these queries were not relevant to this Responsiveness Summary, additional
information on these subjects is available by writing or calling:
Ann Riedesel
Public Communications Coordinator
BNFL Inc.
(208) 524-8484
or medeselbnflinc.com
Information about the Advanced Mixed Waste Treatment Project is available on the internet at
http://environment.inel.gov/wm/amwtp.cfm
Copies of all documents referenced in this Responsiveness Summary can be obtained by writing or
calling the INEEL Community Relations Office at the address provided above. Many of the documents also
are available on the internet at httrj://environment.inel.gov/.
Part III 1-2
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2. BACKGROUND ON COMMUNITY INVOLVEMENT
The Proposed Plan for WAG 4 was released in August 1999. During the 30-day public comment
period, three public meetings were held, in Idaho Falls, Boise, and Moscow. The comment period was
extended an additional 30 days in response to requests from members of the public. All written comments
received before the close of the comment periods, and oral comments made during the formal comment
session of each public meeting, are responded to by the Agencies in this Responsiveness Summary.
Each public meeting included an informal question and answer session as well as the formal public
comment session. The meeting format was described in published announcements and meeting attendees
were reminded of the format at the beginning of each meeting. The informal question-and-answer session
was designed to provide immediate responses to the public's questions and concerns. Several questions were
answered during the informal question-and-answer periods during the public meetings on the Proposed Plan.
This Responsiveness Summary does not attempt to summarize or respond to issues and concerns raised
during that part of the public meeting. However, written transcripts of the meetings capture the presentations
and informal questions and answers for members of the public that were unable to attend the meeting. The
transcripts are included in the Administrative Record for WAG 4 and can be found at:
INEEL Technical Library
DOE Public Reading Room
1776 Science Center Drive
Idaho Falls, ID 83415
(208)529-1185
Albertsons Library
Boise State University
1910 University Drive
Boise, ID 83725
(208)385-1621
University of Idaho Library
University of Idaho Campus
434 2nd Street
Moscow, ID 83843
(208)885-6344
An electronic copy of the Administrative Record is available on the internet at http://ar.inel.gov.
Part III 2-1
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3. SUMMARY OF COMMENTS RECEIVED DURING
PUBLIC COMMENT PERIOD
The public comment period for WAG 4 Proposed Plan (DOE-ID 1999c) began on August 5, 1999
ended October 4, 1999. Public meetings on the WAG 4 Proposed Plan were conducted in Idaho Falls on
August 17, Boise on August 18, and Moscow on August 19, 1999. Written comments and the meeting
transcripts are available in the three INEEL information repositories listed in Section 2 as part of the
Administrative Record for the WAG 4 Comprehensive RI/FS.
Five members of the public provided oral comments on the Proposed Plan during the August public
meetings. Eight groups or members of the public provided written comments. The thirteen comments and
questions received during the public comment period have been summarized into succinct statements to
capture the significant issue discussed or information requested and assigned individual numbers The
summaries were then grouped by topics and responses were prepared.
Table 1 identifies the members of the public who provided comments and their affiliation, if any. It
also shows the alphanumeric designation given to their comments. Written comments are numbered Wl
through W7 corresponding with the seven individual commenters or commenting groups who submitted
them. Oral comments transcribed during the formal comment sessions of the public meetings are numbered
according to the location of the meetings and the commenter (IF1 and 1F2 from the Idaho Falls meeting; Bl
and B2 from the Boise public meeting; and Ml from the Moscow public meeting).
Comments were further subdivided by identifying a numbering individual issues contained in the
thirteen oral or written comments. Appendix A contains the original comments in their entirety, either as
scanned written submissions or as public meeting formal comment period transcripts. It also contains a table
showing the numbering system for the individual issues and the respective response number.
The Responsiveness Summary begins with a group of questions and comments on INEEL
environmental remediation goals, the community relations process, and the budget and planning process for
CFA remediation. The second group of questions and comments concerns the comprehensive remedial
investigation and feasibility study (RI/FS) and the activities carried out during this process. The third group
of questions and comments focuses on the individual sites retained for remedial action under this ROD, their
descriptions, and the alternatives developed and evaluated for them. The final group covers tangential but
significant concerns that some commenters felt were related to CFA remediation. Within the first three
groups of questions and comments, issues are presented in an order parallel to the development of topics in
the Proposed Plan. A total of 36 issues or topics are identified in this summary.
3.1 WAG 4 Cleanup and Public Participation
3.1.1 General Comments on WAG 4 Cleanup
1. A commenting group expressed support for the use of disposal and remediation actions that are
technically appropriate and cost-effective. [W6-3] Another commenter expressed a low opinion of
DOE's scientific and technical standards, and asked why better and more efficient cleanup
technologies aren't used. [IF2-1]
Response: The remedial alternatives described in the Proposed Plan were selected from the range
of technologies demonstrated to be effective for sites with similar contaminants and media.
Preference was given to technologies that have been demonstrated at the
Part III 3-1
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Table 3-1. Oral and written comments for the WAG 4 Proposed Plan.
Affiliation or
Commenter Organization
Name (If provided)
Paul Randolph
Charles M. Rice INEEL Citizen Advisory
Board
George Marriott
Jared Newman ONYX Environmental
Services
Warren Adler
John C. Coalition 21
Commander
Charles M. Rice INEEL Citizen Advisory
Board
Beatrice Brailsford Snake River Alliance
Beatrice Brailsford Snake River Alliance
Vaughn Nebeker
Steve Hopkins
Pam Allister
Chuck Broscious
City and State
Sun Valley, ID
Idaho Falls, ID
Rigby, ID
Garden City, ID
Jackson Hole, WY
Idaho Falls, ID
Idaho Falls, ID
Idaho Falls, ID public
meeting
Idaho Falls, ID public
meeting
Boise, ID public
meeting
Boise, ID public
meeting
Moscow, ID public
meeting
Document
Number
Assigned
Wl
W2
W3
W4
W5
W6
W7
W8
LF1
LF2
Bl
B2
Ml
Number of
Comments
Identified
1
1
3
3
1
3
4
11
5
1
4
8
1
Part III 3-2
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INEEL. Innovative and emerging technologies that have been demonstrated at a pilot-scale or
greater also were considered.
Each category of possible remedial actions (e.g., containment; removal and disposal;
removal, treatment, and disposal) includes many potential technologies. The WAG 4
feasibility study considered only those technologies that met or exceeded the criteria of
effectiveness, implementability, and cost. Also considered for each potential technology are:
potential impacts to human health and the environment during implementation; whether the
technology has proven its reliability; whether the required permits can be obtained; whether
treatment, storage, and disposal services are fully available; and the range of equipment and
personnel that are required.
Cleanup activities conducted under CERCLA must be cost-effective. Cost-effectiveness is
determined by evaluating three of the five balancing criteria that determine overall
effectiveness: long-term effectiveness and permanence; reduction of toxicity, mobility, or
volume through treatment; and short-term effectiveness. A remedy is considered to be
cost-effective if its costs are proportional to its overall effectiveness.
2. A commenting group expressed approval that the technical feasibility of the Proposed Plan
alternatives seems straightforward. [W8-1]
Response: Thank you. The feasibility of an alternative is determined by the application of
three criteria: effectiveness (short-term and long-term), implementability, and cost. The
preferred alternatives meet these criteria and this information was communicated in the
Proposed Plan.
3. A commenting group noted that the term "interim action" is defined under CERCLA as "any
action that will not result in full remediation." However, the group emphasized that proposed
remedial actions should constitute final remedies for the contamination sources they are
designed to address. The group wrote that it has repeatedly expressed frustration at cleanup
efforts that must be repeated, at great cost to taxpayers, because prior efforts were
incomplete. All remedial actions taken at WAG 4 should completely and finally address the
contamination present to avoid a need for follow-on remediation. [W7-1]
Response: As explained in Parts I and II, this ROD is now called the Comprehensive ROD.
The selected remedies described in the Proposed Plan constitute final remedies or the three
sites with surface contamination as well as no action sites that require institutional controls.
4. A commenter noted that it seems irrational that DOE dumped powdered waste containing
mercury on the surface but buried less hazardous construction materials. The general DOE
rationale for past disposal practices was questioned. [IF1-5]
Response: Although DOE's past waste treatment, storage, and disposal practices were
considered acceptable at the time, some practices led to the release of contaminants to the
environment. As a result, DOE developed its environmental restoration program in 1989 to
identify and, where necessary, clean up releases from past activities. In addition, a waste
management program was developed to safely treat, store, and dispose of DOE waste
generated by current and planned activities in an environmentally and economically sound
manner.
Part III 3-3
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3.1.2 Public Participation and Community Relations
5. A resident of Jackson Hole, Wyoming, commented on concerns in his region about the
INEEL's general safety record and, specifically, whether there were real dangers to human
health. He asked for information about the INEEL's recent environmental safety record and
about cancer rates around the INEEL in comparison to other areas. He expressed concern
about public ignorance of scientific issues which he feels lead to unwarranted distrust of the
government. The commenter would like to learn more himself as well as to be able to better
discuss issues with neighbors. [W5-1]
Response: The INEEL Health Effects Subcommittee is comprised of approximately 12
members from the public, the State of Idaho, the Shoshone-Bannock tribe, and other interest
lay persons. They are tracking an INEEL Dose Reconstruction project that is being
conducted by the National Center for Environmental Health of the Centers for Disease
Control and Prevention. The purpose of this project is to assess human health effects from
potential exposure to chemicals from the INEEL. The due date for the project report has not
been established, but it is anticipated to be complete in the 1 to 2 year time-frame.
Additionally, your comment was forwarded to the Community Relations Office to provide
you with more information. The phone number is (208) 526-7400.
6. A commenter charged that DOE's public documents, in a pattern too consistent to be other
than intentional, omit facts about the true extent of problems, which can then only be found
through research into the Administrative Record. The commenter expressed disappointment
that the regulatory agencies do not use their review of these documents to require that more
extensive data be presented. [Ml-1]
Response: Data that are salient to the remedial alternative evaluation and selection process
are never intentionally omitted. The Proposed Plan is a summary of those sites at CFA where
remedial action is required to protect human health and the environment from risks posed by
past releases of contamination. It is based on the comprehensive RI/FS for WAG 4. The
Proposed Plan is intended to be a high level document that summarizes the most important
data that lead to a selected remedy; it is not intended to repeat all the data provided in the
baseline documents. The Agencies believe that the Proposed Plan issued in August 1999
adequately summarizes the information in the comprehensive RI/FS.
7. A commenting group and an individual commenter appreciated the willingness of the INEEL
to extend the original 30-day comment period. [W2-1, B2-7]
Response: The Agencies appreciate the public's interest and participation in the public
comment period and were pleased to extend the comment period to allow the public ample
time to prepare their comments.
8. Several commenters took issue with the Proposed Plan's statement that the INEEL
contamination resulted from research activities. One commenter stated that this is a
euphemism for what was really nuclear weapons work. [Bl-1] The majority of
contamination, certainly the most perilous, wrote a commenting group, came from weapons
production activities. [W8-2, B2-8]
Part III 3-4
-------
Response: The Agencies thank you for your input and will consider whether to discuss
past and present defense-related activities as a source of contamination at the INEEL in
future documents.
While the INEEL will most likely continue to support national defense initiatives, its present
mission is to develop and transfer advanced engineering technology and systems to private
industry to improve the competitiveness and security of the nation.
9. A commenting group urged public involvement in setting the waste acceptance criteria for
the INEEL CERCLA Disposal Facility (ICDF). [W8-10] A commenter concerned about the
waste acceptance criteria for disposal on the INEEL urged that there be public involvement
in establishing the ICDF waste acceptance criteria. [B2-5]
Response: The Agencies signed a ROD for the Idaho Nuclear Technology and Engineering
Center (INTEC; formerly the Idaho Chemical Processing Plant) on October 11, 1999. A
major component of the ROD is the construction of the ICDF. The facility will be used to
consolidate radioactively contaminated soil and debris from the INTEC and other areas on
the INEEL. As described in Part II, Section 12.1.1 and 12.1.3, of this ROD, some materials
from CFA are anticipated to be disposed of at the ICDF.
The development of the ICDF itself is part of the remedial design/remedial actions at WAG 3
at the INTEC. DOE has committed to hold at least one public meeting during the WAG 3
remedial design process to solicit input on the ICDF waste acceptance criteria. Questions
about the ICDF can be directed to the INEEL Community Relations Office at (208)
526-4700 or (800) 708-2680.
10. A commenting group asked that the INEEL continue to hold briefings or meetings on all
cleanup activities, progress, and problems. The group recommended quarterly briefings.
[W8-11)
Response: The Agencies encourage citizen involvement in decision-making at the INEEL.
Public meetings held in connection with Proposed Plans for cleanup are one of many
avenues for public involvement. Other avenues include briefings and tours. Postal addresses,
telephone numbers, e-mail addresses, and internet site addresses are provided in all
informational materials published by the INEEL. Citizens can contact INEEL representatives
through these means to get additional information, briefings, or tours from Agency and
project representatives. The range of activities that the public can participate in is described
in the INEEL Community Relations Plan (May 1995) available from the INEEL Community
Relations Office (208) 526-4700 or (800) 708-2680.
3.1.3 Content and Organization of the Proposed Plan
11. A commenter thought that including cancer-causing elements, toxic chemicals, and risks
from lead in Table 1 was confusing. Given the different kinds of uptake criteria, the
commenter said, these risks could not easily be evaluated individually when the data were
combined. An expanded table, or the addition of separate multiple tables, was recommended.
[B2-1]
Response: The comment is noted and appreciated and will be relayed to future Proposed
Plan writers. The table design was an effort to present the three types of data together.
Part III 3-5
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3.1.4 WAG 4 Remediation Planning and Costs
12. A commenter referring to the $18 million estimated cost to clean up the CFA, called
it exorbitant, and wrote that this money should instead be spent at the INTEC. The
commenter noted that these public tax dollars should be spent wisely. [W3-1]
Response: The federal government has an obligation to clean up all contamination
resulting from its past activities that pose a significant risk to human health or the
environment. One of the purposes of doing risk assessment is to determine which
sites create risk as defined by CERCLA. The three sites to be remediated at CFA
have been determined to pose an unacceptable risk to human health.
Cost estimates for the alternatives analyzed during the WAG 4 feasibility study were
developed for comparison purposes only. The estimates were developed on the
basis of a preliminary conceptual design. Many specific details of the alternatives are
not well defined at this time and cannot be included in the estimates. Instead, these
details are accounted for as a contingency cost element in each estimate. The cost
estimates most likely do not reflect the actual cost of implementing an alternative.
Actual project expenditures will likely be less than the cost estimates in the Proposed
Plan. As the project design is finalized, the cost estimates will be refined.
More information about DOE's strategies to improve efficiency and cost saving can
be found in Accelerating Cleanup: Paths to Closure (June 1998) (available from the
INEEL Community Relations Office, (208) 526-4700 or (800) 708-2680, or on the
internet at http://www.em.doe.gov/closure/final/index.html).
13. Several commenters suggested that the assumption of a one-time disposal fee is
optimistic and probably has more to do with INEEL's budget than with taxpayer
costs. Does this cost estimate assumption hide additional costs for use of the ICDF?
[IF 1-3, W8-9]
Response: Typically, disposal facilities charge a one-time fee. The off-INEEL
disposal costs were determined by the existing contract between the INEEL and a
representative off-INEEL disposal facility. The tippage fee is calculated through
determining what the landfill will cost to build and maintain over its life span and
then dividing that dollar amount by the amount of material that can be disposed of in
the landfill. The fee paid to dump each truckload of waste is a portion of the
landfill's lifetime cost.
As with the individual using the local landfill, the INEEL must pay to dispose of
wastes at off-INEEL facilities. However, no fee is paid for facilities on the INEEL.
This is because facilities on the INEEL are funded under a separate line item within
the budget.
The Agencies realize that it is difficult to compare two alternatives when one
includes a tippage fee and the other does not. If WAG 3 were to charge other
INEEL users for the ICDF, the tippage fee would be approximately $104 per cubic
yard. The tippage fee for off-INEEL disposal is approximately $300 per cubic yard.
The off-INEEL disposal fee is based existing contract between the INEEL and a
representative off-INEEL disposal facility.
Part III 3-6
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14. One commenter stated that the Proposed Plan has a lot of fat in it. The commenter
recommended that a panel of experts evaluate this project. [W3-3]
Response: The cost estimates provided in the Proposed Plan are rough estimates given for
the purpose of comparing the remedial alternatives. As the project continues, the known
factors increase, the unknowns and uncertainties decrease, and the cost estimate becomes
more specific to the project. During the design phase, as schedules and specifications are
developed, the cost estimates will become more precise.
The cost estimates are prepared by professional cost estimators with education and
experience comparable to that of professionals in the private sector. Cost estimates for DOE
sites must include worker health and safety concerns related to radiologic concerns that are
not required in the private sector. (The INEEL's Cost Estimating Guide contains more
information about DOE's cost estimating process. It is available at
www.inel.gov/capabilies/cost-estimating/eindex.html on the Internet.)
15. Several comments dealt with the relationship between RCRA and CERCLA. One commenter
questioned whether the distinction between a RCRA landfill and a CERCLA (Superfund)
cleanup site is related to the number of years, or other concerns. [Fl-1] A commenting
group asked for clarification about how the various waste classification types are disposed
of. Are the classifications made in terms of physical, chemical, legal, or political
characteristics? Why is decontamination waste accepted for placement in the Radioactive
Waste Management Complex (RWMC), but not environmental restoration waste? How do
waste types accepted for the RWMC or proposed for the INEEL CERCLA Disposal Facility
(ICDF) differ from those going to the Waste Experimental Reduction Facility (WERF)?
[W8-3]
Response: Both RCRA and CERCLA establish comprehensive regulatory frameworks to
protect human health and the environment from environmental contamination. However,
CERCLA is the more comprehensive statute. The principal distinction between the two
programs is that RCRA authorizes the safe and protective current said future management of
wastes, while CERCLA authorizes cleanup responses whenever there has been a past release
of wastes. The literature on RCRA and CERCLA is extensive, and this response can only
address the points raised by the WAG 4 public comments. (More information about RCRA is
available at http://www.epa.gov/epaoswer/general/orientat/ on the Internet. Information
about CERCLA is available at http://www.epa.gov/superfund/whatissf/cercla.htm on the
Internet.)
The term hazardous waste is defined under RCRA regulations as a waste with physical
and/or chemical properties that make it dangerous to, or capable of having a harmful effect
on, human health or the environment. Classification of waste types is a complicated process
and has resulted in a large number of defined categories of waste, some of which are
present at the INEEL (more information about the waste types can be found at
http://environment.inel.gov/tsd.cfm on the Internet. The amount, status, and handling of the
waste types are summarized in the INEEL Annual Reports available on the Internet at
http://www.inel.gov/environment/annual reports/index.html.
Hazardous substances covered under CERCLA include all RCRA hazardous wastes as well
as toxic pollutants addressed by other regulations. In general, contamination that contains
radionuclides is covered by CERCLA but not RCR-A, and petroleum/natural gas
Part III 3-7
-------
products are covered by RCRA but not CERCLA. CERCLA requires that on-INEEL
remedies meet any legally applicable or relevant and appropriate requirements (ARARs),
including RCRA, unless site-specific waivers are obtained. When hazardous wastes are
transported off a CERCLA site, they are subject to full RCRA regulation: all transportation
and treatment, storage, and disposal requirements under RCRA must be followed. This
ensures that wastes resulting from a CERCLA activity are sent to environmentally sound
waste management facilities.
Low-level waste is defined as radioactive waste that is not high-level waste, transuranic
waste, spent nuclear fuel, or by-product material. Mixed low-level waste contains both
hazardous materials and low-level radioactive components.
The RWMC can not accept mixed waste. The ICDF, which is part of the remedial
design/remedial actions at WAG 3 at the INTEC, is planned to be a facility that can
consolidate low-level waste from several areas on the INEEL, including the CFA. It will also
be able to receive low-level mixed waste. A description of the proposed ICDF is contained in
the ROD for WAG 3 (available from the INEEL Community Relations Office (208)
526-4700 or (800) 708-2680 or at http://environment.inel.gov/er/erplans.htm on the
Internet.) As planned, the soil repository will be an engineered facility meeting state and
federal design and construction requirements, including the RCRA requirements.
16. A commenter would like more information on disposal costs for facilities off the INEEL and
the factors that lead to variability in those costs. [B2-6]
Response: Cost estimates are based on an existing contract with a representative
off-INEEL disposal facility. The cost estimates for disposal of waste at facilities include:
a. How a material has to be handled to prepare it for shipment (whether it must be in
barrels, bags, or other containers)
b. The waste media involved (e.g., liquid, solid, sludge)
c. Characterization before the waste is shipped
d. Distance from the INEEL, and whether a special route must be followed
e. Tippage fees charged by the disposal facility
f. Characterization required to be conducted by the receiving facility
g. Transportation of any residuals (such as ash) back to the INEEL (including
containers in which it is shipped, the waste media, special transportation routes, and
characterization upon its return)
h. Legal, procurement, and subcontracting documentation.
Part III 3-8
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3.2 The CERCLA Process at WAG 4
3.2.1 Risk Assessment
17. A commenter expressed concern about worker health and safety, and asked why the current
occupational scenario was not included in the Proposed Plan. [B2-2] A commenting group
wrote that it was not clear why only future occupational health risks were considered in
Table 1. Do future occupational risks pose current occupational risks as well? [W8-41
Response: The current occupational scenario was included in the baseline risk assessment
conducted as part of the comprehensive RI/FS. Risk assessment results for the current
occupational scenario were not provided as a separate column in Table 1 of the Proposed
Plan because risks that exceed threshold levels are managed to ensure worker health and
safety (see footnote (b) in Table 1). Worker safety is a high priority at the INEEL for all
operations. Safeguards used at the INEEL to ensure worker health and safety include
engineered barriers, robotics, and personal protective equipment.
18. A commenting group believed the risk assessments were very inaccurate. The group stated
that the risk assessments are based on the linear non-threshold theory, which has no
scientific basis. [W6-1]
Response: Risk assessments at CERCLA sites are conducted following EPA guidance
which directs use of the linear non-threshold theory. While some deviation from the
guidelines is allowed based on the type of site and what contaminants are present, the
baseline risk assessments typically follow these guidelines closely. Generally, the EPA
guidelines produce a risk assessment that is very conservative: that is, the risk assessment
tends to overestimate the risks and hazards at a site. This provides an extra level of
protection for the health and safety of humans and the environment.
19. A commenting group would like information on when the future occupational scenario
begins. [W8-5]
Response: For purposes of the risk assessment, the future occupational scenario period
begins in 100 years (the year 2095) and lasts for 25 years (through the year 2120).
20. A commenting group did not understand why cumulative excess cancer risk for uranium
238 and arsenic was collapsed into one cell in Table 1. [W8-6]
Response: Table 1 in the Proposed Plan is a summary the results of the human health risk
assessment. The information follows the guidelines set by EPA for Superfund sites. At each
site, the exposure routes for each contaminant of concern are calculated and summed, and
then the sums of all the contaminants are added together to find the total risk or hazard at the
site. The results are presented in Table 1 of the Proposed Plan. This method not only
provides the most conservative estimate of risk, but also permits comparisons between sites
in each WAG and between WAGs.
Part III 3-9
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3.2.2 Evaluation Criteria and Process
21. A commenter expressed approval that DOE is using the best currently available technology,
rather than using experimental techniques. [Bl-2]
Response: Thank you. The types of contaminants at the three sites requiring remediation
are readily addressed by available technology, therefore no experimentation is required.
22. A commenting group disagreed with the general approach to remediation that leaves in place
contaminants that are deeper than 10 feet below the surface. The group concluded this
merely gives the contaminants a head start toward the Snake River Plain Aquifer. [W8-7,
IF 1-4]
Response: The depth of 10 feet below ground surface is used to evaluate contamination for
a residential scenario in which a basement might be constructed. Contaminants at depths
greater than 10 feet are inaccessible to residential receptors. Unless there is a groundwater
risk from subsurface contamination, mitigative measures are not considered.
23. Several commenters disagreed with the use of the word "containment" for alternatives
involving covers, since the covers are open at the bottom, the side nearest the aquifer. They
contended that, although this technology prevents contamination from migrating upward, it
fails to prevent migration of contaminants downward. [W8-8] One commenter also noted,
however, that the containment cover described is better designed than those recommended
for other INEEL remediation activities. [Bl-4, B2-3]
Response: The comprehensive RI/FS determined that contamination at the three WAG 4
sites does not threaten the aquifer. As used by CERCLA, the term containment refers to the
ability of a constructed barrier to prevent migration of contaminants along a pathway that
results in exposure to human or environmental receptors. For example, if a contaminant
poses a human health risk when it is inhaled, the barrier must prevent it from reaching the
air.
The INEEL uses several types of containment barriers, each designed to meet the specific
requirements of a contamination site. Containment with an engineered barrier is the preferred
alternative only for the drainfield because it will break the exposure pathways of external
radiation exposure, thus protecting human health and the environment. Groundwater
simulation conducted as part of the RI/FS predicted that Cs-137, the COC at CFA-08, would
not impact the Snake River Plain Aquifer above risk-based concentrations. Therefore, the
cap effectively "contains" Cs-137 from the only viable exposure route, external exposure.
Additionally, an evapotranspiration cover will minimize infiltration at the drainfield. (More
information about engineered barrier designs evaluated in the WAG 4 feasibility study can be
found in "Evaluation of Engineered Barriers for Closure Cover of the RWMC SDA" [J. F.
Keck et al. January 1992] available in the Administrative Record.)
24. A commenting group supported the concept of a single, on-INEEL low-level waste disposal
facility to be located at the Idaho Nuclear Technology and Engineering Center (INTEC;
formerly the Idaho Chemical Processing Plant). [W6-2]
Part III 3-10
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Response: The Agencies welcome public support of the concept of an On-INEEL disposal
facility to be located at INTEC. As described in Part II Sections 12.1.1 and 12.1.3 of this
ROD some materials from CFA are anticipated to be disposed at the ICDF. The development
of the ICDF is itself part of the remedial design/remedial actions at WAG 3 at the INTEC.
A description of the proposed ICDF is contained in the ROD for WAG 3 (available from the
INEEL Community Relations Office (208) 526-4700 or (800) 708-2680 or at
http://environment.inel.gov/er/erplans.htm on the internet). It will be used to consiolidate
radioactively contaminated soil and debris from INTEC and other areas on the INEEL.
Containment in an engineered facility with a liner to prevent leaching and a cap to keep out
moisture will significantly reduce the threat to the Snake River Plain Aquifer, protect human
health and the environment, and improve DOE's ability to effectively manage the
contamination. As planned, the soil repository will meet state and federal design and
construction requirements, including the RCRA hazardous waste management requirements.
The decision to locate a repository at the INEEL was driven by cost and benefits. The cost
for sending the large volume of waste to a commercial off-INEEL disposal facility, including
costs to transport, treat, and dispose of contaminated soil, would be extremely large,
compared to the benefits to be gained. DOE estimates that locating a repository on-INEEL
will save taxpayers $377 million over the cost of shipping the contaminated soil to an
off-INEEL disposal facility.
25. A commenter urged that remediation be selected when it is cheaper than monitoring. [Bl-3]
Response: Environmental remedial options are not based solely on cost. A cleanup
treatment must satisfy the two threshold criteria used in CERCLA based evaluations of
remedial alternatives—overall protection of human health and the environment, and
compliance with applicable or relevant and appropriate requirements (ARARS)— before
being ranked according to the five major balancing criteria, one of which is cost.
Monitoring without remedial action, though cheaper than the other alternatives, was
determined not to be protective of human health or the environment.
3.3 Release Sites/Groups at WAG 4
3.3.1 Pond (CFA-04)
6. A commenter asked for more detail about the cost estimates for Alternatives 3a and 3b.
Specifically, why was there such a disparity in costs between Alternatives 3 a and 3b? Was
the entire scope of work considered in both cost estimates? Could the off-INEEL option
have been overestimated? Is it possible to send just the soils containing RCRA-listed waste
off-INEEL, and dispose of the remaining waste on-INEEL? [W4-1]
Response: The estimated cost differences between Alternatives 3a and 3b primarily arise
from the costs of both transporting soils to and disposing of the soils at an EPA-approved
off-INEEL disposal facility. The estimates were based on cost information from such a
Part III 3-11
-------
facility. As the project design is developed and the design parameters are finalized, the
alternatives may be modified. Modifications may include alternate disposal sites.
Many of the operational aspects of the selected alternatives are not finalized, but will be
defined more specifically during the design phase of the project. Stabilization of waste at the
pond would meet all ARARs listed in Part II, Section 13 of this ROD, including state of
Idaho requirements for fugitive dust emissions.
27. A commenter stated that his professional experience leads him to question the preference of
Alternative 3a, given that it has operational and cost disadvantages compared to other
alternatives. [W4-1] The commenter listed, the following items for specific discussion:
a. The requirement of substantial mixing and material setup time to allow for proper
treatment.
b. The requirement of more personnel and equipment for a much longer period of time.
c. The requirement for more preparations and logistics.
The esthetic problem associated with high-volume unloading and mixing of Portland cement.
The small particle size of the cement could lead to a continuous, large white cloud.
Controlling this could be expensive and/or difficult due to the INEEL's typically windy
conditions.
Response: As presented in the Proposed Plan, alternative 3a is the least expensive of the
three action alternatives considered for the Pond. Treatment of the excavated soils must be
conducted in accordance with all applicable or relevant and appropriate requirements
(ARARs), including those applying to fugitive dust emissions. (A complete list of ARARs
that must be met for this project is contained in Part II, Section 13, of this ROD.) All
treatment will be conducted in a manner to ensure the health and safety of workers and the
environment.
28. A commenter felt that an easier and less expensive alternative for the pond contamination
would be to dig it up and ship it off-INEEL. The commenter argued that the large volume of
material would lead to price reductions. [W4-3]
Response: Cost estimates for off-INEEL disposal of waste excavated from the pond show
that the additional shipping and transportation expenses would drive the cost of Alternative
3b to an estimated $12.8 million—nearly double the $6.7 million estimated for Alternative 3a.
29. A commenting group stated that the cost estimate for Alternative 4 seemed very high. The
group suggested that phytoremediation could be a less costly alternative, and asked why it
was ruled out as an alternative technology. [W7-2]
Response: Phytoremediarion uses plants to extract contaminants from the soil.
Contaminants generally are incorporated into the biomass (the plant). At the end of the
Part III 3-12
-------
growing season, the aboveground portion of the plant is collected and incinerated. The
residual waste (ash) is stabilized and disposed of in a suitable landfill.
The cost-effectiveness and technical implementability of phytoremediation are very site
specific. Factors that affect whether phytoremediation is the best overall choice for a site
include type of contaminants, concentration level, depth to which they are present, types of
plants that will uptake the contaminants, and the need for additional management of plants.
For instance, it is best used for contaminants that are within the upper 3 feet of soil, within
the root zones of the plants used. Plants may require additional irrigation and soil
amendments for optimal uptake. Treatability studies must be conducted to select the best
plant species, determine contaminant extraction rates and costs, measure increased
contaminant leaching due to irrigation, and other concerns.
Phytoremediation has been identified for use at the following INEEL sites:
• The Mercury Spill Area (TSF-08) in WAG 1. A phytoremediation treatability study
will be conducted at the Mercury Spill Area to evaluate plant uptake factors and
rates. That area is contaminated with mercury concentrations at 73.7 mg(kg to at
least 2.5 feet below ground surface. (More information can be found in the
Proposed Plan for WAG 1, available from the INEEL Community Relations Office,
(208) 526-4700 or (800) 708-2680.)
Five sites at Argonne National Laboratory - West (ANL-W; WAG 9) Mercury
contamination at the ANL-W sites ranges from 2.62 to 8.83 mg/kg, and is limited to
2 feet below ground surface. The remediation goal for mercury at the ANL-W sites
is 0.74 mg/kg. (More information is available in the WAG 9 ROD, available from the
INEEL Community Relations Office.)
Mercury contamination exists in the pond bottom at areas with uneven soil thickness, which
would make successful growth of the plants difficult. Also, mercury was detected at a
maximum concentration of 439 mg/kg at the pond compared to 73.7 mg/kg at the WAG 1
Mercury Spill Area (TSF-08) and a maximum of 8.83 mg/kg at the WAG 9 ANL-W site. To
reach the final remediation goal of 0.5 mg/kg would potentially require much more time for
the CFA-04 Pond soil. Therefore, implementability of phytoremediation for the pond was
determined to be low to uncertain, and the technology was screened from further
consideration during the feasibility study.
3.3.2 Sewage Treatment Plant Drainfield (CFA-08)
30. A commenter who worked at the CFA for many years questioned how the residue from the
low-level contaminants in the hot laundry wastewater could have resulted in such a large
cleanup cost. [W3-21]
Response: The commenter is correct in believing that very low concentrations of
radionuclides were disposed of in large volumes over a long period of time at the drainfield.
However, the contamination was spread out over a very large area (approximately 200 by
1,000 feet). The residues remain in the approximately 40,000 linear feet of gravel-filled
trenches. The cost to cleanup the drainfield is in direct proportion to the size of the
contaminated area - approximately 74,000 cubic yards.
Part III 3-13
-------
31. A commenting group noted that, in approximately 189 years, the risks from cesium-137
contamination at the site would decrease to a level below the human health risk threshold.
However, according to Title 5, cesium- 137 has a half-life of 30 years, which leads to a
conclusion that the cesium-137 would decay to acceptable levels in 90 years rather than 189
years. The commenting group asked why it would take 189 years to achieve acceptable
risk-based levels. [W7-3]
Response: A preliminary remediation goal, or PRO, is a quantitative cleanup level. PRGs
are used in planning remedial actions and assessing the effectiveness of remedial alternatives.
The maximum concentration of Cs-137 detected at the drainfield was 180 pCi/g. It is this
concentration that would require 189 years to decay to the acceptable value of 2.3 pCI/g for
residential use.
3.3.3 Transformer Yard (CFA-10)
32. The addition of items for information purposes throughout the text (marked with an "info"
icon) was praised, with one exception. A commenting group felt that the text located under
the info icon on page 20 raised unnecessary public concerns related to polychlorinated
biphenyls (PCBs), particularly given the very low level of PCBs detected at WAG 4. The
group stated that this info icon, in particular, was alarmist and served no purpose. [W7-4]
Response: A Proposed Plan is a "brief summary . . . of the RI/FS" (OSWER Directive
9355.3-02, Section 1.2.6). The Transformer Yard (CFA-10) is a fenced yard with a
concrete pad that was used infrequently from 1985 to 1990 to store transformers. The area
was originally named the "Transformer Yard Oil Spills" because PCB contamination from
the transformers was suspected to be present. Although PCB levels were determined to be
well within the threshold for industrial sites, the name was retained (with the deletion of "Oil
Spills" for consistency). The sidebar discussion was appropriate to include in the Proposed
Plan to acknowledge the original suspicions and inform stakeholders of the minor change in
name.
33. While approving of off-INEEL disposal and the INEEL's rapid progress toward cleanup, a
commenter questioned whether the selection of off-INEEL disposal was the result of
expedience or strictly environmental considerations. [B2-4]
Response: The Agencies believe that that the selected alternative, Excavation, Treatment,
and Off-INEEL Disposal, remains the most appropriate remedial action for the CFA-10
Transformer Yard soil. As stated in the Proposed Plan, it was selected because the site could
be remediated within 15 months after signing this ROD. It provides the best balance of
trade-offs among alternatives in terms of the five balancing criteria (long-term effectiveness
and permanence; reduction of toxicity, mobility, or volume through treatment; and
short-term effectiveness; implementability; and cost). It is cost-effective, because its costs
are proportional to its overall effectiveness. Furthermore, it provides the balance of
trade-offs among alternative because it emphasizes long-tern effectiveness and reduction of
toxicity, mobility, or volume through treatment. Finally, selection of this alternative meets
DOE's mission of completing cleanup acrivities as quickly as possible.
Part III 3-14
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3.4 Other Issues
3.4.1 The Snake River Plain Aquifer/Groundwater
34. A commenting group disagreed with the general approach to remediation that leaves in place
contaminants that are deeper than 10 feet below the surface. [W8-7, IF 1-4]
Response: The depth of 10 feet below ground surface is used to evaluate contamination for
a residential scenario in which a basement might be constructed. Under this scenario,
residents could potentially be exposed to excavated soil. Contamination is only left in place
below 10 feet in situations where groundwater modeling indicates that that the contaminants
and/or the concentrations will not impact the aquifer above risk-based concentrations or
maximum contaminant levels.
35. A commenter reiterated that his chief concern is that contamination be removed from over
the aquifer before it is too late -assuming it is not. [Wl-1]
Response: Groundwater modeling conducted as part of the Comprehensive RI/FS indicated
that the WAG 4 release sites and tank sites do not constitute an unacceptable risk to the
Snake River Plain Aquifer, approximately 500 feet below the ground surface. As part of the
remedy for the OU 4-12 Landfills, groundwater monitoring has been conducted for 4 years
and will be conducted for 26 more years to detect potential impacts to the aquifer.
3.4.2 INEEL CERCLA Disposal Facility
36. A commenting group contended that this Proposed Plan, like those from other waste area
groups, selected remedial actions that require on-INEEL disposal at the proposed ICDF, and
that this commitment to a facility that has not yet received public review and community
acceptance is in violation of the CERCLA process. The Agencies have created a de facto
approval process for an over-the-aquifer facility that the public would not accept. [Fl-2,
W8-10]
Response: The Agencies have followed all CERCLA requirements in regard to the ICDF.
The ICDF was identified in the Proposed Plan for WAG 3 (the INTEC; formerly the Idaho
Chemical Processing Plant), and all relevant documentation on the ICDF has been made a
part of the Administrative Record. A description of the proposed ICDFs included in the
recently signed ROD for the (INTEC). (Available from the Community Relations Office
(208) 526-4700 or (800) 708-2680or at http://environnment.inel.gov/er/erplans.htm on the
internet.)
Part III 3-15
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4. REFERENCES
BBWI, 1996-1999, INEEL Site-wide Annual Reports: Idaho Generator Reports for 1997 through 1999,
Nonradiological Waste Management Reports for 1996 and 1997; and Radiological Waste
Management Reports for 1996 through 1998 (available on-line at
http://www.inel.gov/environment/annual reports/index.htmD
BBWI, September 16, 1999, INEEL Cost Estimating Guide, Rev. 13 (available on-line at
http://www.inel.gov/capabilities/cost-estimating/eindex.htmD. INEEL Cost Estimating Department.
DOE, January 1997, Linking Legacies: Connecting the Cold War Nuclear Weapons Production Processes to
their Environmental Consequences, U.S. Department of Energy, Office of Environmental
Management, DOE/EM-0319 (available on-line at
http://legacvstorv.apps.em.doe.gov/thestorv/pdfpic.asp?doc=linky
DOE, June 1998, Accelerating Cleanup, Paths to Closure, DOE/EM-0362, U.S. Department of Energy,
Office of Environmental Management (available on-line at
http:/www.em.doe.gov/closure/final/index.htmiy
DOE-ID, December 4, 1991, Federal Facility Agreement and Consent Order for the Idaho National
Engineering Laboratory, 1088-06-29-120, U.S. Department of Energy, Idaho Field Office, U.S.
Environmental Protection Agency, Region 10; State of Idaho, Department of Health and Welfare.
DOE-ID, September 1999, Final Record of Decision: Idaho Nuclear Technology and Engineering Center,
DOE/ID-10660, U.S. Department of Energy, Idaho Operations Office; U.S. Environmental
Protection Agency, Region 10; and Idaho Department of Health and Welfare (available on-line at
http://environment.inel.gov/er/erplans.htmy
INEEL, May 1995, Community Relations Plan, U.S. Department of Energy, Idaho Field Office, U.S.
Environmental Protection Agency, Region 10; State of Idaho, Department of Health and Welfare.
Keck, J. F., K. N. Keck, S. 0. Magnusson and J. L. Sipos, January 1992 Evaluation of Engineered Barriers
for Closure Cover of the RWMC SDA, EDF-RWMC-523.
U.S. Environmental Protection Agency, CERCLA Overview (available on-line at
http://www.epa.gov/superfund/whatissf/cercla.htmy
U.S. Environmental Protection Agency, RCRA Orientation Manual (available on-line at
http://www.epa.gov/erjaoswer/general/orientat/
Part III 4-1
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Appendix A
Oral and Written Public Comments
-------
Appendix A
Table A-1. Cross-reference for individual comments and their responses.
Comment or Name and
Affiliation or Organization
(If provided)
Written Comments
Paul Randolph
Charles M. Rice
INEEL Citizens Advisory Board
George Marriott
Jared Newman
ONYX Environmental Services
Warren Adler
John C. Commander,
Coalition 21
Charles M. Rice
INEEL Citizens Advisory Board
Beatrice Brailsford,
Snake River Alliance
Document and Comment
No.
Wl-1
W2-1
W3-1
W3-2
W3-3
W4-1
W4-2
W4-3
W5-1
W6-1
W6-2
W6-3
W7-1
W7-2
W7-3
W7-4
W8-1
W8-2
W8-3
W8-4
W8-5
W8-6
W8-7
W8-8
W8-9
W8-10
W8-11
Response No(s)
35
7
12
30
14
26
27
28
5
18
24
1
3
29
31
32
2
8
15
17
19
20
22,34
23
13
9,36
10
Part III A-1
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Table A-1. (continued).
Comment or Name and
Affiliation or Organization
(if provided)
Beatrice Brailsford
Snake River Alliance
Vaughn Nebeker
Steve Hopkins
Pam Allister
Chuck Broscious
Document and Comment
No.
IF1-1
IF 1-2
IF 1-3
IF 1-4
IF 1-5
IF2-1
Bl-1
Bl-2
Bl-3
Bl-4
B2-1
B2-2
B2-3
B2-4
B2-5
B2-6
B2-7
B2-8
Ml-1
Response No(s)
15
36
13
22,34
4
1
8
21
25
23
11
17
23
33
24
16
7
8
6
Part III A-2
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Central Facilities Area, Waste Area Group 4
Idaho National Engineering and
Environmental Laboratory Public Meeting
Central Facilities Area Comprehensive Remedial
Investigation/Feasibility Study Proposed Plan
August 17,1999
Idaho Falls, Idaho
7:00 p.m.
Public Comment
Ms. Brallsford: My name is Beatrice Brailsford. I'm with the Snake River Alliance.
We will submit written comments
I think I do finally-and I do understand that CERCLA and RCRA address different
concerns. I do think that the difference between a RCRA landfill and a CERCLA
Superfund cleanup site is a number of years. It could be 30 years or 100 years or
1,000 years. So, in the real world, there are some similarities.
IF 1-1
IF 1 I think I finally, honestly, just now figured out the chronology for the soil dump.
We signed a ROD, decide to build a soil dump, and then start working on the criteria,
beyond that it's CERCLA waste. We start looking at what really is appropriate to put
above the aquifer or leave above the aquifer, to move above the aquifer. The way we
figure out what is appropriate to put above the aquifer is we go back through all the
cleanup plans and see what we've already decided to put there. And then we figure
out what is in that waste, and that is the waste that we allow in the soil dump.
I think that you might have some problems with that. I'm not sure that that is the
appropriate way to go about making that decision of both, whether to have one, and
hat to put in it.
IF 1-2
I think given the fact that at some point a RCRA dump becomes a Superfund site,
whenever we're looking at these cost estimates and we look at the one-time disposal
fee, I think that is being overly optimistic.
IF 1-3
I am becoming more nervous about this 10-foot basement scenario, that it's okay to
leave pollution if it's deeper than 10 feet. As far as I can see, all it means is that
you're leaving the waste that is 10 feet closer to the aquifer, and you're not ruining
its head start.
IF 1-4
And that's it. I guess just one more thing. I hope I never understand DOE's version
of tidy, but to read that we take powdered mercury and left it on the surface
and we buried roofing material is just irrational. Thank you.
IF 1-5
Mr. Simpson: Thank you. Anyone else? Vaughn, any comments?
Part III A-3
-------
Mr. Nebeker: My name is Vaughn Nebeker, N-e-b-e-k-e-r. I'm the original author
and inventor of the technologies which put out Chenobyl, hydrogen bleed-off system
at Three-Mile Island, Charilabalnck, and also did the cap that let out LR-1 in Iraq.
In putting out the eight atomic nuclear reactors, I'm still batting at 110-percent TF _ ,
average. And I always design my own equipment technologies. And sometimes I
wonder why sometimes they have so low standards m the DOE. Whereas as a
private contractor, I've always tried to have higher and more-efficient standards.
Thank you.
Mr. Simpson: Anyone else?
Mr. Freund: I'm George Freund, F-r-e-u-n-d., Coalition 21, and we will submit our
comments in writing.
Mr. Simpson: With that, I would like to remind people that the comment period for
this project remains open until September 4, 1999. The next time we'll be having
public cleanup meetings will be in the fall of 2001 to discuss the Operable Unit 10-04
options. Operable Unit 10-04—I'm going to try to get most of these sites—includes
EBR-1 and BORAX sites, the Organic Moderated Reactor Experiment, the site
training facilities, the ordinance areas, and various other Waste Area Groups, 6 and
10 site.
Once again, that will be in the fall of 2001. And that is very close to the time frame
that the nitrate investigation will be, and we will have a proposed plan for the Central
Facilities Area.
With that, thank you for coming. Good night.
(Meeting concluded at 8:40 p.m.)
Part III A-4
-------
Central Facilities Area, Waste Area Group 4
Idaho National Engineering and
Environmental Laboratory Public Meeting
Central Facilities Area Comprehensive Remedial
Investigation/Feasibility Study Proposed Plan
August 18,1999
Boise, Idaho
7:00 p.m.
Public Comment
Steve Hopkins: I just have a few short comments. First of all, I have been
concerned when it comes to writing these cleanup path plans. In some of the articles
I've seen involving DOE officials commenting on past INEEL activities that is in a
substantial amount of revision of history going on. And it may seem to be a minor
point, but I think you have to be honest about what has gone on at INEEL in the past,
referring to previous research activities as resulting in contamination is definitely a
euphemism.
Basically you're talking about nuclear weapons work. This was a site that was very
key in reprocessing bomb-grade uranium used to produce tritium and plutonium at
Savannah River. So, I think you should be a little more honest about exactly where
the contamination stemmed from.
Bl-1
Some other comments, in terms of good points, I like the fact that—with this
particular plan, as opposed to the other plans, there is not as much, for lack of a
better word, dinking with the waste like with the soil searcher with WAG that didn't
pan out. At least in this case, you're looking at experimenting for the sake of Bl-2
experimenting. It appears that you're going forth with the best available technology
even though there may not be any truly real good solutions. It appears that you've
selected the best ones.
Also, I would like you to consider—and a WAG 5 is sort of the model for this, that
you look further at sites that you can potentially remediate for less of a cost than Bl-3
monitoring or perhaps not as a significant cost in addition to monitoring. As you
stated, with the WAG 5 clean-up plan, some sites were cheaper to remediate than
monitor.
Approximately, half of the remediated activities so far in terms of Records of
Decisions that have been signed involving WAGs have been essentially just a cap,
very crude cap, at that, just made of soil. Whereas, with this cap, it looks like there is
actually some thought into designing it for it to last for more than a few years.
Although, of course, when you say containment, you're only talking about
containment on the top and not the bottom, but at least it appears to be a better design
than the previous caps.
And that is all I have at this time. Thank you.
Bl-4
Part III A-5
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Mr. Simpson: Thank you.
Audience Member: My name is Pam Allister, and I'm the executive director of the
Snake River Alliance...Thank you very much for your attention and courtesy this
evening. I have a list of comments in no particular priority or flow. I'd like to comment
that I found that Table 1 was confusing. And that there with you a sense for me—and I
consider myself a lay reader, as a mixing of apples and oranges with a final case of B2-1
lemons for the risk. It was too quick a table for looking at the risks, because we were
looking at cancer-causing elements and also toxics, and lead, which is has its own
particular kind of uptake criteria. So, I suggest an expansion some how of Table 1, or
Table 1 like graphs in the future.
I also felt uncomfortable with not including the current occupational scenario in this
review. I am hopefully optimistic that there is careful attention being given to the
workers at the Central Facilities Area, given the large number of them of 800. And that
it is flagged carefully for workers' safety that the nitrates and tritium that is in the B2-2
groundwater, as that investigation continues at the Central Facilities, is given careful
attention, particularly in light of the recent federal revelations. We cannot be too careful
with observing and protecting our workers from risk in Idaho.
I also thank you very much for you acknowledgement that capping is not containment. | B2-3
It takes care of the top but not the bottom. I'm not opposed—I will speak for myself as
one member of the alliance. In this case, I'm not opposed to off-site disposal and the
moving forward with this particular clean-up, project as fast as possible. However, I B2-4
am uncomfortable with the decision-making process that was seemingly based on
expedience rather than what might be best for the environment. I pose that as a
question. I don't have the answer for if it's better stored north or south 300 miles.
Also, I'm beginning to wonder about the waste acceptance criteria for the on-site B2-5
disposal. I talked with my colleagues who were at last night's meeting, and we do
continue to ask that there be good public involvement with setting up the criteria for
that facility, especially in a closely affected area of the state.
In reference to the cost analysis, this hasn't come up for quite the same way as it did
this evening, but looking at the variability and the off-site disposal, I'm wondering
about the cost-I need to do my homework, I guess and look at this other document, but B2-6
what is driving this variability and cost for off-site disposal, I'm assuming its market
driven, however, I think that we need to bring in the factor of environmental risk and
the long-term lifetime cost of disposal and bring to our own awareness the values issue
of the lifetime cost of past and current DOE activities.
I also thank Erik for his informal okay for us to get some of our written comments
after Labor Day because Friday I'm going on vacation. I want to forget about this for a
couple weeks.
B2-7
Lastly, I would like to reiterate what my colleague Steve Hopkins mentioned. I find the
first sentence or two of this introduction euphemistic. The 1300 dues-paying members
of the Snake River Alliance are very concerned about nuclear weapons production
activity, whether they are past, current, or in the future. And it feels very much like a
glossing over to say research activities when we know that these activities were
B2-8
Part III A-6
-------
actually related to tools and instruments, great destruction to the human health and the 090
environment both now and in their intent as weapons. Thank you.
Mr. Simpson: Thank you. Any other comments? Well then, with that, I would just
like to say that the comment period for this project remains open until September 4th.
The next time we will be holding clean-up meetings will be about two years from now.
In fact it will be kind of a horse race between this 413b investigation dealing with the
nitrates in the groundwater, the Central Facilities Area, or the Operable Unit 10-04
investigation. And that investigation deals with the organic moderated reactor
experiment and the site training facilities ordinance area, the Experimental Breeder
Reactor 1 and Boiling Water Reactor Experiment Facilities and other site within WAGs
6 and 10. With that, thank you for coming and good night.
(Meeting concluded at 8:45 p.m.)
Part III A-7
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Central Facilities Area, Waste Area Group 4
Idaho National Engineering and
Environmental Laboratory Public Meeting
Central Facilities Area Comprehensive Remedial
Investigation/Feasibility Study Proposed Plan
August 19,1999
Moscow, Idaho
7:00 p.m.
Public Comment
Audience Member: Chuck Broscious, executive director of environmental Defense
Institute, Troy, Idaho. As I've said many times over the years, all the agencies, not only
the Department of Energy but also the regulatory agencies have an obligation that when
they convey information to the public that it be accurate and that it tell the whole truth
and not be anything less than that.
Since DOE is the polluter, the public might even expect that they might not always tell
everything there is to know that the public may need to know about what is happening
in the process. But what is not acceptable, from our point of view, from the public's
point of view, is that when we have regulatory agencies whose mandate is to track
these things and force the law, and when they have their logo on these documents that
go out to the public, we have an expectation that they do accurately reflect the whole
truth and not a selected part of the truth.
Over the years, I can't say I have ever seen one of those plans go to the public that I
could say accurately reflected the truth, the whole truth. That when I go and do my own
research into the administrative record and look at the sampling data and find radically
different numbers than is the document that goes out to the public, and I see this
consistently year after year after year, it becomes a kind of problem that can't be
attributed to a single oversight or a single mistake by somebody that missed something
because it's too consistent. And the only thing that we're left with is that there is a
deliberate effort on part of all the agencies not to be fully honest about what the extent
of the problems are.
If what we found, if there were inaccuracies in the there that covered that were too low
or too high, we could say, well, there is not a consistent pattern here. But there is a
pattern. And the numbers are always way too low, consistently. There is a problem
here.
And if you wonder about how the public responds to you and if you wonder about
whether you have any credibility, you can look at this and find out why you have no
credibility, why the public doesn't have any faith in this process, and why this is an
empty room. I'm here because it's in my job description. That is what I do. I don't get
paid for it. I'm unpaid staff. But as a member of that organization, that is what my
Ml-1
Part III A-8
-------
board of directors has asked me to come and represent our organization so that, at least,
you get some feedback from somebody telling you it's not working and we don't believe
you and we don't have any faith in you, and that we don't think that you're going to do the
right thing. And you can ask Ruel, a number of years ago—ask him the next time you see
him. There was a meeting in Idaho Falls when Grumbly was still undersecretary, he was
there. I think it was an EMAC meeting or something like that. And I went up to Tom, I
said, "The only thing you guys bloody understand is a court order. You know, this is just
spinning our wheels. We never get anywhere with you unless we go to court and a judge
tells you that this is what you're going to need to do." And even then they ignored it. Penna
almost went to jail. He was cited in contempt by the court because he never followed
through on the PE EIS. And, finally, they settled it, but even then—I mean, how many
years did that take, probably near a decade.
But that is the only thing you understand is a court order. I will tell you under no uncertain
circumstances that that is where I'm putting my work right now. That's where I'm going
to spend my time. I'm going home. Have a safe trip.
(Meeting concluded at 8:40 p.m.)
Part III A-9
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What's Your Opinion?
sn* — rear arcm you K CST--SS ivr;,
W1-1
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IN£S. Envlronmentci Rsitoiation
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FIRST QA5S
US POSTAGE
IDAHO EMtS.K>
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Part III A-10
-------
Citizens Advisory Board
U-S-
L5C
Jrixho Fmlj, ID tUOI
CHinrt
Tb0k you Arc ths opportunity to rsn'ew th* WAG 4 prepewd
nkllza tfait ttui pubbc tcouoSiff penc4 k. pracc^jy y»duic
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Part III A-11
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Waste Area Group 4 Proposed Plan
AUG 24
— Comment Form —
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mail i
: fctm if
jnwi'i'n"";^^?* Qg. SQE~ ^^^j% gnyl J^ft 1Q£0 Of t^ji^Q CflftPff^T*'!1^^ |4^*
?l=i*« pAvid* vcoj 4«cQB. )Uld {p^l^t iddXwt if yon -p-puld !itc
wwu public BOBun«iut laccifuj j» tiii
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Part III A-12
-------
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i*rg* nhit:* clcodl . Concjfuls d*n be wawj. which ssttld be
and/or dli/f i suit co ua* duo to tfs« cypic*! lKf:£t. wif.tty
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Part III A-13
-------
an
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Subject1 Ootti"
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Whafs Your Opinion?
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Part III A-15
-------
Citizens Advisory Board
Utah* NaiioBaJl Engineering gg_d Eavirttungatal
, fcf ._
I N c
: 1- tiaw
nmaJ RJ
UJ.Dcpannsent of EacTiy, l&hu Opennwu OHies. MS 39 ( L r
Idaho FiJIt, CD
DourMt. Fiaic
i
Stanley
Note; The Site-Specific .^irtioiy Bwrt (S$AB) for the Uatottkifonal
tad gnvimmrmsnlal jjbOrtHfli^ (INEELl. itao Imown is the CCE EL Ti
A3|, is i lueal irfmsnrf KHnmncechtncrcd ua
I Energy" i (Do£) EnvironirwmiJ Mvnj|«ncnT SSAB
ftcn ~,
Hi El
Jan M, EdcL»lcin
A- J
Thf WcEL CAS JTTIEWHJ the ?rqpo«:ij Plaa fe* Qpcnbk Unit 4-1 3 A
Waste Area Gwup 4 (WAG d). CeBS»l Fui line* Afca al the |« ^pprcCUIcd yqur
s«tuncnr pcnod ;
DOE-CD'
10
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Carol Coir
Jo Ede:nn>«
Green Lowe
Kcvui Manri
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Insun Associaici Corpora uti>; " -W7 Sheup Avenue. SuiUf 10!
I'feartr ' (20* » S22-lfiS3 F« • (20S1 522
htrpi'j wwvr. kds.iteVkver tfusb
Fall*. Edohu 83^
V W7-1
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Part III A-16
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_„_ W7-3-
Tdoha Nadonat Engineerings *J*d Em-Hzonmerml Laijoriiory icons,)
PUB for Opvrsbl* Unii 4-13 A Inttrim Action*
Croup 4 (WAG 4), Central Facilltfia Area, Tdaho ^Cafibqa
and Eavtroixn«nE3] Labcraiory ^x '^V7-4
Thi* 1NSEL CAB ^%-jewcd tfas proposed Plan &w Openjisle Unii4-l3A larerim Ac:i«m. Wane
Area Group 4 (WAG 4), Central Facilities Area at foe fdAo National Engineering and
EovirowncTitaJ LabaraJofy. The doeaiKoii was well formaiicd arjd easy ID undefStaAd, We
panicularly apprenisad the ""Consumer Kjepoits"'-(jpc tables- We have; four recommendations io
ithei
We andsTtmif! thai the ;cnn "interim acdon," is defined under the Comprehensive En
Rcir.cdiaticn. CoicpcmaiiDQ. and Ljabiliry ACL as any iciion Uiatwill not result in fun
remediation. We umdersumd dial some saniamiBBtlon sourcts ut WAG 4 arc not addressed by
chic PrflpdsetJ Plan, lience thfi dtlc of ihe dpC"JErneiit refstv to j[ aj an ""imcrim action*"1 We
aiaccrely hope. b.ow*v«r4 &al Lt'.e proposed ttntBcift] acisnn6 dcscri^«I RI the Prapassd flan will
•constitute flnzl rertic!{|i«s for itiBconiuRimaiian souicas they ire dssig»«I -10 addresa, l*hs C,-VB
has repeated)/ expressed Shistiaiitni ai cteinup EfTorts thai musi te rep«54«l, at great com to
. b«3iisc prior effort* were Eacccnpfete, The IN EEL CAB rccoraracsds thai all
actioos lakra ai VVAG 4 completely ta.il Jiually mrfdrcsa Itc contaminaiicsa present
avoid a need fdr follow- on
We understand tha [Mi c&nutmtnanl ofconcEm in the Disposal Pond ii mercury. We sl
umdarsianil Uiat anaiyijs Eb5»scd on. tie Toxiciiy Ciuuattemuc Ltf^baw Prccc±lurcj
&nm Larss of liic SS iarBpling totaisemi In th« pond 'aottoffi sunpafu adansJusion ihsa the
sffdini*i3l inaeess ifcir litJifiiiion fcr fisaardoys wasic under iftt Resource ConSCftTiKoa and
Rccuvefy ACL We ijucsiipii, however, why phyLsmtrtdiaiion wns ruled jjm as an aJisiunJi
tha: could be less cosily ilian *e prefirr-al alicrnanyc. In addiiitjn, th* S9.9
for operating and moniicrins costs nadcr Aitdraaiivc -J secm^ toy high. ThK IN EEL
CAB rtcomtntn-dj further evaluation of alternative £*chnotagiej la redacc the
c prefcn/cd aitcmsiive for ibe Sewaye Trcaunenl Plans Dwinndd 'amiss thai "'in
189 year* ihe risks from she Cesium -13" conimnjiiaiion ai ihesiie would decrease
K> t Jcvcs b«tcw th* human health risk threshn]d.T" Table 5 ctatcs lhat Cesiam-lSt has a iialr-Sife
o£*10 veafS. The- table leads iss lo i conclusion that (he Ccssuna-J 37 woufd decay to 4eccrpic3b)
-------
idecdon cf ASieraDtive 4 as The preferred alternative wfihoui a twuer understanding of how long
it will take the Cesium-* ! 57 to decay la acceptable I
We appreeilied ibe addition ofiicms for tnfecinaiisnal puipwrss ihrwgbEnn ihc ttxi
with an "tofe" icon), *iih one exception. TheDs"E£L CAB frtls ihil the Text located under the
info icon en pa}t 20 T*is« i flpg raliM tp pol v^blonrwted bjphcn>is fPCBs), Tien was no
neitd to raiat umtsEssaiy public MIKCTTIE. parricalarlv given the very lew level of ?CB(
it WAG 4 Thtf IT^EEL CAB rccammeads againsl ite laclusJun of alarmist
Jafnrinatlaa tiat jerv« no pcrpost la tire
RECOMMENDATION # 62
September 28, 1999
Page 2
Part III A-18
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Snake River Alliance
" t «•
tO fJH*
Cotammis SB eh* Frtyjased Plum fjf _J
Uoii 4- 1 3A lam ris» Action
Group 4 — Gcszxnl Ficiliuei Aro»
Snaleti Ravt r AHt
S, 1906
Th< follBwinf ccz,m«Et» and qur sliau* arc suib&Jxud an, fcebslf if rte i
r~ f"
, _
* mcnlcarnd sKrci^Tna1* at the I ditto S'jtcioiul j£nfuuw;iinf and _J
The current p^an dtxran't 3e*m fa h*v» «y •ptrrinilar tetcia La li |pf, soli ^r jV8~9
TAKE'S ist^bibli1 & (cod rtiuf^ J^
Tho fin" pt(« af Eha plm MVI ih*t "reuareh >«viil>4" «t IMKEL bft I
Gunr-Bmimnti. "Hia m.«;oriiy of Kmutcusfttuia. euuruuiu^ thg. ioau pttik&Uf. ]
dau frttui vffimfjons production; acsivicei. (*"• W8-10
Ac tk.a Idmha Fkllj public miotinf an T:hi»?Un, tat djasu^iiDti of
ROC* where Jii^fhlif httui an artft of oocfysicn-. Th* w^itn "c!xi>?i££atiQB*"
Sir IXHELiekiaup dXB not alwiys phyiicm^ or chemical; they are
svtn pnlllieal. For fcjeampt*. it S;a« ntv«r fct5«n axplamed ^- W5-11
" wky it'« sluy w put waste Irom dueonivisinKtiDR in tfce
13? aise Matwm*3-«i5t CoAplexcv»n ihcta^hit'* no* alcay us
rcitoradsa wac.ra tfiir*. Furtlur, wi\#n Site official*
h» «»wite ettrrtntjj1 jfcwytn jlWMC or j:xnpo»td ICJT tji« sail
with th*ictarTOEt!|' fccinjt bunis
*, the napoTu* *»s tkai '-V^SF it
chas WTJSf da*a &oc buifn iciic w-'a* ft mor* kwJpful J
, tliac brtjitglit up armthcn socfct of srafiisiaii chut
tho ticopc of (his ptWJ hut well ^vslhm Jie *copt cf INEEL elccuup.
eCEciuls bavc «s»id 9P nlorr- ihzn qjir QCClitt&a thKt Sb* Artif«itrr;rj ^
Tns»trtijans PKijact ca^W burn tHa nil fans Pit 9. RWMC j»yf3rtnol don't
to
Part III A-19
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It'll not ciomi why coly £«rux* ocsttpaaoaal b«ilth xa«l* w canxidcrcci (T*bl*
1>, pmrticuLurly fivcn tfa* IAOM> mfcrem-y- eont>m in»t*d c*lcic*. Do chca-s not
po*e a. current occupational htilth riak UK welT* Wh«n die** ihv future be eta
for tbc
It is Htiii not ci««y why the emiuifttiv* txcees cancer riak fcr
and {tncnii: wtrt coiiamd in Tab I* 1.
S»mc INZEL cl«iAup plaui *T* ba-ted on thi piamia* diac it's ukuy lo
^(iliutLou where it ic if it's alraady 4aepfrth2D 10 fast, ML tiuit nccixu; in do is
fT^«Tirf •i-rt tiie tr«taiiitA_n, t^Wnria Lh« Siulka Hive;
Flan 3 c AOts tbftC, *v*ti when c«pa a««m *ocgmtt», which tha en* for
diapa^ul pond does, cltey *_r* not cucfa.i&zBft&i.. ConncciuiUcii IM cuvcrxrd but
left uja*n nt 'he b^tiDcrv, tb* Aiida ncirns
tht gcncrml nckno w ledge m«st tha.t the only differ&aiitt be(wui»n it
RCRA disponU ficilit/ And m CZRCLA deKnup «it« :« wme numbsr of yanrs,
ptioii of* ana -time disp&ud £M prcbubly has anra tn do with
'^ bud^rx -^an with taxpayer
Fuji* mtttanfi on thin plurt, I b*camt esnfident chat
jToi.'tff ftLzcs tha nead &rr *
-------