PB95-964112
EPA/ROD/R05-95/287
February 1996
EPA Superfund
Record of Decision:
Feed Materials Production Center,
(USDOE), Operable Unit 4, Fernald, OH
12/7/1995
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FINAL
RECORD OF DECISION
FOR REMEDIAL ACTIONS AT
OPERABLE UNIT 4
FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
FERNALD, OHIO
DECEMBER 1994
U.S. DEPARTMENT OF ENERGY
FERNALD FIELD OFFICE
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FEMP-OU4ROD-8 FINAL
December 1994
DECLARATION STATEMENT
SITE NAME AND LOCATION
Fernald Environmental Management Project (FEMP) Site — Operable Unit 4,
Fernald, Hamilton County, Ohio
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for Operable Unit 4 of the Fernald Site in
Fernald, Ohio. This remedial action was selected in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent practicable 40 Code of Federal Regulations (CFR)
Part 300, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
For Operable Unit 4 at the FEMP, DOE has chosen to complete an integrated CERCLA/NEPA process.
This decision was based on the longstanding interest on the part of local stakeholders to prepare an
Environmental Impact Statement (EIS) on the restoration activities at the FEMP and on the recognition
that the draft document was issued and public comments received. Therefore, this single document is
intended to serve as DOE's Record of Decision (ROD) for Operable Unit 4 under both CERCLA and
NEPA; however, it is not the intent of the DOE to make a statement on the legal applicability of NEPA
to CERCLA actions.
The decision presented herein is based on the information available in the administrative record for
Operable Unit 4 and maintained in accordance with CERCLA. The major documents prepared through
the CERCLA process include the Remedial Investigation (RI), the Feasibility Study (FS), and the
Proposed Plan (PP) for Operable Unit 4. The FS and the PP also comprised DOE's draft EIS and were
made available for public review and comment. This decision is also based on the public hearing held
on March 21, 1994, in Harrison, Ohio, and the public meeting held on May 11, 1994, in Las Vegas,
Nevada following the issuance of the Feasibility Study/Proposed Plan-Draft Environmental Impart
Statement (FS/PP-DEIS). DOE has considered all comments received during the public comment period
on the FS/PP-DEIS and following issuance of the final EIS in the preparation of this ROD.
The State of Ohio concurs with the remedy and the applicable or relevant and appropriate requirements
(ARARs) put forth in this ROD for Operable Unit 4.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from Operable Unit 4, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This is the selected remedial action for Operable Unit 4, one of five operable units at the FEMP. The
materials within Operable Unit 4 exhibit a wide range of properties. Most notable would be the elevated
direct radiation associated with the K-65 residues versus the much lower direct radiation associated with
cold metal oxides in Silo 3. Even more significant would be the much lower levels of contamination
associated with the soils and building materials, like concrete, within the Operable Unit 4 Study Area.
To account for these differences and for the varied cleanup alternatives applying to each waste type,
Operable Unit 4 was segmented into three subunits. These subunits are described as follows:
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FEMP-OU4ROD-8 FINAL
December 1994
Subunit A: Silos 1 and 2 contents (K-65 residues and bentonite clay) and the sludge in the
decant sump tank
Subunit B: Silo 3 contents (cold metal oxides)
Subunit C: Silos 1, 2, 3, and 4 structures; contaminated soils within the Operable Unit 4
boundary, including surface and subsurface soils and the earthen berm around
Silos 1 and 2; the decant sump tank; the radon treatment system; the concrete
pipe trench and the miscellaneous concrete structures within Operable Unit 4, any
debris (i.e., concrete, piping, etc.) generated through implementing cleanup for
Subunits A and B, and any perched groundwater encountered during remedial
activities.
On the basis of the evaluation of final alternatives, the selected remedy addressing Operable Unit 4 at the
FEMP is a combination of Alternatives 3A.1/Vit - Removal, Vitrification, and Off-site Disposal - Nevada
Test Site (NTS); 3B.1/Vit - Removal, Vitrification, and Off-site Disposal - NTS; and 2C - Demolition,
Removal and On-Property Disposal. These alternatives apply to Subunits A, B, and C respectively. The
major components of the selected remedy include:
• Removal of the contents of Silos 1,2, and 3 (K-65 residues and cold metal oxides) and
the decant sump tank sludge.
• Vitrification (glassification) to stabilize the residues and sludges removed from the silos
and decant sump tank.
• Off-site shipment for disposal at the NTS of the vitrified contents of Silos 1, 2, 3, and
the decant sump tank.
• Demolition of Silos 1, 2, 3, and 4 and decontamination, to the extent practicable, of the
concrete rubble, piping, and other generated construction debris.
• Removal of the earthen berms and excavation of contaminated soils within the boundary
of Operable Unit 4, to achieve remediation levels. Placement of clean backfill to original
grade following excavation.
• Demolition of the vitrification treatment unit and associated facilities after use.
Decontamination or recycling of debris prior to disposition.
• On-property interim storage of excavated contaminated soils and contaminated debris in
a manner consistent with the approved Work Plan for Removal Action 17 (improved
storage of soil and debris) pending final disposition in accordance with the Records of
Decision for Operable Units 5 and 3, respectively.
• Continued access controls and maintenance and monitoring of the stored wastes
inventories.
• Institutional controls of the Operable Unit 4 area such as deed and land use restrictions.
• Potential additional treatment of stored Operable Unit 4 soil and debris using Operable
Unit 3 and 5 waste treatment systems.
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FEMP-OU4ROD-8 FINAL
December 1994
• Pumping and treatment as required of any contaminated perched groundwater encountered
during remedial activities.
• Disposal of Operable Unit 4 contaminated debris and soils consistent with the Records
of Decision for Operable Units 3 and 5, respectively.
The remedy specifies off-site disposal of vitrified contents of Silos 1, 2 and 3 at the NTS. At the time
of the signing of this ROD, The Department of Energy - Nevada Operations Office (DOE-NV) is in the
process of preparing a site-wide environmental impact statement (EIS) under NEPA for the NTS.
Shipments of Operable Unit 4 vitrified waste are not proposed to begin until after the planned completion
of the EIS for the NTS.
The planned date of completion of the EIS for the NTS is December 1995, at which time a Record of
Decision is expected to be issued. Shipments of low-level waste generated from the remediation of
Operable Unit 4 are not proposed to begin until mid-1997, which should be after the planned completion
of the NTS site-wide EIS. Given these timeframes, DOE does not anticipate the NTS EIS schedule will
negatively impact the Operable Unit 4 remediation schedule discussed in the ROD.
The containerized vitrified product will require interim storage at the FEMP prior to its transportation
to the NTS for disposal. The purpose of this interim storage is two-fold; first, the vitrified product will
require verification sampling in order to certify that each production lot has met specific performance and
waste disposal criteria; and second, to provide the Femald waste shipping program a buffer staging area
where the material can be safely managed prior to its shipment to NTS in accordance with DOE as low
as reasonably achievable (ALARA) principles, ARARs identified and included in the Operable Unit 4
ROD, as well as in a manner protective of human health and the environment. It has been anticipated
that the interim storage area will be needed to accommodate the interim handling of approximately 90
days of vitrification production.
The decision regarding the final disposition of the remaining Operable Unit 4 contaminated soil and debris
will be placed in abeyance, until completion of the Records of Decision for Operable Units 3 and 5
remedial actions, in order to take full advantage of planned and in progress waste minimization treatment
processes by these operable units. Further, this strategy enables the integration of disposal decisions for
contaminated soils and debris on a site-wide basis.
In the unlikely event unforeseen circumstances preclude the integration of Operable Unit 4 soil and debris
into the Operable Unit 3 and/or Operable Unit 5 treatment and disposal decisions, the disposal decision
for Operable Unit 4 contaminated soils and debris will be documented in a ROD amendment for Operable
Unit 4 in accordance with Section 117(c) of CERCLA and United States Environmental Protection
Agency (EPA) guidance. The ROD amendment will provide the public and the EPA further opportunity
to review and comment on the final disposal option for Operable Unit 4 soils and debris. A ROD
amendment to the Operable Unit 4 ROD will not be necessary in the event the Operable Unit 3 remedy
for debris and the Operable Unit 5 remedy for contaminated soils can be feasibly implemented for
Operable Unit 4.
In reaching the decision to implement this remedial alternative, DOE evaluated other alternatives for each
subunit, in addition to no action. The other alternatives are: (a) Submit A - Silos 1 and 2 Contents: (1)
Removal, Cement Stabilization, Off-Site Disposal at Nevada Test Site; (b) Subunit B - Silo 3 Contents:
(1) Removal, Vitrification, On-Property Disposal; (2) Removal, Cement Stabilization, On-Property
Disposal; (3) Removal, Cement Stabilization, Off-Site Disposal at Nevada Test Site; (c) Subunit C - Silos
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December 1994
/. 2. 3, and 4 Strucntres, Soils, and Debris: (1) Demolition. Removal. Off-Site Disposal at Nevada Test
Site: (2) Demolition. Removal. Off-Site Disposal at Permitted Commercial Facility.
A description of the alternatives is provided in the Decision Summary of the ROD, hereby incorporated
by reference for DOE's NEPA ROD, and is available in the Administrative Record. CERCLA's nine
criteria set forth in 40 CFR Part 300, the National Oil and Hazardous Substances Pollution Contingency
Plan were used to evaluate the alternatives. The selected remedy represents the best balance among the
alternatives with respect to these criteria and is the environmentally preferable alternative.
The preferred alternative for Operable Unit 4 provides the best performance when compared with the
other alternatives, with respect to the evaluation criteria. This remedy will achieve substantial risk
reduction by removing the sources of contamination, treating the material which poses the highest risk,
shipping the treated residues off-site for disposal, managing the remaining contaminated soils and debris
consistent with the site-wide strategy. The selected treatment alternative both reduces the mobility of the
hazardous constituents and results in significant reduction in the volume of materials requiring disposal.
The selected remedy also provides the highest degree of long-term protectiveness for human health and
the environment.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost
effective. This remedy utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable, and satisfies the statutory preference for remedies that
employ treatment, and also reduce toxicity, mobility, or volume as a principal element. This remedy will
result in contaminated debris and soil being dispositioned by Operable Units 3 and 5, respectively.
Because this remedy will result in hazardous substances (i.e., contaminated soil and debris) remaining
on site, above health-based levels, a review will be conducted every five years after commencement of
remedial action to ensure that the remedy continues to provide adequate protection of human health and
the environment.
All practical means to avoid or minimize environmental harm from implementation of the selected remedy
have been adopted. During excavation activities, sediment controls will be implemented to eliminate
potential surface water runoff and sediment deposition to Paddys Run. Final site layout and design will
include all practicable means (e.g., sound engineering practices and proper construction practices) to
minimize environmental impacts.
Regional Administrator, pf
U.S. Environmental Protection Agenc&/Region V
Assistant Secrewry for Environmental Management
U.S. Department of Energy
Date
D-iv
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December 1994
TABLE OF CONTENTS Page
List of Tables v
List of Figures v
Acronym List vi
List of Weights and Measures viii
1.0 Site Location and Description 1-1
1.1 Location 1-1
1.2 Demographics and Land Use 1-6
1.3 Topography and Surface Water Hydrology 1-7
1.4 Geology and Hydrogeology 1-9
1.5 Ecology 1-11
2.0 Site and Operable Unit 4 History and Enforcement Activities 2-1
2.1 Site History 2-1
2.2 Operable Unit 4 History 2-2
3.0 Community Participation 3-1
3.1 Operable Unit 4 Public Involvement Activities 3-1
4.0 Scope and Role of Remedial Action 4-1
4.1 Integration of NEPA into CERCLA 4-2
5.0 Summary of Operable Unit 4 Characteristics 5-1
5.1 Investigative Studies 5-1
5.2 Summary Description of Contamination Sources 5-1
5.2.1 Classification of Contamination Sources 5-1
5.2.2 Source Characteristics 5-2
5.3 Nature and Extent of Contamination 5-4
5.3.1 Surface Soils 5-4
5.3.2 Subsurface Soils 5-6
5.3.3 Surface Water and Sediment 5-6
5.3.4 Groundwater 5-6
5.4 Potential Exposure Pathways for Contaminant Migration 5-8
5.4.1 Direct Radiation 5-9
5.4.2 Air Emissions 5-9
5.4.3 Surface Water Runoff 5-10
5.4.4 Groundwater Transport 5-10
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TABLE OF CONTENTS FEMP-OU4ROD-8 FINAL
(Continued) December 1994
6.0 Baseline Risk Assessment 6-1
6.1 Summary of the Baseline Assessment of Risks to Human Health 6-2
6.1.1 Constituents of Concern 6-2
6.1.2 Exposure Assessment 6-2
6.1.3 Toxicity Assessment 6-7
6.1.4 Risk Characterization Results 6-21
6.1.4.1 Current Land Use Without Access Control/Current
Source-Term Scenario 6-21
6.1.4.2 Current Land Use Without Access Control/Future
Source-Term Scenario 6-24
6.1.4.3 Current Land Use With Access Control/Current
Source-Term Scenario 6-24
6.1.4.4 Future Land Use/Current Source-Term Scenario 6-24
6.1.4.5 Future Land Use/Future Source-Term Scenario 6-25
6.1.5 Risk Assessment Uncertainties 6-25
6.1.5.1 Sources of Uncertainty 6-26
6.1.5.2 Toxicity Assessment 6-26
6.2 Overview of the Baseline Ecological Risk Assessment 6-27
7.0 Description of Remedial Alternatives 7-1
7.1 No-Action Alternative For All Subunhs 7-3
7.2 Subunit A - Contents of Silos 1 and 2 and the Decant Sump Tank 7-4
7.2.1 Alternative 3A.1/Vit - Removal, Vitrification, and
Off-Site Disposal - Nevada Test Site 7-4
7.2.2 Alternative 3A.1/Cem - Removal, Cement Stabilization, and
Off-Site Disposal - NTS 7-7
7.3 Subunit B - Contents of Silo 3 7-8
7.3.1 Alternative 2B/Vit - Removal, Vitrification, and
On-Property Disposal 7-9
7.3.2 Alternative 2B/Cem - Removal, Cement Stabilization, and
On-Property Disposal 7-11
7.3.3 Alternative 3B.1/Vit - Removal, Vitrification, and
Off-Site Disposal - NTS 7-12
7.3.4 Alternative 3B.1/Cem - Removal, Cement Stabilization, and
Off-Site Disposal - NTS 7-13
7.3.5 Alternative 4B - Removal and On-Property Disposal 7-14
7.4 Subunit C - Silos 1, 2, 3, and 4 Structures, Soils, and Debris 7-14
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TABLE OF CONTENTS FEMP-OU4ROD-8 FINAL
(Continued) December 1994
7.4.1 Alternative 2C - Demolition, Removal, and On-Property Disposal 7-16
7.4.2 Alternative 3C.1 - Demolition, Removal, and Off-Site
Disposal - NTS 7-19
7.4.3 Alternative 3C.2 - Demolition, Removal, and Off-Site
Disposal (Permitted Commercial Disposal Site) 7-19
8.0 Summary of the Comparative Analysis of Alternatives 8-1
8.1 Evaluation Criteria 8-1
8.2 Comparative Analysis of Alternatives 8-2
8.2.1 Analysis for Subunit A 8-2
8.2.1.1 Threshold Criteria 8-2
8.2.1.2 Primary Balancing Criteria 8-7
8.2.1.3 Modifying Criteria 8-10
8.2.1.4 Subunit A Comparative Analysis Summary 8-10
8.2.2 Subunit B 8-10
8.2.2.1 Threshold Criteria 8-10
8.2.2.2 Primary Balancing Criteria 8-13
8.2.2.3 Modifying Criteria 8-15
8.2.2.4 Subunit B Comparative Analysis Summary 8-15
8.2.3 Subunit C 8-16
8.2.3.1 Threshold Criteria 8-16
8.2.3.2 Primary Balancing Criteria 8-17
8.2.3.3 Modifying Criteria 8-20
8.2.3.4 Subunit C Comparative Analysis Summary 8-20
9.0 Selected Remedy 9-1
9.1 Key Components 9-1
9.1.1 Removal of Silo 1, 2 and 3, and Decant Sump Tank Contents 9-2
9.1.2 Vitrification of Silo 1, 2 and 3, and Decant Sump Tank Contents 9-2
9.1.3 Off-Site Shipment and Disposal of Treated Material 9-3
9.1.4 Demolition and Decontamination of Structures 9-3
9.1.5 Demolition and Decontamination of Other Operable Unit 4 Structures 9-4
9.1.6 Disposition of Demolished Structures and Debris 9-4
9.1.7 Soil Removal 9-5
9.1.8 Soil Disposition 9-6
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TABLE OF CONTENTS FEMP-OU4ROD 8 final
(Continued) December 1994
9.1.9 Cost 9-7
9.2 Soil Cleanup Criteria 9-7
9.2.1 Land Use and Receptor Description 9-7
9.2.2 Preliminary Remediation Levels 9-9
9.3 Measures to Control Environmental Impacts 9-13
10.0 Statutory Determinations 10-1
10.1 Protection of Human Health and the Environment 10-1
10.2 Compliance With Legally Applicable or Relevant and Appropriate
Requirements 10-2
10.3 Cost Effectiveness 10-3
10.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable 10-3
10.5 Preference for Treatment as a Principal Element 10-4
10.6 Unavoidable Adverse Impacts 10-4
10.7 Irreversible and Irretrievable Commitment of Resources 10-7
11.0 Documentation of Significant Changes 11-1
11.1 Repromulgation of 40 CFR § 191 11-1
11.1.1 Background 11-1
11.1.2 Impacts of Repromulgation 11-2
References R-l
Appendix A Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives A-l
Appendix B Summary of ARARs for the Operable Unit 4 Remedial Action B-l
Appendix C Responsiveness Summary C-l
Appendix D Administrative Record File Index D-l
Appendix E State of Ohio Concurrence E-l
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FEMP-OU4ROD-8 FINAL
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LIST OF TABLES
Page
6-1 Constituents of Concern for Operable Unit 4 6-3
6-2 Summary of Land-Use/Receptor/Source-Term Scenarios 6-8
6-3 Cancer Slope Factors for Carcinogenic Effects of Constituents of
Concern for Operable Unit 4 6-12
6-4 Cancer Slope Factors for Operable Unit 4 Radionuclides of
Concern 6-16
6-5 Reference Doses for Noncarcinogenic Effects of Constituents of
Concern for Operable Unit 4 6-17
6-6 Incremental Lifetime Cancer Risk Summary All Sources/All
Pathways 6-22
6-7 Hazard Index Summary All Sources/All Pathways 6-23
8-1 Comparison of Remedial Alternatives 8-3
8-2 Operable Unit 4 Remedial Alternative Cost Summary (Million $) 8-11
9-1 Combined Cost Estimate for Selected Remedy 9-8
9-2 Preliminary Remediation Levels in Soils - Radionuclides 9-10
9-3 Preliminary Remediation Levels in Soils - Chemicals 9-11
10-1 Unavoidable Adverse Impacts on Resources 10-5
LIST OF FIGURES
Page
1-1 FEMP Facility Location Map 1-2
1-2 Waste Storage Area 1-3
1-3 Operable Unit 4 1-5
1-4 Surface Water Hydrology 1-8
1-5 Approximate Boundaries of Jurisdictional Wetlands at FEMP 1-13
1-6 Great Miami River and Paddys Run 100-Year and 500-Year Floodplain 1-14
6-1 OU4 Conceptual Model - Silo Contents 6-9
6-2 OU4 Conceptual Model - Soil and Berm Fill Material 6-10
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December 1994
ACRONYM LIST
AEA
Atomic Energy Act
AEC
Atomic Energy Commission
ARAR
applicable or relevant and appropriate requirements
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CIS
Characterization Investigation Study
CFR
Code of Federal Regulations
CMSA
Consolidated Metropolitan Statistical Area
COC
Constituents of Concern
COE
United States Army Corps of Engineers
CT
central tendency
DOE
United States Department of Energy
DOE-FN
United States Department of Energy - Fernald Field Office
DOE-NV
United States Department of Energy - Nevada Operations Office
DOT
U. S. Department of Transportation
EIS
Environmental Impact Statement
EP
Extraction Procedure
EPA
United States Environmental Protection Agency
FEMP
Fernald Environmental Management Project
FERMCO
Fernald Environmental Restoration Management Corporation
FFCA
Federal Facility Compliance Agreement
FMPC
Feed Materials Production Center
FRESH
Fernald Residents for Environment, Safety, and Health
FS
Feasibility Study
FS/PP-DEIS
Feasibility Study/Proposed Plan - Draft Environmental Impact Statement
FS/PP-FEIS
Feasibility Study/Proposed Plan - Final Environmental Impact Statement
HEAST
Health Effects Assessment Summary Table
HEPA
High-Efficiency Particulate Air (filter)
HI
Hazard Index
HQ
Hazard Quotient
IARC
International Agency for Research on Cancer
ILCR
incremental lifetime cancer risk
IRIS
Integrated Risk Information System
ISA
Initial Screening of Alternatives
vi
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ACRONYM LIST
(Continued)
FEMP-OU4ROD-8 FINAL
December 1994
LRA
MCL
MCLG
MCW
MSL
NCP
NEPA
NOEL
NOI
NOV
NPDES
NPL
NRHP
NTS
O&M
OAC
OEPA
ORC
PAH
Pb
PCB
PEIC
Po
PP
PRG
PRL
Ra
RCRA
RfD
RI
RI/FS
RME
Rn
ROD
leading remedial alternative
maximum containment level
maximum containment level goal
Mallinckrodt Chemical Works
mean sea level
National Oil and Hazardous Substances Pollution Contingency Plan
National Environmental Policy Act
No Observed Effect Level
Notice of Intent
Notice of Violation
National Pollutant Discharge Elimination System
National Priorities List
National Register of Historic Places
Nevada Test Site
operation and maintenance
Ohio Administrative Code
Ohio Environmental Protection Agency
Office of Regional Council
polyaromatic hydrocarbons
lead
polychlorinated biphenyls
Public Environmental Information Center
polonium
Proposed Plan
proposed remediation goals
proposed remediation level
radium
Resource Conservation and Recovery Act
reference dose
Remedial Investigation
Remedial Investigation/Feasibility Study
reasonable maximum exposure
radon
Record of Decision
vii
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ACRONYM LIST
(Continued)
RTS radon treatment system
SARA Superfund Amendment and Reauthorization Act
SDWA Safe Drinking Water Act
TBC to be considered
TCLP Toxicity Characteristic Leaching Procedure
Th thorium
U uranium
USDA United States Department of Agriculture
VOC volatile organic compounds
LIST OF WEIGHTS AND MEASURES
cm
centimeter
ft
feet
ha
hectare
in
inch
kg
kilogram
km
kilometer
km2
square kilometers
L
liters
m
meter
m3
cubic meters
Mg/1
micrograms per liter
M
million
mi
miles
mi2
square miles
mg
milligram
mg/kg
milligrams per kilogram
mg/kg-day
milligrams per kilogram day
mg/1
milligrams per liter
pCi/1
picoCuries per liter
pCi/g
picoCuries per gram
PPb
parts per billion
yd3
cubic yards
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FEMP-OU4ROD-8 FINAL
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1.0 SITE LOCATION AND DESCRIPTION
1.1 LOCATION
The Fernald Environmental Management Project (FEMP) site is a 425 hectare (ha) (1050 acres),
government-owned facility located in southwestern Ohio, approximately 29 kilometers (km) (18 miles)
northwest of downtown Cincinnati. The facility is located just north of Fernald, Ohio, a small
farming community, and lies on the boundary between Hamilton and Butler counties (Figure 1-1).
In accordance with the requirements of the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), the FEMP was placed on the National Priorities List (NPL) in
November 1989 as a result of environmental impacts caused by facility operations.
From 1952 until 1989, the FEMP site provided high-purity uranium metal products to support United
States defense programs. Uranium production was halted in 1989 due to declining demand and a
recognized need to commit available resources to environmental remediation. Former uranium
operations at the FEMP site were limited to a fenced 55 ha (136 acres) tract of land known as the
former Production Area located near the center of the site. The former Production Area consists of
plant buildings, scrap metals, equipment, and drummed inventories all of which are components of
Operable Unit 3. Large quantities of liquid and solid wastes were generated by the various production
operations at the FEMP site. Prior to 1984, solid and slurried wastes received from off site sources
and generated from FEMP processes were stored or disposed in the Waste Storage Area. This area,
located west of the production facilities, includes: six low-level radioactive waste storage pits, two
earthen-bermed concrete silos containing K-65 residues, one concrete silo containing metal oxides,
one unused concrete silo, two lime sludge ponds, a burn pit, a clearwell, and a solid waste landfill.
The Waste Storage Area, shown graphically in Figure 1-2, is addressed under FEMP Operable Units
1, 2, and 4. The former Production Area and Waste Storage Area are fenced and closed to the
general public. Operable Unit 5 consists of all environmental media not associated with the preceding
operable units. The remaining FEMP site areas consist of forest and pasture lands, a portion on which
a nearby dairy farmer is authorized to graze livestock.
A sixth operable unit, known as the Comprehensive Site-Wide Operable Unit, was added as a
provision of the Amended Consent Agreement (signed in 1991). This is not a specific site area;
rather, it was created to enable DOE, the EPA, and the public to make a final assessment from a site-
wide perspective that ongoing planned remedial actions identified in the Records of Decision for
1-1
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Indiana
Kentucky
Graphics #2634.a 3.94
& Ross
Fernald
'Harrison
Miami
Cleves
Cincinnati
Great -
Cincinnati
Northern Kentucky
International
Airport
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FEMP-OU4ROD-8 FINAL
December 1994
OPERABLE
UNIT 1
OPERABLE
UNIT 2
BOUNDARY
ni
Landf
• ••//
Pit 1: //
HtflU
Lagoon
I *•fr • •
Sludge
_ Ponds
>¦¦¦¦¦¦
-65-^B
|| T OPERABLE
\\ UNIT 4
BOUNDARY
Scale in Feet
250
LEGEND
500
Covered Pits
—=x— Fenceline
¦4—+— Railroad
::::: Roadway
FIGURE 1-2. WASTE STORAGE AREA
1-3
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FEMP-OU4ROD-8 FINAL
December 1994
the five operable units will provide a comprehensive remedy which is protective of human health and
the environment.
This remedial action addresses Operable Unit 4 at the FEMP. Operable Unit 4 (Figure 1-3) is a 2.3
ha (5.8 acres) area located on the western side of the facility and is comprised of the following
facilities and associated environmental media:
• Silos 1 and 2 and their contents (also termed K-65 silos);
• Silo 3 and its contents (termed cold metal oxide silo);
• Silo 4 (empty);
• The decant sump (an underground tank and its contents);
• A radon treatment system;
• A portion of a concrete pipe trench and other concrete structures;
• An earthen berm surrounding Silos 1 and 2;
• Soils beneath and immediately surrounding Silos 1, 2, 3, and 4;
• Perched groundwater in the vicinity of the silos that are encountered during the
implementation of remedial actions;
Silos 1 and 2, the K-65 silos, contain 6,120 cubic meters (m3) [8,005 cubic yards (yd3)] of K-65
residues generated from the processing of high-grade uranium ore. The silos are large, cylindrical,
above-grade, concrete vessels with post-tensioned steel reinforcing. Each of the domed silos is 24.4
meter (m) [80 feet (ft)] in diameter and 11 m (36 ft) high to the center of the dome.
The K-65 residues contain large activity concentrations of radionuclides, including radium and
thorium. These radionuclides contribute to an elevated direct penetrating radiation field in the vicinity
of the silos and to the chronic emission of significant quantities of the radioactive gas, radon, to the
atmosphere from the silos. The K-65 residues are classified as by-product materials, consistent with
Section ll(e)2 of the Atomic Energy Act (AEA), generated consequential to the processing of natural
uranium ores.
Silo 3 contains 3,890 m3 (5,088 yd3) of residues, known as cold metal oxides, which were generated
at the FEMP site during uranium extraction operations in the 1950s involving the previously
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CN
ad
4g1.000
SiLO 4
FORMER K—65
DRUM STAGING
AREA
SILO 3
CONCRETE FOUNpATTG
FORMER K—65 DRUM
HANDLING BUILDING/
RADON TREATMENT
SYSTEM
SILO 2
CONCRETE FOUNDATION
FOR SUMP LIFT STATION
CONCRETE
PIPE TRENCH
JL
DECANT SUMP TANK
SILO 1
SCALE:
250 FEET
LEGEND:
OPERABLE UNIT 4
BOUNDARY
FENCE
x.
ROADWAY
480,000
STATE PLMMR COORDINATE
FIGURE 1-3. OPERABLE UNIT 4
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mentioned uranium ores and ore concentrates received from a variety of uranium mills in the United
States and abroad. Silos 3 and 4 are identical in design and construction to Silos 1 and 2. The
residues within Silo 3 are similarly classified as by-product materials pursuant to Section ll(e)2 of the
AEA. Silo 4 was never used for waste storage; however, rainwater has infiltrated the silo and has
been removed in 1989 and again in 1991.
1-2 DEMOGRAPHICS AND LAND USE
The FEMP is located in the Cincinnati Consolidated Metropolitan Statistical Area (CMSA) which
encompasses a regional area comprised of eight counties in Ohio, Kentucky, and Indiana. Population
within the eight-county metropolitan area exceeded 1.7 million in 1990, and within a 5-mile radius of
the FEMP site, there were an estimated 22,927 residents in 1990.
The on-property work population includes employees of DOE, it's site restoration management
contractor, the Fernald Environmental Restoration Management Corporation (FERMCO), and other
subcontractors. Physical structures are located on approximately 82 ha (203 acres) in the center of
the FEMP site, in the administration area and in the former Production Area. The FEMP maintains
strict access controls, including a security force and fences, which control public access to the site.
The land adjacent to the FEMP is primarily devoted to open land use such as agriculture and
recreation. Scattered residences and several villages, including Fernald, New Baltimore, Ross, New
Haven, and Shandon are located near the FEMP site. The nearest residence is within three quarters
of a mile from the center of the facility. The nearest residences to the western FEMP property
boundary (the boundary along the eastern side of Paddys Run Road) are located along the western
side of Paddys Run Road. A dairy farm is located on Willey Road just outside the southeast corner
of the FEMP property boundary. Several residences are located off Paddys Run Road approximately
2.4 km (1.5 mi) south of the FEMP property. These residences are in the vicinity of the South
Plume, a portion of the Great Miami Aquifer that contains a plume of uranium contamination
originating from the FEMP extending south of the property boundary for approximately three-quarters
of a mile.
More than 160 ha (395 acres) of the open land on the FEMP property are leased to a nearby dairy
farmer who grazes livestock on the property. Pine plantations are located to the northeast and
southwest of the former Production Area. A considerable amount of the soils within the boundaries
of the FEMP site are designated by the United States Department of Agriculture (USDA) as prime
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agricultural soil (USDA 1980, 1982). However, none of the land on the FEMP site is designated
prime farmland under the Farm and Policy Protection Act regulations (7 CFR §658) of 1981.
Because the area had been intensively used for agricultural purposes prior to the establishment of the
FEMP facility, there is no land on or in the vicinity of the FEMP site where a pre-developed natural
environment remains intact. The land closest to this description would be recreated prairie lands on
the Miami Whitewater Forest Park, several miles south of the FEMP site.
The area surrounding the FEMP site has a large and diverse archaeological and historical resource
base. According to records kept by the Miami Purchase Association for Historic Preservation, an
unusually high percentage of the existing 19th century buildings in the area are historically important.
Within the vicinity of the FEMP site [a 3.2 km (2 mi) radius from the boundary], there are properties
listed on the National Register of Historic Places (NRHP) and a number of additional structures that
have been judged eligible for inclusion in the listing. Six major archaeological sites lie within five
miles of the FEMP site and five of these are included in the NRHP. No archaeological sites or
properties on the NRHP are located in or adjacent to Operable Unit 4.
1.3 TOPOGRAPHY AND SURFACE WATER HYDROLOGY
The maximum elevation along the northern boundary of the FEMP property is a little more than 213
m (700 ft) above mean sea level (MSL). The former Production Area and Waste Storage Area rest
on a relatively level plain at about 174 m (580 ft) above MSL. The plain slopes from 183 m (600 ft)
above MSL along the eastern boundary of the FEMP to 174 m (570 ft) above MSL at the K-65 silos,
and then drops off toward Paddys Run stream at an elevation of 168 m (550 ft) above MSL.
All drainage, including surface water on the FEMP site is generally from east to west towards Paddys
Run, with the exception of the extreme northeast corner which drains east toward the Great Miami
River. Major surface water bodies on and adjacent to the FEMP site include the Storm Sewer Outfall
Ditch, Paddys Run, and the Great Miami River (see Figure 1-4). The Storm Sewer Outfall Ditch
originates within the FEMP site and flows toward the southwest where it enters Paddys Run, which
flows southward along the western boundary of the facility. Paddys Run is a tributary of the Great
Miami River. The Great Miami River flows generally toward the southwest; however, locally it
flows to the east and south of the FEMP site.
Paddys Run originates north of the FEMP site, flows southward along the western boundary of the
facility, and enters the Great Miami River approximately 2.4 km (1.4 mi) south of the southwest
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FEMP
SITE
FORMER
PRODUCTION
AREA
OUTFALL
MH—175
MAIN EFFLUENT LINE
STORMWATER
RETENTION BASINS
•STORM SEWER
OUTFALL DITCH
BIG BEND AREA"
LEGEND:
• SOUTHWESTERN OHIO
WATER COMPANY WELL FIELD
~ MANHOLE
FIGURE 1 — 4. SURFACE WATER HYDROLOGY
SCALE
1000 2000 FEET
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comer of the FEMP property. The stream is approximately 14 km (8.8 mi) long and drains an area
of approximately 40.9 square kilometers (km2) [15.8 square miles (mi2)]. Due to the highly
permeable channel bottom, the stream loses water to the underlying Great Miami Aquifer in some
locations. In addition, the stream is ephemeral and is generally dry during the summer months.
The Great Miami River is the main surface water feature in the vicinity of the FEMP site, which
receives effluent water from a National Pollutant Discharge Elimination System (NPDES) permitted
discharge from the FEMP site. The river flows generally to the southwest and has a drainage area of
approximately 8702 km2 (3360 mi2) at the Hamilton gauge, which is located about 16.1 km (10 mi)
upstream from die FEMP site NPDES discharge outfall.
The river exhibits meandering patterns that result in sharp directional changes over distances of less
than 900 m (2,953 ft). Directly east of the FEMP site and within the site-wide Remedial
Investigation/Feasibility Study (RI/FS) Area, the river passes through a 180-degree curve known as
the Big Bend. A 90-degree bend in the river also occurs near New Baltimore, approximately 3.2 km
(2 mi) downstream from the FEMP site discharge outfall.
Surface water flow within Operable Unit 4 is directed through a series of trench drains, concrete
curbs, and gutters to an inground concrete sump located in waste storage area. Water from these
storm water control facilities are directed through existing site treatment systems prior to discharge
through the FEMP effluent line to the Great Miami River.
1.4 GEOLOGY AND HYDROGEOLOGY
The FEMP overlies a 3.2 to 4.8 km (2 to 3 mi) wide buried Pleistocene valley known as the New
Haven Trough. This valley was formed (eroded) by the ancestral Ohio River during the Pleistocene
period and was subsequently filled with glacial outwash materials that were in turn covered by glacial
overburden as glaciers advanced across the area. The outwash deposits under the FEMP are a part of
die Great Miami Aquifer, which is a widely distributed buried valley aquifer. In addition to surface
water, the valley fill aquifer system is the major source of drinking water in the southwestern Ohio
area.
Since the last retreat of continental glaciers, the streams in the area have removed much of the glacial
overburden and lacustrine strata left by the ice sheets. The Great Miami River has eroded through
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the glacial overburden and is now in direct contact with the outwash deposits that comprise the Great
Miami Aquifer. Paddys Run is also in contact with these deposits in its lower reaches.
The Great Miami Aquifer is the principal aquifer within the FEMP Study Area and has been
designated a sole-source aquifer under the provisions of the Safe Drinking Water Act (SDWA). The
buried valley in which it occurs varies in width from about 0.8 km (0.5 mi) to more than 3.2 km (2
mi), having a U-shaped cross section with a broad, relatively flat bottom and steep valley walls. This
valley is filled with extensive deposits of sand and gravel that range in thickness from 36 to 60 m
(120 to 200 ft) in the valley to only several feet along the valley walls, along with scattered silt and
clay deposits.
Contained within the sand and gravel that underlies much of the FEMP property is a relatively
continuous, low-permeability clay interbed ranging from about l.S to 4.S m (S to IS ft) in thickness.
The clay interbed which exists below the Operable Unit 4, occurs at an approximate elevation of 140
m (460 ft) above MSL. This clay interbed divides the aquifer into upper and lower sand and gravel
units, referred to as the Upper Great Miami Aquifer and the Lower Great Miami Aquifer.
Overlying the Great Miami Aquifer throughout most of the FEMP property, including Operable Unit
4, are a series of glacial overburden deposits. The glacial overburden is composed primarily of till, a
dense, silty clay that contains discontinuous and isolated lenses of poorly sorted fine- to medium-
grained sand and gravel, silty sand, and silt. The glacial overburden exposed at the surface has
relatively low permeability, so most of the precipitation that falls on it is lost to evaporation and
surface water runoff. Within Operable Unit 4, sand and gravel outwash deposits of the buried valley
are overlain by 1.5 to 3 m (5 to 10 ft) of till that is in turn overlain by 4.5 to 6 m (15 to 20 ft) of
lacustrine sediments. The till is an unsorted mixture of clay, silt, sand, and pebble to cobble size
material with 70 to 80 percent of the material falling in the clay and silt size range.
Erratically distributed pockets of silty sand and gravel within the glacial overburden contain zones of
perched groundwater. Perched groundwater is separated from the underlying aquifer by the
surrounding relatively impermeable clay and silt components of the overburden. These low-
permeability units behave as an aquitard that can store groundwater, then transmit it slowly downward
from one more porous saturated zone to another.
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The conceptual model for groundwater flow in the glacial overburden in Operable Unit 4 indicates
that the lacustrine strata have good, but slow, hydraulic communication and that the till that underlies
the lacustrine strata acts as an aquitard. Groundwater within the approximately 6 m (20 ft) of
lacustrine strata is predicted to flow at a lateral rate that is significantly greater than its downward
rate. Therefore, groundwater is likely discharging westward to the bank of Paddys Run and
southward in the east-west drainageway immediately south of Silo 1.
1.5 ECOLOGY
The FEMP site and surrounding areas lie in a transition zone between two distinct sections of the
Eastern Deciduous Forest Province; the Oak-Hickory and the Beech-Maple. The dominant species
are oaks, with an abundance of hickories. The fauna vary little between the two forest sections and
include white-tailed deer, gray fox, gray squirrel, white-footed mouse, and short-tailed shrew; the
cardinal, woodthrush, summer tanager, red-eyed vireo, and the hooded warbler; the box turtle,
common garter snake, and timber rattlesnake.
The Indiana bat is listed as both a federally and state endangered species and occurs in Butler and
Hamilton Counties. Surveys were conducted at the FEMP to determine the distribution and presence
of the Indiana bat and to identify potential habitat on the FEMP and in the immediate vicinity. The
Indiana bat has not been identified at the FEMP. Potential habitat for the Indiana bat occurs in
portions of the riparian woodland associated with Paddys Run.
The Sloan's crayfish, a state listed threatened species, has been identified in Paddys Run in northern
sections on property and southern sections off property in preliminary surveys in September 1993.
Potential harm may occur as a result of siltation and runoff into Paddys Run.
The cave salamander, a state listed endangered species, has not been identified at the FEMP site.
Moderate habitat has been identified in a well in the northeastern section of the FEMP and a ravine in
the north woodlot.
A site-wide wetland delineation was conducted in February 1993, in accordance with the 1987 United
States Army Corps of Engineers (COE) Wetlands Delineation Manual. A jurisdictional determination
was approved in August 1993 by the COE that verified wetland boundaries and waters of the United
States. Results from the site-wide delineation, subject to COE approval, indicate a total of 14.4 ha
(35.9 acres) of wetlands that include 10.6 ha (26.6 acres) of palustrine forested wetlands, 2.8 ha
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(7 acres) of drainage ditches/swales, and 0.95 ha (2.37 acres) of isolated emergent and emergent-
scrub/shrub wetlands (see Figure 1-5).
Floodplains within the FEMP property are confined to the north-south corridor containing Paddys
Run. Outside the boundaries of the FEMP site, the 100-year floodplain of the Great Miami River
extends west nearly to the eastern boundary of the facility (see Figure 1-6). The 100-year floodplain
of the river also extends northward along Paddys Run from the confluence of the two streams to a
point about 180 m (600 ft) from the southern boundary of the FEMP site.
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WETLANDS/RE5 NO.2227-11xl7-FIG1-10.DGN-CRU»4
FERMCO/ENGCAD/ 5/5/94
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FEMP-OU4i
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S.Rv
BUTLER COVHTY
HAMILTON COUNTY
SEE INSET
FOR DETAIL
OF THIS AREA
HAMILTON COUKTT
SCALE
TOT
LEGEND:
FEMP PROPERTY BOUNDARY
COUNTY UNE
100-YEAR FUOOOPLAIN
AREAS WHERE 900-YEAR OOOOPUUN
EXTENDS BETONO 100-YEAR FUOOOPLAIN
SOURCE;
FEDERAL EMERGENCY
MANAGEMENT AGENCY. 19B2"
FIGURE 1-6. GREAT MIAMI RIVER AND PADDYS RUN
100-YEAR AND 500-YEAR FLOODPLAIN
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2.0 SITE AND OPERABLE UNIT 4 HISTORY
AND ENFORCEMENT ACTIVITIES
2.1 SITE HISTORY
In January 1951, the New York Operations Office of the Atomic Energy Commission (AEC)
proceeded on an expedited basis with the selection of a suitable site for the construction of a new feed
material production center to supply high purity uranium products. Sixty-three sites were considered
with a site near Fernald, Ohio being selected as best meeting established criteria. Construction
operations were initiated in May 1951, on the 1050 acre site. The facility was designated the Feed
Material Production Center (FMPC) prior to initiation of on-property pilot operations in October
1951. Production operations were initiated in 1952 and continued until July 1989, at which time
operations were placed on standby to focus on environmental compliance and waste management
initiatives. Following appropriate congressional authorizations, the facility was formally closed in
June 1991. To reflect a new site mission focused on environmental restoration, the name of the
facility was changed to the Fernald Environmental Management Project (FEMP) in August 1991.
On March 9, 1985, the EPA issued a Notice of Noncompliance to the DOE identifying EPA's
concerns over potential environmental impacts associated with the FEMP's past and ongoing
operations. On July 18, 1986, a Federal Facility Compliance Agreement (FFCA) detailing actions to
be taken by DOE to assess environmental impacts associated with the FEMP was signed by DOE and
EPA. The FFCA was entered into pursuant to Executive Order 12088 (43 FR 47707). The purpose
of the FFCA was to ensure compliance with existing environmental statutes and implementing
regulations. Also, environmental impacts associated with past and present activities at the FEMP site
would be thoroughly and adequately investigated so that appropriate response actions could be
implemented. As required by the FFCA, a RI/FS was initiated in July 1986, pursuant to 42 U.S.C.
9601 et seo.. CERCLA.
In November 1989, the FEMP was placed on the NPL for investigation and remediation under
CERCLA. This placement, in addition to progressive findings in the RI/FS program, necessitated the
amendment of the FFCA. The 1986 FFCA was superseded by a Consent Agreement under Sections
120 and 106(a) of CERCLA (Consent Agreement) providing for the implementation of operable units
for the FEMP RI/FS and revising the milestone commitments for the RI/FS program without
modifying the underlying objectives of the FFCA. The Consent Agreement also provided for the
implementation of removal actions to address site conditions which pose an immediate threat to
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human health and the environment, including removal actions for Operable Unit 4, such as the K-65
Silos Removal Action. The Consent Agreement was signed on April 9, 1990, and became effective
on June 29, 1990, following a period of public comment.
In October 1990, the first version of the RI Report for Operable Unit 4 was submitted to the EPA for
review and comment. The EPA determined that the FMPC had not adequately characterized Operable
Unit 4, and subsequently, issued a Notice of Violation (NOV) against the site. The EPA issued two
other NOVs at approximately the same time regarding other components of the ongoing RI/FS.
Following negotiations between the EPA and DOE, a resolution agreement was jointly signed by the
EPA and DOE. Pursuant to the terms of this resolution agreement, DOE paid a financial penalty to
EPA, agreed to perform a supplemental project beneficial to the environment surrounding the site,
and also agreed to enter into negotiations with EPA to define new schedules for re-submittal of the
RI/FS documents.
The Consent Agreement was amended in 1991 to revise the schedules for completing the RI/FS for
the five identified operable units. This Amended Consent Agreement was signed on September 20,
1991, and became effective on December 19, 1991, following a period of public comment.
2.2 OPERABLE UNIT 4 HISTORY
Originally constructed in 1951 and 1952, three of the four reinforced concrete storage silos within
Operable Unit 4 received by-product materials until 1960. Silos 1 and 2 received K-65 residues
generated from the processing of high assay uranium ores, termed pitchblende ores, at the FEMP and
the Mallinckrodt Chemical Works (MCW) in St. Louis, Missouri. The pitchblende ores processed at
MCW and the vast majority of pitchblende ores processed at the FEMP came primarily from one
mine, the Shinkolobwe Mine in the Belgian Congo (now Zaire).
The Shinkolobwe Mine was owned and operated by the African Metals Corporation. These ores
contained relatively high concentrations of uranium oxides (U3Og) in the range of 40 to 50 percent as
well as high concentrations of radium. Based on the high value of radium at the time, the agreement
reached between the AEC and the African Metals Corporation stipulated that the African Metals
Corporation would retain ownership of the radium within any processing residues; after the United
States had processed the pitchblende ore to extract uranium, the residue would be returned to the
African Metals Corporation.
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The K-65 silos were constructed at the FEMP site to provide interim storage of the residues, pending
the return of the materials to the country of origin. For more than 30 years, these materials remained
in storage at the FEMP site, under the terms of the original agreement, awaiting transfer. In 1984,
ownership of the K-65 residues was transferred to DOE.
As the drums were received by railroad car at the FEMP, from MCW, the drums were temporarily
staged in an area to the east of Silos 3 and 4 (Figure 1-3). The drummed material was slurried in the
Drum Handling Building, formerly located between Silos 2 and 3, and then pumped to Silos 1 and 2
for storage. Approximately 31,000 drums of residues generated through MCW processing operations
were received at the FEMP. Approximately 24,000 of these drums were transferred to Silo 1,
completely filling the structure in November 1953. The remaining 7,000 drums were transferred to
Silo 2 for storage.
Additionally, Silo 2 received residues generated at the FEMP from the processing of pitchblende ores
from the Shinkolobwe Mine and a small quantity of Australian ores from two mines, the Rum Jungle
Mine and the Radium Hill Mine. The last residues were placed in Silo 2 in January 1959. Following
the end of K-65 processing operations at the FEMP, approximately 150 drums of radium
contaminated material, consisting of soils from drum staging areas, clean-up materials, and excess K-
65 samples were placed into Silo 2 in June 1960.
Silos 3 and 4 were constructed in 1952 for storing metal oxides generated by the FEMP refinery.
Unlike Silos 1 and 2, which received residues from the processing of ores from mainly one mine, Silo
3 received metal oxides generated from FEMP refinery operations from May 1954, until late 1957.
During this period, the FEMP refinery processed the previously mentioned pitchblende ores and
uranium ore concentrates received from a number of foreign and domestic uranium mills. Select
refinery waste streams were first filtered to remove radium and subsequently directed to an evaporator
and calciner. These finely powdered, dried refinery residues (termed cold metal oxides) were
transferred to a surge hopper from where the materials were pneumatically conveyed through a
pipeline to Silo 3.
Following a programmatic decision in early 1957 to utilize raffinate surface impoundments, the
calcining systems were eventually abandoned. As a result of this decision, Silo 4 was never
employed for the storage of cold metal oxides or other site materials and remains empty. Inspections
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completed on Silo 4 during the Rl-related site investigations confirmed that no waste materials are
present within the silo.
In 1963, it became visually obvious that Silos 1 and 2 were deteriorating. In 1964, site workers
repaired the concrete coating around each silo and constructed an earthen berm around them to
counterbalance the outward load from the silos contents. The berm also protected the silos walls
from weathering and served as a radiation shield. This berm was expanded in 1983 to reduce soil
erosion.
Other improvements to Silos 1 and 2 included: sealing the vents in the domes in 1979; installing
plywood covers on the domes in 1986; and adding a polyurethane coating in 1987 to reduce
weathering and to help lower radon emissions. This coincided with the installation of the radon
treatment system (RTS), which was designed to draw air from the silos, remove moisture and radon
through a charcoal-adsorption process, and recirculate clean air back into the silos. The RTS, which
was upgraded in 1991, helped to lower radon emissions to allow workers to apply a layer of bentonite
clay (November 1991) over the K-65 residues within the silos (K-65 Silo Removal Action No. 4).
The bentonite clay layer has reduced the amount of radon escaping from the silos into the
environment and would help prevent the release of contaminants into the air if a natural disaster (e.g.,
a tornado) should occur or if the silo dome should collapse. An expedited removal action was
conducted in December 1991 to remove the Silo 3 dust collector after an inspection had revealed
significant deterioration of the dust collector (Removal Action No. 21). Also, in April 1991, a time-
critical removal action was performed to remove approximately 30,300 liters (8000 gallons) of liquid
from the decant sump (Removal Action No. 5).
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3.0 COMMUNITY PARTICIPATION
Various forums has been used to provide information to the community, including a periodic
newsletter, regular community meetings, and other availability sessions. Other activities included site
tours, open houses, a speakers bureau, and fact sheets about the Fernald site. Several readings
rooms, which later were consolidated into one facility near the Fernald site, were opened. This
reading room contains information about all aspects of the RI/FS at Fernald. In 1990, DOE
established an "Administrative Record" for the site; a copy of the Administrative Record also is
maintained at the U.S. EPA's Region 5 offices in Chicago.
In November 1993, DOE implemented a public participation program at Fernald, in an attempt to
involve community members and other interested parties in the Fernald decision-making process. The
public involvement program at Fernald consists of three elements:
1. Public information
2. Management involvement
3. Person-to-person communication
These efforts, in conceit with other community relations activities, such as publication of notices of
availability, which are required by law, reflect DOE's new initiative to offer opportunities for
interested parties to take part in the decision-making process at Fernald.
3.1 OPERABLE UNIT 4 PUBLIC INVOLVEMENT ACTIVITIES
To encourage stakeholders to review drafts of the Operable Unit 4 RI/FS documents, Notices of
Availability for public inspection were published in April 1993 for the Operable Unit 4 RI Report and
in September 1993 for the FS/PP-DEIS in three local newspapers: The Gncinnati Enquirer, the
Journal-News and The Harrison Press. No public comments were received on the RI Report for
Operable Unit 4.
On September 9, 1993, the FS/PP-DEIS were made available at the Public Environmental Information
Center, and stakeholders were encouraged to provide informal comments on the preliminary
documents. Encouraging public inspection and informal comment on these preliminary documents,
prior to EPA approval, provided a genuine opportunity for stakeholders to identify issues, voice their
concerns and learn about proposed cleanup plans for Operable Unit 4. The informal opportunity for
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the public to provide input enabled DOE to address some stakeholder questions and concerns in
advance of the formal public comment period.
On October 14, 1993, approximately 29 stakeholders attended a public roundtable on "Proposed Plans
and Technology for Operable Unit 4 Remediation." At the roundtable, attendees were invited to offer
opinions on the draft final Proposed Plan and the preferred alternative for Operable Unit 4
remediation. These stakeholder comments were documented and evaluated during preparation of the
final document.
In addition, a two-way information exchange on the Operable Unit 4 Risk Assessment occurred at the
October 19, 1993, Science, Technology, the Environment and the Public (STEP) session on "Risk."
Again, Fernald personnel addressed the stakeholders' questions and concerns presented at the
meeting. Information about the Operable Unit 4 Remedial Investigation Report was also provided at
DOE's October 21, 1993, RI/FS public meeting and at local township trustee meetings.
In response to stakeholder requests at the January 5, 1994, formal public hearing on the Operable
Unit 3 (Production Area) Interim Record of Decision, a public roundtable to discuss integration of
CERCLA and NEPA was held January 24, 1994. The roundtable included discussions on differences
between environmental assessments and environmental impact statements; approximately 45
stakeholders attended.
On February 21, 1994, invitations to attend the March 21, 1994, formal public hearing on the FS/PP-
DEIS were mailed to 2,000-plus Fernald stakeholders. The Proposed Plan for Remedial Actions at
Operable Unit 4 fact sheet was enclosed with each invitation.
On February 24, 1994, advance copies of the Proposed Plan for Remedial Actions at Operable Unit 4
were mailed to several key stakeholders. Also on February 24, copies of the final FS/PP-DEIS and
Proposed Plan fact sheets were mailed to the Nevada Operations Office and to Nevada environmental
protection organizations. The DOE Operable Unit 4 Branch Chief personally distributed several
advance copies of the Proposed Plan to attendees at the February 24, 1994, Fernald Residents for
Environmental, Safety, and Health (FRESH) meeting. In addition, she provided an update on
Operable Unit 4 activities, plans and progress, and was available for an informal question-and-answer
session.
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To encourage stakeholders to review and offer input on the final FS/PP-DEIS, a Notice of
Availability for formal public comment was published in March 1994 in the Federal Register and
three local newspapers: The Cincinnati Enquirer, the Journal-News and The Harrison Press. On
March 1, 1994, the Proposed Plan, FS/PP-DEIS became available at the Public Environmental
Information Center.
On March 2, 1994, Ohio EPA representatives discussed the FS/PP-DEIS with members of the
Fernald Citizens Task Force and FRESH.
On March 4, 1994, a Fernald site news release titled "Key Fernald Cleanup Plan Receives
Conditional U.S. EPA Approval" was sent to local electronic and print media, as well as local elected
officials, FRESH and the Fernald Citizens Task Force. Articles were published in local newspapers.
On March 7, 1994, the formal 45-day public comment period on the final FS/PP-DEIS officially
began.
On March 8, 1994, Fernald representatives met formally with officials of the DOE Nevada Operation
Office and Nevada protection agencies.
On March 15, 1994, postcard reminders about the March 21, 1994, formal public hearing were
mailed to Fernald stakeholders. In addition, courtesy phone calls were made to key stakeholders,
inviting them to the formal public hearing.
Display advertisements announcing the March 21, 1994, formal public hearing were published in
three local newspapers: The Cincinnati Enquirer, March 18 and March 20; The Cincinnati Post,
March 18; and the Journal-News, March 18.
On March 21, 1994, approximately 80 people attended the formal public hearing on the Operable
Unit 4 FS/PP-DEIS. Formal oral public comments were documented by a court reporter and are
available in a transcript at the Public Environmental Information Center. In addition, several .
stakeholders submitted formal written comments. All formal written and oral stakeholder comments
and questions asked informally during the March 21 public hearing, as well as DOE's responses, are
documented in the Operable Unit 4 Responsiveness Summary.
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The formal public comment period for the Operable Unit 4 FS/PP-DEIS was originally scheduled to
conclude April 20, 1994. However, the public comment period was extended 30 days, until May 20,
1994, in response to a request for a 60-day extension by a Nevada State Clearinghouse representative.
The extension request was made on behalf of a group of concerned Nevadans, affected indian tribes
and local government officials, who, along with officials from the State of Nevada and DOE, jointly
participated in the establishment of a site-specific advisory board for the U.S. Department of Energy -
- Nevada Operations Office (DOE-NV) Environmental Restoration and Waste Management Program
at the Nevada Test Site (NTS). "The Citizens Advisory Board for NTS Programs (CAB)" will play a
key role in advising DOE-NV about stakeholder concerns involving major program decisions at NTS,
such as those proposed for Fernald's Operable Unit 4 waste. CAB's first meeting was held March 8,
1994.
The National Contingency Plan, section 300.430(0 (3)(i) (C) states, "... Upon timely request, the
lead agency will extend the public comment period by a minimum of 30 additional days. ..." In
accordance with the Amended Consent Agreement (1991), DOE and U.S. EPA concurred with a 30-
day extension of the formal public comment period to minimize impact to the Operable Unit 4
schedule, yet still provide what DOE and EPA considered adequate time for stakeholder review. A
Notice of Availability was published May 4 in The Cincinnati Enquirer, the Journal-News and The
Harrison Press.
On May 11, 1994, the DOE-NV conducted a public meeting in Las Vegas, Nevada. In attendance
were members from the DOE, EPA (Region V), Ohio EPA, CAB and the public. This meeting was
the first meeting of the newly-organized CAB. As part of the meeting's agenda, the DOE conducted
two presentations. One of the presentations, furnished by the DOE-FN, discussed the Operable
Unit 4 FS/PP-DEIS and summarized the proposal to transport and dispose of low-level radioactive
waste, which would be generated by the cleanup and environmental restoration of the FEMP site as a
whole (including Operable Unit 4), at the NTS. The other presentation was furnished by the
DOE-NV which summarized the current low-level radioactive waste management program at the
NTS. During the discussions following the presentation of the Operable Unit 4 FS/PP-DEIS, the
CAB requested a second 30-day extension of the Operable Unit 4 formal public comment period.
DOE and EPA concurred with the second extension of the formal public comment period, which
finally concluded June 19, 1994. A Notice of Availability regarding the second 30-day extension
was published May 25, 1994, in The Cincinnati Enquirer, the Journal-News and The Harrison Press.
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During the Operable Unit 4 formal public comment period, stakeholders expressed concern regarding
public participation opportunities and activities after the conclusion of the RI/FS Study process. In
1994, Records of Decision will be completed for Operable Unit 4 and Operable Unit 1 (Waste Pits),
and an Interim Record of Decision will be completed for Operable Unit 3 (Production Area).
In 1994, Fernald's Community Relations Plan, which guides public involvement activities, was
revised with input from stakeholders who participated in formal in-person and telephone "community
assessment" interviews. Fernald's Community Relations Plan is located in the RI/FS Work Plan,
Volume III, which is available at the Public Environmental Information Center, 10845 Hamilton-
Cleves Highway, Harrison, Ohio (phone: 513-738-0164).
The community assessment interviews were conducted to ensure stakeholder participation in
determining public involvement activities and programs during Remedial Design and Remedial Action
at Fernald. Fernald's first community assessment was done in 1986, when Fernald's original
Community Relations Plan was developed. In 1988, minor revisions were made to the Community
Relations Plan and were reflected in the RI/FS Work Plan, Volume III. In 1989, a second community
assessment was conducted, and the Community Relations Plan was again revised and approved in
August 1990. In 1992, Fernald's Community Relations Plan was revised a fourth time; however, no
community assessment was conducted in 1992.
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4.0 SCOPE AND ROLE OF REMEDIAL ACTION
The FEMP site and associated environmental issues have been segmented into five operable units.
The operable unit concept at the FEMP site involves grouping waste areas or related environmental
concerns in a manner so as to permit the more expedient completion of the RI/FS process. The five
FEMP operable units are broadly defined as:
• Operable Unit 1 - Waste Pit Area
• Operable Unit 2 - Other Waste Units
• Operable Unit 3 - Former Production Area
• Operable Unit 4 - Silos 1 through 4
• Operable Unit 5 - Environmental Media
Separate RI/FS documentation and RODs are being issued for Operable Units 1 through 5. A sixth
operable unit known as the Comprehensive Site-Wide Operable Unit was added as a provision of the
Amended Consent Agreement. Operable Unit 6 is not a specified area; however, it was created to
perform a final assessment from a site-wide perspective that ongoing or planned remedial actions
identified in the RODs for the five operable units will provide a comprehensive remedy for the FEMP
site which is protective of human health and the environment.
The primary focus of this remedial action is the permanent disposition of inventoried processing
residues contained in three concrete silos and an underground sump at the FEMP. The scope also
includes the disposition of contaminated building materials associated with the concrete silos and
ancillary support facilities. The action further involves the disposition of contaminated soils, process
wastewater and perched water encountered within the Operable Unit 4 Study Area. The nature of the
residues, coupled with their potential threat of release from their present storage configuration and the
potential threat of contaminant migration from the affected soils into the atmosphere and the
underlying aquifer system, represent a potential threat to human health and the environment. Hie
purpose of the remedial action is to prevent current and future exposure to the inventoried residues,
contaminated soil and debris within Operable Unit 4, and remove the threat of release of hazardous
substances into the environment.
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Several removal actions are ongoing or have been completed within the Operable Unit 4 study area.
These removal actions are summarized as follows:
• Installation of a bentonite clay layer over the K-65 residues in Silos 1 and 2.
• Removal and treatment of water from the K-65 decant sump tank at the FEMP
advanced wastewater treatment plant. Water within the tank is removed whenever the
liquid level in the sump reaches 80 percent of the tanks capacity.
• Removal of a deteriorated dust collector on the dome of Silo 3.
• Installation of a series of drainage control structures, swales, and culverts to direct
surface runoff to the existing in-ground sump.
In addition to the removal actions listed above, polyurethane foam insulation was applied to the
exterior of the dome surfaces of Silos 1 and 2 to inhibit wide temperature swings within the silos.
These removal actions have been conducted to respond to contaminant releases and to mitigate health
and safety threats in accordance with CERCLA. These actions have also been conducted in
accordance with Council on Environmental Quality regulations for implementing the provisions of
NEPA.
Cleanup decisions for groundwater beneath the Operable Unit 4 Study Area, sediment in Paddys Run,
and soil and waste source areas outside the Operable Unit 4 Study Area are not included in the scope
of this remedial action. Separate RI/FS and other remediation documentation will be prepared for
these facilities and media by other FEMP operable units. These documents will be issued consistent
with the terms of the Amended Consent Agreement.
4.1 INTEGRATION OF NEPA INTO CERCI.A
For Operable Unit 4 at the FEMP, DOE has chosen to complete an integrated CERCLA/NEPA
process. This decision was based on the longstanding interest on the part of local stakeholders to
prepare an EIS on the restoration activities at the FEMP and on the recognition that the draft
document was issued and public comments received. Therefore, an integrated Feasibility
Study/Proposed Plan - Final Environmental Impact Statement (FS/PP-FEIS) has been completed
which evaluates alternatives for the treatment and disposal of radioactive residues contained in storage
silos at FEMP.
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In accordance with both CERCLA and NEPA processes, this documentation was made available to
the public for comment. The contents of the documents prepared for the remedial actions at the
FEMP are not intended to represent a statement on the legal applicability of NEPA to remedial
actions conducted under CERCLA.
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S.O SUMMARY OF OPERABLE UNIT 4 CHARACTERISTICS
Several investigative studies were conducted to determine the characteristics of the contamination
sources and the nature and extent of contamination within Operable Unit 4. These investigative
activities focused on the following facilities and associated environmental media:
• Silos 1 and 2 and their contents (also termed the K-65 silos)
• Silo 3 and its contents (also termed the cold metal oxide silo)
• Silo 4
• K-65 decant sump tank, its contents, and associated piping
• A radon treatment system (RTS)
• A portion of a concrete pipe trench and other concrete structures
• An earthen berm surrounding Silos 1 and 2
• Soils beneath and immediately surrounding Silos 1, 2, 3, and 4
• Perched groundwater encountered in the vicinity of the silos during implementation of
Operable Unit 4 cleanup activities. Note that groundwater within the Great Miami
Aquifer underlying the silo area is not within the scope of Operable Unit 4, but it is
within the scope of Operable Unit 5.
5.1 INVESTIGATIVE STUDIES
The Operable Unit 4 RI/FS sampling program was the primary source of the information utilized to
characterize contamination sources and to evaluate the nature and extent of contamination associated
with Operable Unit 4. Other investigative studies which provided characterization data for Operable
Unit 4 include the Waste Pit Area Runoff Control Removal Action, the FEMP Environmental
Monitoring Program, and the Characterization Investigation Study (CIS). Section 6 provides a list of
the contaminants of concern which were identified and used to determine baseline risks attributable to
Operable Unit 4.
5.2 SUMMARY DESCRIPTION OF CONTAMINATION SOURCES
5.2.1 Classification of Contamination Sources
The residues in Silos 1, 2, and 3 are classified as by-product material as defined under the AEA of
1954, and are therefore excluded from regulation as solid or hazardous waste under the Resource
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Conservation and Recovery Act (RCRA), 40 CFR § 261.4(a)(4). By-product material, as defined by
the AEA, includes tailings or wastes produced as a result of the extraction or concentration of
uranium (U) and thorium (Th) from any ore processed primarily for its source material content (42
United States Code 2014).
Since the residues contained in the silos are excluded from regulation as solid or hazardous waste, the
requirements under RCRA are not applicable to Operable Unit 4 remedial actions. However,
analytical data for the silo residues indicate that these materials exceed Toxicity Characteristic
Leaching Procedure (TCLP) limits for various metals, as defined under RCRA. The silo residues are
therefore sufficiently similar to hazardous waste regulated under RCRA resulting in some RCRA
requirements being appropriate for the conditions of release or potential release of hazardous
constituents during disposal. As a result of this, the relevant and appropriate substantive requirements
of RCRA are being applied as part of the Operable Unit 4 remedy for the silo residues.
5.2.2 Source Characteristics
Silos 1 and 2, known as the K-65 silos, contain approximately 6,796 m3 (8,890 yd3) of waste residues
generated from processing high-grade uranium ores. As part of the remedial investigation, samples
were collected from die contents of the silos. The waste materials within the silos are primarily a
silty clay with an average moisture content of approximately 40 percent. Analytical results from these
samples confirmed prior process knowledge and identified significant activity concentrations of
radionuclides within the uranium decay series.
The average Silo 1 concentration of radium (Ra)-226 is 391,000 pCi/g, thorium (Th)-230 is 60,000
pCi/g, lead (Pb)-210 is 165,000 pCi/g and polonium (Po)-210 is 242,000 pCi/g. The average Silo 2
concentration of Ra-226 is 195,000 pCi/g, Th-230 is 48,300 pCi/g, Pb-210 is 145,(XX) pCi/g and Po-
210 is 139,000 pCi/g. The two silos contain in excess of 3,700 Curies of Ra-226, 600 Curies of Th-
230, and 1,800 Curies of Pb-210. It is also estimated that Silos 1 and 2 contain more than 28 metric
tons of uranium.
Other significant metals include more than 118 metric tons of barium, 830 metric tons of lead^ and
2.6 metric tons of arsenic. TCLP tests indicate that the lead is leachable with leach test
concentrations from Silo 1 averaging 614 milligrams per liter (mg/1) and leach test concentrations
from Silo 2 averaging 516 mg/1. The silos also contain elevated concentrations of the polychlorinated
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biphenyls (PCBs) Aroclor-1248 [1.2 milligrams per kilogram (mg/kg)], Aroclor-1257 (7.4 mg/kg),
Aroclor-1260 (2.6 mg/kg), and tributylphosphate (15 mg/kg).
Silos 1 and 2 are equipped with a decant sump tank, which was first used to decant liquids from
waste slurried into the silos. The system also served to collect silo leachate that entered the Silos 1
and 2 underdrain system. The tank is located beneath the silo berm, between Silos 1 and 2, at a
depth approximately 0.6 m (2 ft) below the base of the silos. The decant sump tank is connected to
the berm surface via a standpipe. In 1990, personnel noted 1.2 m (4 ft) of liquid in the standpipe. In
1991, and again in February 1993, the decant sump tank was emptied and sampled. Analytical results
of the decant sump tank liquids are, in general, consistent with the contents of Silos 1 and 2.
The presence of significant quantities of liquid in the decant sump tank indicates that the system is
collecting leachate from the silo underdrain system, as it was designed to do. Excess quantities of
liquid in the decant sump tank, causing liquid to overflow into the standpipe, appear to provide a
mechanism for leachate from the silos to enter perched groundwater.
Structural evaluations completed in 1986 on Silos 1 and 2 identified a significant loss of the load-
carrying capability at the center portion of the domes on both structures. A protective barrier was
placed over the deteriorated central portions of the silo domes in 1986 to minimize potential
environmental impacts in the event of a catastrophic dome collapse. The remaining structures, Silos 3
and 4, like Silos 1 and 2, are beyond their original design life and show visible signs of deterioration
due to the effects of weathering. However, based on the more recent February 1994 Silo Structural
Integrity Report, the silos are considered to be more structurally sound than previously reported in the
1986 study by Camargo. The extensive non-destructive testing and computer analysis indicated that
the silos are not in immediate danger of collapse.
As a natural consequence of the decay of the Ra-226 present in the Silo 1 and 2 waste materials, a
radioactive gas, Rn-222, is generated. Samples collected in 1987 from the unfilled, upper portions of
Silos 1 and 2 showed a maximum concentration of 30 million picocuries per liter (pCi/1). Average
background concentrations of Rn-222 in ambient air are approximately 0.5 pCi/l. In 1991, a layer of
bentonite clay was placed over the residues in Silos 1 and 2. This clay layer was installed to reduce
the release of radon gas to the atmosphere. Samples collected following emplacement of the bentonite
clay show a significant reduction in the Rn-222 present in the headspace of the silos.
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The inventory of radionuclides present in the K-65 residues significantly elevates the direct
penetrating radiation field in the vicinity of the silos. Measurements collected from the dome surfaces
prior to the installation of the bentonite clay layer showed exposure rates in excess of 200 millirem
per hour, or approximately 20,000 times natural background radiation levels. Measurements collected
from the surfaces of the domes following bentonite installation showed a greater than 95 percent
decrease in the direct radiation fields on the dome surfaces.
Silo 3 contains waste residues, known as cold metal oxides, which were generated at the FEMP site
during uranium extraction operations in the 1950s. The residues in Silo 3 are substantially different
than those in Silos 1 and 2. First, Silo 3 residues are dry, while the residues in Silos 1 and 2 are
moist. Second, while the radiological constituents are similar to those in Silos 1 and 2, certain
radionuclides, such as radium, are present in Silo 3 in much lower concentrations. Thus, Silo 3
exhibits a significantly lower direct radiation field and radon emanation rate than Silos 1 and 2.
Samples collected from the contents of Silo 3 confirmed process knowledge and indicated the presence
of significant activity concentrations of the radionuclides within the uranium decay series. The
predominant constituent identified within Silo 3 was Th-230, a radionuclide produced from the natural
radioactive decay of U-238. Distributed within the 3,890 m3 (5,088 yd3) of waste residues inside Silo
3 is approximately 450 Curies of Th-230. Extraction Procedure (EP) Toxicity tests performed on
samples of the Silo 3 residues to determine the leachability of inorganic substances present detected
eight metals, with the highest mean concentrations being attributed to arsenic (9.48 mg/1), cadmium
(0.85 mg/1), chromium (5.05 mg/1), and selenium (2.65 mg/1).
5.3 NATURE AND EXTENT OF CONTAMINATION
Investigations were performed as part of the RI and other site programs to examine the nature and
extent of contamination present in environmental media associated with Operable Unit 4. These
investigations included the collection and laboratory analysis of samples and the collection of direct
field measurements. The investigations included examination of surface and subsurface soil, surface
water and sediment, and groundwater.
5.3.1 Surface Soils
Sampling performed as part of the RI/FS and other site programs in the vicinity of Operable Unit 4
indicates the occurrence of above background concentrations of uranium, and to a lesser degree other
radionuclides, in the surface soils within and adjacent to the Operable Unit 4 Study Area. Activity
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concentrations observed during the RI for the surface soils in the vicinity of Operable Unit 4 were as
much as 20.8 picocuries per gram (pCi/g) for U-238, or 16 times natural background, and 4.8 pCi/g
for Th-230, or two times background. These above background concentrations appear to be generally
limited to the upper six inches of soil.
Of the inorganic constituents detected in the Operable Unit 4 surface soils, antimony, beryllium,
chromium, copper, magnesium, nickel, silver, and sodium were consistently above background. The
only volatile organic compounds detected consisted of common laboratory contaminants. With the
exception of one sample collected at a depth of 0.5 to 0.6 m (1.5 to 2.0 ft), which contained elevated
concentrations of a number of semivolatile organic compounds including benzo(a)pyrene, semivolatile
organic compounds were at or only slightly above the contract required quantitation limit for the
laboratory. Available sample data and process knowledge indicate no direct relationship between the
surface soil contamination in the Operable Unit 4 Study Area and the silo contents. Further, more
than 70 percent of the surface soil samples indicate that the uranium contamination in surface soils is
depleted uranium (i.e., the uranium contains depleted percentages of U-235). The silo residues
consist of natural uranium. Thus, the existence of these activity concentrations in the surface soils is
attributed to air deposition resulting from the former Production Area and past plant production
operations and/or waste handling practices in the waste pit area.
Soil samples were collected from the soils contained in the earthen embankment (berm) surrounding
Silos 1 and 2. The highest concentrations of radionuclide constituents were detected in a sample
taken at a location 9 m (30 ft) below the berm surface, near the base of Silo 1. This sample indicates
the occurrence of either some spillage of silo residues during filling operations or seepage from the
silo onto the original surface soils adjacent to the silo at that location. Analytical results from other
berm samples showed the presence of radionuclides at relatively lower concentrations, with the
majority of samples showing concentrations near background.
The concentration ranges for those constituents in relatively higher concentrations are 0.62 to 417
pCi/g for Pb-210; 1.03 to 943 for polonium (Po)-210; 0.62 to 876 pCi/g for Ra-226; 0.74 to 51.2
pCi/g for Th-230; and 0.75 to 24.7 pCi/g for U-238. Inorganic constituents detected consisted.mostly
of metals in concentrations close to background concentrations. There were also some organic
constituents reported. Most of these constituents are common laboratory contaminants and do not
demonstrate any direct linkage to the silo contents.
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5.3.2 Subsurface Soils
As part of the RI for Operable Unit 4, samples were collected from the subsurface soils located under
and adjacent to the K-65 silos. Analytical results reveal elevated concentrations of radionuclides from
the uranium decay series in the soils at the interface between the berm and the original ground level.
Elevated concentrations (up to 53 pCi/g for U-238, about 40 times background) were also noted in
slant boreholes, which passed in close proximity to the silo underdrains. The occurrence of these
above background concentrations in soils near the silo underdrains are attributed to vertical migration
of leakage from the silo underdrains or decanting system. Elevated readings at the interface between
the silo berms and the native soils may be attributed to historical air deposition or past spillage from
the silos during filling operations in the 1950s, prior to installation of the berms.
5.3.3 Surface Water and Sediment
Extensive sampling was conducted on the sediment and surface water present in Paddys Run and on
key drainage swales leading to Paddys Run, as part of the RI for Operable Unit 4 and other site
programs. Results of the surface water sampling indicate the occurrence of above background
concentrations of U-238, up to 1500 times background, in the drainage swales in the vicinity of the
Silos 1 through 4. The highest readings were recorded in a drainage ditch, which flows from east to
west, located approximately 76 m (250 ft) south of Silo 1. The most probable source of the
contamination in Paddys Run and the drainage swales is the resuspension of contaminated particles
from surface soils within the Operable Unit 4 and Operable Unit 1 Study Areas into storm water.
5.3.4 Groundwater
Groundwater samples were collected from wells within the Operable Unit 4 Study Area during the RI
for Operable Unit 4. Groundwater occurs not only in the Great Miami Aquifer underlying the
FEMP site, but also in discrete zones of fine-grained sands located in the glacial overburden. The
water contained in these sand pockets in the clay-rich glacial soils are termed perched water zones.
Samples were collected from slant borings placed adjacent to and under Silos 1 and 2; 1000-series
wells screened in the glacial overburden; 2000-series wells screened at the water table in the Great
Miami Aquifer; and 3000-series wells screened at approximately the central part of the Great Miami
Aquifer, just above the clay interbed.
Background concentrations of naturally occurring inorganics and radionuclides in groundwater in the
vicinity of FEMP site were being established under the site-wide RI/FS during the completion of the
RI for Operable Unit 4. In accordance with background data available at the time, background
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concentration of total uranium in groundwater of less than 3 micrograms per liter (jigfl) or 3 parts per
billion (ppb) was utilized.
Perched Water
Uranium was the major radionuclide contaminant found in the perched water. Elevated
concentrations of total uranium were detected in the slant boreholes under and around Silos 1 and 2.
Slant Boring 1617, immediately southwest of Silo 1, contained the highest concentration of total
uranium (9,240 fig/X). Uranium concentrations were also elevated in samples collected from the
1000-series wells. The highest observed total uranium concentrations obtained from 1000-series wells
were in samples collected from Well No. 1032, located 46 m (150 ft) due west of Silo 2. The range
of the concentrations was 196 to 276 fig/]. Considering both the slant borings and 1000-series wells,
U-238 was found in the range of 1.1 to 1313 pCi/1.
The major inorganic constituents found in the perched water samples taken from 1000-series wells
and the slant borings, included elevated concentrations for major cations (iron, magnesium,
manganese, and sodium) and major anions (chloride, nitrate, and sulfate). In particular, the
concentrations of sodium, sulfate, and nitrate were significantly above background in slant boring
samples. Boring 1615, northwest of Silo 2, had the highest sodium concentration1,040 mg/1), boring
1618, southeast of Silo 1, had the highest sulfate concentration (2,200 mg/1), and boring 1617 had the
highest nitrate concentration (554 mg/1). Low levels of organic constituents, determined to be
contaminants, were detected in some samples. Overall, well measurements and analytical results
confirmed that the perched groundwater in the vicinity of Operable Unit 4 flows from west to east.
Further, contaminants within Operable Unit 4 are contributing to contamination of perched
groundwater in this region of the site.
Great Miami Aquifer
The concentration of total uranium in the upper portion of the Great Miami Aquifer, based on
analysis of samples from the 2000-series wells, ranged from less than 1 fig/l to 40.3 /tg/1. These data
do not necessarily suggest that the silos are the source of the observed contamination because both
upgradient and downgradient wells contain above background concentrations of total uranium.. Well
No. 2032, located 46 m (150 ft) west of Silos 1 and 2, exhibited a concentration of total uranium at
39.0 /ig/1- Well No. 2033, located 46 m (150 ft) east of Silos 1 and 2, exhibited a concentration of
total uranium at 40.3 fig/]. Because groundwater flow in this region of the Great Miami Aquifer is
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from west to east, these two wells are located upgradient and downgradient of Operable Unit 4,
respectively.
The isotopic ratio of U-234 and U-238 would suggest a natural uranium ratio in these samples. Such
a ratio may be expected from Operable Unit 4, but is not a "fingerprint" for this source. The
presence of uranium upgradient in the aquifer from an Operable Unit 4 source could be explained by
leachate travel in the perched groundwater zone of the glacial overburden with emergence to Paddys
Run. Here the diluted leachate could enter the aquifer via stream bed infiltration or flow at the
perched zone/stream channel interface. No evidence is available to support or preclude this potential
route.
The concentration of total uranium measured at deeper levels in the Great Miami Aquifer (3000-series
wells) ranged from less than 1 to 4 jtxg/1, with the exception of 1 sample out of 16, which contained
IS ngfl. Like the 2000-series wells, no conclusion could be drawn that linked this contamination to
the silos.
5.4 POTENTIAL EXPOSURE PATHWAYS FOR CONTAMINANT MIGRATION
Contaminant transport from Operable Unit 4 may occur via the following pathways:
• Direct radiation
Direct exposure to gamma radiation from radioactive constituents within the silos.
Direct exposure to Silo 3 residues under the future source term scenario assuming
structural collapse of the silo.
Direct exposure to gamma radiation from radioactive constituents in surface soil.
• Air emissions
Dispersion of radon that escapes from the silos into the atmosphere.
Dispersion of volatile organic compounds (VOC) or fugitive dust emissions
generated from soil erosion.
Dispersion of Silo 3 contents under the future source term scenario assuming
structural collapse of the silo.
• Surface water runoff
Erosion of contaminated soils into Paddys Run from the vicinity of the silos.
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Erosion of released Silo 3 contents under the future source term scenario assuming
structural collapse of the silo.
• Groundwater transport
Leaching of contaminants from the silo contents via soils to underlying
groundwater.
Each of these potential contaminant transport pathways is discussed below. The summary of the
baseline risk assessment presented in Section 6 provides additional information about the impacts on
environmental media or human receptors.
5.4.1 Direct Radiation
Gamma radiation from the K-65 residues and surface soils are transported as electromagnetic
radiation, thus requiring no transport mechanism. As the distance from the K-65 silos and the surface
soil source increases, the magnitude of the radiation's intensity decreases. The soil berms around
Silos 1 and 2 provide shielding to potential receptors from the direct gamma radiation associated with
the K-65 residues. The bentonite clay layer covering the silo residues decreases the diffusion of
radon into the silo headspace. Radon progeny are gamma-emitters that contribute significantly to
direct radiation exposure. Therefore, as long as the integrity of the berms, the bentonite clay liner,
and silos is maintained, there should be no change or increase in direct radiation exposure due to this
pathway.
5.4.2 Air Emissions
Rn-222 generated by the radioactive decay of Ra-226 in the K-65 and metal oxide residues accumu-
lates in the void headspace inside the silos. At the time of their design, the four silos were not
required to be airtight; therefore, air exchanges with the outside environment occur. The air
exchange is a result of changes in ambient temperatures that cause expansion and contraction of the
air mass inside the silos. The foam installed on top of Silos 1 and 2 in 1987 has reduced the K-65
silo breathing losses by limiting daily temperature variations inside the silo dome. In addition to
direct release to the atmosphere, radon gas can also diffuse through the K-65 silo walls into the
surrounding soil berms. Radon has a short half-life (3.82 days) and is expected to decay into its
progeny, Pb-210 and Po-210, in the silo walls and in the soil berms surrounding Silos 1 and 2.
These are nonvolatile constituents that accumulate in the soil berms. These progeny could be
transported via resuspension if the berms are eroded to a point where this area is exposed.
5-9
-------
FEMP-OU4ROD-8 FINAL
December 1994
Contaminated soil particulates can also be resuspended into the air from the surface of the K-65 berms
and the surrounding Operable Unit 4 soils and transported by winds to other locations.
5.4.3 Surface Water Runoff
Contaminants in the surface soils can be transported away from Operable Unit 4 through surface soil
erosion caused by surface water runoff. If the existing runoff control structures (i.e., trench drains
and curb and gutters) at the perimeter of Operable Unit 4 were to fail, this would permit storm water
runoff to directly enter Paddys Run. Contaminants contained in near surface soils which are subject
to erosion can be transported to Paddys Run by either dissolving in the runoff surface water or
attaching to entrained sediment carried by the water. A portion of these contaminants will partition
(i.e., separate) into stream sediment and will not be available for immediate transport to the aquifer.
Contaminants in the dissolved phase could be transported to the Great Miami Aquifer by recharge
from Paddys Run throughout the length of Paddys Run from Operable Unit 4 to the Great Miami
River.
5.4.4 Groundwater Transport
The final potential transport route is via groundwater. Contamination may be transported through the
vadose zone into the Great Miami Aquifer in the vicinity of Operable Unit 4 by traveling through the
glacial overburden present beneath the silos. A conceptual model of potential contaminant transport
from the bottom of the silos to the Great Miami Aquifer has been developed. This model is based on
the current understanding of the Operable Unit 4 Study Area and data from past investigations and is
listed below:
• Leachate derived from Silos 1 and 2 is formed under the current storage configuration
of the silos from liquids used to slurry waste materials into the silos. Additional
leachate may be formed based on the assumption that precipitation infiltrates the silos
through the silo top and sidewalls and interacts with the wastes within. This leachate
may pass through the wastes, out the bottom of the silo, and enter the glacial
overburden.
• Perched groundwater in the vicinity of Operable Unit 4 flows to the west, toward
Paddys Run. Thus, once out of the silo, leachate may migrate through the glacial
overburden toward the west, until it reaches Paddys Run, or in a vertical direction until
it reaches the Great Miami Aquifer.
• Once in Paddys Run or the Great Miami Aquifer, the contamination can be transported
through surface water or groundwater to either on-property or off-site receptors.
5-10
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FEMP-OU4ROD-8 FINAL
December 1994
6.0 BASELINE RISK ASSESSMENT
Baseline risk assessments were performed to determine the potential human health effects and
ecological risks which could result from exposure to contaminants currently present in Operable
Unit 4.
The baseline assessment of human health risks quantified the health risks to hypothetical human
receptors due to exposure from chemical sources in Operable Unit 4 under the no-action alternative.
The process analyzed the human health consequences that could occur under different scenarios if no
remedial actions were taken to address identified environmental concerns. This process utilized a
structured, sequential analytical process that:
• Identified the specific Constituents of Concern (COCs) for Operable Unit 4.
• Assessed contaminant transport from the sources to potential exposure
points.
• Quantified potential exposures to receptors under current and future land use
scenarios.
• Characterized the potential baseline risks associated with Operable Unit 4
under current and potential future land use scenarios.
Appendix D and Section 6.0 of the RI Report for Operable Unit 4 provide detailed information on the
baseline assessment of human health risks.
Site-wide baseline ecological risks were evaluated and included in the Site-Wide Characterization
Report (DOE 1993b). An overview of that discussion is included in Section 6.2 of this ROD. The
purpose was to conduct a qualitative assessment of the potential current and future risks posed by
FEMP site contaminants to ecological receptors (e.g., plants and animals) if no remediation is
implemented, thus, serving as a baseline for all future assessments. The Amended Consent
Agreement between EPA and DOE stipulates that Operable Unit 5 is responsible for the preparation
of the Site-Wide Ecological Risk Assessment as part of the RI and FS Reports for Operable Unit 5.
6-1
-------
FEMP-OU4ROD-8 FINAL
December 1994
6.1 SUMMARY OF THE BASELINE ASSESSMENT OF RISKS TO HUMAN HEALTH
6.1.1 Constituents of Concern
The COCs for human health and their ranges of concentration in effected Operable Unit 4 media are
provided in Table 6-1. COCs were detected in Silos 1, 2, and 3, the surrounding surface soil and
subsurface soil, and the silo berm soils. Baseline risk assessment source term concentrations were
determined for the COCs in these media. Fate and transport modeling was then conducted to estimate
the exposure point concentrations of contaminants in environmental media (e.g., groundwater, air,
and surface water). Contaminants with the potential of posing risk to human health include
radionuclides, metals, inorganic anions, polyaromatic hydrocarbons (PAHs), and
pesticides/polychlorinated biphenyls (PCBs). The selection of COCs was based on the evaluation of
characterization data with respect to the distribution on contaminants in various media and the
potential contribution of these contaminants to the overall human health effects. Appendix E of the
RI Report for Operable Unit 4 provides full details of the process for selecting COCs.
6.1.2 Exposure Assessment
The exposure assessment and baseline risk assessment follow the methodology described in the Risk
Assessment Work Plan Addendum (DOE 1992), with the exception of those items identified in
Section D.1.0 of Appendix D of the RI Report for Operable Unit 4 (DOE 1993a). Baseline risks
were calculated under a number of contaminant release mechanisms providing exposure to
hypothetical receptors under three separate land use scenarios. Baseline risks under these land use
scenarios were calculated for a current source term and a future source term. The concentrations of
contaminants found in the contents of Silos 1,2, and 3, the surrounding surface soil, the silo berm
soil, and subsurface soil within the Operable Unit 4 Study Area were used to determine the source
term concentrations used in each exposure scenario.
Land use scenarios include: (1) current land use without access controls, (2) current land use with
access controls, and (3) future land use without access controls. Under the first scenario, the FEMP
site is assumed to be managed by an industrial concern other than DOE. Access restrictions currently
provided by DOE are assumed to be discontinued. In addition, no remedial actions are assumed to
have been taken, and no members of the public establish residence within the boundaries of Operable
Unit 4. Thus, potential receptors include an off-property resident farmer, a trespassing child, an
on-property worker (groundskeeper), and an off-property user of surface water from the Great Miami
River.
6-2
-------
FEMP-OU4ROD-8 FINAL
December 1994
TABLE 6-1
CONSTITUENTS OF CONCERN FOR OPERABLE UNIT 4
Silo 1 & 2
Silo 3
Surface Soil
Berm Soil
Range of Detection for Chemicals
-------
FEMP-OU4ROD-8 FINAL
December 1994
Table 6-1
(continued)
Silo 1 & 2
SQo 3
Surface Soil
Berm Soil
Range of Detection for Chemicals (mg/kg)
Endrin
0.089*
Fluoranlhene
0.064*
0 040-6.70
Fluoride
15.0-394
Heptachlor epoxide
0.022-0.20
IndenoO ,2,3-cd)pyrene
4.20*
Lead
153-299000
646-4430
Manganese
2420-6500
Mercury
0.150-2.80
0.300-0.690
Methylene chloride
0.015-0.190
0.025*
Molybdenum
148-8600
3.60-4.90
2.400-13 300
N-nitroso-di-n-propylamine
0.059-0.260
Nickel
14.60-3380
1760-6170
22.8-38.9
21.700-32 400
Nitrite
2216-8900
Phenanthrene
2.60*
Phenol
0 40*
0.230*
0,110*
Phosphonii
0.40-3290
Pyrene
0.047*
0.045-8.20
Selenium
49.60-2810
101 000-349.000
Silver
5.0r34.9
9.200-23.800
6.60-9.70
5 800-14.400
T etrachlorethene
0.140*
Thallium
0.090-5.700
4.000-73.900
0.510*
0.710*
Toluene
0.002-0.190
0.001*
0 002-0.200
Total xylenei
0.003*
0.069*
Tributyl Phosphate
0.200-73.00
Uranium
137.0-8394.0
738.0-4554.0
4.0-64.0
10.50-12.40
Vanadium
21.90-535.00
418-4550
15.9-27.7
24.600-28.400
Zinc
7.70-212.00
301-672
32.9-65.2
44.200-59.600
6-4
-------
FEM P-OU4ROD-8 FINAL
December 1994
Table 6-1
(continued)
Silo 1 & 2
Silo 3
Surface Soil
Berm Soil
Range of Detection for Radionuclides (pCi/g)
Actinium-227
2905.0-17390
234.0-1363
Cesium-137
0 23"
Lead-210
48980.0-399200
454.0-6427
0.98-4 45
Polonium-210
55300-43400
1.68-4 70
Protactiruum-231
4041'
266.0-931
Radium-224
64.00-453.00
1.020"
Radium-226
657.0-890700
467.0-6435
0.6-2.3
1.04-6.68
Radium-228
82.0-559
0.5-1.7
0.8-0 98
Strontium-90
0.8-1.8
Technetium-99
1.2-3.6
Thorium-228
411.0-7360
459.0-996
0.9-1.4
1.12-1.52
Thorium-230
8365.0-132800
21010.0-71650
1.4-4.8
1.69-4.78
Thorium-232
661.0-1106
411.0-1451
0.9-1.7
0.86-1.45
Uranium-234
89.0-1548
348.0-1935
2.4-6.9
1.26-3 62
Uranium-235/236
19.1-172
42.0-158
Uranium-238
46.0-1925
320.0-2043
2.4-20.8
1.13-4.19
'-only one sample was found to be above the detection limit.
6-5
-------
FEMP-OU4ROD-8 FINAL
December 1994
Under the second scenario, the site access restrictions historically provided by DOE are assumed to
be maintained, and no remedial actions are assumed to have been taken. The scenario further
assumes that no members of the public have established residence in the Operable Unit 4 Study Area,
and that DOE maintains a site-specific health and safety program to ensure that non-remediation
workers and visitors are properly protected. Therefore, the risk assessment addresses workers
subjected to short exposure durations under controlled conditions. These controls include engineered
emission control equipment, personnel protective equipment, and administrative health and safety
practices. Potential receptors under this scenario include an off-property resident farmer, a
trespassing child, and an off-property user of surface water from the Great Miami River.
The third land-use scenario, future land use without access controls, includes exposure routes that
require development time, such as establishing a home and farm within Operable Unit 4. Access
controls are assumed to be absent and no remedial actions are assumed to have been taken. In
addition, members of the public are assumed to have established a residence within the Operable Unit
4 boundaries. Hypothetical receptors under this scenario are a reasonable maximum exposure (RME)
on-property resident fanner, a central tendency (CT) on-property resident farmer, an on-property
resident child, an off-property resident farmer, and an off-property user of surface water from the
Great Miami River.
In addition to the three land use scenarios, there are two source term scenarios: the current source-
term scenario and the future source term scenario. The current source term scenario considers the
silos as they exist today. The future source term scenario considers complete structural failure of Silo
3, resulting in the spread of its contents to Operable Unit 4 surface soil, and dome collapse for Silos
1 and 2, consequently exposing their contents to the elements and increasing leaching of the contents
through the interception of rainwater.
Under the current land use scenario without access control and the future land use scenario, risks are
calculated using both the current source term and the future source term. Under the current land use
with access control scenario, the future source term does not apply; if the site remains under the
institutional control of DOE, the assumption is made that measures would be undertaken to maintain
the current configuration of the silos and implement mitigative action in the event of silo failure.
Thus, under the current land use with access control scenario, risk was calculated only for the current
source term.
6-6
-------
FEMP-OU4ROD-8 FINAL
December 1994
The on-property resident farmer receptor was also evaluated using exposure and intake parameters
such as exposure duration, which represents the CT of risk. This was performed in response to new
guidance from EPA, which suggests that all risk assessments provide an evaluation of the CT of the
risk range, using the best information available to describe the average situation (EPA 1992a). This
scenario is used to provide an estimate of risk closer to average for the resident adult scenario. This
receptor scenario is currently being developed by EPA and will require additional review as guidance
becomes available. The CT receptor for this scenario is located at the same location as the RME on-
property resident farmer receptor. Table 6-2 provides a summary of the land use/source
term/receptor scenarios used for the Baseline Risk Assessment.
Exposure pathways quantified in the risk assessment for each scenario are shown in Figures 6-1 and
6-2 and are discussed in greater detail in Appendix D of the RI Report for Operable Unit 4. A
summary of exposure pathways that have the most impact to site risks is presented in Section 6.1.4.
The conceptual model depicted in Figures 6-1 and 6-2 indicates which exposure routes are
quantitatively evaluated in the risk assessment for each receptor and land use scenario, and the basis
for excluding other exposure routes. Exposures to the RME resident farmer due to the ingestion of
groundwater consider two scenarios, which include water obtained from the Great Miami Aquifer and
water obtained from perched water beneath and west of Silos 1 and 2.
Section 5.0 and Appendix E of the RI Report for Operable Unit 4 address in detail all fate and
transport modeling efforts employed in the determination of exposure point concentrations of the
COCs. Appendix D of the RI Report for Operable Unit 4 discusses the assumptions regarding source
term and potential release mechanisms upon which the fate and transport modeling is based.
6.1.3 Toxicity Assessment
The human health hazards identified in the toxicity assessment are cancer induction and chemical
toxicity. Chemical toxicity includes numerous health effects such as kidney damage, liver disease, or
eye irritation. For both types of health hazards, dose-response data from human and animal studies
are used to determine the potency of the individual radionuclides and chemicals.
Intakes calculated in the exposure assessment are used in conjunction with the cancer slope factor
from the dose-response data to determine the incremental lifetime cancer risk (ILCR). Toxicity data
for the Operable Unit 4 risk assessment were taken from the Integrated Risk Information System
6-7
-------
TABLE 6-2
SUMMARY OF LAND-USE/RECEPTOR/SOURCE TERM SCENARIOS
RECEPTORS
LAND USE
CURRENT SOURCE TERM
FUTURE SOURCE
Current Land Use Without Access Control
Off-Property Farmer, Trespassing Child,
Groundskeeper Worker, Off-Property User
of Surface Water from the Great Miami
River
Off-Property Farmer, Trespassing Child,
Groundskeeper Worker, Off-Property User
of Surface Water from the Great Miami
River
Current Land Use With Access Control
Off-Property Farmer, Trespassing Child,
Off-Property User of Surface Water
N/A
Future Land Use
RME On-Property Resident Farmer, CT
On-Property Resident Farmer, On Property
Resident Child, Off-Property Farmer, Off-
Property User of Surface Water from the
Great Miami River
RME On-Property Resident Farmer, CT
On-Property Resident Farmer, On Property
Resident Child, Off-Property Farmer, Off-
Property User of Surface Water from the
Great Miami River
Notes: N/A Not Applicable
RME Reasonable Maximum Exposure
CT Central Tendency
-------
a.
I
sO
CT =
RMF.
Cross-hatched boxes indicate receptor exposure routes
that are included in the quantiatove risk assessment
Central Tendency
Reasonable Maximum Exposure
Primary
Source
Primary
Release
Mechanism
Secondary
Source
Silo
1. 2, 3
Contents
Structural
Failure
£
Soil/
Surface
Silo 1. 2, 3
Secondary
Release
Mechanism
Pathway
Gaseous Emissions
YftliM7ftigri
Wind Bros ton
Air
Leaching
Groundwater
Surface Runoff
Surface Water
and
Sediments
Root Uptake/
Ingestion by Cows
Exposure
Routes
Inhalation
Dermal Contact
Direct Radiation
Food Stuffs
Ingest Drinking Water
lnhaiation V(X?s
Dermal Contact
Food Stuffs
SW
Ingest Drinking Water
Inhalation V()Os
Dermal Contact
Food Stuffs
Incidental Ingestion
Dermal Contact
Food Stuffs
Incidental Ingestion
Dermal Contact
Penetrating Radiation
Direct Radiation
Racapfors
Current Land Use
without Access Controls
Current l-and Use
with Access Controls
Future I-and Use
LAPW1 i UVvl . IWWJ
2,3
2,3
2.3
23
2.3
2,3
S3
2,3
2.3
2.3
2.3
rvtwN«
L !_ v2S2x.^
IWM 'M-l ' W>Tx!
1
1) The objective of quantifying exposure routes to the off-property user of
surface water is (o isolate and evaluate the impact of contamination from the
Great Miami River through water pathways.
2) Potential impad of exposure route is minor compared to other exposure routes .
3) EPA Risk assessment methodology for radionuclides dos not address this exposure route.
4) Exposure route is not applicable to a transient, non-resident receptor.
5) Evaluated using two different exposure point concentrations: modeled aquifer
concentration and modeled sand lens concentration.
6) Off-property soils is within the scope of OUS. Impact on food stuff exposure routes from
air deposition is included in the air exposure routes.
7) Receptor is assumed to obtain water for all needs from groundwater
8) Receptor is assumed to restrict activities to work at (>U4 and not contact
surface water via these exposure routes.
9) Evaluated for sediment ingestion and dermal contact with sediment using
modeled concentration impacted by sand lens.
O
8
n
3
o*
o
FIGURE 6-1. 0U4 CONCEPTUAL MODEL - SILO CONTENTS
-------
On
i
O
Cross-hatched boxes indicate receptor exposure routes
that are included in the quantitative risk assessment
CT = Central Tendency
RME = Reasonable Maximum Exposure
Soil:
Surface,
Subsurface,
Berm Fill
Release
Mechanisms
Wind Erosion —«
Leaching
Surface Runoff
Direct Contact
Gaseous Emissions-
Volitization
Penetrating Radiation
Pathway
Air
Groundwater
Surface Water
and
Sediments
SW^
Root Uptake/
Ingestion by Cows
Exposure
Routes
Inhalation
Dermal Contact
Direct Radiation
Food Stuffs
Ingest Drinking Water
Inhalation VOCs
Dermal Contact
Food Stuffs
Ingest Drinking Water
Inhalation VOCs
Dermal Contact
Food Stuffs
Incidental Ingestion
Dermal Contact
Food Stuffs
Incidental Ingestion
Dermal Contact
Receptors
Current Land Use
without Access Controls
it
Current Land Use
with Access Controls
Future Land Use
h
h
I:
2,3
2,3
2,3
mi
2,3
2,3
2,3
2,3
2,3
Direct Radiation
~vs*v
««
U
1) The objective of quantifying exposure routes to the off-property user of
surface water is to isolate and evaluate the impact of contamination from the
Great Miami River through water pathways.
2) Potential impact of exposure route is minor compared to other exposure
routes.
3) EPA Risk assessment methodology for radionuclides does not address this
exposure route.
4) Exposure route is not applicable to a transient, non-resident receptor.
5) Soil in Operable Unit 4 is not included as a source term to groundwater
modeling.
6) Off-property soils is within the scope of OUS. Impact on food stuff exposure
routes from air deposition is included in the air exposure routes.
7) Receptor is assumed to obtain water for all needs from groundwater.
8) Receptor is assumed to restrict activities to work at OU4 and not contact
surface water via these exposure routes.
*T1
m
2
6
c
S
D
I
00
3
2
FIGURE 6-2. OU4 CONCEPTUAL MODEL - SOIL AND BERM FILL MATERIAL
-------
FEMP-OU4ROD-8 FINAL
December 1994
(IRIS, EPA 1992a) and the updated Health Effects Assessment Summary Table (HEAST, EPA
1992b). Cancer slope factors have been developed by the EPA for estimating ILCRs associated with
exposure to carcinogenic chemicals. The slope factors, which are expressed in units of milligrams
per kilograms-day (mg/kg-day)"1, are multiplied by the estimated intake of a carcinogen, in mg/kg-
day, to provide an upper-bound estimate of the ILCR associated with exposure at that intake level.
The term "upper-bound" reflects the conservative estimate of the risks calculated from the slope
factor. Use of this approach makes underestimation of the actual cancer risk highly unlikely. Cancer
slope factors are derived from the results of human epidemiological studies, or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty factors have been applied. Tables
6-3 and 6-4 provide the cancer slope factors for Operable Unit 4 chemical COCs and radiological
COCs respectively.
For cancer induction, it is assumed that no dose threshold exists. Therefore, for any dose of a
carcinogen, there exists a possibility, however small, of contracting cancer. Incremental lifetime
cancer risks are expressed in terms of the probability that a given receptor (person) will contract
cancer due to the calculated exposures. For example, if the receptor has an additional 1 chance in
10,000 of contracting cancer due to the calculated exposures, the probability of developing cancer is
expressed as a 10"4 (1 in 10,000) risk. However, these risk factors should only be used to make a
qualitative estimate of individual receptor impact, because the risk coefficients are intended for
predicting cancer in a large population.
For chemical toxicants, the data suggests a dose threshold or reference dose (RfD) exists below which
no toxic effect is observed. RfDs have been developed by the EPA for indicating the potential for
adverse health effects from exposure to chemicals exhibiting non-carcinogenic effects. RfDs, which
are expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes of chemicals itom environmental media (e.g., the
amount of a chemical ingested from contaminated drinking water) can be compared to the RfD. RfDs
are derived from human epidemiological studies or animal studies to which uncertainty factors have
been applied (e.g., to account for the use of animal data to predict effects on humans). These
uncertainty factors help ensure that the RfDs will not underestimate the potential for adverse non-
carcinogenic effects to occur. Table 6-5 provides the RfDs for Operable Unit 4 COCs.
To determine if the exposure levels of Operable Unit 4 constituents may cause adverse health effects,
the estimated intake of a particular constituent (calculated from the exposure assessment) is compared
6-11
-------
TABLE 6-3
CANCER SLOPE FACTORS FOR CARCINOGENIC EFFECTS OF CONSTITUENTS OF CONCERN
FOR OPERABLE UNIT 4
Tumor Site
ON
I
fo
Chemical
Oral Cancer Stape Factor
(mg/kg/day)1
Inhalation Cancer Slope
Factor (mg/kg/day) '*
Oral
Inhalation
Cancer
Classification**
Reference
Inorganics
Ammonia
ND*
ND
ND
ND
ND
ND
Antimony
ND
ND
ND
ND
D
d
Arsenic
1.75
15
skin
respiratory tract
A
e
Barium
ND
ND
ND
ND
D
d
Beryllium
4.3
8.4
gross tumors
lung
B2
e
Boron
ND
ND
ND
ND
ND
ND
Cadmium (food)
ND
6.3
ND
respiratory tract
B1
e
Cadmium (waler)
ND
6.3
ND
respiratory tract
Bl
e
Chromium (VI)
ND
42
ND
lung
A
e
Cobalt
ND
ND
ND
ND
ND
ND
Copper
ND
ND
ND
ND
D
e
Cyanide
ND
ND
ND
ND
D
e
Fluoride
ND
ND
ND
ND
ND
ND
Lead
ND
ND
kidney
ND
B2
e
Manganese
ND
ND
ND
ND
D
e
Mercury
ND
ND
ND
ND
D
e
Molybdenum
ND
ND
ND
ND
D
d
Nickel
ND
0.84
ND
respiratory tract
A
e
Nitrate
ND
ND
ND
ND
ND
ND
Phosphorus
ND
ND
ND
ND
D
e
Selenium
ND
ND
ND
ND
D
e
Silver
ND
ND
ND
ND
D
e
Thallium compounds
ND
ND
ND
ND
ND
e
•n
ru
2
no
6
c
D &
§ 8
I- oo
q 2
^ z
-------
TABLE 6-3
(Continued)
Tumor Site
Chemical
Oral Cancer Slope Factor
(mg/kg/day)'
Inhalation Cancer Slope
Factor (mg/kg/day) '*
Oral
Inhalation
Cancer
Classification"''
Reference
Uranium
ND
ND
ND
ND
ND
f
Vanadium
ND
ND
ND
ND
ND
d
Zinc
ND
ND
ND
ND
D
e
Volatiles
2-Buu none
ND
ND
ND
ND
D
e
2-Hexanone
ND
ND
ND
ND
ND
ND
4-Methyl-2-pentanone
ND
ND
ND
ND
ND
ND
Acetone
ND
ND
ND
ND
D
e
Carbon tetrachloride
0.13
0.053
liver
ND
B2
e
Methylene chloride
0.0075
0.0016
liver
lung, liver
B2
e
Tetrachloroethene
0.052
0.002
lung
lung
B2-C
e
Toluene
ND
ND
ND
ND
D
e
Total xylenes
ND
ND
ND
ND
D
e
Semivola tiles
Acenaphthylene
ND
ND
ND
ND
D
e
Aldrin
17
17
liver
ND
B2
e
Anthracene
ND
ND
ND
ND
D
e
Benzo(a)anthracene
7.3
6 1
ND
ND
B2
h
Benzo(a)pyrene
7.3
6.1
stomach
respiratory tract
B2
e> g
Benzo(b)fluoranthene
7.3
6.1
ND
ND
B2
h
Benzo(g,h,i)perylene
ND
ND
ND
ND
D
e
Benzoic acid
ND
ND
ND
ND
D
e
bis(2-Ethylhexyl)phthalate
0.014
ND
liver
ND
B2
e
Chrysene
7.3
6 1
. lymphoma, skin
ND
B2
h
Di-n-butylphthalate
ND
ND
ND
ND
D
e
-------
TABLE 6-3
(Continued)
Chemical
Oral Cancer Slope Factor
(mg/kg/day)'
Inhalation Cancer Slope
Factor (mg/kg/day)'1*
Oral
Tumor Site
Inhalation
Cancer
Classification*'
Reference
Di-n-octylphthalate
ND
ND
ND
ND
ND
ND
Dibenzo(a,h)anthracene
7.3
6.1
ND
ND
B2
h
Diethyl phthalate
ND
ND
ND
ND
D
e
Dimethyl phthalate
ND
ND
ND
ND
D
e
Fluoranthene
ND
ND
ND
ND
D
e
lndeno(l ,2,3-cd)pyrene
7.3
6.1
ND
ND
B2
h
2-Nitrophenol
ND
ND
ND
ND
ND
ND
4-Nitrophenol
ND
ND
ND
ND
ND
ND
N-Nitroso-di-n-propylamine
7
ND
multiple
ND
B2
e
Phenanthrene
ND
ND
ND
ND
D
e
Phenol
ND
ND
ND
ND
D
e
Pyrene
ND
ND
ND
ND
D
e
Tributyl phosphate
ND
ND
ND
ND
D
i
Pesticides/PCBs
Aroclor-1248
7.7
ND
liver
ND
B2
i
Aroclor-1254
7.7
ND
liver
ND
B2
i
Aroclor-1260
7.7
ND
liver
ND
B2
e
4,4'DDE
0.34
ND
liver
ND
B2
e
4,4'DDT
0.34
0.34
liver
ND
B2
e
Dieldrin
16
16
liver
ND
B2
e
Ti
ra
2
Endouilfan 1
ND
ND
ND
ND
ND
ND
6
Endotulfan 11
ND
ND
ND
ND
ND
ND
c
D
73
Endrin
ND
ND
ND
ND
D
d
8
n
O
D
3
1
9 1
O"
00
Heptachlor epoxide
9.1
liver
ND
B2
e
n
3
-------
TABLE 6-3
(Continued)
Tumor Site
Oral Cancer Slope Factor Inhalation Cancer Slope Cancer
Chemical (nig/kg/day)"1 Factor (mg/ltg/day)1* Oral Inhalation Classification"' Reference
'Derived from inhalations unit risk.
'Cancer weight-of-evidence Group A = human carcinogen; Group B1 and B2 — probable human carcinogen; Group C = possible human
carcinogen; Group D - not classifiable as to carcinogenicity to humans; Group E = evidence of noncarcinogenicity to humans
*ND - no data
dEPA 1993b, 'Drinking Water Regulations and Health Advisories"
'Integrated Risk Information System (IRIS), 1993 (EPA 1993a) current as of April 1993
*The carcinogenicity of uranium is attributed to its radioactivity; see Appendix D of the Operable Unit 4 Remedial Investigation.
'EPA, Health Effects Assessment Summary Table (HEAST)(EPA 1992a).
'The oral and inhalation cancer slope factors for benzo(a)pyrene are used for the other polyaromatic hydrocarbons assigned to cancer classification B2 (see the lexicological profile for
polyaromatic hydrocarbons of Appendix D from the Operable Unit 4 Remedial Investigsation for additional information).
'EPA, 1993d, Memorandum from J. Dollarhide ECAO to P. VanLeeuwen Region V, 7/21/93, including Attachments 1-6.
-------
TABLE 6-4
CANCER SLOPE FACTORS FOR OPERABLE UNIT 4 RADIONUCLIDES OF CONCERN"
On
I
5
ICRP
Inhalation
GI Absorption
Factor
Penetrating External
Ingestion Exposure
Radionuclide
Lung Classb
(pCi)'
(f.)
(pCi)'
(pCi • yr/g)1
Uranium - 238 Series
U-238 + 2 dtrs
Y
5.2 x 108
5.0 x 102
2.8 x 10"
3.6 x 108
U-234
Y
2.6 x 108
5.0 x 102
1.6 x 10"
3.0 x 10 "
Th-230
Y
2.9 x 108
2.0 x 10^
1.3 x 10"
5.4 x 10"
Ra-226 + 5 dtrs
W
3.0 x 109
2.0 x 101
1.2 x I010
6.0 x 10A
Rn-222 + 4 dtrs
Gas
7.7 x 1012
1.0 x i(y
1.7 x 1012
5.9 x 106
Pb-210 + 2 dtrs
D
4.0 x 109
2.0 x 101
6.6 x 1010
1.6 x 10 10
Uranium - 235 Series
U-235 + 1 dtr
Y
2.5 x 108
5.0 x 102
1.6 x 10"
2.4 x 10 7
Pa-231
Y
3.6 x 108
1.0 x 103
9.2 x 10"
2.6 x 10 8
Ac-227 + 7 dtrs
Y
8.8 x 108
1.0 x 103
3.5 x 1010
8.5 x I0 7
Thorium - 232 Series
Th-232
Y
2.8 x 108
2.0 x 10^
1.2 x 10"
2.6 x 10"
Ra-228 + 1 dtr
W
6.9 x 1010
2.0 x 101
1.0 x 10'°
2.9 x 106
Th-228 + 7 dtrs
Y
7.8 x 108
2.0 x 10^
5.5 x 10"
5.6 x 106
Fission Products
Tc-99
W
8.3 x 1012
8.0 x 101
1.3 x 1012
6.0 x 1013
Sr-90 + 1 dtr
D
6.2 x 10"
3.0 x 10 '
3.6 x 10"
0.0 x 10°
"EPA, Health Effects Assessment Summary Tables, Annual FY 1992 including the July 1992 and November 1992 supplements (EPA
1992a)
•"Classification recommended by the ICRP for half-time for clearance from the lung. "Y" = years, "W" = weeks, "D" = days.
•n
ro
2
6
c
>1
S? »
8 o
g o
I- <*>
9 2
-------
TABLE 6-5
REFERENCE DOSES FOR NONCARCINOGENIC EFFECTS OF CONSTITUENTS OF CONCERN
FOR OPERABLE UNIT 4
Target Organ
Uncertainty Factor
Oral Reference Dose
inhalation Reference Dose
Chemical
(mg/kg/day)
(mg/kg/day)'
Oral
Inhalation
Oral
Inhalation
Inorganics
Amrfionia
ND
0.029'
ND
Respiratory system
ND
30
Antimony
0 0004"
nd*
Liver
ND
1000
ND
Arsenic
0.0003'
ND
Skin
ND
3
ND
Barium
0.07'
0.00014'
Cardiovascular system
Fetus
3
1000
Beryllium
0.005'
ND
ND
ND
100
ND
Boron
0.09'
0.005T1
Testis
Respiratory system
100
100
Cadmium (food)
0.001'
ND
Kidney
Cancer (see Table 6-3)
10
ND
9s
Cadmium (water)
0.0005'
ND
Kidney
Cancer (see Table 6-3)
10
ND
1
i—*
-j
Chromium (VI)
0.005'
ND
ND
ND
500
ND
Cobalt
0.06'
0.0000003'
Cardiovascular system
Respiratory system
ND
1000
Copper
ND
ND
ND
ND
ND
ND
Cyanide
0.02'
ND
Central nervous system
ND
500
ND
Fluoride
0.06'
ND
Teeth
ND
1
ND
Lead
ND
ND
Central nervous system
Central nervous system
ND
ND
Manganese
0.14 (food)'
0.00011'
Central nervous system
Respiratory system
1
300
Manganese
0.005 (water)'
0.00011'
Central nervous system
Respiratory system
1
300
Mercury
0.00034
0.0000864
Kidney
Central nervous system
1000
30
Molybdenum
0.005'
ND
Liver
ND
30
ND
Nickel
0.02'
ND
ND
Cancer (see Table 6-3)
300
ND
Nitrate
1.6"
ND
Blood
ND
1
ND
•n
ra
2
6
c
_ a
o 50
8 o
a a
3 i
a- 0"
£» T1
-------
TABLE 6-5
(Continued)
Target Organ
Uncertainty Factor
Chemical
Oral Reference Dose
(mg/kg/day)
Inhalation Reference Dose
(mg/kg/day)'
Oral
Inhalation
Oral
Inhalation
Inorganics
Phosphorui
0.00002k
ND
Reproductive system
ND
1000
ND
Selenium
0.005k
ND
Skin
ND
3
ND
Silver
0.005k
ND
ND
ND
3
ND
Thallium
0.00006b»
ND
Central nervous system
ND
3000
ND
Uranium
0.003k
ND
Kidney
ND
1000
ND
Vanadium
ooor
ND
ND
ND
100
ND
Zinc
0.3"
ND
Blood
ND
3
ND
Volatiles
2-Butanone
0.05'
0.3"
ND
Fetus
1000
1000
2-Hexanone
0.04'
ND
ND
ND
ND
ND
4-Methyl-2-pentanone
0.05'
0.023'
Liver
Liver
1000
1000
Acetone
0.lk
ND
Liver
ND
1000
ND
Carbon tetrachloride
0.0007"
0.00057*
Liver
ND
1000
ND
Methylene chloride
0.06k
0.86'
Liver
Liver
100
100
T etrachloroethene
0.0lk
ND
Liver
ND
1000
ND
Toluene
0.2k
0.114
Liver
Central nervous system
1000
300
Total xylenes
2k
ND
Central nervous system
ND
100
ND
Semivola tiles
Acenaphthylene
ND
ND
ND
ND
ND
ND
Aldrin
0.00003k
ND
Liver
ND
1000
ND
Anthracene
0.3"
ND
ND
ND
3000
ND
"tl
m
2
•o
6
c
_ a
o 33
8 o
o o
I- °°
£5 m
5 I
£ £
-------
TABLE 6-5
(Continued)
Target Organ
Uncertainly Factor
On
i
v©
Oral Reference Dose
Inhalation Reference Dose
Chemical
(mg/kg/day)
(mg/kg/day)*
Oral
Inhalation
Oral
Inhalation
Semivolatiles
Benzo(a)anthracene
ND
ND
ND
ND
ND
ND
Benzo(a)pyrene
ND
ND
ND
ND
ND
ND
Benzo(b)fluoranthene
ND
ND
ND
ND
ND
ND
Benzo(g,h,i)perylene
ND
ND
ND
ND
ND
ND
Benzoic acid
4b
ND
ND
ND
1
ND
bis(2-Ethylhexyl)phthalate
0.02b
ND
Liver
ND
1000
ND
Chrysene
ND
ND
ND
ND
ND
ND
Di-n-butylphthalate
0.1'
ND
ND
ND
1000
ND
Di-n-octylphthalale
0.024
ND
Liver
ND
1000
ND
Dibehzo(a,h)anthracene
ND
ND
ND
ND
ND
ND
Diethyl phthalate
0.8b
ND
ND
ND
1000
ND
Dimethyl phthalate
10*
ND
Kidney
ND
10
ND
Fluoranthene
0.04k
ND
Kidney
ND
3000
ND
lndeno(l ,2,3-cd)pyrene
ND
ND
ND
ND
ND
ND
2-Nitrophenol
ND
ND
ND
ND
ND
ND
4-Nitrophenol
0.008'
ND
ND
ND
ND
ND
N-Nitroso-di-n-propylamine
ND
ND
ND
ND
ND
ND
U
Phenanthrene
ND
ND
ND
ND
ND
ND
m
2
"O
Phenol
0.6b
ND
Fetus
ND
100
ND
6
c
Pyrene
0.03b
ND
Kidney
ND
3000
ND
O W
8 o
Tributyl phosphate
0.005'
ND
ND
ND
ND
ND
§ o
1- 0°
5 3
s 5
-------
TABLE 6-5
(Continued)
Target Organ Uncertainty Factor
Oral Reference Dose Inhalation Reference Dose
Chemical (mg/kg/day) (mg/kg/day)' Oral Inhalation Oral Inhalation
Pesticides/PC Bs
Aroclor-1248
0.00007''
ND
Fetus
ND
100
ND
Aroclor-1254
0.00007'-'
ND
Fetus
ND
100
ND
Aroclor-1260
0.00007"
ND
Fetus
ND
100
ND
4,4'-DDE
ND
ND
ND
ND
ND
ND
4,4'DDT
0.0005'
ND
Liver
ND
100
ND
Dieldrin
0.00005'
ND
Liver
ND
too
ND
Endosulfan I
0.00005'
ND
Kidney
ND
3000
ND
Endosulfan II
0.00005"
ND
Kidney
ND
3000
ND
Endrin
0.0003'
ND
Liver
ND
100
ND
Heptachlor epoxide
0.000013'
ND
Liver
ND
1000
ND
'Derived from inhalation RfC.
'Integrated Risk Infornution System (IRIS) (EPA 1993') current as of April 1993.
•ND - no data.
'EPA, Health Effects Assessment Summary Tables, (HEAST) Annual FY 92 including July and November Supplements (EPA 1992a).
"EPA 1992*, Memorandum from D. L. Forman, U. S. EPA Region VII, Philadelphia, Pennsylvania, 'Subject: Cobalt Toxicity,' dated March 12, 1992.
'EPA 1990c, Memorandum from Pei-Fung Hurst, ECAO, Cincinnati, Ohio, to R. Riccio, U.S. EPA Region Ul, Philadelphia, Pennsylvania, "Subject: Toxicity of Cobalt (Halby
Chemical/Wilmington, Delaware)," dated October 9, 1990.
'Derived by analogy to thallium sulfate, adjusting for differences in molecular weight.
'EPA 1993c
'Based on anology to Aroclor - 1016.
¦EPA, 1993e, Health Effects Assessment Summary Tables, (HEAST), March, 1993.
'EPA, 1993d, Memorandum from J. Dollartiide, ECAO to P. VanLeeuwen, Region V, 7/21/93. rn
2
6
c
o 73
8 o
§ D
I- 00
™ 2
— 2
-------
FEMP-OU4ROD-8 FINAL
December 1994
to the RfD, which defines the acceptable intake. If the ratio of estimated intake to the acceptable
intake is greater than one, the site-related intake may cause toxic effects. This ratio is called the
Hazard Quotient (HQ). When HQs for multiple COCs are summed, the resultant value is the Hazard
Index (HI).
6.1.4 Risk Characterization Results
Excess lifetime cancer risks are determined by multiplying the intake level with the cancer potency
factor. These risks are probabilities that are generally expressed in scientific notation (e.g. 1 x 10^ or
1E-6). An excess lifetime cancer risk of 1 x 10"6 indicates that, as a plausible upper bound, an
individual had a one in one million chance of developing cancer as result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is expressed
as the HQ (or the ratio of the estimated intake derived from the contaminant concentration in a given
medium to the contaminant's reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may reasonably be exposed, the HI can be
generated. The HI provides a useful reference point for gauging the potential significance of multiple
contaminant exposures within a single medium or across media.
Tables 6-6 and 6-7 shows the baseline risks and His for each hypothetical receptor by land use and
source term scenario. Risk values in Table 6-6 are reported in units of ILCR for radiological,
chemical, and total risk. The chemical HI, which has no units, is presented in Table 6-7.
6.1.4.1 Current Land Use Without Access Control/Current Source-Term Scenario
The receptor with the greatest total radiological risk is the trespassing child (Table 6-6). The greatest
contributor under this scenario is from exposure to external radiation while the receptor is on top of
the Silo 1 or 2 dome (5 x 1CT3). In addition, the receptor is exposed to air, soil, and surface water
pathways resulting in radiological risk of 3 x 10"5. The total radiological risk to the trespassing child
is 5 x 10"3 (external radiation) plus 3 x 10'3 (nuclide-specific radiation) totalling 5 x 10"3. The
receptor with the greatest total chemical risk (1 x KT4) is the off-property resident fanner (Table 6-6).
The greatest contribution under this scenario is from exposure to air pathways (1 x 10"4). The
receptor with the greatest total radiological plus chemical risk under this scenario (5 x 10"3, Table 6-6)
is the trespassing child. The greatest HI is 0.3 to the trespassing child (Table 6-7). The greatest
contribution, under this scenario is from soil exposure pathways (0.2).
6-21
-------
TABLE 6-6
INCREMENTAL LIFETIME CANCER RISK SUMMARY ALL SOURCES/ALL PATHWAYS
Land Use/
Source Term
Scenario
Type of Risk
Trespassing Child
Grounds
Keeper
Off-Property
Resident Farmer
Off-Property
User of Surface
Water
CT On-Property
Resident Farmer
RME On-Property
Resident Farmer'
On-Property
Resident Child
Current Land Use
without Access
Control/Current
Source Term
Scenario
Radiological-Nuclide Specific'
3.0 x 105
8.0 x 101
1.0 x 10 s
1.0 x 10'
NA'
NA
NA
Radiological- External'
5 x 10'
1 x 104
NA
NA
NA
NA
NA
Chemical Risk
1.0 x 10 s
2.0 x 10'
1.0 x lO"
1.0 x 107
NA
NA
NA
Total Risk
5.0 x 10'
2.0 x 10"
1.0 x lO"
2.0 x 107
NA
NA
NA
Current Land Use
without Access
Control/Future
Source Term
Scenario
Radiological-Nuclide Specific
1.0 x 10'
3.0 x 101
2.0 x 10'
1.0 x 10"6
NA
NA
NA
Chemical Risk
4.0 x lfr4
6.0 x lO"
2.0 x lO"1
7.0 x 10 '
NA
NA
NA
Total Risk
1.0 x 10J
3.0 x 10'
2.0 x 10 '
2.0 x 10"6
NA
NA
NA
Current Land Use
with Access
Control/Current
Source Term
Scenario
Radiological-Nuclide Specific
3.0 x 10'
NA
1.0 x 10s
1.0 x 107
NA
NA
NA
Radiological-External
5.0 x 10'
NA
NA
NA
NA
NA
NA
Chemical Risk
1.0 x 105
NA
1.0 x lO"
1.0 x 107
NA
NA
NA
Total Risk
5.0 x 10 '
NA
1.0 x lO"
2.0 x 10 '
NA
NA
NA
Future Land
Use/Current Source
Term Scenario
Radiological-Nuclide Specific
NA
NA
1.0 x 103
1.0 x 10'
2.0 x 10"
3 .0 x 10 1
3.0 x I04
Radiological-External
NA
NA
NA
NA
2.0 x 10"1
2 .0 x 10 '
9.0 x 10 1
Chemical Risk
NA
NA
1.0 x lO"
1.0 x 107
5.0 x 10»
8 0 x 101
5 0 x 101
Total Risk
NA
NA
1.0 x 10"
2.0 x 10 '
5.0 x 10'
9.0 x 10 '
6.0 x 10'
Future Land Use/
Future Source Term
Scenario
Radiological-Nuclide Specific
NA
NA
2.0 x 10 '
1.0 x I0"6
1.0 x 101
1 0 x 10°
1.0 x 10'
Chemical Risk
NA
NA
2.0 x 10"
7.0 x 10 '
1.0 x 10'
2 .0 x 10 1
9.0 x 101
Total Risk
NA
NA
2.0 x 10 '
2.0 x 10"6
1.0 x 10 1
>1.0
2 0 x 10'
"The 1LCR values were identical for the future land use/future source term scenario evaluated for either the Great Miami Aquifer or for perched water.
The ILCR result from exposure to radionuclides from air, water, (ground and surface), soil and sediment as detailed in Attachment II of Appendix D and summarized in tables within Section D.5.
°NA signifies not applicable.
'This risk results from exposure to direct external radiation from large sources (Silos 1, 2, and 3) and are presented in Table D.5-2. It does not include exposure to external radiation
emanating from radionuclides in surface soils. These later risk are accounted for in the nuclide-specific ILCR.
55
-------
TABLE 6-7
HAZARD INDEX SUMMARY ALL SOURCES/ALL PATHWAYS
On
i
N>
UJ
Land Use/
Source Term Scenario
Type of Risk
T respassing
Child
~rounds
Keeper
Off-Property
Resident
Farmer
Off-Property
User of Surface
Water
CT On-Property
Resident Farmer
RME On-Property
Resident Farmer*
On-Property
Resident Child
Current Land Use
without Access Control/Current
Source Term Scenario
Chemical Hazard Index
0.3
0.1
0.05
0.0004
NAb
NA
NA
Current Land Use
without Access Control/Future
Source Term Scenario
Chemical Hazard Index
20
20
5
0.002
NA
NA
NA
Current Land Use
with Access Control/Current
Source Term Scenario
Chemical Hazard Index
0.3
NA
0.05
0.0004
NA
NA
NA
Future Land
Use/Current
Source Term Scenario
Chemical Hazard Index
NA
NA
0.05
0.0004
8
20
100
Future Land
Use/Future
Source Term Scenario
Chemical Hazard Index
NA
NA
5
0.002
300
500
2000
The HI (500) was identical for the future land use/future aource-term scenario.
bNA signifies not applicable.
3
2
¦p
c
¦«k
50
0
D
1
00
3
z
>
r
-------
FEMP-OU4ROD-8 FINAL
December 1994
6.1.4.2 Current Land Use Without Access Control/Future Source-Term Scenario
The receptor with the greatest total radiological risk is the groundskeeper (Table 6-6). The greatest
contribution under this scenario is from exposure to soil pathways (2 x 10"2). The total radiological
risk to the groundskeeper under this scenario is 3 x 10"2 (Table 6-6). The receptor with the greatest
total chemical risk is also the groundskeeper (Table 6-6). The greatest contribution is from exposure
to soil pathways (5 x KT4). The total chemical risk to the groundskeeper under this scenario is 6 x
10"4. The total radiological plus chemical risk to the groundskeeper under this scenario is 3 x 10"2
(Table 6-6). The greatest HI is 20 to the groundskeeper (Table 6-7) and to the trespassing child
(Table 6-6). The greatest contribution to both receptors under this scenario is from exposure to air
pathways.
6.1.4.3 Current Land Use With Access Control/Current Source-Term Scenario
This scenario most closely approximates current conditions at the FEMP site. However, the risk and
HI results for this scenario are numerically the same as the results for the current land-use scenario
without access controls assuming the current source term (Section 6.1.4.1). This is because the
presence or absence of access controls does not change the numerical values of exposure parameter
values for receptors. The trespassing child's exposure parameter values reflect the standard scenario
specified by the EPA. Also, the off-property resident farmer, and surface water user exposures are
not impacted by the status of access controls.
6.1.4.4 Future Land Use/Current Source-Term Scenario
The receptor with the greatest total radiological risk is the on-property resident child (Table 6-6).
The greatest contribution under this scenario is from exposure to external radiation while the receptor
is on top of the Silo 1 or 2 dome (9 x 10*). In addition, the receptor is exposed to air, soil, and
surface water pathways resulting in a radiological risk of 3 x 1CT\ primarily from the soil pathway
(2 x 10"4). The total radiological risk to the on-property resident child is 9 x 10° plus 3 x 10"4
totalling 9 x 10"3. The receptor with the greatest total chemical risk (8 x 10"2) is the RME on-
property resident farmer (Table 6-6). The greatest contribution under this scenario is from exposure
to soil pathways (8 x 10"2). The receptor with the greatest total radiological plus chemical risk under
this scenario (9 x 10"2, Table 6-6) is the RME on-property resident farmer. The greatest HI is 100 to
the on-property resident child (Table 6-7). Hie greatest contribution to chemical hazard under this
scenario is from soil exposure pathways (100).
6-24
-------
FEMP-OU4ROD-8 FINAL
December 1994
6.1.4.5 Future Land Use/Future Source-Term Scenario
This represents the most conservative scenario considered under the baseline risk assessment. Within
this scenario, a family is assumed to have established a residence within the Operable Unit 4
boundaries. Additionally, the domes of Silos 1 and 2 are assumed to have failed and Silo 3 is
assumed to have suffered total structural failure, spreading its contents to the surface of Operable
Unit 4. As described in Section D.3 of the RI Report for Operable Unit 4, the failure of Silo 3 and
the assumed distribution of its contents on the surrounding surface makes it more appropriate to
evaluate direct external exposure in a nuclide- specific manner rather than as a large source. With the
failure of the domes of Silos 1 and 2 it is no longer appropriate to evaluate direct external radiation
exposure at these locations. Therefore, the separate entry in Table 6-6 for external radiation does not
appear for the future source-term scenario.
The receptor with the greatest total radiological risk is the RME on-property resident farmer
(Table 6-6). The greatest contribution under this scenario is from exposure to soil pathways
(approaching unity risk). The total radiological risk to the RME on-property resident farmer under
this scenario also approaches unity (1) risk. The receptor with the greatest total chemical risk is also
the RME on-property resident farmer (Table 6-6). The greatest contribution is from exposure to soil
pathways (2 x 10"1). The total chemical risk to the RME on-property resident farmer under this
scenario is 2 x 10"'. The total radiological plus chemical risk to the RME on-property resident
former under this scenario exceeds unity (Table 6-6). The greatest HI is 2000 to the on-property
resident child (Table 6-7). The greatest contribution to this receptor under this scenario is from
exposure to soil pathways.
6.1.5 Risk Assessment Uncertainties
The uncertainties inherent in the risk assessment process are presented in detail in Section D.6.0 of
Appendix D of the RI Report for Operable Unit 4. These uncertainties are summarized below to
enable a better understanding of their impacts on the foregoing risk assessment.
Uncertainty is a factor in each step of the exposure and toxicity assessment process. Such uncertainty
can involve variations in sample analytical results, the values of variables used as input to a given
model, the accuracy with which the model itself represents actual environmental or biological
processes, the manner in which the exposure scenario is developed, and the high-to-low dose and
interspecies extrapolations for dose-response relationships.
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Generally, risk assessments carry two types of uncertainty. First, measurement uncertainty refers to
the usual variance that accompanies scientific measurements (such as the range of an exposure
estimate) and reflects the accumulated variances of the individual measured values used to develop the
estimate. The second form of uncertainty is due to the absence of information needed to complete the
database for the assessment. In some instances, the impact is significant, such as the absence of
information on the adverse effects or the biological mechanism of action of a chemical agent.
6.1.5.1 Sources of Uncertainty
As noted previously, uncertainties are associated with the information and data used in each phase of
the Operable Unit 4 baseline risk assessment. The first source of uncertainty arises from data gaps or
limitations in the data. For example, the data set for soil is limited, and virtually nothing is known
regarding contaminants in the area of the former Drum -Handling Building. These limitations could
result in failure to identify some COCs which may result in underestimating risk. (This data
limitation and its expected impact on the baseline risk assessment is further discussed in greater detail
in Section 7.5 of the RI Report for Operable Unit 4).
Other sources of uncertainty include the conservative bias of parameters, parameter variability
(random errors or natural variations), and the necessity of using computer models to predict complex
environmental interactions. Uncertainties also arise from the use of animal data to predict the toxic
effects and the toxic potency in humans. Uncertainties associated with information and data are
evaluated below to provide the spectrum of information in regard to the overall quality of the risk
assessment results. The uncertainties are associated with exposure route selection, selection of COCs,
exposure point concentrations, and exposure factors.
6.1.5.2 Toxicity Assessment
Considerable uncertainty is associated with the qualitative (hazard assessment) and quantitative
(dose-response) evaluations of a Superfund risk assessment. A hazard assessment deals with
characterizing the nature and strength of the evidence of causation, or the likelihood that a chemical
that induces adverse effects in animals will induce adverse effects in humans. Hazard assessment of
carcinogenicity is evaluated as a weight-of-evidence determination, using either the International
Agency for Research on Cancer (IARC) (1987) or EPA (1986) schemes. Positive cancer test data in
experimental animals suggest that a human exposed to the same agent may suffer adverse effects.
However, animal data, may not accurately predict the same response or the same target organ tissue
for cancer in humans. Also, biochemical repair mechanisms present in humans may inhibit or
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preclude an identical response. Accordingly the uncertainty of possible effects is significant. In
assessing noncancer effects, however, positive experimental animal data from well designed studies in
appropriate models suggest both the target tissues and type of effects that may be anticipated in
humans (EPA 1989a).
6-2 OVERVIEW OF THE BASELINE ECOLOGICAL RTSK ASSESSMENT
The purpose of the ecological risk assessment, which was completed as a companion to the
preliminary site-wide baseline risk assessment in the Site-Wide Characterization Report (SWCR), was
to estimate the potential and future baseline risks of FEMP contaminants to ecological receptors.
The EPA and DOE have agreed in the Amended Consent Agreement (September 1991) that the Site-
Wide Ecological Risk Assessment will be performed as part of the RI for Operable Unit 5. The Site-
Wide Ecological Risk Assessment in the RI for Operable Unit 5 will quantify and assess the possible
risks from current concentrations of site contaminants to ecological receptors inhabiting on-property
and off-site areas not presently targeted for remediation based on human-health concerns. More
discussion on the Risk Assessment and Ecological Risk issues specific to Operable Unit 4 can be
found in the Operable Unit 4 Proposed Plan.
The ecological receptors potentially exposed to FEMP contaminants include all organisms, exclusive
of humans and domestic animals. The ecological risk assessment focused on a group of indicator
species selected to represent a variety of exposure pathways and trophic positions. Terrestrial
vegetation was represented by a generic plant species. Terrestrial wildlife species to be evaluated
were selected based on species abundance on the FEMP site, trophic level position, and habitat
requirements. The species evaluated were the white-tailed deer (Odocoileus virginianus), white-footed
mouse (Perotnyscus leucopus), raccoon (.Procyon lotor), red fox (Vulpes fidva), muskrat (Ondatra
zibethica), American robin (Turdus migratorius), and red-tailed hawk (Buesto jamaicensis).
The assessment examined risks to terrestrial organisms associated with contaminants in two
environmental media — surface soils, summarized for the entire site, and surface water in Paddys Run
from the northern boundary of the FEMP site to the confluence with the storm sewer outfall ditch.
Risks to aquatic organisms were evaluated for exposure to contaminants in Paddys Run, the Great
Miami River, and in runoff into the storm sewer outfall ditch. All nonradioactive and radioactive
constituents of greatest human health risk were considered to be of concern for the ecological risk
assessment. Estimated ecological risks associated with exposure to FEMP site COCs are primarily
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due to nonradioactive inorganic chemicals in soils, rather than to organic chemicals or radionuclides.
This is true for both terrestrial and aquatic organisms and for plants as well as wildlife. In particular,
estimated intakes of arsenic, cobalt, lead, and silver from FEMP soils were all higher than the
estimated No Observed Effect Levels (NOELs) for at least six of the seven indicator species selected
for this assessment. The relative hazards to individual species varied, but the white-footed mouse
consistently had the highest indices of these chemicals. This can be attributed to the assumed intake
by the mouse of insects (using earthworms as surrogates), which in turn were assumed to assimilate
chemicals from soil with a transfer coefficient of 1.0.
Estimated hazards to terrestrial organisms of exposure to COCs in FEMP surface waters were
relatively low, with His greater than one only for arsenic, lead, molybdenum, and silver. These
chemicals presented hazards of two, five, four and three to species, respectively, and the highest HI
estimated was for lead intake by the mouse.
Estimated doses to terrestrial organisms at the FEMP site, originating from soil uptake by plants and
earthworms, were below levels expected to cause detectable effects. However, as with inorganic
chemicals, this conclusion is sensitive to assumptions about muscle-to-muscle transfer of
radionuclides. If perfect transfer or biomagnification of uranium occurs (i.e., transfer factor equals
1.0), it could expose terrestrial wildlife at the FEMP to potentially harmful radiation levels.
However, if more realistic muscle-to-muscle transfer coefficient were assumed (i.e., 0.1), the
estimated radiation doses would fall below the range likely to result in harmful effects. Radiation
doses due to water intake were insignificant.
Exposure to radiological contaminants does not appear to pose a significant risk to aquatic organisms
at the measured concentrations in the surface waters and sediments impacted by the FEMP site.
However, modeled concentrations of radionuclides in runoff from the FEMP site into surface water
would cause estimated exposures to exceed the upper limit of 1 rad/day. A chronic dose rate of 1
rad/day or 3.65 x 10"1 mrad/year or less to the maximally exposed member of a population of aquatic
organisms would ensure that there were no deleterious effects from radiation on the population. The
most affected organisms would be aquatic plants, receiving a total dose from internal and external
exposure of about 140 rad/day. Hie total dose to fish is minimally over the limit, at 1.6 rad/day, and
the total dose to benthic macroinvertebrates is about 14 rad/day. The maximum concentrations
calculated in the storm sewer outfall ditch were used in source runoff calculations. Doses to aquatic
organisms in the storm sewer outfall ditch may exceed the limit of 1 rad/day. Doses in Paddys Run
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and the Great Miami River would be lower than that indicated in the storm sewer outfall ditch and
would be well below 1 rad/day. The measured concentrations of cadmium in Paddys Run and the
Great Miami River, copper in the Great Miami River, mercury in Paddys Run, the Great Miami
River, and the storm sewer outfall ditch, and silver in Paddys Run water exceeded chronic toxicity
criteria for the protection of freshwater organisms.
Field studies on the impact of the FEMP site on terrestrial and aquatic communities do not indicate
any effects consistent with contaminant impacts except for above-background levels of arsenic and
mercury recorded in RI/FS plant samples. In addition, although potential impacts at the individual
level were predicted for wildlife species, detrimental or adverse impacts have not been observed in
the field. This suggests that the potential exposures predicted by modeling may not occur in the field
or that the resulting potential effects as a result of exposures may not occur. A comparison of the
concentrations of inorganic chemical concentrations in FEMP soils to regional background values
indicate the mean FEMP concentrations may be similar to the upper 95 percent confidence levels of
background values. This indication suggests that ecological risks estimated using background values
of inorganics would be comparable to those estimated for the FEMP site, and emphasizes the
conservative nature of the method used.
In summary, although radionuclides are the most ubiquitous contaminants at the FEMP, estimated
ecological risks to both terrestrial and aquatic organisms are primarily associated with nonradioactive
inorganic chemicals. Although estimated risks are substantial in some instances, they are based on
soil inorganic chemical concentrations comparable to background levels, and deleterious effects have
not been observed in the field. This suggests that current FEMP site-specific ecological risks are low.
However, remedial actions are appropriate to address contaminants which have potential to cause
harm in the future.
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7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES
As previously discussed in Section 5.0, the waste materials within Operable Unit 4 exhibit a wide
range of properties. Most notable would be the elevated direct radiation associated with the moist to
wet Silos 1 and 2 residues versus the much lower direct radiation associated with the dry, powdery
cold metal oxides in Silo 3. Even more significant would be the much lower levels of contamination
associated with the soils and building materials, like concrete, within the Operable Unit 4 Study Area.
To account for these differences and for the varied cleanup alternatives applying to each type of
waste, Operable Unit 4 was segmented into three subunits. These subunits, which are listed below,
were used through the detailed evaluation of alternatives and the identification of the preferred
alternative.
Subunit A: Silos 1 and 2 (K-65 residues and bentonite clay) and the sludge in the decant sump tank
Subunit B: Silo 3 (cold metal oxides)
Subunit C: Silos 1, 2, 3, and 4 structures; contaminated soils within the Operable Unit 4 boundary
including surface and subsurface soils and the earthen berm around Silos 1 and 2; the
decant sump tank; the radon treatment system; the concrete pipe trench and the
miscellaneous concrete structures within Operable Unit 4, any debris (i.e., concrete,
piping, etc.,) generated through implementing cleanup for Subunits A and B, and any
perched groundwater encountered during remedial activities.
With the exception of Alternatives 2A/Vit and 2A/Cem (see Section 11 for details) the remedial
alternatives, which went through detailed analysis during the FS for Operable Unit 4, are summarized
below. The discussions presented here are based on the information used for detailed analysis of
alternatives during the FS. Actual methods used during the implementation of the selected
alternative^) will be determined during detail engineering design described in the remedial design and
may differ from the descriptions provided below.
Section 121 of CERCLA requires that remedial actions be protective of human health and the
environment, and a level or standard of control that is consistent with federal or state environmental
laws or state facility siting regulations, which are termed applicable or relevant and appropriate
requirements (ARARs). ARARs pertain to all aspects of a remedial action, including the
establishment of cleanup levels, the operation and performance of treatment systems, and the design
of disposal facilities.
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The baseline risk assessment performed as part of the RI Report for Operable Unit 4, quantified the
health risks to hypothetical human receptors due to exposure from chemical and radiological sources
in Operable Unit 4 under the no-action alternative. A summary of the risk assessment and results is
presented in Section 6.0. Essentially, the results emphasize the need to effectively complete the
selected remedial actions at Operable Unit 4 in order to ensure overall protection of human health and
the environment.
Potential remedial alternatives were developed and evaluated in the FS Report for Operable Unit 4 as
to how these risks would be eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls. Both long-term and short-term risks associated with implementing
an alternative were considered in determining whether a given alternative was protective. Each
alternative evaluated provides a description of its overall effectiveness in reducing risks to human
health and the environment.
ARARs consist of two sets of requirements, those that are applicable and those that are relevant and
appropriate. Applicable requirements are those substantive standards that specifically address a
situation at a CERCLA site. Relevant and appropriate requirements are standards that address
problems sufficiently similar to the situation at a CERCLA site that their use is well suited to the site.
In certain cases, standards may not exist in the promulgated regulation that address the proposed
action or the constituents of concern. In these cases, non-promulgated advisories, criteria, or
guidance that were developed by the EPA, other federal agencies, or states are to be considered
(TBC) in establishing remedial action objectives that are protective of human health and the
environment.
A detailed discussion of all ARARs and TBC criteria associated with the remedial alternatives being
evaluated for Operable Unit 4 is presented in Appendix F of the FS Report for Operable Unit 4.
From these detailed lists, certain major ARARs and TBCs were selected based on their importance in
protecting human health and the environment. These include those associated with the protection of
drinking water sources, the control of radionuclide emissions, the design and siting of a solid waste
disposal facility, the management of RCRA hazardous waste, and compliance with NEPA.
The major ARARs associated with the remedial alternatives evaluated in this section, with the
exception of the no action alternatives, are presented in Appendix A of this ROD. These major
ARARs are segregated into three types:
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(a) Chemical-specific ARARs are usually health- or risk-derived numerical values or methodologies
that establish an acceptable level or concentration of chemical or radionuclide that may remain
in specific environmental media after remediation is complete. These levels are deemed to be
protective of human health and are used to help establish remedial cleanup goals.
(b) Location-specific ARARs generally restrict certain activities or dictate where certain activities
may be conducted, solely because of geographical, hydrologic, hydrogeologic, or land use
concerns.
(c) Action-specific ARARs are usually technology or activity based requirements or restrictions on
the conduct of certain activities or the operation of certain technologies at the site.
Appendix A identifies all remedial alternatives evaluated along with their major regulatory
requirements, the rationale for designation of each regulatory requirement as an ARAR/TBC, and the
mechanism by which the remedial alternative will comply with the requirement.
7.1 NO-ACTION ALTERNATIVE FOR ALL SUBUNITS
The No-Action Alternative for Subunits A, B, and C is presented to provide a baseline for
comparison with the other alternatives per the President's Council on Environmental Quality and 40
CFR Part 300, the National Oil and Hazardous Substances Pollution Contingency Plan regulations.
Under the No-Action Alternatives, designated as OA, OB, and 0C for each of the three subunits, the
contaminated and/or uncontaminated materials within each subunit would remain unchanged without
any further waste removal, treatment, or containment activities.
Alternatives OA, OB, and 0C do not provide for the monitoring of soil, groundwater, or radon
emissions from the Operable Unit 4 facilities or soils, and do not provide for access controls (e.g.,
physical barriers and deed restrictions) to reduce the potential for exposure to any human or
ecological receptors. The No-Action Alternatives would not decrease the toxicity, mobility, or
volume of contaminants or reduce public health or environmental risks. Also, goals for protecting the
underlying groundwater aquifer would not be met. No costs are associated with the No-Action
Alternative.
ARAR Compliance for No-Action Alternatives
Alternatives OA, OB, and 0C would not comply with a number of chemical-specific, location-specific,
or action-specific ARARs. Under the no-action alternatives, Silos 1, 2, and 3 would eventually fail,
resulting in the release of silo contents to the air, soil, groundwater, and surface water. Fate and
transport modeling indicates that uranium and gross alpha and beta radiation would exceed safe
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drinking water limits under 40 CFR §141. In addition, localized "hot spots" could exceed the limits
established in 40 CFR §192.12.
7.2 SIJBUNIT A - CONTENTS OF SILOS 1 AND 2 AND THE DECANT SUMP TANK
With the exception of Alternatives 2A/Vit and 2A/Cem (see Section 11 for details) this section
presents the alternatives which were evaluated for Subunit A during the detailed analysis of
alternatives phase of the FS for Operable Unit 4. These alternatives focus on the remediation of the
K-65 residues contained in Silos 1 and 2 and the sludges in the decant sump tank.
All of the alternatives would provide overall protection of human health (assuming continued federal
government control) and the environment by eliminating, reducing, or controlling risk through
treatment, engineering controls, or institutional controls. The selected remedy (3A.1/Vit) would
provide greater certainty for overall protection than other alternatives because the Subunit A residues
would be vitrified and removed to the NTS to reduce the potential for contaminant migration to
human and ecological receptors. The source of unacceptable risks to the Operable Unit 4 expanded
trespasser and off-site farmer would be eliminated, and in the event that the government lost control
of the FEMP site, there would be no risk from Subunit A residues to an on-property farmer.
Overall protection at the NTS would be maintained because the vitrified residues resist leaching and
the NTS is located in a climatic, demographic, and hydrogeologic setting which favors minimization
of contaminant migration to both human and environmental receptors.
7.2.1 Alternative 3A.1/Vit - Removal. Vitrification, and Off-Site Disposal - Nevada Test Site
Capital Cost: $38.3 Million (M)
O&M Costs:
During Remediation: $11.7 M
Post-Remediation: $0
Present Worth: $43.7 M
Years to Implement: 6
This alternative involves the removal, vitrification, and off-site disposal of the treated Silos 1 and 2
contents and decant sump tank sludge. Treated material would be transported by rail, then truck, to
the NTS, a DOE-owned facility that currently accepts low-level radioactive material from DOE
facilities for disposal. Under Alternative 3A. l/Vit, approximately 6,796 m3 (8,890 yd3) of untreated
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residues would be removed from Silos 1 and 2 and combined with approximately 3,785 Liters (L)
(1,000 gallons) of sludge from the decant sump tank and treated. Approximately 2,770 m3 (3,623
yd3) of vitrified material would be packaged in containers and transported to the NTS for disposal.
Disposal of contaminated materials from the berms, Silos 1 and 2 structures, the material removal
equipment, and the vitrification system would be managed under the selected alternative for Subunit
C. No five-year CERCLA reviews would be required under this alternative since no Subunit A
residue material would remain at the FEMP. The components of this alternative not previously
described are as follows.
Material Removal
Silos 1 and 2 residues and decant sump tank sludge would be slurried and pumped to the vitrification
plant for processing. During the material removal phase, Silos 1 and 2 and the decant sump tank
would be equipped with an off-gas handling system to treat radon and other potential airborne
contaminants. This off-gas handling system would be operational during material removal and before
personnel enter the area above the silo domes to reposition material removal equipment and conduct
repairs or maintenance. The off-gas handling system and operating procedures would be designed as
necessary to minimize exposure to personnel located over the work areas and to prevent the escape of
radon and radioactive particulates from the silos and the decant sump tank to the atmosphere.
Material Stabilization
Silos 1 and 2 residues and decant sump tank sludge would be combined with glass forming agents,
processed in a high temperature furnace, and converted into a stable vitrified glass form exhibiting
excellent durability and constituent leaching characteristics. It should be noted that current planning
focuses upon pouring the molten glass directly into containers capable of withstanding the high
temperature of the vitrified waste form. The final waste form would continue to be optimized in pilot
plant treatability studies and final decision regarding the final waste form would be reached during the
pilot plant treatability studies. Process tanks/vessels and piping containing slurried K-65 residues
would be designed to minimize potential radon and particulate emissions to the atmosphere during
treatment. The direct radiation associated with the treated residues would remain relatively
unchanged from the untreated form of the K-65 residues.
Interim Storage
The containerized vitrified product will require interim storage at the FEMP prior to its transportation
to the NTS for disposal. The purpose of this interim storage is two-fold; first, the vitrified product
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will require verification sampling in order to certify that each production lot has met specific
performance and waste disposal criteria; and second, to provide the Fernald waste shipping program a
buffer staging area where the material can be safely managed prior to its shipment to NTS in
accordance with DOE ALARA principles, ARARs identified and included in the Operable Unit 4
ROD, as well as in a manner protective of human health and the environment. It has been anticipated
that the interim storage area will be needed to accommodate the interim handling of approximately 90
days of vitrification production.
Disposal of Treated Material
Off-site disposal for this alternative involves the packaging, loading, and shipping of the treated
material, in accordance with all required United States Department of Transportation (DOT)
specification regulations, to the low-level radioactive waste disposal site at the NTS, a DOE-owned
facility that currently accepts low level radioactive material from DOE facilities for disposal.
Shipment of the treated material to the NTS would be performed by rail and/or truck transportation
from the FEMP site. Currently, there are no direct rail lines into the NTS. The treated material
would be transported by rail to either a point near Las Vegas, Nevada, or one of the areas north of
Las Vegas. From either location, the containers carrying the treated material would be transferred to
trucks for transportation over roads to the NTS.
The NTS is located approximately 3,219 kilometers (km) [2,(XX) miles (mi)] from the FEMP site.
Because the vitrified residues resist leaching and the NTS is located in a sparsely populated, arid
region, where depths to groundwater are at least 23S m (771 ft) below the surface, disposal at the
NTS would be very effective at precluding human contact with and contaminant migration from the
treated residues from Subunit A. The FEMP site has an approved NTS waste shipment and
certification program that is periodically audited by the NTS. Efforts have been initiated to amend
the current program to include Operable Unit 4 treated material. All the NTS waste acceptance
requirements would need to be satisfied prior to any shipment of the Operable Unit 4 treated material
to the NTS.
Implementation Time and Costs
Remedial action activities under Alternative 3A.1/Vit could be completed in approximately six years.
Approximately three years is projected for completion of site preparation, facilities construction, and
equipment installation. Material removal and treatment activities would require about three years.
Transportation and off-site disposal would conclude shortly after the completion of material
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processing. Capital costs for Alternative 3A.1/Vit are estimated to be 38.3 million dollars. O&M
costs during remediation are estimated at 11.7 million dollars over three years. Due to the off-site
disposal option, there are no post-remediation O&M costs associated with this alternative. The total
present worth cost for this alternative is estimated at 43.7 million dollars.
7.2.2 Alternative 3A.1/Cem - Removal. Cement Stabilization, and Off-Site Disposal - NTS
Capital Cost: $71.8 M
O&M Costs:
During Remediation: $ 11.7 M
Post-Remediation $0
Present Worth: $73.1 M
Years to Implement: 6
This alternative is identical to Alternative 3A.1/Vit except that the vitrification of the Silos 1 and 2
contents and decant sump tank sludge have been replaced by cement stabilization. Treated material
and debris would be transported by rail, then truck to the NTS. Under Alternative 3A.1/Cem,
approximately 6,796 m3 (8,890 yd3) of untreated materials would be removed from Silos 1 and 2,
combined with approximately 3,785 L (1,000 gallons) of sludge from the decant sump tank, and
treated. Approximately 18,166 m3 (23,760 yd3) of cement stabilized product would be packaged in
containers and transported to NTS for disposal. Disposal of contaminated materials from the berms,
Silos 1 and 2 structures, the material removal equipment, and the cement stabilization system would
be managed under the selected alternative for Subunit C. No five-year CERCLA reviews would be
required since all Subunit A materials would be removed from the site. The components of this
alternative not previously described under alternative 3A.1/Vit are as follows.
Material Stabilization
Silos 1 and 2 residues and the decant sump tank sludge would be combined with cement and other
additives necessary for stabilizing the materials into a cement form. Similar to Alternative 3A.1/Vit,
process tanks/vessels and piping containing slurried K-65 residues would be designed to minimize
potential radon and radionuclide particulate emissions to the atmosphere during treatment. Studies
conducted on a small scale in a laboratory, as part of the Operable Unit 4 RI/FS, indicate that an
estimated ISO percent increase can be expected in the volume of waste requiring disposal following
stabilization. This increase is a result of the large volume of additives needed to effectively stabilize
the silo residues and decant sump tank sludge in cement. These studies have also concluded that the
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cement stabilization of the wastes does not effectively reduce the radon emission rate from the waste
and the tendency of the waste to leach contaminants into groundwater. The direct radiation associated
with the untreated residues would be slightly reduced due to the effects of mixing the additives with
the residues. The solidified materials would be packaged in containers for disposal.
Implementation Time and Costs
Remedial action activities under Alternative 3A.1/Cem could be completed in about six years.
Approximately three years are projected for completion of site preparation, facilities construction, and
equipment installation. Material removal and treatment activities would require about three years.
Transportation and off-site disposal would conclude shortly after the completion of material
processing. Capital costs for Alternative 3A.1/Cem are estimated to be 71.8 million dollars. O&M
costs during remediation are estimated at 11.7 million dollars over three years. Due to the off-site
disposal option, there are no post-remediation O&M costs associated with this alternative. The total
present worth cost of this alternative is estimated at 73.1 million dollars.
7.3 SUBUN1T B - CONTENTS OF SILO 3
This section presents the alternatives which were evaluated for Subunit B during the detailed analysis
of alternatives phase of the Operable Unit 4 FS. These alternatives focus on the remediation of the
cold metal oxides contained in Silo 3.
As discussed in Section 6, this evaluation assumes that the federal government would continue to own
the FEMP site. For a cleanup remedy to be considered protective, it should not result in any
unacceptable risks to an Operable Unit 4 expanded trespasser or an off-site fanner.
All alternatives would provide overall protection of human health and the environment. These
alternatives will eliminate, reduce, or control the health or environmental risks resulting from
constituents in Subunit B materials. All of the action alternatives, except Alternative 4B, would limit
exposure to contaminants by removing the material, treating the material by either vitrification or
cement stabilization, and then disposing the treated material in an on-property above-grade disposal
vault (Alternative 2B) or off site at NTS (Alternative 3B. 1). Alternative 4B*s protection is based on
removal and disposal in an on-property above-grade vault, and by retaining institutional controls.
Long-term effectiveness would be attained for each of these alternatives.
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In summary, the preferred alternative (3B.1/Vit) would provide for overall protection because the
Subunit B residues would be vitrified and removed to the NTS to reduce the potential for contaminant
migration to human and ecological receptors.
7.3.1 Alternative 2B/Vit - Removal. Vitrification, and On-Propertv Disposal
Capital Cost: $25.2 M
O&M Costs:
During Remediation: $4.9 M
This alternative requires the removal, vitrification, and on-property disposal of the Silo 3 contents.
Under Alternative 2B/Vit, approximately 3,890 m3 (5,088 yd3) of untreated materials would be
removed from Silo 3 and stabilized in a vitrified glass form. Following treatment, approximately
1,471 m3 (1,924 yd3) of vitrified material would be packaged in containers and placed in an on-
property above-grade reinforced concrete disposal vault. The Silo 3 structural materials, associated
soils, the material removal system and the vitrification system would be managed under the selected
alternative for Subunit C. In accordance with CERCLA 121(c) requirements, after commencement of
remedial activities, a review would be performed every five years by the EPA to ensure the continued
protection of human health and the environment.
Material Removal
Due to the powder-like characteristics of Silo 3 cold metal oxide residues, Alternative 2B/Vit would
utilize a pneumatic removal process to transport Silo 3 contents to the material processing facility.
The pneumatic removal system consists of a compressed air-driven pump that displaces and removes
the dry wastes. Air entrained in the cold metal oxides, suctioned from Silo 3, would be separated
using filter/receiver systems allowing the cold metal oxides to be pneumatically "pushed" to the
vitrification facility. A glove box system will be used at the interface of the pneumatic removal
system and the silo dome to function as secondary containment. This arrangement, along with,
appropriate operations procedures, would be designed to prevent releases to the atmosphere during
operations.
Present Worth:
Years to Implement:
Post-Remediation:
$3.2 M
$28.0 M
4
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Material Stabilization
The vitrification process is identical to that described in Section 7.2.1 for Alternative 3A.1/Vit.
Bench-scale studies conducted in a laboratory as part of the RI/FS for Operable Unit 4 indicate that
vitrification can effectively reduce the tendency of the Silo 3 residues to leach inorganics and
radionuclides to groundwater. This testing also demonstrated that over a SO percent reduction in the
volume of material requiring disposal could be achieved through the application of vitrification
technology to the Silo 3 residues. The vitrified residues would be packaged in containers for
disposal.
Disposal of Treated Material
Studies completed on a bench-scale as part of the RI/FS project that the volume of material requiring
disposal can be reduced by over 50 percent as a result of applying the vitrification process. The
vitrified material would be containerized and disposed in an above-grade reinforced concrete disposal
vault located on property. The vault would be constructed on a reinforced concrete mat and equipped
with a leachate collection/detection system to facilitate the collection of any contaminated leachate
after final closure. The capping system would be composed of alternating composite soil liners and
drainage layers to minimize the potential release of contaminated leachate to the underlying Great
Miami Aquifer. The proposed disposal facility would be located at a suitable location of the FEMP
site.
Final closure would be completed by the construction of a multimedia cap over the vault. This cap
would include a clay cover to eliminate radon emanation from the disposed materials to the
atmosphere and a barrier to preclude intrusion by burrowing animals and hypothetical future residents
of the area. Upon completion of the multimedia cap, security controls such as fencing would be
installed. Monitoring wells would be appropriately located to evaluate the effectiveness of the above-
grade disposal vault in ensuring long-term protection of human health and the environment.
To provide added assurance against any future activities by humans to intrude into the disposal vault,
permanent markers would be installed to identify the vault, and restrictions would be placed on the
site. Additionally, in order to ensure long-term protectiveness for this alternative, it is assumed that
the effected disposal areas at the FEMP would require the continued ownership by the federal
government. While the disposal vault would be designed to not require any continued active
operations or maintenance, long-term ownership would permit the government to continue to exercise
the right to preclude any development or drilling in areas where contaminated materials are disposed.
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All facilities and equipment installed and used by this alternative would be disassembled and
decontaminated during the post-remediation phase. Contaminated materials would be disposed in
accordance with the selected remedy for Subunit C.
Implementation Time and Costs
Remedial action activities under Alternative 2B/Vit could be completed in about four years. Site
preparation and construction activities would take approximately three years. Removal and material
processing activities would require about one year. Capital costs for Alternative 2B/Vit are estimated
to be 25.2 million dollars. O&M costs during remediation are estimated at 4.9 million dollars over
one year, while post-remediation O&M costs are estimated at 3.2 million dollars over a thirty year
period. The total present worth cost for this alternative is estimated at 28.0 million dollars.
7.3.2 Alternative 2B/Cem - Removal. Cement Stabilization, and Qn-Propertv Disposal
Capital Cost: $35.9 M
O&M Costs:
During Remediation: $4.9 M
This alternative uses the material removal methodology presented in Alternative 2B/Vit, followed by
treatment of the Silo 3 contents by cement stabilization and on-property disposal of the stabilized
material. Under Alternative 2B/Cem, approximately 3,890 m3 (5,088 yd3) of untreated materials
would be removed from Silo 3 and stabilized in a cement form. Approximately 5,999 m3 (7,846 yd3)
of stabilized material would be packaged in containers and placed in an on-property above-grade
reinforced concrete disposal vault. The Silo 3 structural materials, the material removal system, and
the cement stabilization system and associated soils would be remediated with the selected alternative
for Subunit C. In accordance with CERCLA 121(c) requirements, after commencement of remedial
activities, a review would be performed every five years by the EPA to ensure the continued
protection of human health and the environment. The components of this alternative not previously
discussed are as follows.
Present Worth:
Years to Implement:
Post-Remediation:
$3.2 M
$37.4 M
4
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Material Stabilization
The cement stabilization process is identical to that described in Section 7.2.2 for Alternative
3A.1/Cem with the exception of differences in the cement formulations required to accommodate
physical and chemical differences between K-65 residues and Silo 3 cold metal oxides. The FS
Report for Operable Unit 4, Appendix C, discusses the results of bench-scale treatability studies
which indicate that cementation of the Silo 3 metal oxides would result in an approximately 50
percent increase in the volume of treated material requiring disposal.
Implementation Time and Costs
Remedial action activities under Alternative 2B/Cem could be completed in about four years. Site
preparation and construction activities would take approximately three years. Removal and material
processing activities would require about one year. Capital costs for Alternative 2B/Cem are
estimated to be 35.9 million dollars. O&M costs during remediation are estimated at 4.9 million
dollars over one year, while post-remediation O&M costs are estimated at 3.2 million dollars over a
thirty year period. The total present worth cost for this alternative is estimated at 37.4 million
dollars.
7.3.3 Alternative 3B.1/Vit - Removal
Capital Cost:
O&M Costs:
During Remediation:
Post-Remediation:
Present Worth:
Years to Implement:
and Off-Site Disposal - NTS
Vitrification.
$26.8 M
$4.9 M
$0
$28 M
4
This alternative involves the removal, stabilization, and off-site disposal of the Silo 3 contents. This
alternative is identical to Alternative 2B/Vit, except the on-property disposal, monitoring, and
institutional controls have been replaced by the transportation of the treated material by rail and/or
truck to the NTS for disposal. Under Alternative 3B. 1/Vit, approximately 3,890 m3 (5,088 yd3) of
untreated materials would be removed from the silo. Approximately 1,471 m3 (1,923 yd3) of vitrified
material would be packaged in containers and transported to NTS for disposal. Alternative 3B. 1/Vit
would have to meet applicable off-site requirements, which include the NTS material acceptance
criteria and DOT regulations pertaining to the transport of hazardous and radioactive materials. No
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five-year reviews would be required since all Subunit B wastes would be removed from the site under
this alternative.
Implementation Time and Costs
Remedial action activities under Alternative 3B.1/Vit could to be completed in about four years. Site
preparation and construction activities would take approximately three years. Removal activities
would require about one year. Transportation and off-site disposal would conclude shortly after the
completion of material processing. Capital costs for Alternative 3B.1/Vit are estimated to be 26.8
million dollars. O&M costs during remediation are estimated at 4.9 million dollars over one year.
Due to the off-site disposal option, there are no post-remediation O&M costs associated with this
alternative. The total present worth cost of this alternative is estimated at 28 million dollars.
7.3.4 Alternative 3B.1/Cem - Removal. Cement Stabilization, and Off-Site Disposal - NTS
Capital Cost: $36.8 M
O&M Costs:
During Remediation: $4.1 M
Post-Remediation: $0
Present Worth: $36 M
Years to Implement: 4
This alternative is identical to Alternative 3B.1/Vit (Section 7.3.3), except that Silo 3 contents would
be stabilized in cement prior to off-site disposal at NTS as described for Alternative 2B/Cem (Section
7.3.2). Under Alternative 3B.1/Cem, approximately 3,890 m3 (5,088 yd3) of contaminated materials
would be removed from Silo 3. Approximately 5,999 m3 (7,846 yd3) of stabilized material would be
transported to NTS for disposal. No five-year reviews would be required since all Subunit B wastes
would be removed from the site under this alternative.
Implementation Time and Costs
Remedial action activities under Alternative 3B.1/Cem could be completed in about four years. Site
preparation and construction activities would take approximately three years. Removal activities
would require about one year. Transportation and off-site disposal would conclude shortly after the
completion of material processing. Capital costs for Alternative 3B.1/Cem are estimated to be 36.8
million dollars. O&M costs during remediation are estimated at 4.1 million dollars over one year.
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Due to the off-site disposal option, there are no post-remediation O&M costs
alternative. The total present worth cost of this alternative is estimated at 36
7.3.5 Alternative 4B - Removal and On-Pronertv Disposal
Capital Cost: $21.8 M
O&M Costs:
During Remediation: $1.1 M
Post-Remediation: $3.2 M
Present Worth: $22.0 M
Years to Implement: 2
This alternative requires removal of the Silo 3 contents, packaging, and on-property disposal of the
untreated material. This alternative is identical to Alternative 2B, with the exception that it does not
include treatment. Under Alternative 4B, approximately 3,890 m3 (5,088 yd3) of contaminated
materials would be removed from Silo 3 and packaged in containers for disposal in an on-property
above-grade reinforced concrete disposal vault. The Silo 3 structural materials, associated soils, and
removal system would be managed under the Subunit C alternative. In accordance with CERCLA
121(c) requirements, after commencement of remedial activities, a review would be performed every
five years by the EPA to ensure the continued protection of human health and the environment.
Implementation Time and Costs
Remedial action activities under Alternative 4B could be completed in about two years. Site
preparation and construction activities would take approximately one year. Removal and packaging
activities would require about one year. Capital costs for Alternative 4B are estimated to be 21.8
million dollars. O&M costs during remediation are estimated at 1.1 million dollars over one year.
Post-remediation O&M costs are estimated to be 3.2 million dollars. The total present worth cost of
this alternative is estimated at 22 million dollars.
7.4 SUBUNIT C - SILOS 1. 2. 3. AND 4 STRUCTURES. SOILS. AND DEBRIS
This section presents the alternatives which were evaluated for Subunit C during the detailed analysis
of alternatives phase of the FS for Operable Unit 4. These alternatives focus on the remediation of
Silos 1, 2, 3, and 4 structures, contaminated soils within the Operable Unit 4 boundary including
surface and subsurface soils and the earthen berms around Silos 1 and 2, the existing Radon
Treatment System (RTS), the K-65 Drum Handling Building pad, standing water within Silo 4 (if
FEMP-OU4ROD-8 FINAL
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associated with this
million dollars.
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any), the decant sump tank, the process piping and trenches, and any rubble or debris [i.e.,
decontamination and decommissioning (D&D) of the treatment facility] generated consequential to the
implementation of remedial actions for all Operable Unit 4 subunits. The volumes of soil, rubble,
and debris to be generated under Subunit C are small in comparison to the volume of similar
materials that will be generated by other FEMP operable units. All the Subunit C alternatives
evaluated through detailed analysis consider integration of disposal activities with Operable Unit 3 and
Operable Unit 5. These integration efforts allow waste minimization initiatives developed for
Operable Units 3 and 5 to be integrated into the final remedy chosen for Subunit C materials.
As discussed in Section 6, evaluations were conducted for future land uses with and without continued
federal ownership. For a cleanup remedy to be considered protective, it would not result in any
unacceptable risks to an Operable Unit 4 expanded trespasser or an off-site farmer under the future
land use with continued federal ownership scenario.
All of the evaluated alternatives would limit exposure to constituents by decontaminating,
demolishing, and removing the material to either an on-property above-grade disposal facility or off-
site disposal facility, and then excavating contaminated soils and placing clean fill over residual
contaminated subsurface soils. The placement of the clean fill was not used as a measure to limit
exposures but rather to restore the natural drainage patters and promote revegetation. Table 9-2
summarizes the proposed remedial levels for soils, all of which would be protective to the Operable
Unit 4 expanded trespasser, trespassing child and off-site resident over the long-term. Short-term
risks would be higher for off-site disposal due to the increased risk of transportation accidents. These
action alternatives would be protective of all anticipated receptors assuming continued federal
government ownership and control of the area; this includes the off-site farmer and the Operable
Unit 4 expanded trespasser receptors.
The basic difference among the action alternatives is the disposal option. On-property disposal
(Alternative 2C) would be in an above-grade disposal facility. Off-site disposal options include NTS
(Alternative 3C.1) and a permitted commercial disposal site (Alternative 3C.2).
The on-property, above-grade disposal facility would be designed for a 1,000 year life with no active
maintenance. Fate and transport modeling using conservative assumptions concludes that
protectiveness would be maintained over the long-term.
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NTS and the permitted commercial disposal facility would incorporate engineering controls to ensure
protectiveness. Both are located in a climatic, demographic, and hydrogeologic setting which favors
minimization of constituent migration to human or environmental receptors. Short-term risks to the
public and workers are slightly greater for the off-site disposal options due to the increased risks of
transportation accidents resulting in injuries or radiation exposure.
For all of the Subunit C alternatives, hazardous substances (i.e., contaminated soil or debris) will
remain on site at levels which preclude unlimited use or unrestricted exposure. Therefore, in
accordance with the requirements of CERCLA 121(c), all the Subunit C alternatives would require
that a review be conducted every five years, after commencement of remediation to ensure that the
alternative continues to provide adequate protection of human health and the environment.
7.4.1 Alternative 2C - Demolition
Capital Cost:
O&M Costs:
During Remediation:
Post-Remediation:
Present Worth:
Years to Implement:
Removal, and On-Propertv Disposal
$36.3
$0
$3.6 M
$34.3 M
2
Alternative 2C involves the demolition of the Silos 1, 2, 3, and 4 structures and disposal of the
materials from the removal of the earthen berm, decant sump tank, process piping, and trenches.
Alternative 2C further addresses the excavation of contaminated subsurface soils within the operable
unit boundary and disposal of the debris generated as a result of implementing remedial actions for
Subunits A and B. Contaminated material would be placed in an above-grade disposal vault at the
FEMP site. Under Alternative 2C, approximately 34,956 m3 (45,748 yd3) of material would be
placed in an on-property above-grade disposal vault.
Demolition and Decontamination of the Silo Structures
Before Silos 1, 2, 3, and 4 are demolished, loose interior materials and concrete would be removed
from the silo surfaces. Concrete exhibiting highly elevated direct radiation levels would be
segregated from other Subunit C waste and dispositioned as part of the selected remedy for
Subunit A. Silo demolition would consist of the systematic decontamination, removal, dismantling,
and disposal of the Silos 1, 2, 3, and 4 domes, walls, floor slabs and footers. Removal would
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involve cutting each of the silo structures into manageable pieces after appropriate bracing has been
installed. The demolition would begin with the dismantling of Silo 4, since this silo has never been
used, making it an ideal full-scale model to test and confirm demolition methodologies with minimal
risk of radiological release to the environment. Based on experience obtained through the dismantling
of Silo 4, demolition of Silos 1, 2, and 3 would proceed according to the sequencing and procedures
established during the remedial design and remedial action phases.
Demolition and Decontamination of Other Operable Unit 4 Structures
The existing RTS, Drum Handling Building pad, sump lift station foundation, concrete pipe trench,
and the decant sump tank would also be removed and decontaminated. It is estimated that
approximately 790 m (2,600 ft) of process piping in the process piping trenches would be cut into
manageable sections and disposed. It is estimated that 280 m3 (36S yd3) of concrete from the trench,
decant sump tank process piping, and existing RTS would be disposed. Additionally, all facilities
constructed and equipment installed and used to implement the selected alternatives for Subunits A
and B would be disassembled, decontaminated (if necessary), and either recycled, reused, or
disposed.
Non-porous materials, such as steel fencing and structural steel, attaining the unrestricted use, free
release criteria defined in DOE Order 5400.5 would be released from the site as uncontaminated.
Materials not attaining these levels would be retained for disposal as contaminated waste consistent
with the approved Operable Unit 3 Record of Decision.
Remediation of Soil
After the silos are demolished, the contaminated surface soils within the boundary of Operable Unit 4
would be excavated to attain proposed remediation levels for each of the constituents of concern.
After the silos are demolished, the contaminated surface soils within the boundary of Operable Unit 4
would be excavated to attain proposed remediation levels, as described in Section 9.2.2 of this ROD,
for each of the contaminants of concern. Attainment of these levels would be demonstrated applying
regulatory guidance available at the time. The cleanup levels are considered protective of the
hypothetical expanded trespasser receptor. To attain these goals, a minimum of 15 centimeters.(cm) [6
inches (in)] of soils across the entire operable unit area would be excavated. Additional soils beneath
the silos, decant sump tank, concrete pipe trench, or other locations below this depth would be
removed as necessary to attain these cleanup goals.
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Soils exhibiting highly elevated direct radiation levels (i.e., potentially contaminated soils beneath
Silos 1 and 2) would be segregated from other Subunit C wastes and dispositioned as part of the
selected remedy for Subunit A. Following excavation, the affected areas would be returned to
original grade with the placement of clean backfill and seeded. The area would then be fenced and
appropriate signs placed indicating no trespassing and no hunting. Continued federal ownership with
appropriate deed restrictions would be implemented to ensure that any future transfer of property
would be consistent with CERCLA 120(h).
Water Treatment
Wastewater generated as a result of this remedial action, along with water removed from the decant
sump tank, Silo 4 (if any), and any perched groundwater encountered during remedial activities would
be collected, pretreated if necessary, and sent to the FEMP Advanced Wastewater Treatment facility
for treatment prior to discharge to the Great Miami River. In accordance with the Amended Consent
Agreement, groundwater remediation will be handled by Operable Unit 5. Operable Unit 4 would
only handle the cleanup of perched water encountered during remedial action activities.
Disposal of Soil. Debris, and Rubble
The volume of contaminated soil, rubble, and debris to be addressed under Operable Unit 4
represents a small fraction (less than one percent) of the total volume of similar wastes to be
addressed under Operable Units 5 and 3. Operable Unit 3 is currendy in the process of conducting a
RI/FS which will include gaining additional insight into the effectiveness of various decontamination
technologies on building materials. Additionally, the Operable Unit 3 RI/FS is evaluating the
appropriate type and location of disposal for contaminated rubble and debris. The decision on the
Operable Unit 3 RI/FS is presently scheduled at a time which coincides with the implementation of
remedial actions for Operable Unit 4.
Contaminated soil and debris generated from the selected remedy for Operable Unit 4 will be placed
into interim storage, if necessary, and final disposition of that material will be determined as part of
the Record of Decision for Operable Units 5 and 3. Placing the Operable Unit 4 on-property disposal
decision in abeyance permits an integrated site-wide (FEMP) disposal approach for soil and debris.
In addition, Operable Unit 4 would be able to take advantage of any applicable waste minimization
initiatives developed for soil and debris by Operable Units 5 and 3 respectively.
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Implementation Time and Costs
Approximately three months would be required for site preparation; IS months would be required to
demolish and decontaminate the silo structures as well as the surface soil, berm soils, subsurface
soils, process piping, and decant sump tank. Demobilization activities would extend the duration of
the alternative to two years. During this time frame, the above-grade disposal facility would also be
constructed and capped. Capital costs for Alternative 2C are estimated to be 36.3 million dollars.
Post-remediation O&M costs are estimated to be 3.6 million dollars. The total present worth cost of
this alternative is estimated at 34.3 million dollars.
7.4.2 Alternative 3C.1 - Demolition. Removal, and Off-Site Disposal - NTS
Capital Cost: $83.6 M
O&M Costs: $0
Present Worth: $75.5 M
Years to Implement: 2
This alternative is identical to Alternative 2C, except that the on-property disposal, monitoring, and
institutional controls have been replaced by packaging and off-site transportation of the material by
rail or truck to the NTS for disposal. The off-site disposal option for Alternative 3C. 1 involves the
packaging, loading, and shipping of the material generated by this alternative to the NTS.
Implementation Time and Costs
Remedial actions for Alternative 3C.1 could require about two years to complete, including the
transportation of the packaged materials to the NTS. Capital costs for Alternative 3C.1 are estimated
to be 83.6 million dollars. Due to the off-site disposal aspect of this alternative, there are no O&M
costs anticipated. The total present worth cost of this alternative is estimated at 75.5 million dollars.
7.4.3 Alternative 3C.2 - Demolition. Removal, and Off-Site Disposal (Permitted Commercial
Disposal Site')
Capital Cost: $48.6 M
O&M Costs: $0
Present Worth: $44.0 M
Years to Implement: 2
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This alternative is identical to Alternative 3C.1, except that the off-site disposal at the NTS has been
replaced by the off-site disposal at a permitted commercial disposal site and the waste will not be
packaged, but rather it would be shipped in bulk. One such site is located near Clive, Utah,
approximately 3,058 km (1,900 mi) from the FEMP site. The facility has been permitted by the State
of Utah to accept mixed hazardous waste and naturally occurring by-product materials such as those
in Subunit C.
Disposal
Due to its relatively long distance from the FEMP site, coordination with several states for
transportation of Subunit C wastes would be required. Additionally, an exemption from DOE Order
5280.2A prohibiting disposal of DOE wastes at a commercial facility would be needed for the
Operable Unit 4 waste before it could be transported to the disposal site.
Implementation Time and Costs
Remedial actions for Alternative 3C.2 would require about two years to complete, including the
transportation of the materials to a permitted commercial disposal site. Capital costs are estimated to
be 48.6 million dollars. Due to the off-site disposal option, no operation and maintenance (O&M)
costs are anticipated for Alternative 3C.2. The total present worth cost of this alternative is estimated
at 44.0 million dollars.
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8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
8.1 EVALUATION CRITERIA
Specific legal requirements for remedial actions are specified under CERCLA Section 121. These
requirements include protection of human health and the environment, compliance with ARARs
(unless a waiver is obtained), a preference for permanent solutions which use treatment as a principal
element (to the maximum extent possible), and cost-effectiveness. To determine whether alternatives
meet the requirements, EPA has identified nine criteria in the National Oil and Hazardous Substances
Pollution Contingency Plan that must be evaluated for each alternative selected for detailed analysis.
These criteria are as follows:
1.
2.
3.
4.
5.
6.
7.
8.
8-1
Overall protection of human health and the environment: Examines whether a remedy
would provide adequate overall protection to human health and the environment in the
short- and long-term . Evaluates how risks would be eliminated, reduced, or controlled
through treatment, engineering controls, or institutional controls included in the alternative.
Compliance with ARARs: Addresses whether the alternative attains compliance with
federal and state environmental laws and requirements, unless a waiver of an ARAR
applies.
Long-term effectiveness and permanence: Evaluates the permanence of the remedy,
long term effectiveness and likelihood that the remedy will be successful.
Reduction of toxicity, mobility, or volume through treatment: Reviews the anticipated
treatment technologies to reduce the hazards of, prevent the movement of, or reduce the
quantity of waste materials.
Short-term effectiveness: Evaluates the ability of a remedy to achieve protection of
workers, the public, and the environment during construction and implementation of the
remedial action.
Implementability: Examines the practicality of carrying out a remedy, including the
availability of materials and services needed during implementation of the remedial action.
Cost: Reviews both estimated capital and operation and maintenance costs of the remedy.
Costs are presented as present worth costs. "Present worth" is defined as the amount of
money that, if invested in the first year of implementing a remedy and paid out as needed,
would be sufficient to cover all costs associated with the remedy over its planned life.
Present worth costs allow remedies that would occur over different time periods to be
compared on an even basis.
State Acceptance: Evaluates the technical and administrative issues and concerns that the
State of Ohio may have regarding each of the alternatives; and the State comments on
ARARs or proposed use of waivers.
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9. Community Acceptance: Evaluates the issues and concerns the public may have
regarding each of the alternatives, including which parts of the alternatives are supported
or opposed.
The first two criteria are considered threshold criteria and must be met by the final remedial action
alternatives for Operable Unit 4 (unless a specific ARAR is waived). The next five criteria are
considered primary balancing criteria and are considered together to identify significant tradeoffs that
must be addressed. The last two are considered modifying criteria which are considered in final
remedy selection. The alternatives comparison for each subunit is summarized in Table 8-1.
8.2 COMPARATIVE ANALYSIS OF ALTERNATIVES
The following sections summarize the information presented in Section 5.0 of the FS Report for
Operable Unit 4 and rely upon the detailed analysis of alternatives presented in Section 4.0 of the
same report.
8.2.1 Analysis for Subunit A
8.2.1.1 Threshold Criteria
The analysis of the Subunit A alternatives against the threshold criteria of overall protection of human
health and the environment and compliance with ARARs is summarized below.
Overall Protection of Human Health and the Environment. As part of the FS, two potential future
land uses of the FEMP were evaluated to assess the ability of the individual alternative to adequately
protect human health and the environment. These land uses consider potential exposures to
contaminants released during or following the implementation of the alternatives and were evaluated
for a range of viable receptors. These scenarios included future land use with and without the
assumption of continued federal ownership. With continued government ownership, the FEMP land
would not be available for residential or farming use. Access to the site would be limited by fencing
and physical markers, it would be reasonable to assume that an Operable Unit 4 expanded trespasser
would visit the site occasionally.
It is also assumed that the land surrounding the FEMP site would continue to be used for family
farms. For a cleanup remedy to be considered protective, it should not result in any unacceptable
risks to an expanded trespasser or an off-site farmer. The evaluation also considers the future
possibility that the federal government might not have control of the FEMP site. In that case, a farm
8-2
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TABLE 8-1
COMPARISON OF REMEDIAL ALTERNATIVES
SUBUN1T A - SILOS 1 AND 2 CONTENTS
Alternative
Overall
Protection of
Human Health
and Environment
Compliance with
ARARs
Long-Term
Effectiveness and
Permanence
Reduction of
Toxicity, Mobility
or Volume
through treatment
Short-Term
Effectiveness
ImplemenUhility
Total
Present
Worth
Cost
OA - No Action
Not protective
Does not comply
with all ARARs
Not effective or
permanent
No treatment;
therefore, no
retfeiction
High
Easy
-0-
3A.I/VU - Removal, Vitrification,
Off-Site Disposal - Nevada Test
Site
Protective
Complies with
all ARARs
Effective and
most reliable
Reduces toxicity,
mobility, and
volume
Medium
Innovative
technology,
Difficult
S43.7M
3A.1/Cem - Removal, Cement
Stabilization, Off-Site Disposal -
Nevada Test Site
Protective
Complies with
all ARARs
Effective and most
reliable
Reduces mobility
Medium
Reliable
technology,
Difficult
$73. IM
1 Assessment of protectiveness adopts the use of continued federal goverment ownership and evaluates risk to expanded trespassers and the off-property farmer.
1 Assumes substantive technical requirements for Ohio disposal facility siting are met.
Bold - Preferred Remedial Action Alternative.
Shaded areas — Did not meet threshold criteria (Overall Protection or Compliance with ARARs), therefore, not compared.
Protective - Risk is within the one in ten thousand to one in a million (10* to 10*) EPA target risk range.
-------
TABLE 8-1
(Continued)
SUBUNIT B - SILO 3 CONTENTS
Alternative
Overall
Protection of
Human Health
and
Environment
Compliance with
ARARs
Long-Term
Effectiveness and
Permanence
Reduction of
Toxicity,
Mobility or
Volume
through
treatment
Short-Term
Effectiveness
Implementability
Total
Present
Worth
Cost
OB - No-Action
Not protective
Does not comply
with all ARARs
Not effective or
permanent
No treatment;
therefore, no
reduction
High
Easy
-0-
2B/Vit - Removal, Vitrification,
On-Propetty Disposal
Protective1
Complies with all
ARARs2
Effective and
reliable
Reduces
mobility and
volume
Medium
Innovative
technology,
Moderately
Difficult
S28M
2B/Cem - Removal, Cement
Stabilization, On-Propetty
Disposal
Protective1
Complies with all
ARARs1
Effective and
reliable
Reduces
mobility
Medium
Reliable
technology,
Easy
$37.4M
3B.I/Vit - Removal,
Vitrification, Off-Site Disposal -
NTS
Protective
Complies with all
ARARs
Effective and most
reliable
Reduces
mobility and
volume
Medium
Innovative
technology,
Difficult
$28M
3B.1/Cem - Removal, Cement
Stabilization, OfT-Site Disposal -
NTS
Protective
Complies with all
ARARs
Effective and most
reliable
Reduces
mobility
Medium
Reliable
technology,
Difficult
$36M
4B - Removal and On-Propetty
Disposal
Protective1
Complies with all
ARARs2
Effective and
reliable
No treatment;
therefore, no
reduction
High
Reliable
technology,
Easy
$22 M
' - Assessment of proteciiveocss adopts the use of continued federal goverment ownership and evaluates risk to expanded trespassers and the off-property farmer.
1 -¦ Assumes substantive technical requirements for Ohio disposal facility siting are met.
Bold -• Preferred Remedial Action Alternative
Shaded areas — Did not meet threshold criteria (Overall Protection or Compliance with ARARs), therefore, not compared.
Protective -- Risk is within the one in ten thousand to one in a million USEPA target risk range
-------
TABLE 8-1
(Continued)
SUBUNIT C - SILOS 1, 2, 3, AND 4 STRUCTURES, SOILS, AND DEBRIS
OO
I
ISI
Alternative
Overall
Protection of
Human Health
and
Environment
Compliance
Long-Term
Effectiveness and
Permanence
Reduction of
Toxicity, Mobility
or Volume
through treatment
Short-Term
Effectiveness
Implementability
Total
Present
Worth
Cost
OC - No-Action
Not protective
Does not comply with all
ARARs
Not effective or
permanent
No treatment;
therefore, no
reduction
High
Easy
-0-
2C - Demolition, Removal,
On-Property Disposal
Protective1
Complies with all
ARARs1
Effective and
reliable
No treatment;
therefore, no
reduction
Medium
Reliable
technology,
Easy
$J4.3M
3C.1 - Demolition, Removal,
Off-Site Disposal - Nevada
Test Site
Protective
Complies with all
ARARs
Effective and most
reliable
No treatment;
therefore, no
reduction
Medium
Reliable
technology,
Moderately
difficult
$75.5M
3C.2 - Demolition, Removal,
Off-Site Disposal - Permitted
Commercial Facility
Protective
Complies with all
ARARs
Effective and most
reliable
No treatment;
therefore, no
reduction
Medium
Reliable
technology,
Moderately
difficult
$44 M
ra
2
-- Assessment of protectiveness adopts the use of continued federal govcrmenl ownership and evaluates risk to expanded trespassers and the off-property fanner. "p
1 -- Assumes substantive technical requirements for Ohio disposal facility siting are met. O
Bold -- Preferred Remedial Action Alternative J
Shaded areas — Did not meet threshold criteria (Overall Protection or Covopliance with ARARs), therefore, not compared. ^ ^
Protective -• Risk is within the one in ten thousand to one in a million USEPA target risk range a £3
I"
3 3
S>
t £
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FEMP-OU4ROD-8 FINAL
December 1994
might be established on the FEMP property. The remedial alternatives were evaluated as to what risks
might exist for a hypothetical on-property farmer if government control is no longer present. The
basis for and detailed results of these evaluations are in Appendix D of the FS Report for Operable
Unit 4.
All of the alternatives would provide protection of human health and the environment by eliminating,
reducing, or controlling risk through treatment, engineering controls, or institutional controls. The
preferred alternative (3A.1/Vit) would provide for overall protection, because the Subunit A residues
would be treated and removed to the NTS. The source of risks to the Operable Unit 4 expanded
trespasser and off-site farmer would be eliminated, and in the event that the government lost control
of the FEMP site, there would be no risk from Subunit A residues to an on-property farmer. Overall
protection at the NTS would be maintained because the vitrified residues resist leaching and the NTS
is located in a sparsely populated, arid region, where depths to groundwater are at least 235 m
(771 ft) below the surface.
Compliance with ARARs. CERCLA requires that remedial actions achieve a standard or level of
control that is consistent with federal and state environmental laws or state siting regulations, which
are termed applicable or relevant and appropriate requirements (ARARs). ARARs apply to all aspects
of remedial action, including the establishment of cleanup levels, the operation and performance of
treatment systems, and the design of disposal facilities. In addition to meeting ARARs, operations at
DOE-owned facilities must be conducted according to DOE Orders. Although DOE Orders are not
promulgated standards, the technical requirements may be adapted if they cover areas not addressed
by other laws, or if they improve protection of human health and the environment because they are
more stringent than existing laws. Detailed discussion of compliance with ARARs is provided in
Appendix F of the FS Report for Operable Unit 4.
With the exception of Alternatives 2A/Vit, 2A/Cem (see Section 11 for details) and the no action
alternative, all of the Subunit A alternatives would meet ARARs. Since the preferred alternative,
Alternative 3A. Wit, includes off-site disposal at NTS, there would be no long-term compliance
issues associated with the FEMP site. For example, off-site disposal would eliminate the need to
demonstrate that drinking water MCLs are attained for Subunit A residues. In the short-term, the on-
property remediation activities during removal and treatment would address the operational
requirements for airborne emissions, soil pathways, and penetrating radiation by engineered controls.
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FEMP-OU4ROD-8 FINAL
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For Alternative 3A.1/Vit, the packaging and transportation of the treated waste would comply with
the requirements for the protection of worker and public safety from the radiological hazards (49 CFR
§171-177). This alternative would also comply with other off-site requirements, such as the waste
acceptance criteria specified by NTS, to meet their disposal requirements. The probability of an
inadvertent intruder coming in contact with the Subunit A residues at NTS is less than that for the
FEMP site, based on the demographic characteristics of both locations.
8.2.1.2 Primary Balancing Criteria
Those alternatives which satisfy the threshold criteria comparative analysis were carried forward to
the primary balancing criteria for further comparative analysis. Because Alternative OA (No Action)
did not satisfy either of the threshold criteria, and Alternatives 2A/Vit and 2A/Cem (see Section 11
for details) do not satisfy compliance with specific ARARs, these alternatives were not considered
further in this analysis.
Long-Term Effectiveness and Permanence. Alternatives 3A.1/Vit and 3A.1/Cem would ensure long-
term protectiveness to human health and the environment because residual risks to viable receptors
(off-site fanner and expanded trespasser) would be less than a 1CT6 incremental lifetime cancer risk,
and no non-carcinogenic effects (hazard index less than 0.2) would be indicated for either receptor.
All alternatives involve the removal and treatment of Subunit A residues by either vitrification or
cement stabilization. The preferred alternative would be most effective based on the results of bench-
scale treatability studies conducted during the RJ/FS (Feasibility Study Report for Operable Unit 4,
Appendix C) on the Subunit A materials which demonstrated that vitrification would be effective in
reducing radon emanation and in minimizing the leaching of constituents. Tests using cement
stabilization demonstrated that this process would be effective in preventing the movement of
constituents from the stabilized form; however, there was little or no reduction in radon emanation
rates. The vitrified material is expected to have greater durability over the long term.
The characteristics (i.e., demographics, climate, geology, groundwater level) of the NTS would
provide for greater certainty than FEMP on-property disposal over the long term, that the treated
residues would not affect human health and the environment.
Reduction of Toxicity. Mobility, or Volume through Treatment. Alternative 3A. 1 /Vit would use the
vitrification process to treat the Subunit A material. This technology would physically bind the
8-7
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December 1994
contaminants in a glass-like matrix which would significantly reduce contaminant mobility and
material volume. Mobility would be reduced because the contaminants would be bound in the matrix
and the volume of the treated material would be less than SO percent of the untreated material
volume. Vitrification would also destroy organic contaminants in the treated material. Although
most contaminants in the treated material would be incorporated into the vitrified product to reduce
mobility over the long term, some contaminants would be released during the vitrification process and
must be treated through an off-gas treatment system. The material generated through the off-gas
treatment system may require stabilization to limit subsequent contaminant mobility.
Alternative 3A.1/Cem would use the cement stabilization process to treat contaminated material. This
technology will physically and chemically bind the constituents in a cement-like matrix, so the
mobility of constituents via leaching from this treated material would be greatly reduced. However,
organic constituents would not be destroyed. The total volume of material would increase by
approximately ISO percent as a result of adding the cement stabilizing and setting agents.
Alternative 3A. 1 /Vit is favored over Alternative 3A. 1/Cem because they would: reduce the toxicity
of organic contaminants; more effectively reduce the radon emanation from the treated material;
generate a treated form which has very good resistance to leaching; and significantly reduce the
volume of Subunit A materials.
Short-Term Effectiveness. Alternatives 3A. 1/Vit and 3A. 1/Cem, the various removal, treatment, and
disposal activities will result in increased short-term risks for exposures (compared to no action). The
short-term effectiveness of the material removal operations is expected to be the same among all
alternatives for Subunit A. There is some uncertainty associated with controlling and treating the off-
gases generated by the vitrification process. The on-property risks for 3A. 1/Cem from transportation
would be higher than 3A.1/Vit, because the increased volume of the treated material would increase
the number of potential transportation accidents. Short-term impacts at the NTS associated with the
transportation and off-loading of the treated residues would be indistinguishable from normal
operations.
In summary, Alternative 3A. 1/Cem is favored over Alternative 3A.1/Vit because of the uncertainty
associated with off-gas control and treatment for the vitrification process.
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Implementabilitv. The removal and treatment activities in Alternative 3A.1/Cem could be
implemented using standard equipment, procedures, and readily available resources. Hydraulic
removal is a standard mining technology that is normally reliable and uses readily available
equipment. The cement stabilization technology has been applied successfully at a number of
remedial sites. EPA considers cement stabilization a demonstrated treatment technology and has
approved its use in the final remedy for many NPL sites. This technology has also been applied at
other sites that have radioactively contaminated waste. The cement stabilization process would
require large quantities of cement, flyash, and blast furnace slag, which are available.
Although removal and disposal are the same for Alternative 3A.1/Vit as for Alternative 3A.1/Cem,
the vitrification process is more difficult to implement than the cement stabilization process. The
vitrification process would require fewer chemical reagents than the cement stabilization process, but
larger amounts of energy (electricity). Vitrification would allow the re-processing of off-specification
treated materials compared to cement stabilization. However, the vitrification process equipment
would be more complex to construct and operate than that of the cement stabilization process. There
is limited experience available for the types and quantities of the material from the silos and decant
sump tank on which to base an assessment of the likely performance of the vitrification technology.
The vitrification technology is not as widely available as the cement stabilization technology. Off-gas
treatment is also an additional complexity with vitrification where delays could occur. However,
operational experience is being gained as part of the structured RI/FS treatability studies and planned
vitrification pilot studies currently in progress.
Alternatives 3A.1/Vit and 3A.1/Cem involve off-site transportation and disposal at the NTS. While
technically straightforward, off-site transportation would require coordination efforts with a number of
states located along the transportation route, as well as the State of Nevada. Demonstrated
compliance with die NTS waste acceptance criteria would be required prior to shipping the Subunit A
materials. The transportation of this material would also comply with the off-site acceptability
amendment to CERCLA's implementing regulations, the National Contingency Plan [58 FR 49200
(September 22, 1993)].
In summary, Alternative 3A.1/Cem would be favored over Alternative 3A.1/Vit, based on relative
overall implementation.
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Cost. The estimated total present worth costs for the Subunit A alternatives are provided on
Table 8-2, and include a breakdown of capital and operating and maintenance costs.
The present worth cost of Alternative 3A.1/Cem is approximately 67 percent more expensive than
Alternative 3A.1/Vit, primarily due to the additional packaging, transportation, and disposal for the
larger volume of cement-stabilized material.
8.2.1.3 Modifying Criteria
State Acceptance
The State of Ohio reviewed the preferred remedial alternative for Subunit A that was provided in the
PP, and concurs with the selection of Alternative 3A.1/Vit. A letter from the OEPA conditionally
approving the FS and PP for Operable Unit 4 can be found in Appendix E of this ROD.
Community Acceptance
DOE solicited input from the community on the preferred remedial alternative for Subunit A that was
provided in the PP. Verbal comments received during the public meeting indicated support of the
chosen remedial alternative. Written comments received during the public comment period are
addressed in the responsiveness summary (see Appendix C).
8.2.1.4 Subunit A Comparative Analysis Summary
Alternative 3A.1/Vit is identified as the preferred alternative because it would result in the permanent
treatment and volume reduction of Subunit A materials and it is cost-effective. It would provide
overall protection of human health and the environment with fewer uncertainties over the long-term.
8.2.2 SUBUNIT B
8.2.2.1 Threshold Criteria
Subunit B alternatives would employ the same removal, treatment, and disposal options as those for
Subunit A materials. Many of the factors considered and discussed under the Subunit A analysis are
identical for Subunit B. Therefore, frequent references will be made to the information presented
previously in Section 8.2.1. Only those factors unique to remediation of the Subunit B materials will
be emphasized. This approach will be applied to the discussions under the primary balancing criteria
as well.
8-10
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TABLE 8-2
OPERABLE UNIT 4 REMEDIAL ALTERNATIVE COST SUMMARY (MILLION $)
ALTERNATIVE
CAPITAL
OPERATING & MAINTENANCE
TOTAL.
PRESENT
WORTH
COST
SHORT-TERM
(During Remediation)
LONG-TERM
(Post Remediation)
Subunit A - Silos 1 and 2 Contents
OA - No Action
0
0
0
0
3A.1/Vit - Removal, Vitrification, Off-Site Disposal -
Nevada Test Site
38.3
11.7
0
43.7
3A.1/Cem - Removal, Cement Stabilization, Off-Site
Disposal - Nevada Test Site
71.8
11.7
0
73.1
Subunit B - Silo 3 Contents
OB - No Action
0
0
0
0
2B/Vit - Removal, Vitrification, On-Property Disposal
25.2
4.9
3.2
28
2B/Cem - Removal, Cement Stabilization, On-Property
Disposal
35.9
4.9
3.2
37.4
3B. 1/Vit - Removal, Vitrification, Off-Site Disposal -
Nevada Test Site
26.8
4.9
0
28
3B.1/Cem - Removal, Cement Stabilization, Off-Site
Disposal - Nevada Test Site
36.8
4.1
0
36
4B - Removal, On-Property Disposal
21.8
1.1
3.2
22
Subunit C - Silos 1, 2, 3, and 4 Structures, Soils, and Debris
OC - No Action
0
0
0
0
2C - Demolition, Removal, On-Property Disposal
36.3
0
3.6
34.3
3C.1 - Demolition, Removal, Off-Site Disposal - Nevada
Test Site
83.6
0
0
75.5
3C.2 - Demolition, Removal, Off-Site Disposal - Permitted
Commercial Facility
48.7
0
0
44
NOTES:
The accuracy of the cost estimates are between -1-50% and -30%.
Estimates of capital and operations and maintenance costs are expressed in terms of total costs. The total present worth costs are calculated from the total cost figures applying
a discount rate of 7 percent and an operating and maintenance period of 30 years.
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FEMP-OU4ROD-8 FINAL
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The comparison of the Subunit B alternatives against the threshold criteria of overall protection of
human health and the environment and compliance with ARARs is summarized below.
Overall Protection of Human Health and the Environment. As discussed in Section 8.2.1.1, this
evaluation assumes that the federal government would continue to own the FEMP site. For a cleanup
remedy to be considered protective, it should not result in any unacceptable risks to an expanded
trespasser or an off-site farmer.
All alternatives, with the exception of the no-action alternative (OB), would provide overall protection
of human health and the environment. These alternatives will eliminate, reduce, or control the health
or environmental risks resulting from constituents in Subunit B materials. Except for Alternative 4B,
the alternatives would limit exposure to contaminants by removing the material, treating the material
by either vitrification or cement stabilization. The treated material is disposed in an on-property
above-grade disposal vault for Alternative 2B or off-site at NTS for Alternative 3B.1. Alternative
4B's protection is based on removal and disposal in an on-property above-grade vault and institutional
controls. All alternatives would attain long-term effectiveness.
In summary, Alternatives 3B.1/VU and 3B.1/Cem would provide overall protection to the expanded
trespasser and off-site farmer because they would remove the Subunit B residues from the FEMP site.
Compliance with ARARs. With the exception of the no-action alternative, Subunit B alternatives
would comply with all pertinent ARARs. Under the no-action alternative, Silo 3 would eventually
fail, resulting in the release of cold metal oxides to the environment. This scenario would likely
result in radiological releases to the air, soil, groundwater, and surface water (via storm water
runoff). For example, fate and transport modeling for this scenario indicates that the safe drinking
water limits (MCLs in 40 CFR §141) would be exceeded for uranium, and gross alpha and beta
radiation.
For those alternatives that include on-property disposal, an Alternative 4B is the least favorable on-
property alternative because the material is not treated.
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FEMP-OU4ROD-8 FINAL
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In summary, Alternatives 2B/Vit, 2B/Cem, 3B.1/Vit, 3B.1/Cem, and 4B, would meet all pertinent
ARARs. Because the uncertainty associated with demonstrating that the FEMP on-property disposal
vault would provide for the long-term protection of inadvertent intruders, Alternatives 3B. l/Vit and
3B.1/Cem are favored over 2B/Vit, 2B/Cem, and 4B.
8.2.2.2 Primary Balancing Criteria
Those alternatives that satisfy the threshold criteria comparative analysis were carried forward to the
primary balancing criteria comparative analysis. Because Alternative OB (No Action) did not satisfy
either of the threshold criteria, it is not considered further in this analysis.
Long-Term Effectiveness and Permanence. All Subunit B alternatives would ensure long-term
protectiveness to human health and the environment. For all alternatives, projected FEMP site
residual risks to viable receptors (off-site farmer and expanded trespasser) would be less than 1CT6
incremental lifetime cancer risk, and no non-carcinogenic effects (hazard index less than 0.2) would
be indicated for either receptor.
The characteristics of the treated residue form (vitrification or cement stabilization) and the disposal
options (on-property or off-site at NTS) are similar to those discussed under long-term effectiveness
for Subunit A materials. Long-term environmental impacts are also the same as those considered for
Subunit A.
In summary, Alternatives 3B.1/Vit and 3B.1/Cem provide a greater degree of long-term effectiveness
than Alternatives 2B/Vit, 2B/Cem, and 4B.
Reduction of Toxicity. Mobility, or Volume through Treatment. Alternatives 2B/Vit and 3B.1/Vit
would use the vitrification process to treat the Subunit B material. This technology would physically
bind the contaminants in a glass-like matrix, which would significantly reduce contaminant mobility
and material volume. Mobility would be reduced since the contaminants would be bound in the
matrix and the volume of the treated material would be approximately 62 percent of the untreated
material volume.
Alternatives 2B/Cem and 3B. 1/Cem would use the cement stabilization process to treat the Subunit B
material. This technology will physically and chemically bind the constituents in a cement-like
matrix, so the mobility of constituents (via leaching from) in this treated material would be greatly
8-13
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FEMP-OU4ROD-8 FINAL
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reduced. However, the total volume of material will increase by 55 percent as a result of adding the
cement stabilizing and setting agents.
Alternative 4B does not reduce toxicity, mobility, or volume because it does not include the
treatment. In summary, Alternatives 2B/Vit and 3B.1/Vit are favored over Alternatives 2B/Cem,
3B.1/Cem, and 4B because they would generate a treated form which has very good resistance to
leaching and would significantly reduce the volume of the Subunit B materials.
Short-Term Effectiveness. For the Subunit B action alternatives, the various removal, treatment, and
disposal activities would result in increased short-term risks (compared to no action). The short-term
effectiveness of removal operations is expected to be the same among all alternatives for Subunit B.
There is some degree of uncertainty associated with controlling and treating the off-gases generated
by the vitrification process.
The increased risks due to off-site transportation of the treated residues to NTS and the short-term
environmental impacts associated with removal, treatment, and disposal are similar to those described
in Section 8.2.1.2. Alternative 4B provides the highest short-term effectiveness because no treatment
is provided.
In summary, Alternative 4B is the favored alternative, and Alternatives 2B/Cem and 3B.1/Cem are
favored over Alternatives 2B/Vit and 3B.1/Vit because of the uncertainty associated with off-gas
control and treatment for the vitrification process.
Imnlementahilitv. The removal and treatment activities for all Subunit B action alternatives could be
implemented with standard equipment, procedures, and readily available resources. Pneumatic
removal would be employed for the Subunit B materials and it is a standard technology that is
typically reliable and uses readily available equipment. All other aspects of implementing the action
alternatives for Subunit B are identical to those discussed for Subunit A under the implementability
criterion in Section 8.2.1.2.
In summary, Alternative 4B would be favored and Alternatives 2B/Vit and 3B. 1/Vit would be the
least favored, based on relative overall implementability.
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Cost. The estimated total present worth costs for Subunit B Alternatives are provided in Table 8-2
and include a breakdown of capital and operating and maintenance costs.
Alternative 4B is the least expensive action alternative. The present worth costs of Alternatives
2B/Vit and 3B. 1/Vit are approximately the same, and are about 6 million dollars higher than that of
Alternative 4B. This is due to the treatment component of those alternatives not included in
Alternative 4B. Alternatives 3B.1/Cem and 2B/Cem are approximately 30 percent and 34 percent
more expensive, respectively, than Alternatives 3B. 1/Vit and 2B/Vit, respectively. Alternative
3B.1/Cem is more expensive than Alternative 3B. 1/Vit primarily due to the additional packaging,
transportation, and disposal of the larger volume of cement-stabilized material.
8.2.2.3 Modifying Criteria
State Acceptance
The State of Ohio reviewed the preferred remedial alternative for Subunit B that was provided in the
Proposed Plan, and concurs with the selection of alternative 3B. 1/Vit. A letter from the OEPA
conditionally approving the FS and PP for Operable Unit 4 can be found in Appendix E of this ROD.
Community Acceptance
DOE solicited input from the community on the preferred remedial alternative for Subunit B that was
provided in the Proposed Plan. Verbal comments received during the public meeting indicated
support of the chosen remedial alternative. Written comments received during the public comment
period are addressed in the responsiveness summary (see Appendix C).
8.2.2.4 Subunit B Comparative Analysis Summary
Alternative 3B. 1/Vit is the preferred alternative because it is cost-effective and would result in the
permanent treatment and volume reduction of Subunit B materials. Alternative 3B. 1/Vit would
provide overall protection of human health and the environment with fewer uncertainties over the
long-term.
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FEMP-OU4ROD-8 FINAL
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8.2.3 Subunit C
8.2.3.1 Threshold Criteria
The analysis of the Subunit C alternatives against the threshold criteria of overall protection of human
health and the environment, and compliance with ARARs is summarized below.
Overall Protection of Human Health and the Environment. Alternative OC would not provide
adequate protection of human health and the environment. As discussed in Section 8.2.1.1,
evaluations were conducted for future land uses with and without continued federal ownership. For a
cleanup remedy to be considered protective, it would not result in any unacceptable risks to an
expanded trespasser or an off-site farmer under the future land use with continued federal ownership
scenario, or an on-property fanner under the future land use without continued federal ownership.
All of the action alternatives (Alternatives 2C, 3C.1, and 3C.2) would limit exposure to constituents
by decontaminating, demolishing, and removing the material to either an on-property above-grade
disposal facility or off-site disposal facility, and then excavating contaminated soils and placing clean
fill over residual contaminated subsurface soils. Section 9.2 presents and discusses the soil cleanup
levels, all of which would be protective to the expanded trespasser and off-site resident over the long
term. Short-term risks would be higher for off-site disposal due to the increased risk of transportation
accidents.
The basic difference among the action alternatives is the disposal option. On-property disposal
(Alternative 2C) would be in an above-grade disposal facility. Off-site disposal options include NTS
(Alternative 3C.1) and a permitted commercial disposal she (Alternative 3C.2).
The on-property, above-grade disposal facility would be designed for a 1,000 year life with no active
maintenance. Fate and transport modeling using conservative assumptions concludes that
protectiveness would be maintained over the long term.
NTS and the permitted commercial disposal facility would incorporate engineering controls to ensure
protectiveness. Both are located in a climatic, demographic, and hydrogeologic setting which favors
minimization of constituent migration to human or environmental receptors.
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In summary, Alternatives 3C.1 and 3C.2 would provide overall protectiveness because they would
remove the Subunit C excavated soils and debris from the FEMP site.
Compliance with ARARs. All alternatives, other than Alternative OC (No Action) would meet all
pertinent ARARs. Under the no-action alternative, it would be likely that constituents would continue
to be released to the air, groundwater, and surface water. There would also be a risk for direct
contact with contaminated soil and exposure to direct radiation.
For Alternative 2C, an exemption to Ohio Administrative Code (OAC) rule 3745-27-07(B)(5) may be
granted on the basis of meeting certain technical requirements. Supporting technical data for the
proposed location of the disposal facility on the FEMP site must be developed to satisfy the
requirements of OAC rule 3745-27-07(B)(5).
In summary, Alternatives 3C.1, and 3C.2 would meet all pertinent ARARs. Alternative 2C would
require a waiver of OAC rule 3745-27-07(B)(5) based on demonstration that it would meet certain
technical requirements.
8.2.3.2 Primary Balancing Criteria
Those alternatives that satisfy the threshold criteria of compliance with ARARs and overall protection
of human health and environment were carried forward to the primary balancing criteria comparative
analysis. Because Alternative OC (No Action) did not satisfy either of the threshold criteria, it is the
only alternative not considered further in this analysis.
Long-Term Effectiveness and Permanence. All Subunit C alternatives would ensure long-term
protectiveness to human health and the environment. For all alternatives, projected FEMP site
residual risks to viable receptors (off-site farmer and expanded trespasser) would be less than 10*
incremental lifetime cancer risk and no non-carcinogenic effects (hazard index less than 0.2) would be
indicated for either receptor. Although residual contamination would remain in the Operable Unit 4
Study Area, the level of risk from the contaminated soil would be controlled by excavating soil that
exceeds proposed cleanup levels, by placing clean soil over the excavated areas, and by providing
appropriate access controls and deed restrictions.
Alternative 2C would employ an on-property disposal facility designed to minimize leachate
generation from water infiltration and contact with contaminated soil and debris. Fate and transport
8-17
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FEMP-OU4ROD-8 FINAL
December 1994
modeling using conservative assumptions demonstrates that both risk- and ARAR-based protective
levels would be maintained for the Great Miami Aquifer over the long term.
Alternatives 3C.1 (NTS) and 3C.2 (permitted commercial disposal facility) would provide long-term
protectiveness because the residual soils and debris would be removed from the FEMP site.
Following completion of remedial operations, impacted areas would be restored; long-term
environmental impacts are expected to be minor. Alternative 2C would result in permanent
commitment of approximately 4.7 hectares (11.6 acres) of land for the disposal facility.
In summary, Alternatives 3C.1 and 3C.2 would provide a greater degree of long-term effectiveness
than Alternative 2C.
Reduction of Toxicity. Mobility, or Volume through Treatment. Alternatives 2C, 3C.1, and 3C.2
will isolate the material from the environment by containment. Treatment of the contaminated silo
structures, berm material, or soils is not included in any of the alternatives, so no reduction in
toxicity, mobility, or volume would be achieved.
Short-Term Effectiveness. For all alternatives, the various demolition and removal activities would
result in increased short-term exposures compared to no action. Alternatives 3C.1 and 3C.2 would
pose additional risks to the public and workers associated with off-site shipment to the NTS or the
permitted commercial disposal facility.
During the implementation of any of the action alternatives, the general public is not likely to be
exposed to contaminants because of the distance from the work area, the very low levels of
contamination, and the methods proposed to control emission dust during demolition and excavation.
Potential short-term environmental impacts resulting from the implementation of Alternatives 2C,
3C.1, and 3C.2 include generation of fugitive dust, increased sediment in surface runoff, and
disturbance and/or displacement of wildlife as a result of noise, dust, and human activity.
Engineering controls would be used to minimize these potential short-term impacts.
In summary, Alternative 2C is favored over Alternatives 3C.1 and 3C.2. The short-term risks to the
public and workers for constructing the on-property disposal facility would offset the increased risks
to the public and workers associated with off-site transportation of the contaminated soils and debris.
8-18
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FEMP-OU4ROD-8 FINAL
December 1994
Implementabilitv. Alternatives 2C, 3C.1, and 3C.2 would all employ the same decontamination,
demolition, and excavation operations. With the exception of the remotely controlled operations
proposed for decontaminating Silos 1, 2, and 3, all operations are standard construction activities
which would be easily implemented. The remote silo decontamination operations would be used on
the uncontaminated Silo 4 first to attain improved worker familiarity with the operation processes and
identify any potential operational difficulties.
Alternative 2C involves on-property disposal facility construction, which would employ standard
construction services and materials. The off-site disposal alternatives (3C.1 and 3C.2) would involve
standard transportation practices for radioactive materials. Alternatives 3C.1 and 3C.2 would be
more administratively difficult to implement than Alternative 2C due to the coordination required with
those states through which shipment would pass to the off-site locations. Additional efforts would be
required to ensure that the Subunit C materials complied with criteria established by either the NTS or
the permitted commercial disposal facility. Alternative 2C would require coordination with the State
of Ohio to ensure that all technical requirements for the on-property disposal facility were met.
In summary, Alternative 2C is favored over Alternatives 3C. 1 and 3C.2 based on relative overall
implementability.
Cost. The estimated total present worth costs for Subunit C alternatives are provided in Table 8-2,
and include a breakdown of capital and operating and maintenance cost.
Alternative 2C, which includes an on-property disposal, is the least expensive action alternative.
Transportation to the NTS (Alternative 3C.1) or to a permitted commercial disposal facility
(Alternative 3C.2) are both more expensive than constructing an on-property vault. However, the
overall cost of disposal at a permitted commercial disposal facility is anticipated to be approximately
60 percent lower than the cost of disposal at a DOE-owned facility. This is primarily due to the
packaging requirements of the DOE-owned facility. The commercial disposal facility accepts bulk
shipment of material.
8-19
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FEMP-OU4ROD-8 FINAL
December 1994
8.2.3.3 Modifying Criteria
State Acceptance
The State of Ohio reviewed the preferred remedial alternative for Subunit C that was provided in the
Proposed Plan, and concurs with the decision that the final disposition of the Subunit C contaminated
soil and debris would be placed in abeyance to take full advantage of planned and in progress waste
minimization treatment processes. The contaminated soil and debris would either be processed
through the selected Operable Unit 5 and Operable Unit 3 remedy identified by the respective
Operable Unit 5 and Operable Unit 3 ROD or placed in interim storage to await the finalization of the
disposal decisions for soils and debris under Operable Unit 5 and Operable Unit 3. For the sole
purpose of evaluating the performance of an overall preferred remedial alternative for Operable Unit
4, the State of Ohio concurs with the identification of Alternative 2C as the preferred alternative for
Subunit C.
Community Acceptance
DOE solicited input from the community on the preferred remedial alternative for Subunit C that was
provided in the Proposed Plan. Verbal comments received during the public meeting indicated
support of the chosen remedial alternative. Written comments received during the public comment
period are addressed in the responsiveness summary (see Appendix C).
8.2.3.4 Subunit C Comparative Analysis Summary
Alternatives 2C and 3C.2 are relatively equal, as both would be cost-effective, and would provide
overall protection of human health and the environment both in the short-term and the long-term. For
evaluation purposes only, Alternative 2C has been identified as the preferred alternative for Subunit
C. The decision regarding the final disposition of the Operable Unit 4 Subunit C contaminated soil
and debris would be placed in abeyance to take full advantage of planned and in progress waste
minimization treatment processes. The contaminated soil and debris would either be processed
through the selected Operable Unit 5 and Operable Unit 3 remedy identified by the respective
Operable Unit 5 and Operable Unit 3 ROD or placed in interim storage to await the finalization of the
disposal decisions for soils and debris under Operable Unit 5 and Operable Unit 3.
8-20
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9.0 SELECTED REMEDY
FEMP-OU4ROD-8 FINAL
December 1994
On the basis of the evaluation of final alternatives, the selected remedy to be used at Operable Unit 4
at the FEMP is a compilation of the selected alternatives from each subunit; i.e., Alternatives
3A.1/Vit - Removal, Vitrification, and Off-site Disposal - NTS; 3B.1/Vit - Removal, Vitrification,
and Off-site Disposal - NTS; and 2C - Demolition, Removal and On-Property Disposal. The selected
remedy will satisfy the requirements of both CERCLA and NEPA for the protection of human health
and the environment; will comply with all regulatory requirements; will be cost-effective; will utilize
permanent solutions to the maximum extent practicable; and will utilize treatment as a principal
element of the response. The discussions presented here are based on the information used for
detailed analysis of alternatives during the FS for Operable Unit 4. Actual methods used during the
implementation of the remedy will be determined during detailed engineering design described in the
remedial design and may differ from the descriptions provided below.
9.1 KEY COMPONENTS
The major components of the selected remedy consist of the following:
• Removal of the contents of Silos 1,2, and 3 (K-65 residues and cold metal oxides) and the
decant sump tank sludge.
• Vitrification (glassification) to stabilize the residues and sludges removed from the silos and
decant sump tank.
• Off-site shipment for disposal at the NTS of the vitrified contents of Silos 1, 2, 3, and the
decant sump tank.
• Demolition of Silos 1-4 and decontamination of the gross and loose contamination, to the
extent practicable, of the concrete rubble, piping, and other generated construction debris.
• Removal of the earthen berms and excavation of contaminated soils within the boundary of
Operable Unit 4, to achieve proposed remediation levels. Placement of clean backfill
following excavation (i.e. structure, foundations or large excavations which affect local
topography).
• Segregation of non-contaminated soils, demolition of the vitrification treatment unit and
associated facilities after use. Decontamination or recycling of debris prior to disposition.
• On-property interim storage of excavated contaminated soils and remaining contaminated
debris in a manner consistent with the approved Work Plan for Removal Action 17
(improved storage of soil and debris).
• Continued access controls and maintenance, and monitoring of the stored wastes
inventories.
9-1
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FEMP-OU4ROD-8 FINAL
December 1994
• Institutional controls of the Operable Unit 4 area such as deed and land use restrictions.
• Potential additional treatment of stored Operable Unit 4 soil and debris using Operable Unit
3 and S waste treatment systems.
• Pumping and treatment of any contaminated perched groundwater encountered during
remedial activities.
• Disposal of remaining Operable Unit 4 contaminated soils and debris consistent with the
selected remedies for Operable Units 5 and 3, respectively.
9.1.1 Removal of Silo 1. 2 and 3. and Decant Sump Tank Contents
The K-65 residues in Silos 1 and 2, the cold metal oxides in Silo 3, and the sludge in the decant sump
tank will be removed. Approximately 6,796 m3 (8,890 yd3) of K-65 residues from Silos 1 and 2,
3,785 L (1,000 gallons) of sludge from the decant sump, and 3,890 m3 (5,088 yd3) of cold metal
oxides from Silo 3 will be removed. The silos and the decant sump will be equipped with an off-gas
treatment system(s) designed to handle radon emissions generated during removal.
9.1.2 Vitrification of Silo 1. 2 and 3. and Decant Sump Tank Contents
The major treatment component of the selected remedy consists of a vitrification system to stabilize
the wastes from Silos 1, 2, and 3 and the decant sump tank. The wastes removed from the silos and
the decant sump will be transferred to a vitrification processing facility which will be constructed on
site. The wastes will be thickened as necessary for vitrification and then mixed with glass forming
agents and placed into a vitrification melter. The vitrification process will convert the contents of the
silos and the decant sump into a very durable glass form which is extremely resistant to the effects of
time and weather. The process will destroy organic contaminants and the vitrified waste form will
significantly reduce both the tendency of the waste to leach contaminants into the environment and the
emission rate of radon gas. The direct radiation associated with the treated residues will remain
relatively unchanged from the untreated form of the wastes. Off gases produced as a result of the
high operating temperatures of the vitrification melter will be routed through an off-gas treatment
system designed to remove solid particles and treat gaseous emissions such as radon.
Treatability studies, conducted on a small scale as part of the RI/FS, indicate that the volume of
vitrified material requiring disposal can be reduced by as much as 50 percent of the volume of
untreated material removed from the silos and the decant sump.
9-2
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FEMP-OU4ROD-8 FINAL
December 1994
TABLE OF CONTENTS
Page
List of Tables a-i
List of Acronyms a-ii
A. 1.0 Introduction A-l-1
LIST OF TABLES
Page
A. 1-1 Summary of Major ARARs/TBCs for Operable Unit 4 Remedial Action
Alternatives - Chemical-Specific A-1-2
A. 1-2 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Location-Specific A-l-5
A. 1-3 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Action-Specific A-1-7
a-i
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FEMP-OU4ROD-8 FINAL
December 1994
LIST OF ACRONYMS
ALARA As Low As Reasonably Achievable
ARAR Applicable or Relevant and Appropriate Requirements
AWWT Advanced Waste Water Treatment Facility
CAMU Corrective Action Management Unit
CFR Code of Federal Regulation
DOE United States Department of Energy
FEMP Fernald Environmental Management Project
HEPA High-Efficiency Particulate Air (filter)
HLRW High Level Radioactive Waste
m meter
MCL Maximum contaminant level
MCLG Maximum contaminant level goal
NEPA National Environmental Policy Act
NESHAP National Emission Standards for Hazardous Air Pollutants
OAC Ohio Administrative Code
ORC Ohio Revised Code
OU4 Operable Unit 4
pCi picoCuries
pCi/1 picoCuries per liter
pCi/m2/s2 picoCuries per square meter per second
RCRA Resource Conservation and Recovery Act
SWMU Solid Waste Management Unit
TBC to be considered
TRU Transuranic
TSD Treatment, Storage, or Disposal Facility
TU Temporary Unit
UMTRCA Uranium Mill Tailings Radiation Control Act
WWTS Waste Water Treatment System
a-ii
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FEMP-OU4ROD-8 FINAL
December 1994
A.1.0 INTRODUCTION
This appendix presents a summary of the key Applicable or Relevant and Appropriate Requirements
(ARARs) and to be considered (TBCs) which pertain to the remedial alternatives which were retained in
the Detailed Analysis of Alternatives (Section 4) of the Feasibility Study Report for Operable Unit 4, and
described in Section 7 of the Record of Decision. This table includes ARARs established under federal
and state environmental laws, and TBC criteria which were determined to be necessary to ensure
protection of human health and the environment.
The appendix has three tables in accordance with the three types of ARARs: Chemical-Specific, Location-
Specific, and Action-Specific. The layout of the tables is as follows: the retained alternatives are listed
in the first column, followed by the regulatory citation and classification as applicable, relevant and
appropriate, or TBC. Next the basis for selection and determination of the class of ARAR is described,
followed finally by the strategy for compliance with the ARAR during implementation of the alternative.
This format and contained information is consistent with the United States Environmental Protection
Agency (EPA) Interim Final Guidance on Preparing Superfund Decision Documents: the Proposed Plan,
Record of Decision, Explanation of Significant Differences, and Record of Decision Amendment (OERR;
EPA/540/G-89/007, July 1989b).
Summary tables listing all the ARARs/TBCs specifically identified for the selected remedy are provided
in Appendix B. A detailed listing, and discussion of compliance with ARARs is provided in Appendix
F of the Feasibility Study Report for Operable Unit 4.
A-l-1
-------
TABLE A.l-1
SUMMARY OF MAJOR ARARs/TBCs FOR OPERABLE UNIT 4
REMEDIAL ACTION ALTERNATIVES
Chemical-Specific
Alternative
Regulatory Tide
ARAR/TBC
Rationale for Determination
Basis for Compliance
Number
and Citation
as ARAR/TBC
2B, 4B
Inorganic Cheimcals in Drinking
Relevant
These requirements are not applicable since no
Fate and transport modeling, for
2C
Water
and
public water system (as defined in 40 CFR f 141) is
the proposed disposal facility,
40 CFR f 141.11, 40 CFR f
Appropriate
involved. They are relevant and appropriate to
predicts that potential future
141.IS,
protect drinking water sources from the same
releases to the aquifer from the
40 CFR f 141.16, 40 CFR f
contaminants found in the operable unit. These
facility will not exceed MCLs or
141.51, and 40 CFR { 141.62
contaminants might migrate or leach into the
MCLGs. This is primarily due to
and 143.3
underlying aquifer as a consequence of various
the presence of approximately 9 m
(OAC 3745-81-11, 3745-81-15,
alternatives.
(30 ft) of low hydraulic
and 3745-81-16)
conductivity glacial till, that has no
significant hydrologic connections
with the underlying aquifer,
beneath the proposed disposal
facility.
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TABLE A. 1-1
(Continued)
2B, 4B
2C
Organic Chemicals in Drinking
Water
40 CFR f 141.61
(OAC 3745-81-12)
Relevant
and
Appropriate
The requirement is not applicable since no public
water system (as defined in 40 CFR f 141) is
involved. It is relevant and appropriate to protect
drinking water sources from the same contaminants
found in the operable unit. These contaminants
might migrate or leach into the underlying aquifer as
a consequence of remedial actions.
Fate and transport modeling, for
the proposed disposal facility,
predicts that potential future
releases to the aquifer from the
facility will not exceed MCLs.
This is primarily due to the
presence of approximately 9 m (30
ft) of low hydraulic conductivity
glacial till, that has no significant
hydrologic connections with the
underlying aquifer, beneath the
proposed disposal facility.
3A.1
2B, 3B.1, 4B
2C, 3C.1,
3C.2
Radionuclide Emissions (Except
Airborne Radon-222)
40 CFR f 61, Subpart H
Applicable
Radioactive materials within this operable unit might
contribute to the dose to members of the public from
the air pathway during implementation of remedial
actions. This requirement is applicable to remedial
actions implemented in Operable Unit 4, since
NESHAP applies to operating units.
The pollution control equipment
for the silos and treatment system
for off-gas emissions will be
designed to limit the discharge of
radionuclides to acceptable levels.
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TABLE A.I-I
(Continued)
Alternative
Number
Regulatory Tide
and Citation
ARAR/TBC
Rationale for Determination
as ARAR/TBC
Basis for Compliance
3A.1
2B, 3B.1, 4B
2C
Radon-222 Emissions
40 CFR j 61 Subpart Q
Applicable
Facilities such as the silos within this operable unit
might qualify as sources since they might contain
radium-226 in sufficient concentrations to emit
radon-222. This requirement is applicable only to
storage and disposal of radium-bearing material.
The radon-222 flux rate standard
of 20 pCi/mVs would be met
during storage and/or disposal.
This is due to the presence of a
bentonite layer in the silos (prior
to treatment), and the stabilized
nature of the treated waste.
2B, 4B
2C
Standards for Control of Residual
Radioactive Material
40 CFR f 192, Subpart A
40 CFR f 192.02(b)
Relevant
and
Appropriate
Radioactive materials in this operable unit are
residua] radioactive material from uranium
processing. However, the FEMP site is not an ore
processing site designated under the UMTRCA;
therefore, management of these residues is relevant
and appropriate under this regulation.
Radon-222 emissions would
conqtly with the 20 pCi/mVs
release flux rate and the 0.5 pCi/L
concentration above background at
the disposal site boundary. This is
due to the presence of a bentonite
layer in the disposal cell, and the
stabilized nature of the treated
waste.
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TABLE A. 1-2
SUMMARY OF MAJOR ARARs FOR OPERABLE UNIT 4
REMEDIAL ACTION ALTERNATIVES
Location-Specific
Alternative
Number
Regulatory Title
and Citation
ARAR/TBC
Rationale for Determination
as ARAR/TBC
Basis for Compliance
2B, 4B
2C
Solid, Nonhazardous Waste
Disposal Facility Deaign
Considerations
OAC 3745-27-07
Relevant
and
Appropriate
The State of Ohio solid waste rules are relevant and
appropriate to the disposal of silo residues,
demolition debris, and other solid wastes generated
by the implementation of a remedial alternative
within a CAMU.
Creation of a solid waste landfill requires that the
technical location requirements of the State of Ohio
be satisfied. On-site disposal alternatives might
trigger this part of the Ohio requirements, which are
more stringent than the federal counterparts.
The FEMP site is over a sole source aquifer as
defined in OAC 3743-27-07. An exemption to this
prohibition by demonstration of compliance with the
technical criteria in this rule is permitted under
ORC 3734.02(G).
The proposed disposal vault meets
the technical considerations used to
grant exemptions: approximately 9
m (30 ft) of low hydraulic
conductivity glacial till lies beneath
the proposed liner, saturated zones
in the glacial till have no
significant hydrologic connections
with the underlying aquifer, and
fate and transport modeling
predicts that potential future
releases to the aquifer from the
facility will not adversely impact
human health or safety or the
environment.
3A.1
2B, 3B.1, 4B
2C, 3C.1,
3C.2
Compliance with
Floodplain/Wedands
Environmental Review
Requirements
lOCFRf 1022
(Executive Order 11990)
Applicable
This requirement is applicable because the FEMP is
a DOE facility subject to the NEPA requirements
for environmental activities at federal facilities.
Several alternatives might result in destruction or
modification of wetland areas.
These alternatives would comply
with all NEPA evaluation and
documentation requirements.
NEPA documentation will also
specify public notice requirements,
wetland assessments, and any
mitigative measures that may be
required.
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TABLE A. 1-3
SUMMARY OF MAJOR ARARs FOR OPERABLE UNIT 4
REMEDIAL ACTION ALTERNATIVES
Action-Specific
Alternative
Number
Regulatory Title
and Citation
ARAR/TBC
Rationale for Determination
as ARAR/TBC
Basis for Compliance
3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
Treatment, Storage, or Disposal
Facility (General Standards)
40 CFR f 264, Subpart B
(OAC 3745-54-13 through 16)
Relevant
and
Appropriate
Residues, which exhibit a characteristic similar to
RCRA hazardous waste, removed from this
operable unit might be treated, stored, and disposed
in accordance with TSD facility standards.
These alternatives would undertake
actions to comply with the TSD
Facility general standards.
2B, 4B
2C
Releases from Solid Waste
Management Units
40 CFR f 264, Subpart P
OAC 3745-54-91 through 99;
and OAC 3745-55-01 through
Oil)
Relevant
and
Appropriate
This requirement is relevant and appropriate
because the residues stored in the silos are
sufficiently similar to hazardous waste.
These alternatives would install
monitoring wells to comply with
the groundwater monitoring
requirements.
3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
Closure
40 CFR f 264, Subpart G
40 CFR f 264.111, .114, and
.116
(OAC 3745-55-11, -14, and -16)
Relevant
and
Appropriate
These requirements are relevant and appropriate
because the residues are sufficiently similar to
hazardous waste and the remedial alternatives might
require closure of units used to manage waste
materials.
These alternatives would design,
construct, operate, and monitor the
disposal facility to meet the closure
performance standard;
decontaminate all equipment used
in closure, and file a survey plot
showing location of disposal
facility.
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TABLE A. 1-3
(Continued)
2B, 4B
2C
Post-Closure
40 CFR f 264.117
(OAC 3745-55-17)
40 CFR f 264.119
(OAC 3745-55-19)
Relevant
and
Appropriate
These requirements are relevant and appropriate
because the residues are sufficiently similar to
hazardous waste and some remedial alternatives
might leave residues in place.
These alternatives would comply
with the post-closure requirements
for units involved in disposal,
including continued monitoring,
access controls, and deed
restrictions.
3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
Container Storage
40 CFR f 264.171 - 178 Subpart
1
(OAC 3745-55-71 through -78)
Relevant
and
Appropriate
These requirements pertain to alternatives utilizing
containers for storage, or treatment of hazardous
waste in containment buildings. The requirements
are relevant and appropriate because the residues in
the silos are sufficiently similar to hazardous waste.
These alternatives would take
measures to comply with the
hazardous waste container
requirements.
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TABLE A. 1-3
(Continued)
Alternative
Number
Regulatory Title
and Citation
ARAR/TBC
Rationale for Determination
as ARAR/TBC
Basis for Compliance
3A.1
2B, 3B.1
Tank Systems
40 CFR f 264, Subpart J
(OAC 3745-55-91 through 96)
Relevant
and
Appropriate
These requirements pertain to alternatives utilizing
treatment or storage in a tank. These requirements
are relevant and appropriate because the residues in
the silos are sufficiently similar to hazardous waste.
All process tanks will be
constructed with durable material
that is compatible with the waste
and treatment process for which
the tank is designed. The tank
design will include secondary
containment capable of detecting
and collecting releases. Approved
inspection and maintenance
procedures, which include
scheduled visual inspection of all
tanks will be established prior to
management of waste in the tanks.
2B, 4B
2C
Landfill Capping
40 CFR f 264.310
(OAC 3745-57-10)
Relevant
and
Appropriate
Land disposal of hazardous waste constitutes closure
as a landfill, which requires a cap to prevent
migration of waste constituents due to leaching.
This requirement is relevant and appropriate
because the residues are sufficiently similar to
hazardous wastes.
Compliance would be achieved
through proper design,
construction, and implementation
of institutional controls at the
disposal vault. These controls
would include continued
inspection, monitoring, and
maintenance of the disposal facility
and surveyed benchmarks.
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TABLE A. 1-3
(Continued)
Alternative
Number
Regulatory Title
and Citation
ARAR/TBC
Rationale for Determination
as ARAR/TBC
Basis for Compliance
3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
Corrective Action for SWMUs
(CAMU and TU)
40 CFR f, Subpart S
40 CFRf 264.552-.553
Relevant
and
Appropriate
During the process of remediation, waste materials
might require management in or consolidation in
land based units for the purpose of staging, treating
or disposing the material. All of the materials
generated from remediation of Operable Unit 4 are
considered remediation wastes, amenable to
management under this requirement. Some of the
waste material might exhibit a RCRA characteristic,
or otherwise be sufficiently similar to hazardous
waste to make this requirement relevant and
appropriate.
These alternatives would
demonstrate they can meet the
seven criteria required for use of a
CAMU, and would use only tanks
or containers as temporary units.
3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
Radiation Dose Limit (AH
Pathways)
DOE Order 5400.5, Chapter II,
Section l.a
To be
considered
Radiation sources within this operable unit might
contribute to the total dose to members of the public
from (his DOE facility. This requirement
establishes limits for allowable exposure of the
public to radiation sources from all pathways as a
result of routine DOE activities. It is included as
TBC to ensure adequate protection of human health
and the environment from sources of radioactivity.
Where appropriate, the treatment
facility design will include HEPA
filters to control radioactive
particulate emissions. Excavations,
excavated soil, and other sources
of particulate emissions will be
controlled, as appropriate, through
good construction practices.
Releases to water will be
controlled by design and operation
of secondary containment features
and treatment in the FEMP WWTS
and AWWT. Treatment of the
waste source will reduce
contributions to dose from radon
gas, and reduce the likelihood of
migration of radionuclides.
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TABLE A. 1-3
(Continued)
Alternative
Number
Regulatory Title
and Citation
ARAR/TBC
Rationale for Determination
as ARAR/TBC
Basis for Compliance
3A.1
Environmental Radiation
Protection Standards for Mgt.
and Diapoaal of HLRW, Spent
Nuclear Pud, and TRU Wastes
40 CFR f 191, Subpart A
40 CFR f 191.03(b)
Relevant
and
Appropriate
As directed by the U.S. EPA letter, "Applicable of
40 CFR f 191 to OU4", Jim Saric, U.S. EPA, to
Jack Craig, DOE, dated April 25, 1994.
This requirement would be met
through the use of treatment for
waste stabilization and management
and storage of vitrified material
prior to off-site disposal in
accordance with ALAR A concepts,
proper engineering design, and the
use of administrative controls.
3A.1
2B, 3B.1, 4B
2C, 3C.1, 3C.2
NEPA Implementation
10 CFR f 1021.2
Applicable
This requirement is applicable because the FEMP is
a DOE facility, subject to NEPA evaluation for
specific actions at DOE facilities.
NEPA evaluations and
documentation will be prepared for
the selected remedial alternatives in
accordance with established site
procedures.
-------
TABLE A. 1-3
(Continued)
Alternative
Number
Regulatory Tide
and Citation
ARAR/TBC
Rationale for Determination
as ARAR/TBC
Basis for Compliance
2B, 4B
2C
Standards for Control of Residual
Radioactive Material
40 CFR f 192, Subpart A
40 CFR f 192.02(a)
Relevant
and
Appropriate
Radioactive materials in this operable unit are
residual radioactive material from uranium
processing. However, the FEMP site is not on ore
processing site designated under the UMTRCA;
therefore, management of these residues is relevant
and appropriate under this regulation.
Treatment of the waste and
disposal in a property designed
disposal facility will control
residuals for 200-1000 years.
2C, 3C.1, 3C.2
Standards for Cleanup of Lands
Contaminated with Residual
Radioactive Materials
40 CFR f 192, Subpart B
40 CFR f 192.12(a)
Relevant
and
Appropriate
Radioactive materials in this operable unit are
residual radioactive material from uranium
processing. However, the FEMP site is not on ore
processing site designated under the UMTRCA;
therefore, management of these residues is relevant
and appropriate under this regulation.
This requirement would be met by
removing contaminated soil down
to required levels, and disposal of
the residues in an engineered vault
with a 3 m (10 ft) thick multimedia
cover.
3A.1, 2B,
3B.1, 4B, 2C,
3C.1, 3C.2
Implementation of Health and
Environmental Protection
Standards for Uranium Mill
Tailings
40 CFR f 192, Subpart C
Relevant
and
Appropriate
Radioactive materials in this operable unit are
residual radioactive material from uranium
processing. However, the FEMP site is not on ore
processing site designated under the UMTRCA;
therefore, management of these residues is relevant
and appropriate under this regulation.
These alternatives would use this
guidance during implementation.
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FEMP-OU4ROD-8 FINAL
December 1994
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FEMP-OU4ROD-7 FINAL
November 1994
APPENDIX B
SUMMARY OF ARARs FOR THE OPERABLE UNIT 4
REMEDIAL ACTION
-------
FEMP-OU4ROD-8 FINAL
December 1994
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FEMP-OU4ROD-8 FINAL
December 1994
TABLE OF CONTENTS
Page
List of Tables b-i
List of Acronyms b-ii
B.1.0 Introduction B-l-1
LIST OF TABLES
Page
B. 1-1 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Chemical-Specific B-l-2
B. 1-2 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Location-Specific B-l-4
B.l-3 Summary of Major ARARs for Operable Unit 4 Remedial Action
Alternatives - Action-Specific B-l-5
b-i
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FEMP-OU4ROD-8 FINAL
December 1994
LIST OF ACRONYMS
A
Applicable
AEA
Atomic Energy Act
ARAR
Applicable or Relevant and Appropriate Requirements
CAA
Clean Air Act
CAMU
Corrective Action Management Unit
CFR
Code of Federal Regulation
CWA
Clean Water Act
DCG
Derived Concentration Guide
DOE
United States Department of Energy
EDE
Effective Dose Equivalent
HLRW
High Level Radioactive Waste
NEPA
National Environmental Policy Act
OAC
Ohio Administrative Code
ORC
Ohio Revised Code
pCi/1
picoCuries per liter
pCi/m2/s2
picoCuries per square meter per second
R&A
Relevant and Appropriate
RCRA
Resource Conservation and Recovery Act
SDWA
Safe Drinking Water Act
SWMU
Solid Waste Management Unit
TBC
to be considered
TSD
Treatment, Storage, or Disposal Facility
TU
Temporary Unit
UMTRCA
Uranium Mill Tailings Radiation Control Act
b-ii
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FEMP-OU4ROD-8 FINAL
December 1994
B.1.0 INTRODUCTION
Appendix B presents a summary of ARARs/TBCs associated with the remedial action alternatives
selected for Operable Unit 4. These tables group the ARARs/TBCs according to type (i.e.,
Chemical-specific, Location-specific, and Action-specific) and by the governing regulatory act (e.g.,
CAA, CWA, RCRA, etc.). The tables identify all selected remedial alternatives associated with the
regulatory requirement, a brief description of the requirement, and the classification of the
ARAR/TBC.
It will be noted that several ARARs identified for the selected alternative include requirements that
pertain to siting or operation of an on-site disposal facility for debris, rubble, or soils from
remediation of OU4 (referenced as Alternative 2C in the tables). Disposition of rubble and debris
(e.g., from demolition of the silos) from OU4 will be conducted in accordance with the ARARs
identified in the ROD for OU3; disposition of soils from OU4 will be in accordance with ARARs
established in the ROD for OUS. Any interim storage of soils, rubble, or debris prior to final
disposition under the RODs for OU3 and OU5 will be in accordance with ARARs identified in this
ROD, as well as pertinent DOE orders and applicable site procedures.
B-l-1
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FEMP-OU4ROD-8 FINAL
December 1994
TABLE B.l-1
SUMMARY OF ARARs FOR OPERABLE UNIT 4
SELECTED REMEDIAL ACTION ALTERNATIVES
Chemical-Specific
Alternative
Regulatory
Progiam
Regulatory Title and
Citation
Regulatory Description
ARAR/TBC
3A.1 Vit
3B.1 Vit
. 2C
CAA
Radionuclide Emissions
(Except Airborne Radon-222)
40 CFR§ 61, Subpart H
Operating units shall establish
procedures to prevent a member of the
public from receiving an EDE of 10
mrem per year.
A
3A.1 Vit
3B.1 Vit
2C
CAA
Radon-222 Emissions
40 CFR§ 61, Subpart Q
Storage and disposal activities for
radium-bearing by-product material
shall establish measures to ensure
emissions of radon are maintained
below 20 pCi/m2/s.
A
3 A. 1 Vit
3B.1 Vit
2C
CWA
Ohio Water Quality
Standards (Five Freedoms of
Surface Waters)
OAC 3745-1-04
Establishes requirements for
maintaining integrity and useability of
surface water.
R&A
3A.1 Vit
3B.1 Vit
2C
CWA
Ohio Water Quality
Standards
OAC 3745-1-07
Establishes allowable limits on
discharges or releases to Paddys Run
and the Great Miami River.
A
2C
RCRA
Sub. D
Chemicals in Drinking Water
(Solid Waste Disposal
Facility)
40 CFR§ 257.3-4
[OAC 3745-27-10(D)]
Establishes requirements to protect
underground drinking water sources
from operation of the proposed
disposal facility for Subunit C material.
R&A
2C
RCRA
Sub. C
Chemicals in Drinking Water
(Hazardous Waste Disposal
Facility)
40 CFR§ 264.94
(OAC 3745-54-94)
Establishes requirements to assure
groundwater concentrations of
hazardous constituents do not exceed
regulatory levels due to operation of
the proposed disposal facility for
Subunit C material.
R&A
2C
SDWA
Inorganic Chemicals in
Drinking Water
40 CFR§ 141.11
40 CFR§ 141.15,
141.16, 141.51, 141.62 and
143.3
(OAC 3745-81-11,
OAC 3745-81-15, and
OAC 3745-81-16)
Establishes requirements to assure
protection of drinking water sources
from inorganic contaminants.
R&A
B-l-2
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TABLE B.l-1
(Continued)
FEMP-OU4ROD-8 FINAL
December 1994
Alternative
Regulatory
Program
Regulatory Title and Citation
Regulatory Description
ARAR/TBC
2C
SDWA
Organic Chemicals in
Drinking Water
40 CFR§ 141.61
(OAC 3745-81-12)
Establishes requirements to assure
protection of drinking water sources
from organic contaminants.
R&A
2C
UMTRCA
Standards for Control of
Residual Radioactive
Material
40 CFR§ 192.02 (b)
Establishes standards for managing
residual radioactive material from
inactive uranium processing sites so the
average release rate of radon-222 does
not exceed 20 pCi/nr/s or the average
concentration in air outside facility
boundary does not exceed 0.5 pCi/L
above background following
remediation activities.
R&A
3 A. 1 Vit
3B. 1 Vit
2C
DOE
Radiation Protection of the
Public and the Environment
(DCGs for Water)
DOE Order 5400.5 Chapter
in
Establishes allowable residual
concentrations of radionuclides in
water. Included as TBC to ensure
adequate protection of human health
and the environment from sources of
radioactivity.
TBC
3A.1 Vit
3B.1 Vit
2C
DOE
Radiation Protection of the
Public and the Environment
(DCGs for Air)
DOE Order 5400.5 Chapter
111
Establishes allowable residual
concentrations of radionuclides in air.
Included as TBC to ensure adequate
protection of human health and the
environment from sources of
radioactivity.
TBC
3 A. 1 Vit
3B.1 Vit
2C
DOE
Residual Radioactive
Material (Interim Storage)
DOE Order 5400.5
Chapter IV 6.b
Establishes allowable concentrations of
radon-222 in air during interim storage
of waste material. Included as TBC to
ensure adequate protection of human
health and the environment from
sources of radioactivity.
TBC
B-l-3
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FEMP-OU4ROD-8 FINAL
December 1994
TABLE B.1-2
SUMMARY OF ARARs FOR OPERABLE UNIT 4
SELECTED REMEDIAL ACTION ALTERNATIVES
Location-Speci fie
Alternative
Regulatory
Program
Regulatory Title and
Citation
RegulatoryDescription
ARAR/TBC
3A.1 Vit
3B.1 Vit
2C
NEPA/
DOE
Compliance with
Floodplains/Wetlands
Environmental Review
Requirements
10 CFR§ 1022
(Executive Order 11990)
Establishes requirements for DOE to
evaluate potential adverse effects DOE
actions might have on wetlands.
A
3A.1 Vit
3B.1 Vit
2C
NEPA/
EPA
Endangered Species
Protection
50 CFR§ 402
(OAC 1518, 1513.25)
(OAC 1501-18-1-01)
Remedial actions must not jeopardize
the continued existence of any
endangered or threatened species, or
potential habitat of threatened or
endangered species.
R&A
2C
RCRA
Sub. D
Solid, Nonhazardous Waste
Disposal Facility Design
Considerations
OAC 3745-27-07
Establishes requirements for the
design, construction, and operation of
the proposed disposal facility for
Subunit C material.
R&A
2C
RCRA
Sub. D
Protection of Wetlands (Solid
Waste Disposal Facility)
40 CFR§ 258.12
Establishes restrictions on the location
of a solid waste disposal facility with
respect to potential impacts on
wetlands.
R&A
B-l-4
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FEMP-OU4ROD-8 FINAL
December 1994
TABLE B.l-3
SUMMARY OF ARARs FOR OPERABLE UNIT 4
SELECTED REMEDIAL ACTION ALTERNATIVES
Action-Specific
Alternative
Regulatory
Program
Regulatory Title and
Citation
Regulatory Description
ARAR/TBC
3 A. 1 Vit
3B.1 Vit
2C
CAA
Prevention of Air Pollution
Nuisance
ORC 3704.01-.05
OAC 3745-15-07
Requires control of emissions of air
pollutants during remediation that could
endanger health, safety, or welfare of
the public.
A
3A.1 Vit
3B.1 Vit
CAA
Control of Visible Particulate
Emissions from Stationary
Sources
OAC 3745-17-07
Establishes requirements to prevent
discharge of air emissions of a shade
or density greater than 20 percent
opacity during treatment operations.
A
3A.1 Vit
3B.1 Vit
2C
CAA
Control of Fugitive Dust
OAC 3745-17-08
Visible emissions of fugitive dust
generated during grading, loading, or
construction activities must be
minimized.
R&A
3A.1 Vit
3B.1 Vit
CAA
Restriction on Particulate
Emissions from Industrial
Processes
OAC 3745-17-11
Treatment operations shall maintain
emissions below specified particulate
material release limits.
A
3A.1 Vit
3B.1 Vit
2C
CWA
Nationwide Permit Program
33 CFR§ 330
Establishes requirements for dredge
and fill activities in jurisdictional
wetlands.
A
3 A. 1 Vit
3B.1 Vit
2C
CWA
Discharge of Storm Water
Runoff
40 CFR§ 122.26
Establishes requirements for monitoring
and controlling runoff from
construction sites greater than five
acres.
A
3 A. 1 Vit
3B.1 Vit
2C
CWA
Discharge of Treatment
System Effluent (Best
Management Practices)
40 CFR§ 125.100
40 CFR§ 125.104
Program establishes measures to
prevent releases from spills or runoff
during the implementation of remedial
actions.
R&A
3A.1 Vit
3B.1 Vit
2C
NEPA/
DOE
NEPA Implementation
10 CFR§ 1021
Requires NEPA evaluation and
documentation for DOE activities.
A
2C
RCRA
Sub. D
On-Site Solid Nonhazardous
Waste Management Facilities
(Design Standards)
40 CFR§ 241 Subpart B
(OAC 3745-27-08)
Establishes design criteria for the
proposed disposal facility for Subunit C
material.
R&A
B-l-5
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TABLE B.l-3
(Continued)
FEMP-OU4ROD-8 FINAL
December 1994
Alternative
Regulatoiy
Program
Regulatory Title and
Citation
Regulatory Description
ARAR/TBC
3 A. 1 Vit
3B.1 Vit
2C
RCRA
Sub. C
Hazardous Waste
Determinations
40 CFR§ 262.11
(OAC 3745-52-11)
Establishes procedures for identifying
material as hazardous waste so that it
may be stored, treated, and disposed in
accordance with RCRA requirements.
R&A
(This
requirement
will be
applicable
to non-
excluded
solid
wastes)
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
Management of Empty
Containers
40 CFR§ 261.7
(OAC 3745-51-7)
Requirements to ensure containers are
properly emptied and to ensure
residuals removed from the containers
are properly managed in accordance
with RCRA requirements.
R&A
3 A. 1 Vit
3B.1 Vit
RCRA
Sub. C
Generators Who Transport
Hazardous Waste for Off-Site
Treatment, Storage, or
Disposal
40 CFR§ 262.20 - 262.33
and 263.20-31
(OAC 3745-52-20 through 33
and OAC 3745-53-20
through 31)
Establishes standards for generators
shipping hazardous waste for off-site
treatment, storage, or disposal.
A
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
Treatment, Storage, or
Disposal (TSD) Facility
(General Standards)
40 CFR§ 264, Subpart B
(OAC 3745-54-13 through
16)
Establishes general standards for the
proper management of material
determined to be hazardous waste.
R&A
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
TSD Facility (Preparedness
and Prevention)
40 CFR§ 264, Subpart C
(OAC 3745-54-31)
40 CFR§ 264.32
(OAC 3745-54-32)
40 CFR§ 264.33
(OAC 3745-54-33)
40 CFR§ 264.34
(OAC 3745-54-34)
40 CFR§ 264.35
(OAC 3745-54-35)
40 CFR§ 264.37
(OAC 3745-54-37)
Establishes standards for preparedness
and prevention against fires,
explosions, or unplanned releases of
hazardous waste at TSD facilities.
R&A
B-l-6
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TABLE B.l-3
(Continued)
FEMP-OU4ROD-8 FINAL
December 1994
Alternative
Regulatory
Program
Regulatory Title and
Citation
Regulatoiy Description
ARAR/TBC
3 A. 1 Vit
3B.1 Vit
2C
RCRA
Sub. C
TSD Facility (Contingency
Plan and Emergency
Procedures)
40 CFR§ 264, Subpart D
40 CFR§ 264.51
(OAC 3745-54-51)
40 CFR§ 264.52
(OAC 3745-54-52)
40 CFR§ 264.55 and 56
(OAC 3745-54-55 through
56)
Establishes standards for contingency
plans and emergency procedures in
responding to fires, explosions, or
unplanned releases of hazardous waste
at TSD facilities.
R&A
2C
RCRA
Sub. C
Releases from Solid Waste
Management Units
40 CFR§ 264, Subpart F
(OAC 3745-54-91 through 99
and OAC 3745-55-01
through 011)
Establishes groundwater monitoring
requirements for assuring
concentrations of hazardous
constituents do not exceed regulatory
levels.
R&A
3 A. 1 Vit
3B.1 Vit
2C
RCRA
Sub. C
Closure
40 CFR§ 264, Subpart G
40 CFR§ 264.111,.114, and
.116
(OAC 3745-55-11,-14, and -
16)
Establishes closure requirements for
TSD facilities.
R&A
2C
RCRA
Sub. C
Post-Closure
40 CFR§ 264.117
(OAC 3745-55-17)
40 CFR§ 264.119
(OAC 3745-55-19)
Establishes requirements for the
protection of human health and the
environment following closure of the
facility.
R&A
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
Container Storage
40 CFR§ 264.171 - 178
Subpart I
(OAC 3745-55-71 through -
78)
Establishes standards for use and
management of containers of hazardous
waste.
R&A
3A.1
3B.1
RCRA
Sub. C
Tank Systems
40 CFR§ 264, Subpart J
(OAC 3745-55-91 through
96)
Establishes standards for the tank
systems used in the vitrification
treatment process.
R&A
3A.1 Vit
3B.1 Vit
RCRA
Sub. C
Closure Requirements for
Tanks
40 CFR§ 264.197
(OAC 3745-55-97)
Establishes closure and post-closure
requirements for tank systems.
R&A
2C
RCRA
Sub. C
Landfill Capping
40 CFR§ 264.310
(OAC 3745-57-10)
Establishes design standards for closure
of the proposed disposal facility for
Subunit C material.
R&A
B-l-7
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TABLE B. 1-3
(Continued)
FEMP-OU4ROD-8 FINAL
December 1994
Alternative
Regulatory
Program
Regulatory Title and
Citation
Regulatory Description
ARAR/TBC
3A.1 Vit
3B.1 Vit
RCRA
Sub. C
Miscellaneous Units
40 CFR§ 264, Subpart X
(OAC 3745-57-91 through
92)
Establishes standards for treatment,
storage, and disposal of hazardous
waste in miscellaneous units.
R&A
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
Corrective Action for
SWMUs (CAMU and TU)
40 CFR§ 264, Subpart S
40 CFR§ 264.552 -.553
Establishes requirements and criteria
for corrective action management units
for management of remediation waste
during remediation activities.
R&A
3A.1 Vit
3B.1 Vit
2C
RCRA
Sub. C
Containment Buildings
40 CFR§ 264, Subpart DD
Establishes standards for containment
buildings used for interim storage and
management of material determined to
be hazardous waste during remediation
activities.
R&A
2C
RCRA
Sub. C
Digging Where Hazardous or
Solid Waste Was Located
ORC 3734.02 (H)
Establishes post-remedial action
institutional controls for on-site
disposal of Subunit C material.
A
3A.1 Vit
3B.1 Vit
2C
SDWA
Ohio Water Well Standards
OAC 3745-9-10
Establishes standards for abandonment
of test borings, holes, and wells that
might be used and/or closed as part of
the remediation activities.
A
3A.1 Vit
AEA
Env. Rad. Protection Stds.
for Mgt. and Disposal of
HLRW, Spent Nuclear Fuel,
and TRU Wastes
40 CFR§ 191, Subpart A
40 CFR§ 191.03(b)
Establishes standards for management
and storage for disposal of material
from Subunit A to ensure the combined
annual dose equivalent to any member
of the public does not exceed specified
limits. (This requirement pertains to
only the on-site portion of this
alternative).
R&A
2C
UMTRCA
Standards for Control of
Residual Radioactive
Material
40 CFR§ 192, Subpart A
40 CFR§ 192.02(a)
Requires that controls for the residual
radioactive material in the proposed on-
site disposal facility be effective for
1000 years, where reasonably
achievable, or at least 200 years.
R&A
2C
UMTRCA
Standards for Cleanup of
Lands Contaminated with
Residual Radioactive
Materials
40 CFR§ 192, Subpart B
40 CFR§ 192.12(a)
Establishes standards for remedial
actions to ensure residual concentration
of radium-226 in soils does not exceed
regulatory levels.
R&A
3A.1 Vit
3B.1 Vit
2C
UMTRCA
Implementation of Health and
Environmental Protection
Standards for Uranium Mill
Tailings
40 CFR§ 192, Subpart C
Establishes guidance for remedial
activities involving control and cleanup
of residual radioactive material from
OU4.
R&A
B-l-8
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TABLE B. 1-3
(Continued)
FEMP-OU4ROD-8 FINAL
December 1994
Alternative
Regulatory
Program
Regulatory Title and
Citation
Regulatory Description
ARAR/TBC
3A.1 Vit
3B.1 Vit
2C
DOE
Order
Radiation Dose Limit (All
Pathways)
DOE Order 5400.5, Chapter
n,
Section l.a
Establishes limits for the allowable
exposure of the public to radiation
sources from all pathways as a result
of routine DOE activities. Included as
TBC. to ensure adequate protection of
human health and the environment
from sources of radioactivity.
TBC
B-l-9
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December 1994
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FEMP-OU4ROD-8 FINAL
December 1994
APPENDIX C
RESPONSIVENESS SUMMARY
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December 1994
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FEMP-OU4ROD-8 FINAL
December 1994
TABLE OF CONTENTS
Page
List of Tables c-ii
List of Acronyms c-iii
C.1.0 Purpose C-l-1
C.2.0 Public Involvement for the FEMP C-2-1
C.3.0 Community Participation for Operable Unit 4 C-3-1
C.4.0 Summary of Issues and Responses C-4-1
C.S.O Summary of Comments not Resulting in Issues C-5-1
Attachment C.I Written and Oral Comments C-I-l
Attachment C.n Errata Sheets and Changes to the Feasibility Study/
Proposed Plan - Draft Environmental Impact Statement C-II-1
Attachment C.III Final Environmental Impact Statement Distribution List C-III-1
Attachment C.IV Public Meeting Transcripts C-IV-1
LIST OF TABLES
Page
C.4-1 Formal Oral and Written Comments Received C-4-2
C.4-2 Impacts to the Public During Transportation of Vitrified Silos 1, 2 and 3
Waste to the NTS C-4-34
c-i
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FEMP-OU4ROD-8 FINAL
December 1994
AEA
BAT
CAB
CERCLA
CFR
DOE
DOE-FN
DOE-NV
DOT
EIS
EPA
FEIS
FEMP
FERMCO
FFC Act
FRESH
FS/PP-DEIS
HEAST
MAWS
NCP
NEPA
NOI
NTS
OAC
OATP
OEPA
OHPO
PEIC
RCRA
RI
RI/FS
ROD
STEP
TCLP
LIST OF ACRONYMS
Atomic Energy Act
Best Available Technology
Citizen's Advisory Board
Comprehensive Environmental Response, Compensation, and Liability Act
Code of Federal Regulations
United States Department of Energy
United States Department of Energy-Fernald Field Office
United States Department of Energy-Nevada Field Office
United States Department of Transportation
Environmental Impact Statement
United States Environmental Protection Agency
Final Environmental Impact Statement
Fernald Environmental Management Project
Fernald Environmental Restoration Management Company
Federal Facility Compliance Act
Fernald Residents for Environment, Safety, and Health
Feasibility Study/Proposed Plan-Draft Environmental Impact Statement
Health Effects Assessment Summary Table
Minimum Additive Waste Stabilization
National Oil and Hazardous Substances Pollution Contingency Plan
National Environmental Policy Act
Notice of Intent
Nevada Test Site
Ohio Administrative Code
Ohio Air Toxics Policy
Ohio Environmental Protection Agency
Ohio Historic Preservation Office
Public Environmental Information Center
Resource Conservation and Recovery Act
Remedial Investigation
Remedial Investigation/Feasibility Study
Record of Decision
Science, Technology, the Environment, and the Public
Toxicity Characteristic Leaching Procedure
c-ii
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FEMP-OU4ROD-8 FINAL
December 1994
C.1.0 PURPOSE
As stated in United States Environmental Protection Agency (EPA) Guidance on Preparing Superfund
Decision Documents (EPA 1989b), the responsiveness summary serves three important purposes.
First, it provides United States Department of Energy (DOE) with information about community
preferences regarding both the proposed remedial alternative and general concerns about the site.
Second, it demonstrates how public comments were integrated into the decision-making process.
Third, it allows DOE to formally respond to public comments.
The Feasibility Study/Proposed Plan/Draft Environmental Impact Statement was conditionally
approved on February 9, 1994. In May 1994, five final concerns were received from the EPA on the
document. In responding to these five concerns, several pages in the document were revised and are
included in Attachment C.II.
This Responsiveness Summary has been prepared pursuant to the terms of the 1991 Amended Consent
Agreement between DOE and the EPA, as well as other requirements, including:
• The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) as amended by the Superfund Amendments Reauthorization Act, 42 United
States Code, Sections 9601, et. seq.\
• National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 Code of
Federal Regulations (CFR), Part 300;
• Community Relations in Superfund: A Handbook, January 1992c, EPA/540/R-92/009;
and
• Guidance on Preparing Superfund Decision Documents: The Proposed Plan, The
Record of Decision, Explanation of Significant Differences, The Record of Decision
Amendment, Interim Final, July 1989b, EPA/540/G-89/007.
This Responsiveness Summary is used as the mechanism for DOE to identify and document the public
involvement with the Operable Unit 4 Feasibility Study/Proposed Plan - Draft Environmental Impact
Statement. After public comments and concerns had been formally submitted to DOE, in oral and
written form, the comments were summarized into issue statements and responded to accordingly.
The actual comments received are included in Attachment C.I of Appendix C.
C-l-1
-------
FEMP-OU4ROD-8 FINAL
December 1994
Section C.2.0 of this Responsiveness Summary gives an overview of public involvement for the
Fernald Environmental Management Project (FEMP). Section C.3.0 gives an overview of the public's
involvement in the development and approval of the Operable Unit 4 Feasibility Study/Proposed Plan
- Draft Environmental Impact Statement. Section C.4.0 discusses the development of the issue
statements and presents the public concerns and DOE responses. Section C.S.O presents comments
which did not result in issues.
C-l-2
-------
FEMP-OU4ROD-8 FINAL
December 1994
C.2.0 PUBLIC INVOLVEMENT FOR THE FEMP
Environmental issues at Fernald first became public in 1984 when the site reported that nearly 300
pounds of uranium oxide had been inadvertently released to the atmosphere from the Plant 9 dust-
collector system. It was also disclosed during this time that three privately-owned off-property
groundwater wells south of Fernald had been found to be contaminated with uranium in 1981. In
1984, the citizens group called Fernald Residents for Environment, Safety and Health (FRESH) was
formed and expressed concerns over these events and lack of public notification. In response to this
public concern, die FEMP initiated a community relations program in 1985 aimed at informing the
community of the mission of the facility and the ongoing and planned operations.
As part of this program, four community meetings were held in 1985 to open communication
channels with the members of the public residing near the FEMP. As a result of these meetings and
the need to prepare a community relations plan to support the planned Remedial Investigation/
Feasibility Study (RI/FS), a community assessment was conducted in early 1986. The community
assessment consisted of a series of interviews with local community members to defme their
informational needs, their concerns regarding the environmental issues at the site, and viable
mechanisms to gain public involvement in the RI/FS decision-making process. As work on the RI/FS
continued, DOE authorized the opening of an information repository called the Public Environmental
Information Center (PEIC) in the JAMTEK building, 10845 Hamilton-Cleves Highway, Harrison,
Ohio 45030. The administrative record, on which cleanup decisions are based, is also located at the
JAMTEK building; another administrative record is maintained at EPA Region V headquarters in
Chicago, Illinois.
A RI/FS Community Relations Plan was issued in January 1986 detailing the initiatives that would be
undertaken by the FEMP to promote community participation in the RI/FS decision-making process.
This plan has been progressively revised, as necessary, to accommodate regulatory agency input, the
changing concerns of the community, and emerging concepts on improved vehicles for facilitating
community participation.
On May 15, 1990, a Notice of Intent (NOI) was published [55 Fed. Rey. 20183 (May 15, 1990)]
indicating the intent of DOE to prepare an Environmental Impact Statement (EIS) consistent with the
National Environmental Policy Act (NEPA) to evaluate the environmental impacts associated with the
cleanup actions for the lead FEMP operable unit (i.e., Operable Unit 4). The NOI further defined the
C-2-1
-------
FEMP-OU4ROD-8 FINAL
December 1994
intent of DOE to prepare integrated CERCLA/NEPA documents for the remaining operable units that
will tier from the lead document. The public, interested organizations, and federal, state, and local
agencies were invited to provide oral comments at two EIS scoping meetings held on June 12-13,
1990, and to submit written comments until the close of the scoping period on June 29, 1990.
As a result of the scoping meetings, an EIS Implementation Plan was issued by DOE. The EIS
Implementation Plan includes: a description of the proposed actions and remedial alternatives; a list of
environmental issues to be considered in the EIS (including those identified during the scoping
period); a list of proposed agency consultations; a responsiveness summary to comments received
during scoping; and a discussion on the interrelationship between the NEPA compliance process and
CERCLA project planning and decision-making. Consistent with the NOI and the EIS
Implementation Plan, the resulting integrated process and documentation package developed for
Operable Unit 4 is termed a Feasibility Study/Proposed Plan-Draft Environmental Impact Statement
(FS/PP-DEIS).
In summary, several community relations activities are and have been conducted in support of local
organizations at Fernald including:
• A community assessment (June - July 1989);
• A Community Relations Plan (August 1992 version approved October 15, 1992);
• Public reading rooms and administrative record;
• Regular briefings at local township trustee meetings;
• Presentations to the local community group, FRESH;
• Community meetings held approximately each quarter;
• Workshops and roundtable discussions for interested parties;
• Press releases, fact sheets and a newsletter;
• Public comment periods for decision documents and responsiveness summaries;
• Site tours, as requested;
• Open house events;
• Annual joint emergency response exercises;
• Annual environmental monitoring reports; and
• The Fernald Citizens Task Force.
C-2-2
-------
FEMP-OU4ROD-8 FINAL
December 1994
C J.O COMMUNITY PARTICIPATION FOR OPERABLE UNIT 4
As indicated earlier, a community assessment was conducted in early 1986 which consisted of a series
of interviews with local community members to define their informational needs, their concerns
regarding the environmental issues at the site, and viable mechanisms to gain public involvement in
the RI/FS decision process. Significant concerns associated with Operable Unit 4 facilities identified
during these interviews included:
• The significantly elevated direct penetrating radiation field in the vicinity of the silos.
• The chronic emissions of significant quantities of the radioactive gas, radon, to the
atmosphere from the silos.
• The structural instability of the silos' domes and the age of the remaining portions of the
structures.
• The potential for leaching of the stored residues to the underlying sole-source aquifer.
To adequately identify and address community concerns, several initiatives have been undertaken by
the FEMP to ensure community involvement in the decision-making process for the remediation of
Operable Unit 4.
The draft Remedial Investigation (RI) Report for Operable Unit 4 was released to the public for
review and comment in April 1993. The document was made available to the public at the PEIC and
the EPA offices in Chicago. The notice of availability for the RI Report for Operable Unit 4 was
published in local newspapers near the FEMP site on April 19, 1993. A public comment period was
conducted for the RI Report for Operable Unit 4 from April 19, 1993 through May 19, 1993. No
comments were received on the RI Report for Operable Unit 4.
On September 9, 1993, the draft Feasibility Study/Proposed Plan-Draft Environmental Impact
Statement was made available at the Public Environmental Information Center, and stakeholders were
encouraged to provide informal comments on the preliminary documents. Encouraging public
inspection and informal comment on these preliminary documents, prior to EPA approval, provided a
genuine opportunity for stakeholders to identify issues, voice their concerns and learn about proposed
cleanup plans for Operable Unit 4. The informal opportunity for the public to provide input enabled
DOE to address some stakeholder questions and concerns in advance of the formal public comment
period.
C-3-1
-------
FEMP-OU4ROD-8 FINAL
December 1994
On October 14, 1993, approximately 29 stakeholders attended a public roundtable on "Proposed Plans
and Technology for Operable Unit 4 Remediation." At the roundtable, attendees were invited to offer
opinions on the draft final Proposed Plan and the preferred alternative for Operable Unit 4
remediation. These stakeholder comments were documented and evaluated during preparation of the
final document.
In addition, a two-way information exchange on the Operable Unit 4 Risk Assessment occurred at the
October 19, 1993, Science, Technology, the Environment and the Public (STEP) session on "Risk."
Again, Fernald personnel addressed the stakeholders' questions and concerns presented at the
meeting. Information about the Operable Unit 4 Remedial Investigation Report was also provided at
DOE's October 21, 1993, RI/FS public meeting and at local township trustee meetings.
In response to stakeholder requests at the January 5, 1994, formal public hearing on the Operable
Unit 3 (Production Area) Interim Record of Decision, a public roundtable to discuss integration of
CERCLA and NEPA was held January 24, 1994. The roundtable included discussions on differences
between environmental assessments and environmental impact statements; approximately 45
stakeholders attended.
On February 21, 1994, invitations to attend the March 21, 1994, formal public hearing on the
Operable Unit 4 FS/PP-DEIS were mailed to approximately 2,000-plus Fernald stakeholders. The
Proposed Plan for Remedial Actions at Operable Unit 4 Fact Sheet was enclosed with each invitation.
On February 24, 1994, advance copies of the Proposed Plan for Remedial Actions at Operable Unit 4
were mailed to several key stakeholders. Also on February 24, copies of the final FS/PP-DEIS and
Proposed Plan fact sheets were mailed to the United States Department of Energy-Nevada Field
Office (DOE-NV) and to the State of Nevada Clearinghouse. The DOE Operable Unit 4 Branch
Chief personally distributed several advance copies of the Proposed Plan to attendees of the February
24, 1994, FRESH meeting. In addition, she provided an update on Operable Unit 4 activities, plans
and progress, and was available for an informal question-and-answer session.
To encourage stakeholders to review and offer input on the final FS/PP-DEIS, a Notice of
Availability for formal public comment was published in March 1994 in the Federal Register and
three local newspapers: The Cincinnati Enquirer, the Journal-News and The Harrison Press. On
March 1, 1994, the, FS/PP-DEIS became available at the PEIC.
C-3-2
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FEMP-OU4ROD-8 FINAL
December 1994
On March 2, 1994, Ohio EPA representatives discussed the FS/PP-DEIS with members of the
Fernald Citizens Task Force and FRESH.
On March 4, 1994, a Fernald site news release titled "Key Fernald Cleanup Plan Receives
Conditional EPA Approval" was sent to local electronic and print media, as well as local elected
officials, FRESH and the Fernald Citizens Task Force. Articles were published in local newspapers.
On March 7, 1994, the formal 45-day public comment period on the Operable Unit 4 FS/PP-DEIS
officially began.
On March 8, 1994, Fernald representatives met formally with officials of the DOE-NV and the
Nevada Division of Environmental Protection and provided a presentation on the Operable Unit 4
FS/PP-DEIS.
On March 15, 1994, postcard reminders about the March 21, 1994, formal public hearing were
mailed to Fernald stakeholders. In addition, courtesy phone calls were made to key stakeholders,
inviting them to the formal public hearing.
Display advertisements announcing the March 21, 1994, formal public hearing were published in
three local newspapers: The Gncirmati Enquirer, March 18, 1994 and March 20, 1994; the
Cincinnati Post, March 18, 1994; and the Journal-News, March 18, 1994.
On March 21, 1994, approximately 80 people attended the formal public hearing on the Operable
Unit 4 FS/PP-DEIS. Formal oral public comments were documented by a court reporter and are
available in a written transcript at the PEIC and in Attachment C.IV of Appendix C. In addition,
several stakeholders submitted formal written comments. All formal written and oral stakeholder
comments and questions asked informally during the March 21, 1994, public hearing, as well as
DOE's responses, are documented in the Operable Unit 4 Responsiveness Summary.
During April 1994, the DOE received a request from the State of Nevada to extend the public
comment period for sixty (60) days to allow a newly formed Citizen's Advisory Board (CAB)
additional time to review and comment on the Operable Unit 4 FS/PP-DEIS. In accordance with the
requirements of the NCP and the Amended Consent Agreement, the DOE granted a 30-day extension
of the public comment period from April 20, 1994 to May 20, 1994 to accommodate this request.
C-3-3
-------
FEMP-OU4ROD-8 FINAL
December 1994
On May 11, 1994, the DOE-NV conducted a public meeting in Las Vegas, Nevada. In attendance
were members from the DOE, EPA (Region V), Ohio EPA, CAB and the public. This meeting was
the first meting of the newly-organized CAB. As part of the meeting's agenda, the DOE conducted
two presentations. One of the presentations, furnished by the DOE-FN, discussed the Operable Unit
4 FS/PP-DEIS and summarized the proposal to transport and dispose of low-level radioactive wate,
which would be generated by the cleanup and environmental restoration of the FEMP site as a whole
(including Operable Unit 4), at the NTS. The other presentation was furnished by the DOE-NV
which summarized the current low-level radioactive waste management program at the NTS.
Each presentation was followed by a formal question and answer session, during which the following
concerns were discussed:
• Adequacy of characterization process of all FEMP waste shipped to the NTS.
• Classification of the K-65 by-product material as 11(e)(2) material.
• Availability of any alternative disposal sites for the Operable Unit 4 remedial wastes.
• 40 CFR §191 "relevance" to Operable Unit 4 remedial wastes by EPA.
• Transportation and containerization of the Operable Unit 4 remedial wastes.
• Benefits to be derived by the State of Nevada for disposing of the waste at the NTS.
The complete transcript of this meeting is included in Attachment C.IV of Appendix C.
During the meeting, the CAB noted that they had not received a copy of the Operable Unit 4 FS/PP-
DEIS for review and comment. It was noted that a copy of the Operable Unit 4 FS/PP-DEIS was
available in the DOE-NV Reading Room. Copies of the Proposed Plan and Proposed Plan Fact Sheet
were distributed to members at the meeting. A copy of the Operable Unit 4 FS/PP-DEIS was
provided to the CAB on May 12, 1994.
In addition, the CAB verbally requested in the meeting that the comment review period for the
Operable Unit 4 FS/PP-DEIS be extended an additional thirty days to provide the CAB adequate time
to review the document. Subsequently, on May 19, 1994, DOE submitted to EPA a second request
for extension in the submittal of the Operable Unit 4 ROD. The EPA reviewed this request pursuant
to Section XVIII of the 1991 ACA, which requires EPA to determine whether good cause exists for a
schedule extension based upon, among other things, information submitted by DOE. In response to
the CAB request, the DOE on May 20, 1994 formally granted the thirty-day extension of the public
C-3-4
-------
FEMP-OU4ROD-8 FINAL
December 1994
comment period from May 20, 1994 to June 19, 1994. On May 26, 1994, the EPA granted the 30-
day extension for submittal of the Proposed Draft ROD from July 10, 1994, to August 9, 1994.
On August 8, 1994, DOE submitted the Proposed Draft Record of Decision for Remedied Actions at
Operable Unit 4 and the Responsiveness Summary to the EPA.
C-3-5
-------
FEMP-OU4ROD-8 FINAL
December 1994
{This page intentionally left blank}
-------
FEMP-OU4ROD-8 FINAL
December 1994
C.4.0 SUMMARY OF ISSUES AND RESPONSES
The FS/PP-DEIS for Operable Unit 4 was released for public comment in March 1994. The DOE
reviewed all written and oral comments submitted during the public comment period. Upon review of
these comments, it was determined that no significant changes to the remedy, as was originally
identified in the Operable Unit 4 FS/PP-DEIS, were necessary.
This Responsiveness Summary document has focused on the formal comments submitted during the
public comment period and oral comments received during the March 21, 1994 community meeting
held in Harrison, Ohio and the May 11, 1994 public meeting held in Las Vegas, Nevada. Within this
Responsiveness Summary, oral and written comments (see Attachment C.I) were categorized into
significant issues. For each of these issues, an issue statement has been prepared that addresses the
concerns expressed by one or more of the commentors. In many instances, the issue statements are
paraphrased from the original comments to succinctly represent the combined concerns of several
commentors. The issues resulting from formal comments have been compared with the questions
raised during the public question and answer sessions to ensure that all significant issues have been
represented by the issue statements.
For the purpose of developing issue statements, a comment is considered significant if it involves:
• The definition of the preferred alternative,
• Public or state acceptance of the preferred alternative,
• The implementation or impacts of the preferred alternative,
• Conclusions drawn from evaluations or assessments provided within the document,
• Safety of the work performed, or the
• Enforceability of the decision reached.
At the end of each issue statement, the specific comment Ietter(s)or oral comments) in which the
issue was raised is identified in parentheses. The comments are referred to by an alphabetic
identifier. These comments are also part of the administrative record for this action. Table C.4-1
provides a cross-reference of the alphabetic identifiers with the commentors.
C-4-1
-------
FEMP-OU4ROD-8 FINAL
December 1994
TABLE C.4-1
FORMAL ORAL AND WRITTEN COMMENTS RECEIVED
—
1 ITEM
COMMENTOR
PAGE
NUMBER
Ij ^ FORMAL ORAL COMMENTS
A
Norma Nungester, resident and FRESH member
C-I-8
B
Vicky Dastillung, resident and FRESH Vice President
C-I-19
C
Lou Bogar, resident, Hamilton, Ohio
C-I-20
D
Edwa Yocum, resident and FRESH Secretary
C-I-28
—
n* *~ h FORMAL WRIlTfcN COMMfcNTS
E
Maud Naroll, State of Nevada, State Clearinghouse (April 18, 1994)
C-I-31
F
Jack and Roberta Warndorf, resident, Okeana, Ohio
C-I-34
0
Edwa Yocum, resident and FRESH Secretary, Harrison, Ohio
C-I-35
H
J. E. Walther, resident, Hamilton, Ohio
C-I-36
I
Martha J. Raymond, Department Head, Technical Review Services, Ohio
Historic Preservation Office
C-I-38
J
Lisa Crawford, resident and FRESH President
C-I-40
K
Lawrence L. Stebbins, resident, Hamilton, Ohio
C-I-41
L
Maud Naroll, State of Nevada, State Clearinghouse (April 5, 1994)
C-I-43
M
James K. O'Steen, Director, Office of Hazardous Materials Technology, U.S.
Department of Transportation
C-I-45
N
William L. Vasconi, Acting Chairman, Nevada Test Site Citizens Advisory
Board
C-I-47
0
Nevada Test Site Citizens Advisory Board
C-I-48
P-l
Nichole Davis, 1600 E. University #151, Las Vegas, NV 89119
C-I-49
1
P-2
Shellie Michael, 2800 S. Eastern #717, Las Vegas, NV 89109
C-I-49
P-3
Lynn Rohl, P.O. Box 12303, Las Vegas, NV 89112
C-I-50
Ted Mucha, 301 Orland #8, Las Vegas, NV 89107
C-I-50
P-5
Mark Michael, 2800 S. Eastern #717, Las Vegas, NV 89109
C-I-51
P-6
Kathleen Guise, 4124 Seville St., Las Vegas, NV 89121
C-I-51
P-7
Jo Anne Moran, 3128 E. Flamingo #203, Las Vegas, NV 89121
C-I-52
P-8
Catherine A. McLaughlin, 1721 Howard Ave., Las Vegas, NV 89104
C-I-52
P-9
Nancy Gott, 3212 Brahns Dr., Las Vegas, NV 89102
C-I-53
P-10
Rebecca Webber, 5070 River Glen Dr. #457, Las Vegas, NV 89103
C-I-53
P-ll
Tanya Carr, 2032 Shadow Brook Way, Las Vegas, NV 89014
C-l-54
P-12
Jim Macklin, 5178 Silverheart Ave., Las Vegas, NV (no zipcode provided)
C-I-54
C-4-2
-------
FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
1 P-13
Cindy Weatherby, 1760 N. Decatur #69, Las Vegas, NV 89108
C-I-55 |
I P"14
Rebecca Heider, 6941 W. Forest Vista St., Las Vegas, NV 89117
C-I-55 1
P-15
Troy Weatherby, 1760 N. Decatur #69, Las Vegas, NV 89108
C-I-56 |
P-16
Abraham Hartman, 1872 Pasadena Blvd., Las Vegas, NV 89115
C-I-56
P-17
Vicki Cassman, P.O. Box 72634, Las Vegas, NV 89170
C-I-57
P-18
Art Goldberg, 14810 Living Desert Dr., Las Vegas, NV 89119
C-I-57
P-19
Jillian Beth Wright, 6435 lorn Bark Lane (address provided incomplete)
C-I-58
P-20
Linda Strange, 4830 Nara Vista Way #102, Las Vegas, NV 89103
C-I-58
P-21
Ronnie Strange, 4830 Nara Vista Way #102, Las Vegas, NV 89103
C-I-59
P-22
Mindy Brummett, 6397 Spring Meadow Dr., Las Vegas, NV 89103
C-I-59
P-23
LaLori Rossi, 1929 Franklin Ave. (address provided incomplete)
C-I-60
P-24
Taryn Cunningham, 7383 Newcrest Cir., Las Vegas, NV 89117
C-I-60
P-25
Tiffany Brummett, 6397 Spring Meadow Dr., Las Vegas, NV 89103
C-I-61
P-26
Janet Zimmerman, 1912 Spangle Dr., Las Vegas, NV 89108
C-I-61
P-27
Janene Zimmerman, 1912 Spangle Dr., Las Vegas, NV 89108
C-I-62
P-28
Patricia Bishop, 1400 S. Casino Ct. #19, Las Vegas, NV 89104
C-I-62
P-29
Daniel J. Fedor, 185 Swaab, Las Vegas, NV 89115
C-I-63
P-30
Michael Carrigan, 7217 Tempest PI., Las Vegas, NV 89128
C-I-63
P-31
Renee Halm, 1000 King Richard, Las Vegas, NV 89119
C-I-64
P-32
Tubiola Lopez, 1508 Living Desert Dr., Las Vegas, NV 89119
C-I-64
P-33
Doreina Saenz, 2111 Fairfield #6, Las Vegas, NV 89102
C-I-65
P-34
Jerome Brenberg, 5668 Divot PL, Las Vegas, NV 89130
C-I-65
P-35
Ravon Rodriguez, 538 Kolson Cr. #"A" (address provided incomplete)
C-I-66
P-36
Carmen E. Rodriguez, 538 Kolson Cr. #"A" (address provided incomplete)
C-I-66
P-37
Kimba Rutledge, 399 Steelhead Lane, Las Vegas, NV 89110
C-I-67
P-38
Sheila Rutledge, 399 Steelhead Ln., Las Vegas, NV 89110
C-I-67
P-39
S. Humhe, 9285 Sunten Ct., Las Vegas, NV (address provided incomplete)
C-I-68
P-40
Michelle Lynn Berry, 370 E. Harmon Apt. E310, Las Vegas, NV 89109
C-I-68
P^l
L. Jean McCoy, 6710 Wild Horse Rd., Las Vegas, NV 89108
CrI-69
PA2
Tammy Smith, 6710 Wild Horse Rd., Las Vegas, NV 89108
C-I-69
P-43
Henry B. (?), 1982 N. Rainbow #194, Las Vegas, NV 89108 (name
unreadable)
C-I-70
P-44
Stan Greene, 7845 La Cienega, Las Vegas, NV 89123
C-I-70
C-4-3
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-45
Frances Bruno, 486 Sierra Vista Dr. #24 (address provided incomplete)
C-I-71
P-46
Betty Hay, 1241 South 7th St., Las Vegas, NV 89104
C-I-71
P-47
David Geerts, 3940 S. Algonquin Dr. #83, Las Vegas, NV 89119
C-I-72
P-48
John Engle, 4441 Escondido St. Apt. #4205 (address provided incomplete)
C-I-72
P-49
Alison Orr, 7053 Cheerful Circle, Las Vegas, NV 89117
C-I-73
P-50
David Gohas, P.O. 46204, Las Vegas, NV 89114
C-I-73
P-51
Finu Norris-Coray, 4801 Spencer #56, Las Vegas, NV 89119
C-I-74
P-52
Elizabeth Petit, 2362 N. Green Valley Parkway #141P, Henderson, NV 89014
C-I-74
P-53
Sonja Swenson, 4444 Midway Lane, Las Vegas, NV 89108
C-I-75
P-54
Ron Schaefer, 3950 Mountain Vista #146, Las Vegas, NV 89121
C-I-75
P-55
Victoria Pinkston, 1771 Charnut Lane (address provided incomplete)
C-I-76
P-56
Kathy Granousky, 3355 Dakota Way, Las Vegas, NV 89109
C-I-76
P-57
Emilee Rogers, 1105 Washington (address provided incomplete)
C-I-77
P-58
Michael LoCorriere, 7201 W. Girard Drive, Las Vegas, NV 89117
C-I-77
P-59
Sheri LoCorriere, 7201 W. Girard Drive, Las Vegas, NV 89117
C-I-78
P-60
Breck Nester, 24252 Sparrow, El Toro, CA 92630
C-I-78
P-61
Dana Robbins, 5028 S. Rainbow #101, Las Vegas, NV 89118
C-I-79
P-62
Huy Phan, 3719 Central Park Circle, #4 (address provided incomplete)
C-I-79
P-63
Sandra Travez, 30 Tierra Buena Drive, Las Vegas, NV 89110
C-I-80
P-64
Steve Zahn, 8305 Greshen, Las Vegas, NV (no zipcode provided)
C-I-80
P-65
Lisa Nunaq, 1009 Spire CNYN, Las Vegas, NV 89128
C-I-81
P-66
Tim Jaqua, 3273 E. Flamingo #102, Las Vegas, NV 89121
C-I-81
P-67
Shelli McKenney, 4640 Victoria Beach Way, Las Vegas, NV (no zipcode
provided)
C-I-82
P-68
Carmen Davis, 6666 W. Washington #463, Las Vegas, NV 89107
C-I-82
P-69
Nasreen Bakhtary, 2165 E. Rochelle #71, Las Vegas, NV 89119
C-l-83
P-70
Maribel McAdory, 2529 Pacific Avenue, Las Vegas, NV (no zipcode provided)
C-I-83
P-71
Merlinda Gollegos, 5625 W. Flamingo #2005, Las Vegas, NV 89103
C-I-84
P-72
Chad Hunt, 8222 Beaverbrook Way, Las Vegas, NV 89123
C-I-84
P-73
Barb Brentz, 1015 Franklin Avenue, Las Vegas, NV 89104
C-I-85
P-74
Mayte Villanueva, 1805 Evelyn Avenue, Henderson, NV 89015
C-I-85
P-75
James Min, 5315 Heatherbrook Circle, Las Vegas, NV 89120
C-I-86
P-76
David Johnson, 3632 Hamlin, Las Vegas, NV 89030
C-I-86
C-4-4
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-77
Laura Yada, 4770 Gym Road, Las Vegas, NV 89119
C-I-87
P-78
Shannon Conners, 1213 Sloop Drive, Las Vegas, NV 89128
C-I-87
P-78
Sherri Caron, 3913 Courtside, Las Vegas, NV 89105
C-I-88
P-80
Stevi Carroll, 6505 Burgundy Way, Las Vegas, NV 89107
C-I-88
P-81
Margaret Bean, 3060 Ramrod, Las Vegas, NV 89108
C-I-89
P-82
Patrice L. Harvey, 7412 Summer Crest Lane, Las Vegas, NV 89129
C-I-89
P-83
Robin Wayne, 3400 Turquoise Road, Las Vegas, NV 89108
C-I-90
P-84
George A Bean, 3060 Ramrod Street, Las Vegas, NV 89108
C-I-90
P-85
Robert Pierson, 2974 Liberty Avenue, Las Vegas, NV 89121
C-I-91
P-86
Tim Bartlett, 4504 Fireside Lane, Las Vegas, NV 89110
C-I-91
P-87
Selma and Chuck Umnuss, 8504 Glenmount Drive, Las Vegas, NV 89134-
8648
C-I-92
P-88
Rob Marchant, 650 Whitney Ranch, Henderson, NV (no zipcode provided)
C-I-92
P-89
Jeff Van Ee, 2092 Heritage Oaks, Las Vegas, NV 89119
C-I-93
P-90
Tiffany Braun, 1635 Westwind Circle (address provided incomplete)
C-T-93
P-91
Jeffrey M. Steinbeck, 294 Davis Hill Court, Henderson, NV 89014
C-I-94
P-92
Catherine Tillman, 3107 Lamega Drive, Henderson, NV 89014
C-I-94
[ P-93
Madelaine Dayton, 2253 Castleberry, Las Vegas, NV 89115
C-I-95
J P-94
Lori Johnson, 274 Camino Verde, Henderson, NV 89014
C-I-95
P-95
Sharlyn Anderson, 551 Eiger Way #1312, Henderson, NV 89014
C-I-96 1
I p"96
Kathleen Womack, 5652 S. Latigo, Las Vegas, NV 89119
C-I-96
P-97
S. Gomez, 4255 Tamarus #286, Las Vegas, NV 89119
C-l-97
P-98
Melony Haynes, 1308 N. Jones, Las Vegas, NV 89108
C-I-97 |
P-99
Michele Gilbreth, 2391 Callahan Avenue, Las Vegas, NV 89119
C-I-98 |
P-100
Mary E. July, 5250 E. Lake Mead #26, Las Vegas, NV 89115
C-I-98 J
P-101
Grace K. Tao, P.O. Box 60384, Boulder City, NV 89005
C-I-99 |
P-102
Julia L. Winkler, 1127 E. Toni Avenue #18, Las Vegas, NV 89119
C-I-99 |
P-103
John Heormey, 419 Desert Inn Road, Las Vegas, NV (address provided
incomplete and last name hard to read)
C-I-100
P-104
James Holmes, 604 Freeman (address provided incomplete)
C-l-100
P-105
Merlyn Huguet, 2021 Peyton, Las Vegas, NV 89104
C-I-101
P-106
Barbara Roth, 112 Temple Drive, Las Vegas, NV 89107
C-I-101 I
P-107
John Wells, 6983 Antell Circus, Las Vegas, NV (address provided incomplete)
C-I-102 I
C-4-5
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-108
A1 Roth, 112 Temple Drive, Las Vegas, NV 89107
C-I-102
P-109
Louis Lavietes, 3401 E. Bonanza Road (address provided incomplete)
C-I-103
P-110
Jeff Cooley, 8257 Bermuda Beach Drive, Las Vegas, NV 89128
C-I-103
P-lll
James P. Foster, 817 Lauren Patt, Henderson, NV 89104
C-I-104
P-112
Giovanni Duley, 6251 Viewpoint Drive, Las Vegas, NV 89115
C-I-104
P-113
Trisa Higgins, 1075 Legato Drive, Las Vegas, NV 89123
C-I-105
P-114
Maggie Breki, 3237 E. Flamingo, Las Vegas, NV 89121 (last name hard to
read)
C-I-105
P-115
Joel Delmendo, 3138 Gaucho Drive, Las Vegas, NV 89008 (zip code hard to
read)
C-I-106
P-116
Katherine Garder, 5050 Tamanas #267, Las Vegas, NV 89119
C-I-106
P-117
Jason Benatz, 6317 Hobart, Las Vegas, NV 89107
C-I-107
P-118
Ebony Samerkand, 549 Kristin Lane, Henderson, NV 89015
C-I-107
P-119
Stacy Smith, 4223 Grove Circle #4, Las Vegas, NV 89119
C-I-108
P-120
Sanena Shelling, 1445 E. Rochelle (address provided incomplete)
C-I-108
P-121
Gerald F. Cuetkovic, 135 Grandview Drive, Henderson, NV 89015
C-I-109
P-122
Judy Cuetkovic, 135 Grandview Drive, Henderson, NV 89015
C-I-109
P-123
Michael Cuetkovic, 135 Grandview Drive, Henderson, NV 89015
C-I-110
P-124
Mrs. G. Michakel, 4079 El Segundo Avenue, Las Vegas, NV 89121-1703
C-I-110
P-125
Willene De Langis, 758 Willow Avenue, Henderson, NV 89015
C-I-lll
P-126
Donald A. De Langis, 758 Willow Avenue, Henderson, NV 89015
C-I-lll
j P-127
Robert Tonelli, 1004 University Ridge, Reno, NV (no zipcode provided)
C-I-112
P-128
Ruth Lindahl, 9457 S. Las Vegas Blvd. S. #93, Las Vegas, NV 89123
C-I-112
P-129
Melody Derrick, 330 S. 10th St., Las Vegas, NV 89107
C-I-113
P-130
Doug Jablin, 3559 Markan St., Las Vegas, NV 89121
C-I-113
P-131
Anthony Bondi, 135 Albert Avenue St. E. #16, Las Vegas, NV (no zipcode
provided)
C-I-114
P-132
T. Jones, Box 73215, Las Vegas, NV 89170
C-I-114
P-133
John A. Loeffler, P.O. Box 832, Searchlight, NV 89046
C-I-l 15
P-134
Christopher Mercer, 2517 Huber Hts., Las Vegas, NV 89128
C-I-l 15
P-135
Kurt Buchida, 325 Maryland Parkway, Las Vegas, NV 89101
C-I-l 16
P-136
Liz Marion, 6824 Adobe Court, Las Vegas, NV 89102
C-I-l 16
P-137
Dennis A. Dewitt, Box 5371, Reno, NV 89513
C-I-l 17
C-4-6
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
| P-138
Brenda Weksler, 7904 Marbella Circle, Las Vegas, NV 89128
C-I-l 17
1 P-139
Cheryl Frossa, 3450 Erva St. #101, Las Vegas, NV 89117
C-I-l 18
1 P-140
Harriet R. Gagliano, 2713 Gilmary Avenue, Las Vegas, NV 89102
C-I-118
P-141
Kathy Poma, 2113 Fountain Springs Drive, Henderson, NV 89014
C-I-l 19
P-142
Stacey Hallenberg, 2245 Maple Rose Drive, Las Vegas, NV 89134
C-I-l 19
I P-143
Kelli Koerwitz, 909 Willowtree, Las Vegas, NV 89128
C-I-l 20
P-144
Trish Taylor, 2113 Fountain Springs Drive, Henderson, NV 89014
C-I-l 20
P-145
Heather Davis, 2031 E. Windmill Lane, Las Vegas, NV 89123
C-I-121
P-146
Marilyn Benoit, 3461 Pointe Willow, Las Vegas, NV 89120
C-I-121
P-147
Richard Lewnau, 2950 S. Decatur D-3, Las Vegas, NV 89102
C-1-122 J
P-148
Susan Thornton, 1412 Golden Spur Lane, Las Vegas, NV 89117
C-I-l 22 1
P-149
Lee Dazey, 72 Keystone Avenue, Reno, NV 89503
C-1-123 [
P-150
Pete Mastin, P.O. Box 92, Verdi, NV 89439
C-1-123
P-151
Tracie K. Lindeman, P.O. Box 1672, Fallon, NV 89407
C-I-l 24
P-152
David L. Platerio/Tosa-wi-e, P.O. Box 822, Elko, NV 89803
C-I-l 24
P-153
Jo Ana Garrett, P.O. Box 130, Baker, NV 89311
C-I-l 25
P-154
Margaret Norman, 2332 Grant Street, Berkeley, CA 94703
C-I-l 25
P-155
Judy Treichel, 3926 Bushnell Drive #71, Las Vegas, NV 89103
C-I-l 26
P-156
Lorry C. Johns, 2090 Westwind Road, Las Vegas, NV 89102
C-I-l 26
P-157
Steve Frishman, 208 N. Hwy. 95A, Yerington, NV 89447
C-I-127
P-158
William Rosse Sr., HC61 Box 6240, Austin, NV 89310-9301
C-I-l 27
P-159
Corbin Hanuf (?), P.O. Box 1255, Nevada City, CA 95959 (name was hard
to read)
C-I-128
P-160
Shawn Black, 650 Whitney Ranch #1423, Las Vegas, NV (no zipcode
provided)
C-I-128
P-161
Lawrence Skinner, 1604 E. Evans, Las Vegas, NV 89030
C-I-129
P-162
Mary L. Johns, 2090 Westwind Road, Las Vegas, NV 89102
C-I-l 29
P-163
Bob Fulkerson, 725 McDonald Drive, Reno, NV 89503
C-I-l 30 |
P-164
Carla Baker Wallace, 3245 Mallard, Las Vegas, NV 89107
C-I-l 30
P-165
Louise (?), 4255 Tamarus #217, Las Vegas, NV 89119 (name was hard to
read)
C-I-l 31
P-166
Margaret (?), 1526 Darryl Avenue, Las Vegas, NV 89123
C-I-l 31
P-167
(?), 1526 Darryl Avenue, Las Vegas, NV 89123 (name unreadable)
C-I-l 32
C-4-7
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-168
(?), 1381 E. University Avenue (address incomplete and name unreadable)
C-I-132
P-169
(?), 4801 Spencer #56, Las Vegas, NV 89119 (name unreadable)
C-I-133
P-170
(?), 1431 E. Charleston, Las Vegas, NV 89104 (name unreadable)
C-l-133
P-171
Jamie B. (?), 4630 White Rock Drive, Las Vegas, NV 89121 (name
unreadable)
C-I-134
P-172
(name and address unreadable)
C-I-134
P-173
(name and address unreadable)
C-I-135
P-174
(left blank)
C-I-135
P-175*
Geoff Holton, 2332 Grant Street, Berkeley, CA 94703
C-I-136
P-176"
Richard Glasman, 2212 18th Avenue South, Seattle, WA 98144
C-I-136
P-177"
Kathleen Glasman, 2212 18th Avenue South, Seattle, WA 98144
C-I-137
Q
Pam Dunn, Harrison, OH
C-I-138
R
Thomas A. Schneider, Ohio Environmental Protection Agency
C-I-145
•
Michael W. MacMullen, U.S. EPA Region 5, Planning and Management
Division
C-I-147
"Postcards were received by the DOE on July 5, 1994.
C-4-8
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FEMP-OU4ROD-8 FINAL
December 1994
Issue 1 - Public Participation Process
(a) A formal request was made by Maud Naroll, State of Nevada, Department of
Administration, State Clearinghouse, on the behalf of the Nevada Test Site (NTS)
Citizens Advisory Board (CAB) to extend the public review period for the Operable
Unit 4 FS/PP-DEIS for at least 60 days. The CAB was recently formed and held its
first organizational meeting on March 8, 1994. Because of the key role the CAB
will play in advising the DOE-NV about stakeholder concerns, the requested
extension to the public comment period would allow the CAB adequate time to
address the Operable Unit 4 document. (Commentor: L)
(b) On May 17, 1994, a formal request was made by William L. Vasconi, Acting
Chairman, NTS CAB to extend the public review period for the Operable Unit 4
FS/PP-DEIS. The NTS CAB had the opportunity to meet with representatives of
the Fernald Environmental Management Project on May 11, 1994. The CAB stated
that this meeting was the first time it had an opportunity to receive any information
about the Operable Unit 4 FS/PP-DEIS. Because the CAB had not yet reviewed the
Operable Unit 4 documents and the May 20, 1994 deadline for public comments was
near, the extension of time was necessary in order that the CAB may provide
substantive input into the process. (Commentor: N)
Response: (a) The United States Department of Energy (DOE) considered the request for extension
of the public review period to be in accordance with the provision of the National
Oil and Hazardous Pollution Contingency Plan, 40 CFR 300.430(f)(3)(i)(C) as
follows:
"Upon timely request, the lead agency [DOE] will extend the public
comment period by a minimum of 30 additional days; . . "
The DOE recommended that a 30-day extension, as opposed to the 60-day
extension, be granted in an effort to minimize schedule impacts, as well as providing
adequate time for the CAB to review the Operable Unit 4 document. In accordance
with Sections XVIII.B.5 and XVIII.D of the Amended Consent Agreement (1991),
the DOE requested concurrence from the EPA for the 30-day schedule extension to
the public review period. The EPA verbally concurred with the DOE 30-day
request for schedule extension on April 18, 1994, and followed up with a written
C-4-9
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FEMP-OU4ROD-8 FINAL
December 1994
concurrence on April 29, 1994. The DOE issued formal notification of the 30-day
extension to the State of Nevada on May 3, 1994. This documentation can be found
in the Administrative Record.
(b) The DOE considered the CAB request for extension of the public review period to
be in accordance with the provision of the National Oil and Hazardous Pollution
Contingency Plan, 40 CFR 300.430(f)(3)(i)(C) as follows:
"Upon timely request, the lead agency [DOE] will extend the public
comment period by a minimum of 30 additional days; . . "
On May 20, 1994, the DOE granted an additional 30-day extension to the public
review period for the Operable Unit 4 FS/PP-DEIS. In accordance with Sections
XVIII.B.5 and XVIII.D of the Amended Consent Agreement (1991), the DOE
requested concurrence from the EPA for the 30-day schedule extension to the public
review period. The EPA provided written concurrence on the DOE 30-day
extension request on May 26, 1994. This documentation can be found in the
Administrative Record.
Issue 2 - Characterization of Silo Residues
During the March 21, 1994 Operable Unit 4 public meeting, questions were raised by Mr. Lou
Bogar, a resident of the City of Hamilton Ohio, about perceived discrepancies in the isotopic uranium
data reported for some of the silo residues. He also expressed concerns about the inorganic chemical
data for the silo residues. His specific concerns were as follows:
(a) Why does the analytical data on the silos presented report Uranium 235/236? Do
the silos contain uranium-236 (U-236)?
(b) There seems to be a discrepancy in the ratio of U-234 to U-238. The ratio of these
isotopes should be close to unity. The U-234AJ-238 ratio for Silo 2 appears to be
correct however, the ratio for Silo 1 does not appear to be right.
(c) Is there a full list of inorganic constituents for Operable Unit 4? Why isn't gold
listed as one of the analytes? Are there other elements, for which analysis was not
done, that may impact the vitrification process? In particular, what about rare earths
(the lanthanide series of elements)? Could these affect vitrification?
C-4-10
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FEMP-OU4ROD-8 FINAL
December 1994
(Commentor: C)
In addition, on June 24, 1994, DOE received significant comments from a member of the Nevada
Test Site Citizens Advisory Board (CAB). The CAB expressed the following four concerns over the
physical characteristics of the untreated silo residues and the treated waste form:
Based on the presence of RCRA regulated metals and organics in the waste, we are
concerned that the waste contains both hazardous and radioactive constituents.
(d) Please list the radionuclide and inorganic and organic chemical constituents of the
waste.
(e) Please identify the concentration of each constituent.
(f) Please identify the risk resulting from each constituent.
(g) Please describe how the proposed treatment and disposal mechanism address both
the radionuclide and chemical constituents of the waste.
(Commentor: O)
Response: (a) The Silos do not contain U-236. U-236 is a by-product of nuclear reactor
processing. The residues in the silos were generated exclusively from the chemical
processing of pitchblende ores and uranium concentrates to extract uranium.
Consequently, the residues in silos would not contain U-236.
The U-235 analysis was done using the standard radiochemistry technique of alpha
spectroscopy. Because the energies emitted by U-235 and U-236 are very close in
intensity, it is difficult for the laboratory to individually resolve between U-235 and
U-236 activity concentrations. As a result it is accepted laboratory convention to
report radiochemical results for these isotopes as U-235/236. The analytical data for
U-235 concentrations in the silos were reported from the laboratory using this
convention. This was not intended to imply that the silos contain U-236.
(b) In his comments made during the March 12, 1994 Operable Unit 4 Public Hearing,
Mr. Bogar pointed out that there appeared to be some anomalies in the isotopic
uranium data presented during that meeting. The data provided during the public
meeting represented average activity concentrations calculated from individual
C-4-11
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FEMP-OU4ROD-8 FINAL
December 1994
sample results contained in Volume 2 of the Operable Unit 4 Remedial Investigation
Report (available for review in the PEIC). Through process knowledge it is known
that the K-65 Silos contain natural uranium which resulted from the processing of
pitchblende ores and uranium concentrates. As such, the activity concentration ratio
of U-238 to U-234 in any sample obtained from the silos should be approximately 1.
In the data presented for Silo 1, however, the ratio of U-238 to U-234 is 0.8,
implying that the uranium contained in Silo 1 may be enriched.
This apparent anomaly is caused by a combination of two factors: the use of
average activity concentrations to represent activity concentration ratios and apparent
errors in the U-234 activity concentrations reported by the laboratory for four of the
Silo 1 samples. While average activity concentrations are adequate for gross
estimates of the silo contents, using activity concentration ratios calculated from
these average activity concentrations is inappropriate, due to the heterogeneous
nature of the silo contents (it should also be noted that averaging of the data can
propagate the inherent uncertainty in the analytical data for individual samples).
Instead, the activity concentration ratios of U-238 to U-234 should be addressed on a
sample-by-sample basis.
Review of the individual sample data (contained in Volume 2 of the Operable Unit 4
RI Report) will indicate that the ratios of U-234 and U-238 are close to unity as
expected for natural uranium (within the limits of the total propagated uncertainty)
for 16 of the 20 samples taken. The remaining four samples demonstrated higher U-
234 values, which yielded U-238 to U-234 ratios in the range of 0.4 to 0.6. This
knowledge should have been sufficient to reject the analytical results for these four
samples. The sample results, however, had already been validated using standard
EPA protocols and the determination had been made to publish and use all validated
analytical results. While this decision could have been overturned, it was further
determined that these apparently anomalous U-234 analytical results for these four
samples had no impact on the risk assessment for Operable Unit 4 and, as a result,
would have no impact on the evaluation of remedial action alternatives within the
Operable Unit 4 Feasibility Study.
C-4-12
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FEMP-OU4ROD-8 FINAL
December 1994
(c) Volume 2 of the Operable Unit 4 Remedial Investigation Report presents a full
listing of all analytical data collected during the remedial investigation. The data
presented in the public meeting on March 21, 1994 were taken from the Operable
Unit 4 Remedial Investigation Report. These data primarily provide critical
information used in the risk assessment process to determine the nature and
magnitude of potential chemical hazards and/or cancer risk posed by the contents of
the silos. Treatability studies were conducted using actual silo residues to determine
the effectiveness of the vitrification process in stabilizing these materials (the
Operable Unit 4 Treatability Study Report for the Vitrification of Residues from
Silos 1, 2, and 3 is available for review in the PEIC). Analysis was performed on
the silo residues during the treatability studies to provide information pertinent to
determining the effectiveness of vitrification.
The DOE does have historical data on the gold content of the K-<55 residues. The
vitrification process can be affected if there are large amounts of noble metals such
as gold present. However, the gold present in the silo residues does not pose a
problem as evidenced by the results of the vitrification treatability studies.
"Rare earths" or elements in the lanthanide series are known to improve the
durability of glass [reference, Volf, M.B. 1984, Chemical Approach to Glass (glass
Science and Technology: Vol 71 Elsevier, New York]. Analysis was conducted for
some "rare earth" elements such as cerium and lanthanum during the treatability
studies.
(d, e) The material contained in Silos 1 and 2 (K-65 material), and Silo 3 is by-product
materia] or residue resulting from the processing of uranium ore and is specifically
exempt from regulation as solid waste under RCRA 40 CFR §261.4(a)(4). The
State of Nevada has expressed similar concerns over the regulatory classification of
the Operable Unit 4 remedial wastes. A detailed discussion of these regulatory
issues is presented under Issue 4 - State of Nevada Regulatory Concerns.
A complete list of radionuclide, inorganic and organic chemical constituents of the
Silos 1, 2 and 3 wastes and their respective concentrations can be found in Tables
C-4-13
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FEMP-OU4ROD-8 FINAL
December 1994
A.1-1, A.1-5, A.1-6, A.1-7, A.2-1 and A.2-6 in Appendix A of the FS Report for
Operable Unit 4 (FS/PP-DEIS).
Appendix D, Section D.2.0 of the FS Report for Operable Unit 4 (FS/PP-DEIS)
presents a summary of risk characterization results from the Operable Unit 4
Baseline Risk Assessment, as reported in the Remedial Investigation Report for
Operable Unit 4. The Baseline Risk Assessment was performed, in accordance with
available EPA guidance for conducting CERCLA risk assessments and methodology
described in the EPA-approved Risk Assessment Work Plan Addendum for
performing risk assessments at the FEMP. The complete list of radionuclide,
inorganic and organic chemical constituents of the Silos 1, 2 and 3 wastes were
evaluated along with information describing their toxicity, mobility and
environmental persistence. The baseline risk characterization indicates that baseline
conditions do not meet acceptable public health risk criteria.
Appendix D, Section D.3.0 of the FS Report for Operable Unit 4 (FS/PP-DEIS)
evaluates the short-term and long-term risks associated with implementing the
various remedial alternatives considered for Operable Unit 4. The detailed analysis
of the Operable Unit 4 remedial action alternatives is presented in Section 4.0 of the
FS Report for Operable Unit 4 (FS/PP-DEIS), where each alternative is evaluated
relative to the nine criteria of the NCP. Two of these criteria are short-term
effectiveness and long-term effectiveness.
The short-term effectiveness criterion addresses the effect of an alternative during
the construction and implementation phase until the remedial action objectives are
achieved. The evaluation considers the effects on human health and the environment
posed by operations conducted during the remedial action. The long-term
effectiveness criterion evaluates the extent to which an alternative achieves an overall
reduction in risk to human health and the environment after the remedial action
objectives have been met.
The risk assessment presented in Appendix D supports the application of these
criteria through the Section 4.0 evaluation of human health risks resulting from
potential short-term and long-term exposures associated with the Operable Unit 4
C-4-14
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FEMP-OU4ROD-8 FINAL
December 1994
remedial action alternatives. This includes the preferred remedy for disposing of the
treated Operable Unit 4 residues at the NTS.
Appendix C, Section C.3.0 of the FS Report for Operable Unit 4 (FS/PP-DEIS)
presents a summary of all the vitrification treatability study tests which were carried
out in support of the Operable Unit 4 RI/FS process at the FEMP. The tests were
completed as specified by the EPA-approved Operable Unit 4 Treatability Study
Work Plan for the Vitrification of Residues from Silos 1, 2, and 3 (DOE 1992b).
The purpose of these tests was to allow the performance of vitrification of the Silos
1, 2, and 3 residues to be compared to other remediation technologies for the silo
residues. The criteria upon which this comparison was to be based were the
teachability of the waste form, the waste volume reduction achieved, and the
reduction in radon emanation from the waste.
The Toxicity Characteristic Leaching Procedure (TCLP) results for the vitrified
wastes demonstrated the effectiveness of glass as a durable leach resistant waste
form for Operable Unit 4 remedies. Leachate concentrations of hazardous metals
were below regulatory limits for all of the glasses made in these tests, including the
leachate concentration of lead which was reduced about 500 times less than from the
untreated waste. Radionuclides (in particular, Ra-226) were found to leach from the
glasses at the same rate as the major glass constituents, indicating the absence of
selective leaching of radionuclides.
Appendix C, Table C.3-13 of the FS Report for Operable Unit 4 (FS/PP-DEIS)
reports the specific gravity of the vitrified waste along with the calculated volume
reduction. The volume reduction is based upon the difference between the volume
of the final glass product (including additives) and the initial volume of the waste in
its current state. The waste volume was calculated using the wet, compacted
density, which is assumed to be the most representative of the material in its current
state. Significant volume reductions ranging from SO percent to 68 percent are
achieved through vitrification of the waste. In summary, the final waste volume
ranged from 32 percent of the initial waste volume in the best case to only SO
percent of the initial waste volume in the worst case.
C-4-15
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FEMP-OU4ROD-8 FINAL
December 1994
The radon emanation rate from the vitrified K-65 material ranged from 0.01 to 0.06
pCi/m2/s, more than two orders of magnitude less than the EPA limit of 20 pCi/m2/s
for radon emanation from uranium mill tailings. The measured radon emanation
rate from the glass is approximately equal to the emanation rate from natural
building materials such as brick and concrete, even though the radium content of the
waste glass is 103 to 10° times greater than that of natural building materials.
The NTS has established waste acceptance criteria which consider disposal site
characteristics consistent with an appropriate level of protectiveness to human health
and the environment. The Operable Unit 4 remedial waste will comply with these
waste acceptance criteria and the NTS will also perform evaluation to assure that the
acceptance criteria are met.
Issue 3 - Public Participation During Post-RI/FS Activities
The current FEMP Community Relations Plan does not adequately define the public's role, nor its
nature and extent of opportunities for participation during post-RI/FS activities. During the Operable
Unit 4 formal public comment period, members of the public and the Ohio EPA requested formal
definition of their level of participation during the Remedial Design and Remedial Action processes.
Members of the community expressed a desire to continue their same level of involvement in post-
RI/FS activities, as defined by the current Community Relations Plan for the RI/FS program.
(Commentors: A, B, D, G, J and R)
Response: The DOE is both actively and expeditiously pursuing the revision of the current FEMP
Community Relations Plan to include post-RI/FS public involvement activities throughout the
Remedial Design and Remedial Action processes. Until a comprehensive Community Relations Plan
is finalized by the DOE, an Interim (post-RI/FS) Community Relations Plan has been prepared as
guide. to Fernald personnel on public involvement activities. A revised Community Relations Plan
addressing post-RI/FS public involvement activities will be issued by September 1994.
Issue 4 - State of Nevada Regulatory Concerns
The State of Nevada and a member for the Nevada Test Site Citizen's Advisory Board have expressed
concerns over the regulatory classification of the Operable Unit 4 remedial wastes, as discussed in the
Operable Unit 4 Feasibility Study/Proposed Plan - Draft Environmental Impact Statement. More
specifically, the State of Nevada suggests that the Operable Unit 4 remedial wastes are "mixed
C-4-16
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FEMP-OU4ROD-8 FINAL
December 1994
wastes" [i.e., Resource Conservation and Recovery Act (RCRA) hazardous and radioactive waste]
rather than "by-product material" as defined by the Atomic Energy Act (AEA), Section 11(e)(2),
excluded from being a RCRA hazardous waste. The CAB stated that, "Based on the presence of
RCRA regulated metals and organics in the waste, we are concerned that the waste contains both
hazardous and radioactive components." Accordingly, the State of Nevada contends that the
hazardous components of the Operable Unit 4 wastes are subject to regulation and control by an EPA-
delegated state having such authority. (Commentors: E, O)
Response: The State of Nevada's comment concerns the classification of K-65 and Silo 3 material;
specifically with respect to its regulation as mixed waste. The following response first discusses in
general the issue regarding the classification; secondly, the response addresses specific State of
Nevada concerns described in the letter.
(a) General Discussion
The material contained in Silos 1 and 2 (K-65 material), and Silo 3 is by-product material
or residue resulting from the processing of uranium ore and is specifically exempt as
defined from regulation as solid waste under RCRA 40 CFR §261.4(a)(4). Hie referenced
exclusion applies to ". . . source, special nuclear or by-product material as defined in the .
. . AEA. . The AEA in part defines by-product as: M. . .the tailings or waste produced
by the extraction or concentration of uranium or thorium from any ore processed primarily
for its source material content" [AEA Section 11(e)(2)], Since a material must first be a
solid waste in order to be a hazardous waste, and since the material is excluded from
regulation as solid waste, the subject material cannot be considered hazardous waste.
The silos contain only residues from the chemical extraction (beneficiation) of uranium
from ores; no other solid or hazardous wastes were added to the silos or to the residues.
Therefore, the contents of Silos 1, 2, and 3 are pure "by-product materials" by definition,
and not solid wastes or hazardous wastes subject to regulation under RCRA. The metals
found in the material were present in the natural ore, and were unintentionally extracted
from the parent ore along with the uranium during the process of beneficiation, becoming
more concentrated in the residue after the uranium was removed. The presence of
naturally occurring metals is expected in by-product material, and does not invalidate
either the definition or the exclusion. No metals from a non-ore source were added to the
stream at any point in the beneficiation process; also, no hazardous waste or waste
C-4-17
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constituent was added or created at any time during the beneficiation process. The fact
that several metals in the material fail the RCRA toxicity characteristic leaching procedure
(TCLP) does not cause the material to become subject to RCRA regulation due to a
hazardous waste characteristic, since the metals are not from an external source, but are
associated with the parent material (whose residues, including any ancillary metals, are
excluded from the definition of solid waste).
(b) Specific State of Nevada Comments and Responses
1. Comment: The comment refers to . .thorium mill tailing waste, which is admitted
to be mixed waste. . ."
Response: The comment is unclear, since there is no reference to any admission that the
material is mixed waste. The FS/PP-DE1S does not claim the material is mixed waste.
Rather, the residues in the silos are by-product material from the processing of ore
material for its source material, primarily uranium. The by-product material is qqi itself a
mixed waste, nor is it mixed with a solid or hazardous waste which would cause the
material to be considered a mixed waste. As stated in the document, while they are not
considered applicable as ARARs for the management of this material, various sections of
RCRA have been included in the Operable Unit 4 FS/PP-DEIS as relevant and appropriate
requirements for the management of this material during CERCLA remediation, due to the
similarity of this material to RCRA characteristic hazardous waste. The adoption of
various RCRA ARARs in the CERCLA documents does not confer or waive authorities
agencies may have to regulate the silo material under RCRA.
2. Comment: "In 1987, DOE promulgated regulations (10 CFR §962.1) stating that
RCRA hazardous waste, mixed with by-product material falling under the category
defined in the AEA [42 USC 2014(e)(1)], would be subject to regulation ..."
"However, the by-product material falling under the category given in 42 USC
2014(e)(2) that was mixed with RCRA hazardous waste, . . . would not be subject to
regulations by EPA. . ". . .under the Federal Facility Compliance Act (FFC Act),
Congress defined mixed waste to mean "waste that contains both hazardous waste and
source, special nuclear, or by-product material . . .' This definition shows no
distinction between the two categories of by-product material mentioned above. Hence,
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the attempted exemption from hazardous waste regulations of the hazardous components
of mixed waste containing by-product material ... has been invalidated."
Response: The DOE Final Rule in 10 CFR §962, promulgated in the May 1, 1987
Federal Register (52 FR 15937) for clarification of the term "by-product material," was
limited in scope to by-product material as defined under 42 USC 2014(e)(1) meaning
"radioactive material . . . yielded in, or made radioactive by exposure to the radiation
incident to the process of producing or utilizing special nuclear material." An example
would be reactor fuel reprocessed for its enriched uranium. This rule does not affect
materials that are defined as by-product material under Section 11(e)(2) of the AEA
("tailings or wastes produced by the extraction or concentration of uranium or thorium
from any ore processed primarily for its source material content"). The silo material
falls into this second category.
DOE Order 5400.3A further clarifies the DOE interpretive rule referenced above:
"DOE interprets these definitions to mean that whenever any hazardous waste
identified or listed in 40 CFR §261 is inadvertently mixed [emphasis added]
with any source material, special nuclear material, or by-product material, the
hazardous waste component is subject to regulation under Subtitle C of
RCRA. The May 1, 1987 Federal Register notice did not affect materials that
are defined as by-product material under Section 11(e)(2) of the AEA."
DOE Order 5820.2A contains definitions consistent with the above. Chapter IV,
Management of Waste Containing AEA 11(e)(2) By-product Material and Naturally
Occurring and Accelerator Produced Radioactive Material, specifies:
"By-product 11(e)(2) . . . mixed [emphasis added] with the Resource
Conservation and Recovery Act hazardous chemicals, shall be managed
consistent with both the Resource Conservation and Recovery Act and 40
CFR Part 192."
The FFC Act, DOE Order 5400.3A, and DOE Order 5820.2A are consistent in their
interpretation of the definition of mixed waste. The FFC Act simply reiterates that
hazardous waste mixed with source, special nuclear, or by-product material is subject to
dual regulation under both the AEA and RCRA, and has no bearing on Operable Unit 4
by-product material, since it is not mixed with a solid or hazardous waste (see General
Discussion). The K-65 and Silo 3 material consists of only by-product material as
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defined under Section 11(e)(2) of the AEA, and is therefore subject to the solid waste
exclusion under RCRA.
3. Comment: "... EPA delegated to the states regulatory control over all mixed wastes
without regard to specific radionuclide content. . . consistent with the expression of
Congressional intent in defining mixed waste under the FFC Act (see 51 FR, July 3,
1986, 24504-24505)."
Response: In the referenced July 3, 1986 Federal Register notice, EPA is requiring
that states seeking authorization to regulate under RCRA the "hazardous component" of
radioactive mixed waste revise their programs Of necessary) and demonstrate statutory
authority to regulate said "hazardous component." This notice was issued prior to the
DOE interpretive rule of May 1, 1987. Although "hazardous component" is not
expressly defined, the notice is consistent with previous definitions, and implicitly
restates the definition of mixed waste as "wastes containing both hazardous waste and
radioactive waste." Again, this Federal Register notice does not detract from the stated
position, since the Operable Unit 4 silo material consists solely of by-product material,
and is not mixed with a solid or hazardous waste that would be subject to state
regulation.
In summary, the Operable Unit 4 silo materials are expressly by-product material excluded from
RCRA regulation under 40 CFR §261.4(a)(4), on the basis of "tailings or waste produced by the
extraction or concentration of uranium or thorium from any ore processed primarily for its source
material content" [AEA Section 11(e)(2)].
NOTE: While not applicable as an ARAR for the management of this material, various sections of
RCRA have been included in the FS/PP-DEIS as relevant and appropriate requirements for the
management of this material during CERCLA remediation, due to the similarity of this material to
RCRA characteristic hazardous waste. The proposed alternative for remediation of this material
includes treatment by vitrification, which will remove the "toxicity characteristic" due to the
inadvertent presence of various metals in the material. The adoption of various RCRA ARARs in
the CERCLA documents does not accede the authority of RCRA to regulate the silo material; these
ARARs, among others, are selected on the basis of existing regulatory standards and management
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practices to be followed during remediation to ensure adequate protection of human health and the
environment.
Issue 5 - Off-Site Transportation of Waste to Nevada Test Site
Several members of the local community expressed concerns related to the transportation of the
Operable Unit 4 treated wastes from the FEMP to the Nevada Test Site (NTS). One individual
preferred rail shipments over truck transportation, citing that truck transportation is much more
dangerous. Others requested more details on transportation (i.e., packaging specifications, and
special handling requirements and precautions) and details related to notification when shipments will
occur. (Commentors: A, F and Q)
Response: The preferred remedy for Operable Unit 4 requires a combination of rail and truck
transportation for the shipment of treated silo residues off site for burial at the NTS. Currently, there
are no direct rail lines into the NTS. The treated material would be transported from the FEMP by
rail to either a point near Las Vegas, Nevada, or one of the areas north of Las Vegas. From either
location, the waste containers carrying the treated material would be transferred to trucks for
transportation over roads to NTS. Consistent with regulatory requirements, the DOE will provide
proper notification to all affected parties, including emergency response teams, when off-site
shipments begin.
Additionally, the DOE is engaged in a program to optimize a container design to meet specific
performance requirements for a shipping/burial container and to provide additional protection to
workers and die public, for the eventual transport and disposal of the treated Operable Unit 4 wastes
to be conducted between the FEMP and the NTS. One of the program's goals are focussed upon the
viability of utilizing recycled contaminated scrap metal and other forms of metal for the fabrication of
waste containers.
The success of the container investigation will be measured on the basis of achieving a balance of key
design parameters and requirements such as:
• vitrified product mixture design
• final waste form of vitrified product
• waste loading of vitrified product
• waste additives of vitrified product
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• packaging design
• shielding of package
• shipping limitations
• United States Department of Transportation (DOT) requirements
• NTS Waste Acceptance Criteria
• cost
The optimized container design will be modelled in an effort to minimize the estimated short-term
risks posed to public by transporting the Operable Unit 4 wastes in the container.
Issue 6 - Monitoring of Remedial Actions
Several members of the local community and the Ohio EPA expressed concerns that "real-time"
monitoring should be implemented during the entire remedial action process. It was recommended
that the implementation of "real-time" monitoring should be integrated into short-term remedial
actions such as process controls, project specific health and safety procedures, emergency alarm
systems, standard operating procedures, and emergency response procedures, as well as, long-term
actions involving disposal and maintenance. Additionally, it was requested that information gained
from "real-time" monitoring and related activities should be made readily available to the public.
(Commentors: A, B, D, G, H, J and R)
Response: As part of the remedial design activities for the Operable Unit 4 remedial actions, a
preliminary and final safety assessment will be conducted by DOE to establish the safety basis and
design objectives for the construction and the operation of all remedial facilities. The safety basis
includes those measures (i.e., procedures, training, monitoring equipment) necessary to ensure that
facilities will be constructed and operated in a safe manner and in compliance with applicable or
relevant and appropriate requirements.
It is the DOE policy in its conduct of operations to require facility operations procedures to be
developed and adhered to during all remedial actions. Training of personnel to those procedures will
be paramount to ensure safe conduct of all operations. The FEMP has developed and maintains the
necessary emergency plans and procedures to adequately define the emergency management program,
provide guidance for all emergency responders, proper notification of the public, ensure adequate
monitoring and performance for critical systems, and to meet all regulatory requirements.
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The use of "real-time" monitoring is an integral part of this process and will vary in degree for each
system or action to be consistent with the safety assessment recommendations and comply with
applicable or relevant and appropriate requirements. For example, some systems may require 24-
hour "real-time" monitoring (i.e., fire protection, meteorological stations, perimeter air monitoring
stations, radon treatment system) while others may only require "real-time" monitoring during
normal operations (i.e., air emissions controls, waste water discharge, vitrification process controls,
disposal facilities etc.). These features will all be developed and included in the remedial design and
remedial action packages for review by the public, EPA, and Ohio Environmental Protection Agency
(OEPA). Likewise, "real-time" monitoring data will be made available to the public through the
Public Environmental Information Center.
Issue 7 - Impacts to Sites of Archeological and Historical Importance
The Ohio Historical Preservation Office (OHPO) expressed two areas of concern for the identified
Operable Unit 4 remedial actions. Due to the FEMP site's proximity in an archeological sensitive
area, the first area of concern is the potential for impacts to archeological sites. Secondly, under the
current criteria and regulatory guidelines, the FEMP site itself is eligible for inclusion in the National
Register of Historic Places, thus the proposed demolition of the silos, or any other structure or
facility, could have an adverse effect on the FEMP site. The OHPO recommends the development of
a programmatic agreement to address these sitewide and Operable Unit 4-specific historic preservation
concerns. (Commentor: I)
Response: It is recognized that the FEMP site does lie in an archaeologically rich area and sitewide
remedial activities will result in many ground disturbing and demolition activities. The DOE has
effectively coordinated with the OHPO on several projects at the Fernald site in the past. Therefore,
until the programmatic agreement has been developed between DOE and the OHPO, individual
activities (e.g., the construction of support facilities) will continue to be coordinated with the OHPO.
In response to the second area of concern, it is further recognized that the FEMP site as a whole has
recently been determined to be eligible for inclusion on the National Register of Historic Places.
Therefore, appropriate steps will be taken to coordinate with the OHPO all activities involving the
demolition of structures. The DOE will be pursuing a programmatic agreement with the OHPO in
the near future. However, until such an agreement can be put in place, DOE will be coordinating
with the OHPO office on an individual project-by-project basis.
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Appropriate coordination activities associated with the remediation of Operable Unit 4 and the
demolition of structures on the site will be carried out with the OHPO.
Issue 8 - Future Land Use at the FEMP
One member of the public expressed concern over any future development of the FEMP site (i.e.,
industrial park) which would attract large concentrations of humans, in the event environmental
problems would happen to develop in the future (i.e., similar to Love Canal). (Commentor: F)
Response: The DOE, EPA, and OEPA are closely working with the local community (i.e., FRESH)
to provide technical guidance to participating community members, in an effort to logically reach a
balanced decision regarding the most feasible future land use(s) for the FEMP site. The Operable
Unit 4 soil remediation cleanup levels were established with the assumption that in the future, the
federal government would maintain ownership of the Operable Unit 4 area.
Issue 9 - Impact to Natural Resources
Members of the public expressed concern over the potential impact from the remedial actions to
natural resources surrounding the FEMP site (i.e., wetlands, migratory birds, etc.), and the mitigative
measures being taken by the DOE to minimize their effect. (Commentors: B and F)
Response: The end-use of the FEMP site is currently under consideration by the Fernald Citizens
Task Force. This task force, based on input from the public and various stakeholders, will make a
recommendation to DOE as to what the end-use of the Fernald site should be. This comment will be
forwarded to the task force for their consideration. The task force's recommendation will play a key
role in determining what happens at the site after remediation.
Depending on the types of environmental impacts that occur during remediation, it is possible that
habitats may need to be created as mitigative measures. The specific issue of the need for creating
wetlands is currently being evaluated by DOE and Fernald Environmental Restoration Management
Company (FERMCO) and will be discussed with the stakeholders and formally addressed in the
Operable Unit 5 (Environmental Media) Feasibility Study Report and Record of Decision.
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Issue 10 - EPA Promulgation of Residual Soil Standards for Radionuclides
One local resident inquired whether the residual soil radiation levels, which the EPA has not yet
published in the Federal Register (originally scheduled to be published in March 1994), could
possibly impact the remediation decisions in Operable Unit 4. (Commentor: C)
Response: Residual soil standards for radionuclides are currently being finalized by the EPA. The
EPA has issued a draft proposal which recommends the establishment of an effective dose limit of IS
mrem/year from residual soil radiation. Until the standards are finalized and promulgated by the
EPA, it is uncertain whether they will impact Operable Unit 4. Radionuclide cleanup levels have
been established for Operable Unit 4 which approach background concentrations for nearly all
radionuclides. When the residual soil standards for radionuclides are promulgated by the EPA, a
review of their impact upon the Operable Unit 4 soil remediation will be conducted. Soil cleanup
levels for Operable Unit 4 will be modified as directed by the EPA.
Issue 11 - Air Emissions from Remedial Actions
One local resident, who lives downwind of the FEMP site, expressed concerns over the particulate
matter and off-gases which could be emitted through the exhausts of the Operable Unit 4 vitrification
process. Specific concerns were noted related to the performance of comprehensive site-wide air
modeling which includes the Operable Unit 4 vitrification facility contributions to sitewide emissions
and the quantification of subsequent risks to the local "downwind" community. (Commentor: K)
Response: Air pathway monitoring focuses on the airborne pollutants that may be carried from the
Fernald site as a particulate or gas and how these pollutants are distributed in the environment. Stack
and building vent emissions are obvious sources of pollutants, but dust from construction and
remediation activities, waste handling, and wind erosion are also important potential sources. The
form and chemical makeup of pollutants influence how they are dispersed in the environment as well
as how they may deliver radiation doses. Airborne pollutants are subject to whatever weather
conditions exist.
The meteorological data gathered at the FEMP site are primarily used to evaluate climatic conditions
at the site. Wind speed and direction, rainfall, and temperature play a role in predicting how
pollutants are distributed in the environment. The Fernald Environmental Monitoring Program
routinely uses atmospheric models to determine how airborne effluents mix and disperse; these
models, in turn, are used to assess the impact of operations on the surrounding environment, in
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accordance with DOE requirements. Based upon modeling results, risks to the public are calculated
based upon exposure from the pollutants emitted from the FEMP site. The 1992 Fernald Site
Environmental Report provides detailed breakdown of sitewide emissions, doses to the public, and
their associated risks. This report is updated annually and may be available in the Administrative
Record.
To date, computer modeling for expected radionuclide emissions from the proposed vitrification
facility has not been conducted due to insufficient engineering design data. However, during remedial
design, when these design data become available, this information will be entered into the appropriate
air models to determine compliance with 40 CFR §61 Subpart H for radionuclides, including radium
under the Clean Air Act. In addition, Ohio Administrative Code (OAC) 3745-31-05(A)(3) requires
the use of Best Available Technology (BAT) to control process emissions. Compliance with the
requirement to employ BAT will be determined by evaluating, according to the Ohio Air Toxics
Policy (OATP), emission data collected from performance testing of the Operable Unit 4 vitrification
facility.
Modeling will be conducted on the vitrification facility both prior to startup and during operation.
The preliminary modeling will provide estimates of dose levels based on engineering design and
expected removal efficiencies. Corroborative modeling conducted during operation will be based on
actual data collected during stack performance testing, and will verify engineering design and
compliance with the regulatory standard. Risks associated with these dose levels will be evaluated
and compared to the other alternatives. Upon comparison a determination will be made to implement
design criteria to minimize risk associated with the vitrification facility or if necessary to amend the
selected alternative to one which poses less of a risk to the surrounding community.
Air emission modelling specific to the Operable Unit 4 vitrification processing facility will be
performed as part of the remedial design process, to ensure that the vitrification facility is designed to
meet these air emission ARARs and pertinent DOE Orders. In addition, portable air monitors will be
strategically located around the perimeter of field activities during construction of remedial facilities.
The air monitors will provide real time data regarding the effectiveness of controls to mitigate fugitive
dust emissions.
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Issue 12 - Determination of Risk Levels
A local resident questioned the reason the CERCLA elected to use such small risk levels as lfr* (one
in a million). In addition, the differences in methodologies like Health Effects Assessment Summary
Tables (HEAST) and Biological Effect of Ionizing Radiation result in "vast orders of magnitude"
differences in estimated risks. (Commentor: C)
Response: In accordance with the NCP (40 CFR 300), Operable Unit 4 is required to comply with
the requirement that the excess risk, posed to humans exposed to carcinogenic materials in Operable
Unit 4, would not be greater than one in ten thousand to one in a million. The lower bound of the
range, one in a million (10"6) incremental risk, is the most desired level of residual risk to be posed
by a clean-up action. This risk refers not to "fatal" cancer risk but the risk of the induction of
incremental cancers, over and above the normal risk of contracting cancer, during one's lifetime.
Operable Unit 4 is also legally required to utilize the methodologies defined by the United States
Environmental Protection Agency for calculating the cancer risk posed by Operable Unit 4.
Issue 13 - Compliance with DOT Transportation Regulations
The U.S. Department of Transportation (DOT) provided two comments regarding compliance with
DOT regulations.
(a) The first comment was related to classification of the materials as Low Specific
Activity (LSA) and stated, "We [DOT] believe the expected physical form of the
material transported will result in the radiological risk to the public being equal to or
less than most LSA shipments transported in the Country. However, from Volume
Two, Appendix A, Table A. 1-1, it appears that the activity per gram of material for
some of the package contents might exceed the limits for LSA materials in 49 CFR
173.403(n)."
(b) The second comment expressed concern with the sampling and analysis to be
performed prior to shipment. The comment stated "After material vitrification, the
external radiation dose rates will clearly be the indications of the most significant
radiological hazards of the materials during transportation. However, since the
identity of the radionuclides and the activity of the content in each package is
required by the regulations, documentation with technical reasoning will be needed
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to relate the results of pre-vitrification radioassays to the contents of the packages."
(Commentor M)
Response:
(a) The initial classification and container selection of the vitrified materials as LSA was
used to perform cost estimates for the remedial alternatives evaluated in the FS for
Operable Unit 4. These cost estimates were developed with an intended accuracy of
plus 50 percent/minus 30 percent as required by CERCLA. Therefore these cost
estimates were considered adequate for alternative evaluation. Since the initial
distribution of the FS/PP-DEIS, the FEMP has initiated a study which will further
specify the DOT classification of the vitrified material and container types required
for shipment of the vitrified material. The final selection of container type is
contingent upon several factors, including; the Curie content of the container, its
classification under DOT regulations, the ability of the container to reduce external
dose rate, and the acceptance of the container by the Nevada Test Site.
(b) Demonstration of compliance with regulations is the basis for the sampling and
analysis program to be developed for Operable Unit 4 remediation. Sampling and
analysis will be performed on the vitrified gems 1) to assure compliance with waste
disposal requirements, 2) to demonstrate success of waste treatment, 3) to assure
compliance with DOT requirements, 4) and to complete waste characterization of the
vitrified materials. Specific parameters for testing will be determined in the Project
Specific Sampling and Analysis Plans to be prepared during Remedial Action. The
selection of parameters for analysis will include those which will demonstrate
compliance with the activity limitations for containers per DOT regulations.
Issue 14 - Consideration of Disposal Sites for the K-65 Material
On June 24, 1994, DOE received significant comments from a member of the Nevada Test Site
Citizens Advisory Board (CAB). The CAB stated that the Operable Unit 4 FS/PP-DEIS documents
did not discuss the full range of possible alternatives (e.g., disposal at Hanford, reprocess to recover
materials, dispose of all material at the NTS). The member of the CAB further questioned "...Why
were these options rejected? What is the full list of options initially considered and why was each
option rejected?"
(Commentor: O)
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Response: Identification, screening, and evaluation of potentially applicable technologies and process
options are key steps early in the FS process. The primary objective of this phase of the FS is to
develop an appropriate range of remedial technologies and process options that will be developed into
preliminary remedial alternatives. The criteria for identifying potentially applicable technologies are
provided in EPA guidance and in the NCP. There is strong statutory preference for remedies that
will result in a permanent solution; a significant decrease in toxicity, mobility, or volume; and
provide long-term protection as identified in Section 121 of CERCLA, as amended. The primary
requirements for the final remedy are that it be both protective of human health and the environment
and comply with applicable or relevant and appropriate regulatory requirements.
The Operable Unit 4 FS/PP-DEIS presented information to support the selection of the most
appropriate remedial alternative. The broad range of alternatives considered for remediation in the
FS/PP-DEIS were developed in accordance with EPA guidance by following a series of logical steps
that involved developing, in succession, more specific definitions of potential remedial alternatives.
The steps included the following:
• Development of contaminant- and media-specific remedial action objectives (RAOs) and
preliminary remediation goals (PRGs).
• Identification of general response actions (GRAs).
• Identification of volumes and/or areas of waste media to be addressed.
• Identification and screening of remedial technologies and process options.
• Evaluation and screening of process options within each technology.
• Assemblage of a wide range of remedial alternatives using the selected process options
within each remedial technology.
• Evaluation of initial screening to determine which alternatives will be analyzed more fully
in the detailed analysis phase of the FS.
The detailed analysis of alternatives was performed in Section 4 of the FS on those alternatives which
were retained through the preliminary screening of alternatives step described above. The detailed
and comparative analysis consisted of the analysis and presentation of the relevant information needed
to allow decision makers to select a remedial alternative.
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The Operable Unit 4 FS/PP-DEIS considered several disposal options for each of the on-property and
off-site disposal technologies evaluated for the K-65 material as follows:
On-Property Disposal Technology
• Engineered Disposal Facility (Below-grade)
• Above-grade Disposal Vault
Qff-SHe Disposal Technology
• New Facility within 483 km (300 mi) of the FEMP site
• New Facility Adjacent to the Site
• Permitted Commercial Disposal Site
• Nevada Test Site
In addition, in-situ and no-action alternatives were considered and evaluated as potential disposal
alternatives. Sections 2.6.7.2 and 2.6.7.3 of the Operable Unit 4 FS discuss these representative
options and the results of their preliminary screenings. Subsequently, repromulgation of 40 CFR Part
191 led to changes in the list of relevant and appropriate requirements affecting on-property disposal
as discussed in Attachment C.II.
It is the DOE Defense Waste Management Policy at the Nevada Test Site, "...to approve generators
and to receive, store and dispose of radioactive wastes generated by DOE defense programs in a
manner consistent with DOE Order S820.2A, "Radioactive Waste Management," and applicable
federal, state, and local regulations and requirements."1 Chapter III of DOE Order S820.2A
provides that low-level waste should go to a DOE low-level waste disposal site, such as the NTS.
This policy ensures that low-level wastes will be handled properly in accordance with applicable
standards and DOE guidelines. Exemptions from the DOE Order to allow shipments to commercial
disposal facilities can be granted by the U.S. Department of Energy Assistant Secretary for
Environmental Management on an ad hoc basis. Fernald has made shipments of waste in the past to
the Nevada Test Site and to the commercial facility operated by Envirocare, Inc. in Clive, Utah.
'U.S. Department - Nevada Field Office, June 1992, Nevada Test Site Defense Waste Acceptance
Criteria. Certification, and Transfer Requirements. Publication NVO-325, Rev. 1, Page 1.
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In this case, however, the Operable Unit 4 vitrified silo wastes from Fernald do not meet the waste
acceptance criteria for existing commercial facilities. The U.S. Department of Energy Office of
Environmental Restoration asked for and is in the process of receiving a determination by the U.S.
Department of Energy Office of Waste Management that the silo wastes constituted a small quantity
of by-product material under Chapter III of DOE Order 5 820.2A and therefore, may be disposed at a
DOE low-level waste disposal site, such as the Nevada Test Site. Also, it has been a long-standing
DOE policy that "defense related wastes" would be disposed at the Nevada Test Site and non-defense
related waste disposed at Hanford.
That option, which is the preferred alternative, has been evaluated in this environmental impact
statement as a potential alternative for waste disposal, along with a potential option for commercial
disposal. Disposal at another DOE site, such as Hanford, was considered by DOE to be less feasible
than shipment to the NTS, given past experience with shipping legacy wastes from Fernald to the
NTS, which has been ongoing since 1985. In addition, an appropriate disposal facility is not
currently available at Hanford to receive the Operable Unit 4 waste.
The reprocessing of silo wastes to recover radiological or inorganic constituents was determined not
to be feasible due to poor treatability test results involving chemical separation techniques.
It should be noted that all of the Operable Unit 4 remedial wastes (i.e., Silos 1, 2 and 3 residues,
contaminated soil and debris) were considered for disposal at the NTS. However, it was determined
that only treated silo residues should be disposed at the NTS under the Operable Unit 4 FS/PP-DEIS
(although disposal of contaminated soil and debris is to be determined in subsequent RODs).
The selection of the NTS for disposal of Operable Unit 4 waste is supported by a process option
evaluation presented in Appendix B (Description of Technologies and Process Options) of the FS/PP-
DEIS. This evaluation concluded that based on considerations such as geology, demographics, levels
of precipitation, and depth to groundwater the NTS provided the best location for disposal. Also, the
results of treatability studies conducted on the vitrified waste form indicate that the vitrified waste
fully satisfies current NTS waste acceptance criteria and in general would provide a high level of
long-term protectiveness when disposed at the NTS.
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Issue 15 - FEMP Waste Disposal Program
On June 21, 1994, DOE received a package of 174 postcards from Citizen Alert. Three additional
postcards were received on July 5, 1994. The majority of the postcards were from concerned citizens
of Nevada expressing their comments related to the shipment and disposal of Fernald waste at the
NTS. One of their comments stated that, "...the more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be required to accept
additional risk on top of that already present at the Nevada Test Site." (Commentors: P1-P177)
Response: As part of the FEMP Waste Disposal Program, disposal of waste at the NTS is only one
of several disposal locations being considered for waste resulting from the remediation of the Fernald
site. Other disposal locations include both on-site disposal and commercial facilities.
The overall remediation of Fernald is expected to generate over 2.6 million cubic yards of waste
requiring treatment and/or disposal. Of the estimated 2.6 million cubic yards, 1.4 million cubic yards
are to be managed at the Fernald site, 900,000 cubic yards are to be shipped to commercial facilities,
and 300,000 cubic yards may be shipped to the NTS (including approximately 5580 cubic yards of the
Operable Unit 4 remedial wastes). Therefore, only about 10 percent of the waste from the
remediation of Fernald might be shipped to the NTS. Additionally, these shipments would occur over
a projected 30-year period.
Currently, Fernald is shipping low-level waste to the NTS at a rate of about 18,000 cubic yards of
waste per year (based on the most recent 6 year average). The projected rate for disposal of the
Fernald remedial waste at the NTS is estimated at a rate of approximately 10,000 cubic yards per
year, with the highest estimate for a single year being approximately 16,000 cubic yards for 1995.
Furthermore, the 300,000 cubic yard estimate is a highest case estimate which, in reality, may not
happen. Fernald is making an effort to minimize waste generation and to explore other disposal
options, thereby minimizing waste requiring shipment to the NTS, as well as other locations.
Disposal of waste at the NTS is utilized only when these options have been evaluated and determined
unfeasible. These minimization efforts include recycling, decontamination for free-release of
materia], volume reduction through treatment, disposal of the waste on-site, and use of commercial
disposal facilities.
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FEMP-OU4ROD-8 FINAL
December 1994
Despite these efforts, the Operable Unit 4 FS/PP-DEIS has concluded after a detailed evaluation that
approximately 5580 cubic yards of silo residues are more appropriately disposed at the NTS. This is
driven by several factors, including the location of the Fernald site over a sole-source aquifer (State of
Ohio regulations prevent the establishment of a disposal facility over a sole source aquifer); the close
proximity of die site to large populations and agricultural land; and the lack of commercial disposal
facilities which may accept these wastes. As discussed in the Operable Unit 4 FS/PP-DEIS, these
wastes include the treated residues from Silos 1, 2, and 3.
The State of Ohio recognizes that the final disposition of some Fernald wastes may be on site. In a
letter written to the U.S. EPA, the State of Ohio said: "Large volumes of contaminated construction
and demolition debris, soil, fly ash and bottom ash, and possibly some solid waste will have to be
disposed onsite at Fernald."
The disposal of some wastes at the NTS is one part of a balanced waste management effort for the
Fernald remedial activities. Although Fernald is committed to the minimization of wastes and finding
alternative disposal options for its wastes, Fernald proposes to rely on the NTS for disposal of certain
wastes.
Issue 16 - Evaluation of Transportation Risks
On June 21, 1994, DOE received a package of 174 postcards from Citizen Alert. Three additional
postcards were received on July 5, 1994. The majority of the postcards were from concerned citizens
of Nevada expressing their comments related to the shipment and disposal of Fernald waste at the
NTS. One of their comments stated that, "Transportation risks need to be thoroughly evaluated".
(Commentors: P1-P177)
Response: The FS/PP-DEIS for Operable Unit 4, Section 4, contains a complete detailed analysis of
all the remedial alternatives evaluated for off-site transportation of wastes, which included both long-
term and short-term risks. The preferred remedy for Operable Unit 4 involves the transportation of
the treated silo residues to the NTS by a combination of rail and truck. The material would be
shipped exclusively by use of rail from the FEMP to Las Vegas, Nevada [a distance of 3562 km
(2270 mi)], then by truck from Las Vegas to the NTS [179 km (111 mi)].
The FS/PP-DEIS for Operable Unit 4, Appendix D, contains a detailed discussion of the long-term
and short-term risks associated with each remedial alternative which underwent detailed analysis. The
C-4-33
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FEMP-OU4ROD-8 FINAL
December 1994
RADTRAN IV computer code was used to evaluate potential short-term risks, including risks to the
public during the transportation of the vitrified Silos 1, 2 and 3 material to the Nevada Test Site.
Through Sandia National Laboratory's TRANSNET system, RADTRAN IV simulates the
transportation route, the length of time members of the public are exposed to radiation, and the dose
equivalent delivered for the trip. This exposure is to members of the public sharing the road with the
truck, people living along the rail and truck route, and people encountering the truck at truck stops.
The alternatives call for packaging the treated material in metal boxes meeting U.S. Department of
Transportation packaging requirements of 49 CFR Part 173. The radiological impacts associated with
the transportation of the waste to the NTS for disposal are summarized in Table C.4-2.
TABLE C.4-2
IMPACTS TO THE PUBLIC DURING TRANSPORTATION OF
VITRIFIED SILOS 1, 2 AND 3 WASTE TO THE NTS
ESTIMATED IMPACT
Transportation to the Nevada Test Site
Vitrified Silos 1 and 2
Material
Vitrified Silo 3
Material
Routine Transport
RME Individual dose (mrem)
0.0085
0.00014
Risk -ILCRk
8.32xl010
1.71xl0"n
Transportation Accidents
Public dose from radioactive
material releases following truck
accident, (person - rem)
1.9xl0"s
3.8x10*
Public dose from radioactive
materia] releases following train
accident, (person - rem)
0.026
0.0053
Truck Associated Injuries'
0.013
0.0068
Truck Associated Fatalities*
0.0014
0.00074
Train Associated Injuries*
0.15
0.077
Train Associated Fatalities'
0.038
0.020
"Nonradiological impacts.
kILCR - Incremental Lifetime Cancer Risk Above Background.
C-4-34
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FEMP-OU4ROD-8 FINAL
December 1994
The estimated dose exposure and subsequent risks were calculated and reported as an incremental
lifetime cancer risk (ILCR) to the public from the transportation of the vitrified Silos 1, 2 and 3
material to the Nevada Test Site. Consistent with the goals of CERCLA, it is desirable to have the
risks resulting from remediation to fall within all ILCR range of 1 x 10"* to 1 x Iff4 above
background. For example, if a member of the public has an additional 1 chance in 1,000,000 of
contracting cancer due to exposure to radiation during transportation, the probability of developing
cancer is expressed as a 1 x 10"* (1 in 1,000,000) risk. As presented in Table C.4-2, all short-term
risks from exposure to radiation meet these criteria.
In addition to risks from the radiological exposure from the transportation of Silos 1, 2 and 3 material
to the NTS, accidental injuries and fatalities are predicted to occur because trucks and/or trains would
be used for material transportation to the Nevada Test Site. The following risk coefficients below
were used to evaluate non-radiological risks to truck drivers and rail crews:
Driver/Crew Truck Rail
injury/mile 4.1 x 10"' 4.6 x 10"*
death/mile 2.1 x Iff5 4.6 x Iff8
Likewise, the following risk coefficients presented below were used to evaluate non-radiological risks
to the public:
Public Truck Rail
injury/mile 1.2 x Iff7 6.8 x Iff6
death/mile 1.3 x Iff' 1.8 x Iff*
It should be noted that the risk coefficients for truck and rail transport are not strictly comparable,
since far. more waste is transported per mile of rail transport than per mile of truck transport. These
risks parameters were used consistent with standard risk calculation methodologies as identified in the
Final Risk Assessment Work Plan Addendum, (June 1992),2 which referenced the forementioned
^.S. Department of Energy, June 1992, "Risk Assessment Work Plan Addendum," U.S.
Department of Energy - Fernald Field Office, Fernald, Ohio.
C-4-35
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FEMP-OU4ROD-8 FINAL
December 1994
published statistics by the U.S. Department of Transportation Federal Highway Administration3 and
U.S. Department of Transportation Federal Railroad Administration/
As before, RADTRAN IV computer code was utilized to calculate the short-term impacts of injuries
and fatalities. These impacts are also presented in Table C.4-2 for the transportation of Silos 1, 2 and
3 to the Nevada Test Site.
RADTRAN IV also assesses the impacts from accidental releases of the radioactive material in the
transport containers. The code assesses the total impacts for eight accident severity categories. It
assesses collective radiological impacts to the public from direct radiation exposure from
contamination on the ground, inhalation of contaminants in a plume and resuspended from the
ground, direct radiation exposure from contaminants in a plume, and ingestion of food grown in the
contaminated area. The impacts from a single truck and train accident are included in Table C.4-2.
Issue 17 - Socioeconomic Impacts to the Waste Receptor Community
On June 21, 1994, DOE received a package of 174 postcards from Citizen Alert. Three additional
postcards were received on July 5, 1994. The majority of the postcards were from concerned citizens
of Nevada expressing their comments related to the shipment and disposal of Fernald waste at the
NTS. One of their comments stated that, "Socioeconomic impacts on the receptor community should
be thoroughly evaluated and balanced against the desires of Ohio to move Fernald waste."
(Commentors: P1-P177)
Response: The importance of evaluating the socioeconomic impacts of the Operable Unit 4 Remedial
Action Alternatives on affected off-site locations is recognized by DOE. It is DOE's view that this
issue has been adequately evaluated in the Operable Unit 4 FS/PP-DEIS.
Section 4.0 of the Operable Unit 4 FS/PP-DEIS provides a thorough discussion of the alternatives.
For the alternatives that consider disposal at the NTS, impacts on socioeconomics were evaluated.
'U.S. Dept. of Transportation Federal Highway Administration, Office of Motor Carriers, 1986,
Accidents of Motor Carriers of Property. Publication No. FHWA-MC-88-008, DOT, Washington,
DC.
4U.S. Dept. of Transportation Federal Railroad Administration, Office of Safety, 1988,
Accident/Incident Bulletin. Publication No. 157, DOT, Washington, DC.
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FEMP-OU4ROD-8 FINAL
December 1994
Population demographics, land use of areas adjacent to the site, and potential risks to the surrounding
population are discussed. In addition, impacts on groundwater, soil and geology, biotic resources,
etc., are also presented.
Additional discussion of the NTS is also provided in Appendix B of the Operable Unit 4 FS/PP-DEIS,
Description of Process Options and Technologies. This discussion provides additional detail on the
natural and socioeconomic characteristics of the NTS and the surrounding area. This information
formed the basis for the impacts presented in Section 4.0 of the Operable Unit 4 FS/PP-DEIS.
Additionally, on August 10, 1994, DOE published a Notice of Intent to prepare a site-wide EIS for
NTS (59 FR 40897). This notice invites the public to participate in the scoping process for the NTS
EIS.
Issue 18 - Disposal of DOE Waste at the Nevada Test Site
On June 24, 1994, DOE received comments from a member of the Citizens Advisory Board for
Nevada Test Site Programs which expressed concerns over the current decision process for
considering DOE waste for disposal at the NTS. More specifically, the comment stated as follows:
"The shipments of waste from Fernald are the first of potentially many other shipments to the NTS.
Rather than making decisions on a piecemeal basis, we want to see the full picture before we are
asked to make decisions on individual pieces. That is, we want to first consider the total impact of all
of the waste that is being considered for disposal at the NTS. Following that, we want to consider
each individual piece." (Commentor: O)
Response: A Notice of Intent to prepare a site-wide EIS for the NTS was published on August 8,
1994. The purpose of this Notice is to invite the participation of federal, state and local agencies,
affected Indian tribes, and other interested persons in the process DOE will follow to solicit public
comments on the proposed scope and content of the NTS EIS. The site-wide EIS will address the
impacts of all waste disposal activities at the NTS. Shipments of waste generated from the cleanup of
Operable Unit 4 are not proposed to begin until after the expected completion of the NTS site-wide
EIS.
C-4-37
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December 1994
Issue 19 - Funding for Technical Oversight and Impact Mitigation
On June 24, 1994, DOE received comments from the Citizens Advisory Board for Nevada Test Site
Programs which expressed their belief that:
(a) funds should be provided for technical oversight of waste management activities.
(b) the State of Nevada and affected Counties are entitled to impact mitigation payments
as compensation for costs arising from management of this material.
(Commentor: O)
Response: (a) The first issue regards funding for technical oversight. DOE currently has
a program established for providing such funds. This program is detailed in an
"Agreement in Principle, with the State of Nevada, one of several such agreements
between DOE and the states in which DOE facilities are located. This agreement includes
the provision of funding for technical oversight by the State of Nevada for waste
management activities at the NTS.
(b) The second issue is related to providing impact mitigation payments for management
of waste in Nevada to the State of Nevada and affected counties. Mitigation payments are
associated with actions whose implementation will have significant impact on human health
and the environment. Since no significant impacts are expected to result from the
transportation and disposal of the vitrified Operable Unit 4 waste at the Nevada Test Site,
no mitigation payments for management of the waste in Nevada are anticipated at this
time.
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December 1994
9.1.3 Off-Site Shipment and Disposal of Treated Material
Approximately 2,770 m3 (3,623 yd3) of vitrified material from Silo 1 and 2 and the decant sump,
along with approximately 1,471 m3 (1,923 yd3) of vitrified material from Silo 3, will be packaged and
transported to the NTS for disposal.
The NTS is a DOE owned and operated disposal site located near Las Vegas, Nevada. The treated
material will either be transported by rail to a destination near to or north of Las Vegas, Nevada or
directly to the NTS by truck. If by rail, the waste containers carrying the treated material will be
required to be transferred to trucks for transportation over roads to the NTS.
The NTS is located approximately 3,219 kilometers (km) [2,000 miles (mi)] from the FEMP. The
FEMP has an approved NTS waste shipment and certification program, for low-level radioactive
wastes, that is periodically audited by the NTS. Technical oversight of the waste management
activities at the NTS is provided by the State of Nevada. This existing waste shipment disposal
program will be modified and amended to include the shipment and disposal of treated Operable Unit
4 wastes.
All off-site shipments will comply with the DOT regulations found in 49 CFR Parts 171 - 178
pertaining to transportation of hazardous and radioactive materials. Additionally, all the NTS waste
acceptance requirements will be satisfied. The off-site transport of materials would also comply with
the off-site acceptability requirements under CERCLA.
The remedy specifies off-site disposal of vitrified contents of Silos 1, 2 and 3 at the NTS. At the
time of the signing of this ROD, the Department of Energy - Nevada Operations Office (DOE-NV) is
in the process of preparing a Sitewide Environmental Impact Statement (EIS) under NEPA for the
NTS. Shipments of waste generated from the cleanup of Operable Unit 4 are not proposed to begin
until after the expected completion of the NTS site-wide EIS.
9.1.4 Demolition and Decontamination of Structures
Demolition of the silo structures will proceed with the systematic removal and dismantling of the Silos
1, 2, 3, and 4 domes, walls, floor slabs and footers. After removal of the silo contents and before
Silos 1, 2, 3, and 4 are demolished, loose interior residues and loose concrete will be removed from
the surfaces of the silos and transferred to the vitrification facility to be vitrified. Also, contaminated
concrete from Silos 1 and 2, which exhibit highly elevated direct radiation fields, will be separated
9-3
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FEMP-OU4ROD-8 FINAL
December 1994
from the other Operable Unit 4 concrete and construction debris and prepared for processing in the
vitrification facility. Contaminated piping, steel fencing, and other non-porous materials will be
decontaminated to facilitate segregation for possible unrestricted release or disposal in a permitted
commercial landfill. Only non-porous materials attaining the unrestricted use, free release criteria
defined in DOE Order 5400.5 or any subsequent DOE order or amendment or final promulgated
regulation addressing free release, will be released from the site as uncontaminated.
9.1.5 Demolition and Decontamination of Other Operable Unit 4 Structures
The existing RTS, Drum Handling Building pad, sump lift station foundation, concrete pipe trench,
and decant sump tank will be removed and decontaminated. Additionally, all vitrification facilities
constructed and equipment installed and used for the implementation of this remedy will be
disassembled, decontaminated (if necessary), and dispositioned. Conventional decontamination and
decommission techniques and equipment would be employed for these facilities. Uncontaminated
materials attaining the unrestricted use, free release criteria defined in DOE Order 5400.5 will be
released from the site for unrestricted use or for disposal in a commercial landfill.
9.1.6 Disposition of Demolished Structures and Debris
The selected remedy as defined under Alternative 2C specifies on-property disposal for Operable Unit
4 contaminated rubble and debris. However, this final action will be held in abeyance until a decision
is reached in the Operable Unit 3 ROD for the final treatment and disposal of rubble and debris. The
final decision on disposal of nibble and debris, generated from the demolition of the Operable Unit 4
silos and other facilities, will be determined as part of the ROD for Operable Unit 3. The Operable
Unit 4 waste will be managed consistent with the disposal remedy put forth in the Operable Unit 3
ROD for contaminated nibble and debris. In the unlikely event unforeseen circumstances preclude
the integration of Operable Unit 4 rubble and debris into the Operable Unit 3 treatment and disposal
decision, the disposal decision for Operable Unit 4 rubble and debris will be documented in a ROD
amendment for Operable Unit 4 in accordance with Section 117(c) of CERCLA and EPA guidance.
The ROD amendment will provide the public and the EPA further opportunity to review and comment
on the on-property disposal option for Operable Unit 4 rubble and debris. A ROD amendment to the
Operable Unit 4 ROD will not be necessary in the event the Operable Unit 3 remedy for rubble and
debris can be feasibly implemented by Operable Unit 4.
9-4
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FEMP-OU4ROD-8 FINAL
December 1994
Holding action on the Operable Unit 4 on-property disposal decision in abeyance fosters an integrated
site-wide disposal program for rubble and debris. The volume of rubble and debris to be generated
from Operable Unit 4 is anticipated to be less than 1 percent of the volume expected to be generated
site wide. The largest volume of rubble and debris from the site will be generated from Operable
Unit 3, making it more appropriate to fully develop the on-property disposal option for rubble and
debris through the Operable Unit 3 ROD. Additionally, Operable Unit 4 will be able to take
advantage of any available waste minimization initiatives developed for rubble and debris which are
identified in the Operable Unit 3 ROD.
Demolition and removal of Operable Unit 4 structures and facilities will proceed as described above.
Operable Unit 4 rubble and debris will be dispositioned according to the selected remedy identified in
the Operable Unit 3 ROD. Rubble and debris generated prior to finalization of the Operable Unit 3
ROD will be placed in interim storage to await finalization of the disposal decision for rubble and
debris under Operable Unit 3. The design and management of interim storage facilities will be
consistent with the approved Work Plan for FEMP Removal Action No. 17 - Improved Storage of
Soil and Debris.
9.1.7 Soil Removal
After the silos are demolished, the surface and subsurface soils within the boundary of Operable Unit
4 will be excavated to attain required remediation levels for each of the constituents of concern.
These soil remediation levels are considered preliminary until final soil remediation levels can be
established through the Operable Unit 5 ROD. As indicated earlier, Operable Unit 5 has site-wide
responsibility for soil cleanup. Also, the anticipated volume of soil to be removed from Operable
Unit 4 will be less than 1 percent of the anticipated volume of soil to be remediated for the entire site.
The surface and subsurface soils within Operable Unit 4 will be excavated to achieve the preliminary
remediation levels presented and discussed in Section 9.2. These Operable Unit 4 soil remedial levels
are based upon information available at the time of preparation of this ROD, from the Operable Unit
5 RI/FS. In the event that the Operable Unit 5 ROD determines that lower soil remediation levels are
required, further remedial action will be conducted on the Operable Unit 4 residual soils to achieve
the lower remediation levels for those COCs which are affected.
9-5
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FEMP-OU4ROD-8 FINAL
December 1994
Soils exhibiting elevated direct radiation levels (i.e., potentially contaminated soils beneath Silos 1 and
2) will be segregated from other soils and transported to the vitrification facility for processing.
Following excavation, the affected areas will be returned to original grade with the placement of clean
backfill and revegetated to control erosion.
9.1.8 Soil Disposition
The selected remedy as defined under Alternative 2C specifies on-property disposal for Operable
Unit 4 contaminated soils. However, this final action will be held in abeyance until a site-wide
decision is reached in the Operable Unit 5 ROD for the final disposal of contaminated soils. The
final decision on disposal of contaminated soils generated from Operable Unit 4 will be determined as
part of the Record of Decision for Operable Unit 5. The Operable Unit 4 soils will be managed
consistent with the disposal remedy put forth in the Operable Unit 5 ROD for contaminated soils. In
the event unforeseen circumstances preclude the integration of Operable Unit 4 contaminated soils into
the Operable Unit 5 disposal decision, the final disposal decision for Operable Unit 4 contaminated
soils will be documented in a ROD amendment for Operable Unit 4 in accordance with Section 117(c)
of CERCLA and EPA guidance. The ROD amendment will provide the public and the EPA further
opportunity to review and comment on the final disposal option for Operable Unit 4 contaminated
soils. A ROD amendment to the Operable Unit 4 ROD will not be necessary in the event the
Operable Unit 5 remedy for contaminated soils can be feasibly implemented by Operable Unit 4.
Holding the Operable Unit 4 final disposal decision in abeyance fosters an integrated site-wide
disposal approach for contaminated soils. The largest volume of contaminated soils from the site will
be generated within Operable Unit 5, making it more appropriate to fully develop the final disposal
option for contaminated soil through the Operable Unit 5 ROD. Additionally, Operable Unit 4 will
be able to take advantage of any applicable waste minimization initiatives developed for contaminated
soils under the Operable Unit 5 ROD.
Excavation and removal of Operable Unit 4 contaminated soils will proceed as described above.
Operable Unit 4 contaminated soils will be disposed in accordance with the selected remedy identified
in the Operable Unit 5 ROD for soils. Contaminated soils generated prior to finalization of the
Operable Unit 5 ROD will be placed in interim storage to await finalization of the disposal decision
for contaminated soils under Operable Unit S. The design and management of interim storage
facilities will be consistent with the approved Work Plan for FEMP Removal Action No. 17 -
9-6
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FEM P-OU4ROD-8 FINAL
December 1994
Improved Storage of Soil and Debris. The management of Operable Unit 4 contaminated soils will
include measures to ensure future identification and retrieval of these wastes for final disposition.
Water Treatment
Wastewater generated as a result of this selected remedy along with water removed from the decant
sump tank, Silo 4 (if any), and any contaminated perched water encountered during remediation will
be treated at the FEMP wastewater treatment facility prior to discharge. In accordance with the
Amended Consent Agreement, groundwater cleanup will be handled by Operable Unit 5. Operable
Unit 4 would only handle the cleanup of perched water encountered during implementation of the
selected remedy.
9.1.9 Cost
The total estimated present worth cost for the selected remedy is 91.7 million dollars. Table 9-1
summarizes the capital and the operating and maintenance costs. The total estimated present worth
cost is less than the sum of the total costs of the preferred alternatives for Subunit A, B, and C. This
is because Subunits A and B will share common costs for site preparation, construction of the silo
contents removal work platform and processing facilities, and packaging and transportation.
9.2 SOIL CLEANUP CRITERIA
After the silos are demolished, the surface and subsurface soils within the Operable Unit 4 boundary
will be excavated to attain required remediation levels for each of the constituents of concern. These
soil remediation levels are preliminary until final soil remediation levels can be established through
the Operable Unit 5 ROD. In the event that the Operable Unit 5 ROD determines that lower soil
remediation levels are required, further remedial action will be conducted on the Operable Unit 4
residual soils to achieve the lower remediation levels for those COCs that are affected.
9.2.1 Land Use and Receptor Description
Preliminary remediation levels for soil cleanup were developed for an expanded trespasser receptor
under a future land use with continued federal ownership to represent post remediation conditions at
Operable Unit 4 and, therefore, provide the basis for establishing cleanup levels.
The future land use with continued federal ownership scenario represents a government reserve which
remains under U. S. government control with no future development intended. Active access controls
currently in place at the FEMP site (i.e. fencing, security access control, signs, etc.) will be
9-7
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TABLE 9-1
COMBINED COST ESTIMATE FOR SELECTED REMEDY
DIRECT
INDIRECT
TOTAL
DESCRIPTION
COST
CQSJ
COST
CAf>f?At COSTS
SITE PREPARATION
$768,600
$660,000
$1,428,600
WASTE PROCESSING
$1,695,800
$1,427,700
$3,123,500
VITRIFICATION EQUIPMENT
$2,935,500
$1,703,600
$4,639,100
HYDRAULIC/PNEUMATIC REMOVAL SYSTEM
$6,655,400
$14,068,800
$20,724,200
DEMOLITION & REMOVAL
$3,980,400
$5,977,000
$9,957,400
TRANSPORTATION
$1,915,000
$1,915,000
DISPOSAL
$2,360,200
$2,360,200
PACKAGING (3,694 PKGS. @ $955/PKG.)
$975,200
$2,552,600
$3,527,800
DISPOSAL VAULT
$6,410,200
$10,914,800
$17,325,000
TOTAL CAPITAL
$27,696,300
$37,304,500
$65,000,800
RISK BUDGET
$3,046,600
$4,103,500
$7,150,100
SUBTOTAL
$30,742,900
$41,408,000
$72,150,900
CONTINGENCY (20.0%)
$6,148,600
$8,281,600
$1 4,430,200
TOTAL ESTIMATED INSTALLED COST
$36,891,500
$49,689,600
$86,581,100
(O&M) COSTS
DURING CONSTRUCTION
$16,615,500
POST-REMEDIATION
$3,567,000
TOTAL PRESENT WORTH COST (CAPITAL AND O&M © 7%)
$91.738.000
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FEMP-OU4ROD-8 FINAL
December 1994
discontinued, but the federal government will exercise the right to preclude site development through
deed restrictions. This land use scenario was not included in the Baseline Risk Assessment. It was
developed in a part of the FS for Operable Unit 4 to facilitate evaluation of long-term risks with
continued land use restrictions. In addition to deed and land development restrictions, fences will be
erected and equipped with signs posted to prohibit trespassing.
The expanded trespasser receptor was developed to represent an adult and/or child that visits the site
despite restrictions imposed under continued federal ownership. The possible activities of this
receptor include hiking, roaming, bird watching, and other similar activities. An expanded trespasser
may be exposed to Operable Unit 4 residual contaminants through the following pathways:
• Inhalation of fugitive dust, volatile organic compounds, and radon;
• Incidental ingestion of soil;
• Dermal contact with contaminants in soil; and
• External radiation exposure from radionuclides in soil.
9.2.2 Preliminary Remediation Levels
Tables 9-2 and 9-3 provide preliminary remediation levels for soil cleanup and the estimated risk to
affected receptors from the residual contaminants left in the soils. Specific details on the development
of these preliminary remediation levels are provided in the FS Report for Operable Unit 4.
As mentioned earlier, the future land use scenario for Operable Unit 4 will be as a government
reserve with continued federal ownership. The on-property receptor of concern under this scenario
will be an expanded trespasser. Cancer risks and chemical hazard to the expanded trespasser, from
residual contaminants, are presented in Tables 9-2 and 9-3. For comparison, cancer risks and
chemical hazard to an on-property farmer under a future land use scenario without federal ownership
are also presented. Proposed remediation goals (PRGs), based on an ILCR of 10"6 and an HI of 0.2
were developed in the FS. These PRGs, presented in Tables 9-2 and 9-3 for the expanded trespasser,
represent allowable incremental concentrations above background for these COCs based on targets of
10"6 incremental risk and hazard index of 0.2.
For radionuclide constituents of concern, the PRG was added to the background concentration to
derive the preliminary remediation level. Based on die contaminant concentrations found in Operable
Unit 4 soils, PRLs were not required for non-radionuclide contaminants as indicated in Table 9-3.
9-9
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TABLE 9-2
PRELIMINARY REMEDIATION LEVELS IN SOILS - RADIONUCLIDES
Constituent
of
Concern
Expanded
Trespasser
10* ILCR
PRG
pCi/g
Background
(95th
percentile) '
pCi/g
ARAR
Target
pCi/g
Max. Detected Soil
Concentration, pCi/g
Proposed
Remediation
Level*
pCi/g
ILCR above background
to an Expanded
Trespasser from
Proposed Remediation
Levelb
Surface
Subsurface
Pb-210
+2 progeny
77
1.33
NA
4.5
101
78
1.0x10'®
Ra-226
+ 5 progeny
0.37
1.4S
S (top 6" soil)
15 (max. below 6")
88
206
2
1.0x10 6
Ra-228
+1 progeny
0.77
1.19
NA
0.48
1.24
2
1.0x10 6
Sr-90
+1 progeny
1420
ND
NA
1.8
0.8
NR
<1x10 6
Tc-99
38700
ND
NA
3.6
3.6
NR
<1x106
Th-228
0.4
1.43
NA
2.9
1.3
2
1.0x10'
U-238
+2 progeny
59
1.22
NA
37
53
60
1.0x10 6
Notes:
a) Sum of backround and PRG.
b) Includes the direct radiation, soil ingestion, and inhalation pathways.
NA Not Available
NR No Remediation Required
-------
TABLE 9-3
PRELIMINARY REMEDIATION LEVELS IN SOILS - CHEMICALS
Constituent
of
Concern
Expanded
Trespasser
HI = 0.2
PRG
mg/kg
Expanded
Trespasser
10 * ILCR
PRG
mg/kg
Background
(95"'
percentile)
mg/kg
ARAR
Target
mg/kg
Max. Detected Soil
Concentration,
mg/kg
Proposed
Remediation
Levels
mg/kg
HI to an
Expanded
Trespasser from
Proposed
Remediation
Levels
Risk to an
Expanded
Trespasser from
Proposed
Remediation
Level'
Surface
Sub
surface
Antimony
31
N/A
7.7
NA
32
32
NR
0.2
N/A
Arsenic
510
23
8.45
NA
10
12
NR
N/A
<1x10 6
Barium
>10000
N/A
91.3
NA
112
142
NR
<1
N/A
Cadmium
26
N/A
0.82
NA
6
7
NR
<1
N/A
Chromium (III)
NA
N/A
15.5
NA
23
25
NR
<1
N/A
Molybdenum
930
N/A
2.6
NA
25
30
NR
<1
N/A
Nickel
8300
N/A
20.9
NA
39
39
NR
<1
N/A
Silver
130
N/A
2.6
NA
10
18
NR
<1
N/A
Thallium
31
N/A
0.58
NA
0.5
0.5
NR
<1
N/A
Vanadium
1700
N/A
30.4
NA
28
33
NR
<1
N/A
Zinc
>10000
N/A
62 2
NA
65
67
NR
<1
N/A
-------
Table 9-3
(Continued)
Constituent
of
Concern
Expanded
Trespasser
HI = 0.2
PRG
mg/kg
Expanded
Trespasser
10 * ILCR
PRG
mg/kg
Background
(95*
percentile)
mg/kg
ARAR
Target
mg/kg
Max. Detected Soil
Concentration,
mg/kg
Proposed
Remediation
Levels
mg/kg
HI to an
Expanded
Trespasser from
Proposed
Remediation
Levels
Risk to an
Expanded
Trespasser from
Proposed
Remediation
Level"
Surface
Sub
surface
Benzo(a)anthracene
NA
61
ND
NA
4.7
ND
NR
N/A
< 1x10'
Benzo(a)pyrene
NA
8.8
ND
NA
5.2
ND
NR
N/A
< 1x10'
Benzo(b)fluoranthene
NA
72
ND
NA
9.7
ND
NR
N/A
< 1x10®
Chrysene
NA
2000
ND
NA
3.5
ND
NR
N/A
< 1x10'
Dibenzo(a ,h)anthracene
NA
7.9
ND
NA
0.9
ND
NR
N/A
< 1x10'
lndeno(l ,2,3-cd)pyrene
NA
32
ND
NA
4.2
ND
NR
N/A
<1x10'
'Includes (he direct radiation, soil ingestion, and inhalation pathways.
NA = Not Available.
N/A= Nol Applicable.
ND = Not Detected.
NR = No Remediation Required.
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December 1994
The clean-up levels presented in Tables 9-2 and 9-3 are preliminary. The development of final soil
clean-up levels for Operable Unit 4 will be addressed in the Operable Unit 5 Record of Decision.
These final clean-up levels will be consistent with the overall site approach for the development of
soil clean-up levels as approved by the USEPA.
In those cases where a target concentration level specified by an ARAR is less than the proposed
remedial level, the ARAR level was adopted as the remediation level. Remediation would be
required for COCs that are present in the surface and subsurface soil at higher concentrations than the
preliminary remediation level.
Based on the preliminary remediation levels, the COCs driving soil cleanup are Pb-210 and Ra-226.
Soil remediation targeted at achieving the preliminary remediation levels for Pb-210 and Ra-226 will
generate the largest volume of excavated soils.
9.3 MEASURES TO CONTROL ENVIRONMENTAL IMPACTS
All practical measures will be employed at the FEMP site to minimize environmental impacts during
the implementation of the Operable Unit 4 Remedial Action. In accordance with DOE regulations
for implementing the NEPA (10 CFR §1021), DOE has factored environmental impacts into the
decision making process for the Operable Unit 4 Remedial Action.
Measures to control environmental impacts have been identified in the Operable Unit 4 FS/PP-DEIS
and will be implemented during remedial design and remedial action to minimize impacts to on-
property natural resources (e.g., wildlife and wildlife habitat, cultural resources, wetlands, surface
water, groundwater). Operable Unit 4 remedial activities would not impact floodplain areas at the
FEMP. The 100- and 500-year floodplain of Paddys Run is located near the silos and associated
support facilities. Direct physical impact to the floodplain will not occur; however, the
implementation of engineering controls will eliminate any indirect impact such as runoff and sediment
deposition to the floodplain. Changes in flood elevation will not occur. The following provides a
discussion of the measures that will be taken to minimize impacts to the environment on and adjacent
to the FEMP Site.
Excavation activities and the construction and operation of the various support facilities (e.g., waste
processing facility and storage facility) will result in the disturbance of 1.0 ha (2.5 acres) of terrestrial
and managed field habitat and the potential for increased erosion and sediment loads to surface water
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FEMP-OU4ROD-8 FINAL
December 1994
i.e., Paddys Run. However, appropriate engineering controls such as silt fences, vegetative cover,
and runoff control systems will be utilized to minimize runoff to Paddys Run and its associated
aquatic habitat, including the state-threatened Sloan's crayfish (orconectes sloanii). In addition,
appropriate High Efficiency Particulate Air (HEPA) filtration systems will be utilized during operation
of the vitrification facility to minimize the potential for increased emissions to the ambient air and
potential impacts to surrounding riparian habitat.
Groundwater, surface water, and air monitoring will be performed before, during, and after remedial
activities. If adverse effects are detected in any of these environmental media, work will be
immediately stopped until the effects are controlled and/or the appropriate response actions are
executed.
The selected remedy for Operable Unit 4 includes the removal of the contaminated surface soil from
the entire Operable Unit 4 Area and the replacement with clean fill material. Therefore, the primary
residual contaminant would be uranium below the PRL in the subsurface soil. Because the contact of
ecological receptors is limited (near background levels) to surface soil and surface waters, residual
ecological risks associated with the Operable Unit 4 preferred alternative would be indistinguishable
from those risks posed by background levels in the soil.
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10.0 STATUTORY DETERMINATIONS
In accordance with the statutory requirements of Section 121 of CERCLA, as amended, remedial
actions taken pursuant to Sections 104 and 106 must satisfy the following:
• Be protective of human health and the environment.
• Comply with all ARARs established under federal and state environmental laws (or
justify a waiver).
• Be cost-effective.
• Utilize permanent solutions and alternative technologies or recovery technologies to the
maximum extent practicable.
• Satisfy the statutory preference for remedies that utilize treatment and also significantly
reduce the toxicity, mobility, and volume of the hazardous substances, pollutants, or
contaminants.
In addition, CERCLA requires five year reviews to determine if adequate protection of human health
and the environment is being maintained where remedial actions result in hazardous substances
remaining on-site above health-based levels. A discussion is provided below on how the selected
response actions for Operable Unit 4 satisfy these statutory requirements.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy achieves the requirement of being protective of human health and the
environment by: (1) removing the sources of contamination, (2) treating and stabilizing the materials
giving rise to the principal threats from Operable Unit 4, (3) disposing of treated materials at an off-
site location which provides the appropriate level of protectiveness, and (4) remediating contaminated
soils and debris to levels which are protective. The contents of Silos 1, 2, and 3 and the Decant
Sump Tank will be removed and treated through a vitrification process and disposed at the NTS.
Vitrification will stabilize these materials and inhibit leaching of contaminants to the environment
when they are disposed. All silo structures and other facilities will be removed from Operable Unit 4
and disposed of in a manner consistent with the forthcoming ROD for Operable Unit 3.
Contaminated soil will also be removed and disposed in a manner consistent with the Operable Unit 5
ROD.
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FEMP-OU4ROD-8 FINAL
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Baseline cancer risks from current conditions exceed the 10~* to 10^ acceptable risk range. Under
current conditions, the dominant risk is 5 x 10"3 to the trespassing child. Under the future land use
scenario of continued federal ownership and the expanded trespasser receptor, the residual cancer risk
from Operable Unit 4 will be reduced to less than 1 x 10*. There are no short-term threats associated
with the selected remedy that cannot be readily controlled. In addition, no adverse cross-media
impacts are expected from the remedy.
10.2 COMPLIANCE WITH LEGALLY APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
In accordance with Section 121 of CERCLA, the selected remedy will achieve a standard or level of
control consistent with all federal and State of Ohio ARARs and TBCs. The selected remedy will
also be performed in accordance with all pertinent DOE Orders as well as other requirements.
Appendix B provides a listing of the chemical-, action-, and location-specific ARARs and TBCs
which are invoked by this remedy.
Removal, treatment by vitrification, and shipment for off-site disposal of silo material will be
conducted in accordance with ARARs identified in this ROD. Disposition of rubble and debris from
OU4 will be determined by the ROD for OU3, and will be conducted in accordance with the ARARs
identified in that ROD; similarly, disposition of soils from OU4 will be determined by the ROD for
OU5 and will be conducted in accordance with ARARs established in that ROD. Any interim storage
of rubble and debris or soils, prior to final disposition under the RODs for OU3 and OUS,
respectively, will be in accordance with ARARs identified in this OU4 ROD, pertinent DOE orders,
and applicable site procedures.
Although RCRA is cited as an ARAR for remediation of Operable Unit 4, the silo residues destined
for remediation are by-product material as defined under Section 11(e)(2) of the Atomic Energy Act
of 1954, and as such, are excluded from RCRA regulation [40 CFR § 261.4(a)(4)], By-product
material, as defined by the AEA, includes tailings or wastes produced by the extraction or
concentration of uranium and thorium from any ore processed primarily for its source material
content (42 U.S.C. 2014).
Since the residues are excluded from regulation as solid or hazardous waste, the requirements under
RCRA are not applicable to Operable Unit 4 remedial actions. However, analytical data from Silos
1,2, and 3 material exceed toxicity characteristic levels for various toxicity characteristic metals
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FEMP-OU4ROD-8 FINAL
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under RCRA. Because the residues are sufficiently similar to hazardous waste regulated by RCRA
and some RCRA requirements are appropriate for the circumstances of the release or potential
release, certain substantive requirements of RCRA are relevant and appropriate for management of
these residues, and are included in the table of ARARs.
10.3 COST EFFECTIVENESS
The selected remedial alternatives for each subunit have been determined to be protective of human
health and the environment, and to be cost effective. The present worth cost for this remedy is 91.7
million dollars.
The off-site alternatives selected for the contents of Silos 1, 2, and 3 had a lower cost than the on-
property disposal alternative for these materials. This is due to the fact that costs associated with
construction of a facility that would provide the needed level of protection to human health and the
environment from the silo contents would be greater due to the increased intruder protection
requirements in the event of a trespasser. Also, the packaging and transportation costs associated
with the vitrified material were lower than those for the cement stabilized material. Vitrification is
more cost effective than cementation because the reduction in volume of vitrified product minimizes
the amount of waste requiring handling, resulting in reduced transportation and disposal costs.
Conversely, transportation and disposal costs associated with disposing Operable Unit 4 soils and
debris at NTS or a commercial facility are higher than the costs associated with construction of an
engineered facility designed to manage the material on-property. Also, integration of the Operable
Unit 4 disposal remedy for soils and debris with Operable Units 5 and 3 respectively, allows for
economies of scale through treatment by processes developed for larger volumes of soil and debris.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM
EXTENT PRACTICABLE
The EPA and the State of Ohio have determined that the selected remedy for Operable Unit 4
represents the maximum extent to which permanent solutions and treatment technologies can be
utilized in a cost-effective manner. Of those alternatives that are protective of human health and the
environment and comply with ARARs, EPA, and the State of Ohio have determined that this selected
remedy provides the best balance of tradeoffs among the alternatives in terms of long-term
effectiveness and permanence, reduction in toxicity, mobility, and volume through treatment, short-
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FEMP-OU4ROD-8 FINAL
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term effectiveness, implementability, and cost. The selected remedies also meet the statutory
preference for treatment as a principal element, and meet state and community acceptance.
Vitrification and off-site disposal will provide permanent treatment and volume reduction for the silo
contents. By physically binding the contaminants into a glass-like matrix, the mobility of the
contaminants and the emanation of radon gas would be greatly reduced. Vitrification will also
significantly reduce the leachability of metal contaminants of concern to levels that are below RCRA
regulatory thresholds. Vitrification will destroy any organic contaminants in the waste material due to
the operating temperature of the treatment process. In addition, the treated material would be less
than 50 percent of its original volume. As a result, the selected remedy would meet the CERCLA
requirement for permanent solutions that reduce the toxicity, mobility, or volume through treatment.
Part of the remedy selected for contaminated soils and debris may also involve treatment of the waste
material prior to disposal. The soil and debris will be placed into interim storage pending finalization
of the disposal decision for these wastes through the RODs for Operable Units 3 and 5. This allows
for the implementation of any applicable resource recovery technologies for these wastes, which are
developed and included in the RODs for these operable units.
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating the contents of Silos 1, 2, and 3 in a vitrification process, and providing for treatment of
contaminated debris and soils should treatment become the selected remedy for these wastes in the
Operable Units 3 and 5 RODs, the selected remedy mitigates the principal threats posed by Operable
Unit 4 through the use of treatment technologies. Therefore, the statutory preference for remedies
that employ treatment as a principal element is satisfied.
10.6 UNAVOIDABLE ADVERSE IMPACTS
A number of unavoidable adverse impacts (Table 10-1) would occur when any of the action
alternatives are implemented. As stated in the alternatives and in Table 10-1, many of these impacts
would only be temporary. In addition, it should be noted that these impacts are presented for those
remedial actions that will be implemented under the selected remedy. Those impacts associated with
the final disposition of Subunit C material (soil and debris) will be identified and evaluated as part of
the Records of Decision OUs 3 and 5.
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FEMP-OU4ROD-8 FINAL
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TABLE 10-1
UNAVOIDABLE ADVERSE IMPACTS ON RESOURCES
Affected Resource Impact Type
Soil and Geology Soil at the FEMP site and the NTS would be disrupted by construction
and excavation activities. Many impacts would be temporary, pending
completion of remedial activities and restoration programs. The
implementation of the selected remedy would temporarily disturb
approximately 1.0 ha (2.5 acres) at the FEMP (e.g., excavation and
construction). A permanent disruption of approximately 8 ha (20 acres)
at the NTS would occur. All areas disturbed at the FEMP site would be
regraded and revegetated. The regional geology of the FEMP site and
surrounding area would not be affected by the selected remedy.
Implementation of off-site disposal would not affect the regional geology
of the NTS or surrounding areas.
Water Quality and
Hydrology
Air Quality
Biotic/Ecological
Resources
Wetlands and
Floodplains
Potential short-term impacts (e.g., release of sediment and fugitive dust)
on water quality and hydrology would be minimal regrading and
revegetation around the silos to minimize potential water quality impacts
would occur. Assuming monitoring and maintenance activities continue
at the NTS, no long-term impacts would be expected from waste disposal
at the NTS.
Some temporary impacts to air quality at the FEMP site would result
from fugitive dust emissions associated with construction and excavation
activities (e.g., grading, compacting, loading). Lesser impacts would
also be incurred from vehicle and equipment exhausts. These impacts are
not expected to affect human health or the environment. No long-term
impacts on air quality would be expected from activities associated with
the selected remedy. Disturbed areas would be restored (e.g., regraded
and revegetated) after completion of the remedial activities, thus
minimizing the potential for the fugitive dust release. The off-site waste
disposal facility would be designed to prohibit emission from stored
waste. Only in the case of an accident during remedial actions would
appreciable air quality impacts occur.
Short-term disturbance of terrestrial, managed field, riparian and aquatic
habitat would be expected. Approximately 1.0 ha (2.5 acres) of habitat
at the FEMP site would be disturbed during excavation and construction
activities. Habitat at the NTS is limited and it is believed little
displacement of native species would occur.
Alternative 2C would not impact wetlands. Direct floodplain impacts
resulting in a change of flood elevations would also not occur.
Engineering controls would be implemented to minimize or eliminate
indirect floodplain impacts. No wetlands or floodplains are present at the
NTS.
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FEMP-OU4ROD-8 FINAL
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TABLE 10-1
(Continued)
Affected Resource Impact Type
Socioeconomics and Minimal short-term impacts (e.g., increased traffic noise) to the
Land Use socioeconomics and land use would occur. The long-term socioeconomic
and land use impacts for the FEMP site would be positive because the
waste would be isolated and controlled, thus no changes from current
land use would be expected. Removing waste from the site would help to
eliminate impacts on future populations and economic growth at the
FEMP site. Disposal of this waste at the NTS would not be expected to
impact socioeconomics or land use. Total present worth costs of the
selected remedy is $91.7M. For this analysis, it is assumed that all
resources required for remedial activities can be found within the thirteen
county Consolidated Metropolitan Statistical Area (CMSA). The
cumulative operating budget for the CMSA was approximately
$805,000,000.00. The collectible revenue for the CMSA would increase
up to approximately 11.4%.
Visual Resources Construction and excavation activities would result in some minor
incremental increases over the current visual and aesthetic impacts of the
FEMP site. Short-term impacts would also be incurred at the NTS
during construction, excavation, and transportation activities. The
majority of impacts would be temporary and would cease following
completion of remedial action activities and site restoration; however,
aesthetic impacts would occur from the implementation of waste disposal
facilities.
Noise Ambient noise levels would temporarily increase as a result of
construction, excavation, and transportation activities. All noise impacts
would be temporary and would cease following completion of remedial
activities.
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FEMP-OU4ROD-8 FINAL
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10.7 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES
Implementing the selected remedy will result in permanent commitment of on-property land and
associated natural resource services for material disposal at the FEMP site and off-site land at the
NTS.
Soil at the FEMP site and the NTS will be disturbed by construction and excavation activities. Many
impacts will be temporary, pending completion of remedial activities and restoration programs. The
implementation of the selected remedy will temporarily disturb approximately 1.0 ha (2.5 acres) at the
FEMP site. Furthermore, implementation of this remedy will permanently commit 8 ha (20 acres) at
the NTS. All areas disturbed at the FEMP site will be regraded and revegetated.
Approximately 1.0 ha (2.5 acres) of habitat at the FEMP site will be disturbed during excavation and
construction activities. Approximately 89 ha (220 acres) are expected to be permanently committed
on a site-wide basis, with another twenty to thirty acres subject to temporary disturbances. It is
assumed that processes such as revegetation and regrading are successful; however, the loss of habitat
will result in a permanent displacement or loss of wildlife and associated services. Terrestrial habitat
at the off-site disposal areas is limited, and little displacement of species is expected to occur.
Wetlands and associated natural resource services will not be injured by the selected remedy. Long-
term direct impacts to the floodplain resulting in changes of flood elevations will not occur.
Engineering controls would be implemented to minimize or eliminate any indirect impacts. There
will be no impacts to wetlands or floodplains with disposal at the off-site disposal areas.
Consumptive use of geological resources (e.g., quarried rock, sand, and gravel) and petroleum
products (e.g., diesel fuel and gasoline) will be required for removal, construction, and disposal
activities of the selected remedy. Supplies of these materials will be provided by the construction
contractor. Additional fuel use will result from off-site transport of the materials. However,
adequate supplies are available without affecting local requirements for these products.
The treatment processes for the selected remedy will require the consumptive use of materials and
energy. The vitrification process will be energy-intensive and require commitment of a considerable
supply of electricity. Electricity can be obtained from the local utility.
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FEMP-OU4ROD-8 FINAL
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Maintenance activities will be performed as necessary. Long-term environmental impacts would not
be expected to occur from the Operable Unit 4 selected remedy. Monitoring and periodic site
inspections would be performed to ensure long-term protection of human health and the environment.
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11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The FS/PP-DEIS for Operable Unit 4 was released for public comment in March 1994. The DOE
reviewed all written and oral comments submitted during the public comment period. Upon review of
these comments, it was determined that no significant changes to the remedy, as was originally
identified in the FS/PP-DEIS, were necessary. However, it should be noted that the repromulgation
of 40 CFR §191 by the EPA, did result in minor changes in the comparative analysis of alternatives
presented in the FS/PP-DEIS. The following discussion addresses the nature and extent of these
changes.
11.1 REPROMULGATION OF 40 CFR SI91
Repromulgation of the 40 CFR §191 requirements for Management and Disposal of Spent Nuclear
Fuel, High-Level, and Transuranic Wastes has caused changes to be made to the ARARs as described
in the Draft Final FS/PP-DEIS, conditionally approved by the EPA on February 9, 1994. DOE
chooses not to submit revision pages to the FS/PP-DEIS; all changes to the ARARs for that document
and any impacts from the repromulgation are discussed in this section of the ROD. Since the
repromulgation resulted in relevant and appropriate, rather than applicable requirements, the
repromulgation of 40 CFR §191 will not impact the proposed off-site alternative for disposition of the
K-65 material. However, the on-property disposal alternatives (Alternatives 2A/Vit and 2A/Cem) that
were previously retained, having passed the threshold criteria of the detailed analysis, are no longer
able to meet the threshold criteria of compliance with ARARs, and are consequently dropped from
further consideration. Subsequendy, all references to Alternative 2A are therefore deleted from
reference in the text of the ROD, and in Appendix A.
The only relevant and appropriate requirement from 40 CFR §191 that is retained as an ARAR in this
ROD (Appendices A and B) for the proposed alternative is 40 CFR §191.03(b), which establishes
dose limits for management and storage of the K-65 material. However, since this ARAR is relevant
and appropriate, rather than applicable, it will pertain only to the on-propertv portions of the remedial
activities conducted under this action.
11.1.1 Background
The United States Department of Energy - Fernald Field Office (DOE-FN) received conditional approval
of the Draft Final FS/PP-DEIS for Operable Unit 4 from USEPA on February 9, 1994. Included in the
FS/PP-DEIS applicable or relevant and appropriate requirements (ARARs) was a reference to 40 CFR
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FEMP-OU4ROD-8 FINAL
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§191, "Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear
Fuel, High-Level, and Transuranic Wastes". This reference to 40 CFR §191 was modified in the
Operable Unit 4 FS/PP-DEIS, submitted in February 1994 in response to the conditional approval letter,
to reflect the changes to the regulation that occurred upon its repromulgation on December 20, 1993.
It still accommodates the specific direction previously provided by the USEPA regarding incorporation
of the 40 CFR §191 requirements as an ARAR/TBC ("Operable Unit 4 Screening Dispute Resolution
U.S. DOE Fernald", Catherine McCord, USEPA, to Andy Avel, DOE, dated October 18, 1990). The
final rule became effective on January 19, 1994, during final revision of the Operable Unit 4 FS/PP-
DEIS, and agency comments did not address the repromulgation of the rule. This fact was discussed with
the USEPA, and a DOE position paper on the incorporation of 40 CFR §191 as an ARAR for Operable
Unit 4 remediation was submitted to the USEPA for concurrence. The USEPA disagreed with the draft
position proposed by DOE, and responded with a directive to incorporate the substantive elements of the
repromulgated rule into the ROD, with an option to resubmit change pages to the FS/PP-DEIS
("Application of 40 CFR §191 to OU #4", Jim Saric, USEPA, to Jack Craig, DOE, dated April 25,
1994). DOE elected not to revise the FS/PP-DEIS, but rather to describe in this section of the ROD
changes to the table of ARARs and associated impacts on selection or implementation of remedial
alternatives that have occurred between the time the Draft Final FS/PP-DEIS was conditionally approved,
and the submittal of the ROD to the USEPA and OEPA. The list of ARARs in the ROD, and proposed
approach to compliance with the substantive elements thereof, once approval by the USEPA is obtained,
will be the final approved list of applicable or relevant and appropriate requirements for final remediation
of Operable Unit 4.
11.1.2 Impacts of Repromulgation
Since 40 CFR §191 cannot be considered a legally "applicable" class of ARAR for this CERCLA
remediation, §191 is not applicable to any Operable Unit 4 waste streams. Since compliance with only
applicable requirements is required to be demonstrated for off-site remedial alternatives proposed under
CERCLA, these requirements will not impact the proposed off-site alternative for disposal of the treated
K-65 material at the NTS.
DOE previously included 40 CFR §191 Subpart A as a relevant and appropriate requirement, and Subpart
B as to be considered (TBC) criteria for management of K-65 material in accordance with guidance
received from the USEPA. Subpart A of §191, entitled "Environmental Standards for Management and
Storage" includes public dose rate standards for protection of the public from radiation hazards posed by
spent nuclear fuel, high-level, or transuranic waste material. The repromulgation of the Final Rule did
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FEMP-OU4ROD-8 FINAL
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not materially affect the sections of Subpart A referenced in the Operable Unit 4 FS/PP-DEIS; the
Subpart A requirement referenced in the Operable Unit 4 FS/PP-DEIS remains unchanged in the table
of ARARs as a relevant and appropriate requirement for the on-property portion of the remedial activities
to be conducted on the K-65 material.
Prior to repromulgation, Subpart B requirements were in remand, and were therefore considered TBCs
in the FS/PP-DEIS submitted to the agencies. Since Subpart B of §191, entitled "Environmental
Standards for Disposal", has been repromulgated, the USEPA has directed that sections must now be
considered as relevant and appropriate requirements for any on-property disposal alternatives. Since it
could not be demonstrated that the on-property disposal of treated K-65 material would comply with
specific requirements of this Subpart, those alternatives involving on-property disposal (Alternatives
2A/Vit and 2A/Cem) were no longer able to meet the threshold criteria of compliance with these ARARs,
and were consequently dropped from further consideration. All descriptions to Alternative 2A are
therefore deleted from reference in the text of the ROD, and in Appendix A.
A new Subpart C of §191 "Environmental Standards for Groundwater Protection", was created by the
repromulgated rule. As with Subpart B, this new Subpart pertains only to disposal systems. The
elements of this Subpart must now be considered as relevant and appropriate requirements; however,
since the on-property disposal alternatives to which this Subpart pertains were dropped from further
consideration on the basis of non-compliance with Subpart B requirements, and since Subpart C will not
pertain to any off-site disposal alternatives, these requirements will not be included in the Appendix A
or B tables of ARARs. Subpart C will therefore have no effect on the selected alternative, which includes
off-site disposal.
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REFERENCES
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International Agency for Research on Cancer (IARC), 1987, IARC Monographs on the Evaluation of
Carcinogenic Risks to Humans. Overall Evaluations of Carcinogenicity: An Updating of IARC
Monographs Vol. 1 to 42. Preamble. Supplement 7. World Health Organization: Lyon, France,
pp. 17-34.
National Council on Radiation Protection and Measurements, 1991, "Effects of Ionizing Radiation on
Aquatic Organisms, "NCRP Report No. 109. NCRP, Bethesda, MD.
U.S. Army Corps of Engineers, 1987, "Wetlands Delineation Manual".
U.S. Dept. of Energy, 1992, "Risk Assessment Work Plan Addendum, "Final Draft, FEMP,
Remedial Investigation and Feasibility Study, DOE, Fernald Field Office, Fernald, OH.
U.S. Dept. of Energy, 1993a, "Remedial Investigation Report for Operable Unit 4, "U.S. Department
of Energy, Fernald Field Office, November 1993.
U.S. Dept. of Energy, 1993b, Site-Wide Characterization Report FEMP, Fernald, OH, Remedial
Investigation and Feasibility Study, Draft, DOE, Fernald Field Office, Fernald, OH, March 1993.
U.S. Dept. of Energy, 1994, "Feasibility Study Report for Operable Unit 4, "U.S. Dept. of Energy,
Fernald Field Office, February 1994.
U.S. Dept. of Energy, 1994, "Proposed Plan for Remedial Actions at Operable Unit 4, "U.S. Dept.
of Energy, Fernald Field Office, February 1994.
U.S. Environmental Protection Agency (EPA), 1986, Guidelines for Carcinogen Risk Assessment.
Federal Register 51(185^ pp. 33992-34003.
U.S. Environmental Protection Agency (EPA), 1989a, "Risk Assessment Guidance for Superfund:
Human Health Evaluation Manual, Part A, Interim Final," EPA/540/1-89/002. EPA, Office of
Emergency and Remedial Response, Washington, DC.
U.S. Environmental Protection Agency (EPA), 1989b, "Guidance on Preparing Superfund Decision
Documents: The Proposed Plan, the Record of Decision, Explanation of Significant Differences, the
Record of Decision Amendment," Interim Final, EPA/540/G-89/007. EPA, Office of Emergency and
Remedial Response, Washington, DC.
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U.S. Environmental Protection Agency, 1992a Integrated Risk Information System (IRIS), on-line
data service. EPA, Washington, DC.
U.S. Environmental Protection Agency, 1992b Health Effects Assessment Summary Tables, Annual
Update FY 1992, including Supplement A, July 1992, OERR 9200.6-303 (92-1)
U.S. Environmental Protection Agency (EPA), 1992c, "Community Relations in Superfund: A
Handbook," EPA/540/R-92/009, EPA, Office of Emergency and Remedial Response, Washington,
D.C.
Volf, M.B. 1984, "Chemical Approach to Glass (Glass Science and Technology: Vol. 7)," Elsevier,
New York.
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APPENDIX A
SUMMARY OF MAJOR ARARs FOR OPERABLE UNIT 4
REMEDIAL ACTION ALTERNATIVES
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C.5.0 SUMMARY OF COMMENTS NOT RESULTING IN ISSUES
Commentors A, B, D, G, H, and J inquired as to the possibility of covering the siios and ensuring
pollution prevention measures are implemented during remediation. Through the remedial design
process, appropriate measures will be evaluated, utilized, and monitored to maintain air emissions
resulting from all remedial actions at or below the regulatory requirements.
Commentors A and H wanted assurance that waste from other sites would not be brought to Fernald's
vitrification facility to be treated nor stored at the FEMP for future disposition. At this time, no plans
have been made to treat waste from other DOE sites through the Operable Unit 4 Vitrification Facility
or store materials at the FEMP. However, as part of a treatability study under the Uranium Soils
Integrated Demonstration program, DOE is considering a program that would involve importation of
uranium-contaminated soil samples from Portsmouth, Ohio to be tested at Fernald and returned to the
point of origin. This study would be conducted as an extension of the current Minimum Additive
Waste Stabilization (MAWS) program, which is part of Operable Unit 4 remediation program. These
tests are an essential component of FEMP's ability to conduct necessary research in support of DOE
technology development.
The purpose of doing this test work is to make use of the investment which DOE has already made in
equipment and experience at Fernald; to produce valuable remediation information for a nearby Ohio
site; and to avoid duplication of the resources already available at Fernald.
The pilot-scale soil decontamination work at the FEMP is part of DOE's Uranium Soils Integrated
Demonstration, a DOE Office of Technology Development program aimed at developing and applying
new and enhanced technologies by demonstrating them at one test site.
Currently, a proposed test plan is being circulated for review within DOE and FERMCO management
to solicit comments on approach, feasibility and acceptability. No action has been taken or will be
taken without stakeholder input.
Commentors D and G wanted to suggest the possibility of setting up a trust fund for monitoring and
maintenance of the on-property disposal facilities. A trust fund would not be a viable option due to
the manner in which money is budgeted and allocated to the FEMP cleanup. The United States
Congress annually reviews and approves the fiinding that the FEMP will receive through the DOE for
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remediation activities. A trust fund which would cover the cost of future routine operations and
maintenance would not be viable under the current budgetary process.
Commentor A asked how the vitrified silo residue waste form could emanate radon at the same rate as
building materials, when the waste itself is much more radioactive. She also requested clarification
on the interim storage process. The glass matrix of the vitrified Operable Unit 4 waste form retains
radon much more efficiently than porous building materials such as concrete and masonry.
Therefore, the Operable Unit 4 vitrified material releases radon at a similar rate of building materials
despite the greater quantity of radon emanating radionuclides contained within the vitrified waste
form.
Contaminated soil and debris would either be processed in accordance with the selected Operable Unit
5 (Environmental Media) and Operable Unit 3 (Production Area) remedy identified in the Operable
Unit S and Operable Unit 3 ROD or placed in an interim storage facility to await die finalization of
the disposal decisions for soils and debris under Operable Unit 5 and Operable Unit 3. The interim
storage would be managed pursuant to the approved work plan for Removal Action 17 - (Improved
Storage of Soil and Debris).
The decision regarding the final disposition of the remaining Operable Unit 4 contaminated soil and
debris has been placed in abeyance to take full advantage of planned and in-progress waste
minimization treatment processes. Further, this FEMP remedial management strategy enables the
proper integration of disposal decisions on a sitewide basis. As planned treatment facilities become
available under Operable Units 3 and 5 remedial actions, full consideration would be given to
applying these systems to the inventoried contaminated materials from Operable Unit 4. Following
the application of available waste minimization processes, the remaining Operable Unit 4
contaminated soil and debris would be disposed consistent with the selected remedies for Operable
Units 5 and 3, respectively.
Commentor D wanted to know if the 250 acres calculated to be disturbed during the implementation
of the preferred alternative for Subunit 2C included loss of habitat. The 250 acres discussed in the
Feasibility Study Report for Operable Unit 4 represents the cumulative sitewide acreage of land that
will be disturbed as a result of the implementation of all five operable unit's preferred remedial
actions. An estimated 220 acres out of the total 250 acres would be lost in the long term, with the
remaining 30 acres only rendered temporarily unusable during the implementation of the sitewide
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remedial actions. Therefore, only 220 acres would be permanently committed as a result of
implementing these remedial alternatives.
The State of Nevada (Commentor E) noted that, "... the cost estimates of long-term storage/disposal
of mixed waste at the NTS were not property accounted for in the Draft EIS. The assumptions, for
example, under which storage/disposal of mixed waste at the NTS could be considered "free " when
compared to a commercial facility, were not presented in the document." The cost for disposal of
FEMP waste at die NTS a££ incurred by the FEMP. NVO-325 (Nevada Test Site Defense Waste
Acceptance Criteria, Certification, and Transfer Requirements), Section 3.5 discusses the methods of
payment which generators will use to cover the cost of disposal operations for their waste at the NTS.
Specifically, NVO-325 states ". . .disposal charges are based upon the estimated volumes listed on
their (generator's) 'Three-Year Waste Shipment Forecast' multiplied by the corresponding disposal
charge per cubic foot. . ."
The "Three-Year Waste Shipment Forecast" is prepared annually by the generator and it estimates the
quantity of waste to be shipped to NTS by that generator each year for the next three years. These
forecasts are then used by the NTS to project operating costs for operations related to disposal of the
waste for the upcoming years. Therefore, although the NTS disposal site is a non-commercial, non-
profit government facility, the cost for operations is funded by the generators and is not provided
"free-of-charge." It should be noted that, as stated in the response to Issue 4, the Operable Unit 4
by-product material for disposal at the NTS is not mixed waste.
Commentor B questioned how NEPA was being addressed within these documents. More specifically,
how NEPA values were being integrated into the CERCLA process for the Operable Unit 4 FS/PP-
DEIS. When the Operable Unit 4 EIS process was initiated, it was DOE's policy to integrate the
NEPA requirements into the procedural and documentation requirements of CERCLA whenever
practicable. On June 13, 1994, the Secretary of Energy modified DOE's approach to National
Environmental Policy Act (NEPA) compliance for actions taken under the authority of CERCLA. As
a general policy, DOE will now rely on the CERCLA process for review of remedial actions to be
taken under CERCLA, incorporating NEPA values into CERCLA documents to the extent
practicable. DOE may choose, however, to integrate the NEPA and CERCLA processes for specific
proposed actions. For Operable Unit 4 at the FEMP, DOE has chosen to prepare integrated
CERCLA/NEPA documents. This decision was based on the longstanding interest on the part of
local stakeholders to prepare an EIS on the restoration activities at the FEMP and on the recognition
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that the draft document was issued and public comments received. Therefore, an integrated
Feasibility Study/Proposed Plan - Final Environmental Impact Statement (FS/PP-FEIS) has been
completed which evaluates alternatives for the treatment and disposal of radioactive residues contained
in storage silos at FEMP.
In accordance with both CERCLA and NEPA processes, these documents are made available to the
public for comment. Public involvement is an important factor in the decision-making process for site
remediation. Public comments will be considered in the selection of remedy for each operable unit,
which will be presented in a ROD. Applying the integrated approach for CERCLA and NEPA, DOE
plans to prepare and issue a single ROD to be signed by both DOE and EPA. The contents of the
documents prepared for the remedial actions at the FEMP are not intended to represent a statement on
the legal applicability of NEPA to remedial actions conducted under CERCLA.
Commentor Q provided twenty comments on the Proposed Plan. Some of these comments were
addressed in the issue discussions presented in Section C.4.0 of this document. The remaining
comments were basically requests for clarification of the technical content of the document and did not
have significant impact on the document. The comments are distinguished by the letter and the
response to the comments immediately follows.
(a,l) Comment; The responses to Comments "a" and "1" were similar in content and, therefore,
have been combined. The comments are related to the differences in cost and
implementation between alternatives with the same treatment technologies. The
commentor stated that "...there are variances in the capital cost for the same treatment
alternatives with the only difference being on-site versus off-site disposal. What is the
source of this variance?" Furthermore the commentor stated: "...comparison of remedial
alternatives, state differences in implementing identical treatments with different disposal
options. Is this difference related to transportation issues for off-site rather than on-site?
Please explain these differences. Also Subunit C lists no treatment for all alternatives;
please demonstrate why no treatment is acceptable."
Response: The variances of the capital costs are primarily due to the difference in the
disposal methods. The on-site disposal alternative includes the capital costs associated with
the construction of a disposal vault. The off-site alternative has no capital cost associated
with the construction of the disposal vault, but does include capital costs associated with
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the transportation and disposal of the waste at the off-site disposal facility. The
implementation of these alternatives is also affected by the same factors.
No treatment response actions were utilized in the development of alternatives for Subunit
C waste (i.e., soils and debris). This decision is consistent with the FEMP site-wide waste
management strategy. This strategy is designed to coordinate the disposal of similar waste
between operable units. From a site-wide perspective, the estimated quantity of soils and
debris requiring management by Operable Unit 4 in comparison with the total estimated
quantity of soils and debris to be managed by Operable Units 5 and 3 respectively, is
quite small. Therefore, as opposed to Operable Unit 4 developing its own treatments
methods for soils and debris, the disposition of these wastes will be integrated with the
disposal methods and any treatment methods developed by Operable Units 3 and 5.
(b,d) Comment: The responses to Comments "b" and "d" were similar in content and,
therefore, have been combined. These comments are related to post-remediation
monitoring and site reviews for alternatives which include on-property disposal. The
commentor asked: "...EPA would review on-property disposal every five years in
accordance with CERCLA requirements. Who and how often would a review be
performed in other years?" and also asked: "Post remediation O&M cost are estimated
over a thirty year period. What about the remaining years for which this material will
require monitoring?"
Response: The EPA requires a five-year review under the CERCLA as follows "...if a
remedial action is selected that results in hazardous substances, pollutants, or contaminants
remaining at the site above levels that allow for unlimited use and unrestricted exposure,
the lead agency shall review such action no less often than every five years after initiation
of the selected remedial action." The on-property disposal alternatives for Operable Unit 4
include the five-year reviews. The on-property disposal facility for the Operable Unit 4
materials would be designed to preclude the need for active operation, maintenance, and
monitoring. However, during the active operational phase of the overall FEMP site
remedial activities (approximately 30 years), the disposal facility will be monitored. It is
anticipated that such operations, maintenance, and monitoring and associated costs would
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not be warranted (i.e., no water infiltration will have been observed) beyond that
timeframe.
The Operable Unit 4 selected remedy has adopted preliminary soil cleanup levels with
exhumed soils being placed into on-property storage, pending the establishment of final
remediation levels and a disposition strategy through the Operable Unit 5 Record of
Decision (ROD). The Draft Operable Unit 5 ROD is scheduled for submittal to the
USEPA and OEPA on July 2, 1995. Since this soil disposition strategy has been adopted,
it is not considered appropriate to specify in the Operable Unit 4 ROD the long-term
operation, maintenance and monitoring requirements for any residual concentrations of
hazardous substances in soils in the Operable Unit 4 footprint.
The Operable Unit 5 ROD will establish final remediation levels for soil and the associated
long-term operation, maintenance, monitoring and institutional requirements for the site.
The scope and duration of these requirements will be consistent with the contemplated
future land use for the FEMP property and the final remediation levels documented in the
Operable Unit 5 ROD. Active operation, maintenance and monitoring for the soils staged
in the interim storage facility are contemplated as part of the Operable Unit 4 remedy.
(c) Comment: "There is no mention of retri[ejvability of the materials which would be
disposed of in the on-site disposal vault. Is this option being considered, and if not, why?"
Response: The on-property disposal facility is designed with an intruder barrier and
permanent markings to inhibit purposeful or inadvertent human intrusion of the facility's
engineered protective features and to eliminate water infiltration. This design is utilized to
provide permanent disposal of the wastes and does not include a means to readily retrieve
the waste. Designing a means to easily retrieve the waste would compromise the integrity
of the cap and would present an easier access for intrusion into the disposal facility.
(e) Comment: "Alternative 2B and 4B have an identical post remediation cost, with
Alternative 4B being untreated. Please explain how cost can be the same for treated versus
untreated materials disposed in an on-site vault?"
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Response: Post-remediation cost cover the costs associated with the monitoring and
maintenance of the disposal facility. The monitoring and maintenance requirements and
the disposal facilities for both alternatives are the same. Therefore, the post-remediation
cost associated with these activities are also the same.
(f) Comment: "There is discussions of interim storage. What is the estimated time for this
interim storage?"
Response: The use of interim storage is identified for Subunit C alternatives waste only.
Interim storage would be utilized only if the waste could not immediately be managed by
the remedial alternatives selected for Operable Units 3 and 5. If interim storage is
required, the duration of die storage would be contingent upon the schedule for
implementation of the preferred remedy identified in the Operable Units 3 and 5 ROD.
The interim storage would not exceed the date for final remediation of the FEMP site
which is currently estimated to be completed in 30 years.
(g) Comment: "Alternative 2C states that the contaminated materials would be placed in bulk
(without packaging) into the on-site disposal vault. Please expand on why this material
would not be packaged and state the advantages/disadvantages of packaged versus
unpackaged."
Response: The soils and debris considered for disposal into the disposal vault would be
contaminated with relatively low levels of contamination. The disposal facility for the
contaminated material from Alternative 2C would be designed to be protective of the
environment without the use of packaging. The use of bulk disposal eliminates the
unnecessary cost of the packaging and also reduces the cost of construction by requiring a
much smaller disposal facility.
(h) Comment: "It is stated that non-porous materials will be released from the site as
uncontaminated per DOE Order 5400.5. Will this material be checked for contamination
prior to release or just assumed to be uncontaminated and release?"
Response: As per DOE Order 5400.5, any material which has been used or stored in a
radiation area is to be considered potentially contaminated. Prior to free-release of any
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potentially contaminated material, the material will be surveyed to determine whether the
removable or total surface contamination is within specific limits as established in DOE
Order 5400.5, NRC Regulatory Guide 1.86, and FEMP site procedures. The
establishment of these limits is based on the primary objective to prevent an effective dose
equivalent to the public in excess of 100 mrem per year. This standard is considered
protective of public health and the environment.
(i) Comment: "Will wastewater generated during remediation be treated for non-radioactive
contaminates prior to discharge in the Great Miami River? To what extent will radioactive
and non-radioactive elements be removed prior to discharge?"
Response: All waste water generated at the FEMP, including waste water generated
during Operable Unit 4 remedial activities, is subject to compliance with the FEMP
National Pollution Discharge Elimination System (NPDES) permit. The NPDES permit
limits the amount of contaminants, both radioactive and non-radioactive, which may be
discharged through waste water effluent into the environment. In compliance with the
NPDES permit, all waste water generated from the remedial activities for Operable Unit 4
will be treated to comply with the FEMP NPDES permit standards.
0) Comment: "A material variance in the cost associated with Subunit C exist between 3C.1
and 3C.2 with the only apparent difference being 3C.1 disposal at NTS and 3C.2 at
Envirocare in Utah. Please explain this variance and if this is partially due to more
stringent requirements at NTS, should these more stringent requirements also be required
at a commercial facility? Which requirements is more protective? It is also stated that an
exemption from DOE Order 5820.2A (this is transposed as 5280.2A in document, page
56) is needed to dispose at a commercial facility; has this been granted?"
Response: The variance in the cost between Alternative 3C.1 and 3C.2 is primarily due to
the elimination of packaging for the Permitted Commercial Disposal Facility as opposed to
the use of packaging for the NTS. The elimination of the purchase cost of the packaging
and the reduction of required transportation significantly decreases the costs of Alternative
3C.2 as oppose - to 3C.1. The NTS currently does not accept waste in bulk form (i.e.,
unpackaged railcar) and therefore, the disposal alternative for the NTS does not recognize
the same cost savings. Because both disposal facilities operate within their permits, and
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the environments in which they are located are similar, both disposal facilities are
considered equally protective.
An exemption from DOE Order 5820.2A, which excludes the use of commercial disposal
facilities for DOE waste, has not been specifically pursued for the disposal of Operable
Unit 4 remedial wastes. The evaluation of the alternatives in the FS/PP-DEIS, indicated
that other alternatives were preferred over the alternatives which included the Permitted
Commercial Disposal Facility. Therefore, a request to grant an exemption from this DOE
Order was not required. However, exemptions from this order have been granted and
commercial disposal facilities have been utilized for other FEMP wastes.
(k) Comment: "Will notification of these shipments be given to the areas involved in the
transportation routes for both rail and truck, and what precautions for protection will be
employed?"
Response: Response to this comment is provided in Issue 5 on page C-4-20.
(m) Comment: "Is there a potential for failure of the vitrified material has the radionuclides
trap[p]ed continue to decay, and if so, what is that risk?"
Response: The weathering behavior of volcanic glass (a natural analog to the Operable
Unit 4 vitrified product) can provide some measure of the long-term stability and durability
of the vitrified product. Only very thin weathering rinds develop on volcanic glass over a
period of several million years. The slowness in the overall degradation of a glass grain
suggests that the diffusion coefficient or teachability index would remain relatively
unchanged over time. Data on the long-term stability of vitrified material are not
available, and the life expectancy of the vitrified product is difficult to estimate from short-
term leach rates. However, on the basis of the longevity of volcanic glass and diffusion
calculations, the vitrified product would be expected to withstand direct environmental
exposure for thousands of years. Furthermore, past studies have shown that the decay of
radioactive materials do not affect the durability of the vitrified product.
(n) Comment: "It states that the capital cost associated with the on-site disposal facility has
been removed. Where is (will) this cost be accounted for?"
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Rssnon.se: This comment refers to a sentence in the Proposed Plan (page 67, line 6)
which was erroneous and scheduled to be deleted from the text. However, this deletion
was inadvertently overlooked and the sentence was left in the text. The capitol cost of the
on-site disposal facility is included in the total estimated cost of the preferred remedy.
This cost is identified in Table 9-1 of this document.
(o) Comment: "Line 14, page 67 reads "... results in significant a reduction in the
volume...," this would read better if the "a", preceded significant/rather than follow."
Response: This comment is duly noted. However, it has no significant impact on the
document.
(p) Comment: "Please define the following statement (line 16, page 67) utilize permanent
solutions to the maximum extent practical. What viable permanent solutions presently
exist?"
Response: The intent of the statement"... permanent solutions to the maximum extent
practical..." alludes to the fact that, based on available technology, this remedy provides
the most feasible and permanent solution for the remediation of Operable Unit 4. A
potential remedial alternative's ability to achieve long term permanence is one of nine
criteria used to evaluate a remedy in terms of the risk remaining at the site after response
objectives have been met. Hie primary focus of this evaluation is the extent and
effectiveness of the controls that may be required to manage the risk posed by treatment
wastes.
As discussed in the Operable Unit 4 Feasibility Study and Proposed Plan, the preferred
remedy (removal, vitrification of the waste and offsite disposal at the Nevada Test Site)
would be the most effective based on treatability studies conducted on the silo residues
which demonstrated that vitrification would be effective in reducing radon emanation,
radionuclide teachability, and significantly reducing the residue volume by approximately
50 percent. Off-site disposal at the NTS would provide a greater certainty than on-
property disposal over the long term that the treated residues would not affect human
health and the environment.
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Comment: "Basis for stating long-term environmental impacts of permanent disposal at
NTS are minor and no long-term impacts of biota expected from disposal activities at
NTS. It is stated that to reduce U-238 to essentially background is not feasible; it also
states that it is assumed that the federal government retain ownership of the FEMP site to
consider clean-up protective. While I do not have a problem with these statements, it does
bother me that no formal statement has been made publicly concerning this. These two
statements present future land use constraints which must be addressed. Why hasn't the
DOE adopted a formal position concerning this issue and communicated this to both the
Fernald Citizens Task Force and the community?"
Response: The DOE and the EPA recognize that future land use for the FEMP site is
currently under consideration by the Fernald Citizens Task Force and is actively involved
in and supports this effort. However, due to the stipulations of the Amended Consent
Agreement, Operable Unit 4 is required to put forth a remedy for cleanup of soils within
the operable unit boundary prior to completion of the Fernald Citizens Task Force effort.
As discussed in the Proposed Plan, Section 5.4.1, the preferred remedy for Operable Unit
4 requires cleanup of contaminated soils to the proposed remediation levels presented in
Table 5-2. In addition to this, it is indicated that these cleanup levels for soils may be
adjusted to lower values, if necessary, to insure protectiveness of human health and the
environment. The level of protectiveness required by the soils will be dictated by the final
land use selected for the entire FEMP site, including that for Operable Unit 4, by the
Citizens Task Force, and the ongoing feasibility study modelling efforts being performed
by Operable Unit 5. Factoring in the Fernald Citizens Task Force recommendations,
Operable Unit 5 will evaluate and determine the final cleanup levels required for soils on a
site-wide basis. Accordingly, the Operable Unit 4 FS/PP-DEIS recommends that the
decision for final disposition of the contaminated soils be put in abeyance until the Record
of Decision for Operable Unit 5 is issued, at which time the final soils cleanup levels will
be established.
Comment: "Line 13, page 76 reads "...would bot be...", should that read "...would not
be..."?
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Response: This comment is duly noted. However, it has no significant impact on the
document.
(s) Comment: "It states the on-site, above-grade disposal facility would be designed for a
1000 year life with no active maintenance. What is the half-lives or duration for which the
radionuclide and chemical contaminants are a threat to the environment; do they exceed
1000 years? Also explain why no active maintenance is assumed for 1000 years?
Response: The half-lives of the radioactive constituents in the Operable Unit 4 waste
range from 3 to 4 days for Radon-222 to over 1.4 x 1010 years for Thorium-232 well in
excess of 1000 years.
On-site disposal of contaminated soils and debris in an above-grade disposal facility was
evaluated in the Operable Unit 4 Feasibility Study (FS) and also presented in the Proposed
Plan (PP). For purposes of the FS/PP, this disposal facility would be designed for a life
of 1000 years. This vault would be designed to preclude the need for long-term active
maintenance for the duration of its design life of 1000 years. An assessment of the risks
to human health, presented in Appendix D of the Operable Unit 4 FS, indicates that for the
extended trespasser the residual risk from soil remaining in Operable Unit 4 in addition to
risks posed by disposal of contaminated soils and debris in this facility would be well
within the required risk range of 1 x lfr4 to 1 x 104. However, it should be noted that the
final disposition of soil and debris will be determined by the Records of Decision (RODs)
for Operable Units 3 and 5. In accordance with the requirements of CERCLA, the
Operable Units 3 and 5 RODs will define the appropriate level of protectiveness required
for final disposition of Operable Unit 4 debris and contaminated soil respectively.
(t) Comment: "Has an exemption to the Ohio solid waste facility requirement been requested,
and if not when will such a request be made? Also line 28, page 79, would read better if
"the" or "a" were added to precede disposal. (For disposal facility on the FEMP site.)
Response: Operable Unit 4 will not be creating a new solid waste disposal unit for
management of Operable Unit 4 remediation waste as part of the Operable Unit 4 preferred
remedy. Rather, the decision to treat/dispose of Operable Unit 4 wastes on site will be
part of the Operable Units 3 and 5 RODs, since the disposition of Operable Unit 4
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demolition debris and soils for remediation will be deferred to those respective operable
units. Therefore, compliance with the Ohio siting requirement is not germane to the
Operable Unit 4 FS/PP-DEIS.
Discussions with the EPA and OEPA have taken place regarding exemptions and possible
waiver to this requirement. At this time, the issue of technical exemption under Ohio
statute, versus ARAR waiver by EPA has not been resolved.
The editorial comment on the text contained in Line 28, Page 79, has been noted.
However, it does not have any impact on the document.
The Ohio EPA (Commenior R) noted that DOE should attempt to incorporate pollution
prevention activities whenever possible during the design and operation of the 0134
remedial action system. In addition, the Ohio EPA commented that all available methods
to reduce or eliminate discharges from the treatment system should be considered during
the design of the system. It is DOE policy, in accordance with Executive Order 12856,
whenever feasible to apply pollution prevention and waste minimization principles into the
design and operation of all its facilities. The DOE is committed to employing all available
methods and techniques to minimize waste and/or eliminate discharges from remedial
treatment systems in a manner protective of human health and the environment.
The Ohio EPA (Commentor R) stated that, ... "The OU4 Proposed Plan is the culmination
of efforts by U.S. DOE, Ohio EPA, and U.S. EPA to understand and develop a plan for
mitigating releases to the environment from OU4. The alternative selected in the Proposed
Plan will address potential and actual releases in a manner protective of human health and
the environment." The DOE acknowledges the Ohio EPA comment and believes that the
implementation of the preferred alternative identified in the Proposed Plan will address the
remediation of the Operable Unit 4 area in a manner protective of human health and the
environment.
The US EPA, Planning and Management Division (Commentor S) stated that, ... "the only
comments on the record from our agency are those previously supplied to you by our
Waste Management Division. At this point in time, given the requirements ofNEPA and
its implementing regulations, those comments will have to suffice as our agency's
C-5-13
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FEMP-OU4ROD-8 FINAL
December 1994
comments. Provided that the comments previously provided by our Waste Management
Division are complied with, and further provided that facility in question is subsequently
operated in full accordance with applicable local, State, and Federal requirements, it
appears unlikely at this time that any significant adverse impacts on the environment can
reasonably be foreseen. " The DOE previously addressed the US EPA Region 5, Waste
Management comments on the Operable Unit 4 FS/PP-DEIS in May 1994. These
comments were satisfactorily resolved with the US EPA Waste Management Division at
that time. Section 11 of this responsiveness summary details the significant changes
required by the resolution of the US EPA Waste Management Division comments.
C-5-14
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-138
Brenda Weksler, 7904 Marbella Circle, Las Vegas, NV 89128
C-I-l 17
P-139
Cheryl Frossa, 3450 Erva St. #101, Las Vegas, NV 89117
C-I-118
P-140
Harriet R. Gagliano, 2713 Gilmary Avenue, Las Vegas, NV 89102
C-I-l 18
P-141
Kathy Poma, 2113 Fountain Springs Drive, Henderson, NV 89014
C-I-l 19
P-142
Stacey Hallenberg, 2245 Maple Rose Drive, Las Vegas, NV 89134
C-I-l 19
P-143
Kelli Koerwitz, 909 Willowtree, Las Vegas, NV 89128
C-I-l 20
P-144
Trish Taylor, 2113 Fountain Springs Drive, Henderson, NV 89014
C-I-l 20
P-145
Heather Davis, 2031 E. Windmill Lane, Las Vegas, NV 89123
C-I-121
P-146
Marilyn Benoit, 3461 Pointe Willow, Las Vegas, NV 89120
C-I-121
P-147
Richard Lewnau, 2950 S. Decatur D-3, Las Vegas, NV 89102
C-I-122
P-148
Susan Thornton, 1412 Golden Spur Lane, Las Vegas, NV 89117
C-I-l 22
P-149
Lee Dazey, 72 Keystone Avenue, Reno, NV 89503
C-I-123
P-150
Pete Mastin, P.O. Box 92, Verdi, NV 89439
C-I-l 23
1
P-151
Tracie K. Lindeman, P.O. Box 1672, Fallon, NV 89407
C-I-l 24
P-152
David L. Platerio/Tosa-wi-e, P.O. Box 822, Elko, NV 89803
C-I-l 24
P-153
Jo Ana Garrett, P.O. Box 130, Baker, NV 89311
C-I-125
P-154
Margaret Norman, 2332 Grant Street, Berkeley, CA 94703
C-I-l 25
P-155
Judy Treichel, 3926 Bushnell Drive #71, Las Vegas, NV 89103
C-I-l 26
P-156
Lorry C. Johns, 2090 Westwind Road, Las Vegas, NV 89102
C-I-l 26
P-157
Steve Frishman, 208 N. Hwy. 95A, Yerington, NV 89447
C-I-l 27
P-158
William Rosse Sr., HC61 Box 6240, Austin, NV 89310-9301
C-I-127
P-159
Corbin Hanuf (?), P.O. Box 1255, Nevada City, CA 95959 (name was hard
to read)
C-I-128
P-160
Shawn Black, 650 Whitney Ranch #1423, Las Vegas, NV (no zipcode
provided)
C-I-128
j P-161
Lawrence Skinner, 1604 E. Evans, Las Vegas, NV 89030
C-I-129
1 P-162
Mary L. Johns, 2090 Westwind Road, Las Vegas, NV 89102
C-I-129
P-163
Bob Fulkerson, 725 McDonald Drive, Reno, NV 89503
C-I-l 30
P-164
Carla Baker Wallace, 3245 Mallard, Las Vegas, NV 89107
C-I-l 30
P-165
Louise (?), 4255 Tamarus #217, Las Vegas, NV 89119 (name was hard to
read)
C-I-131
P-166
Margaret (?), 1526 Darryl Avenue, Las Vegas, NV 89123
C-I-l 31
P-167
(?), 1526 Darryl Avenue, Las Vegas, NV 89123 (name unreadable)
C-I-l 32
C-4-7
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-168
(?), 1381 E. University Avenue (address incomplete and name unreadable)
C-I-132
P-169
C?), 4801 Spencer 056, Las Vegas, NV 89119 (name unreadable)
C-I-133 1
P-170
(?), 1431 E. Charleston, Las Vegas, NV 89104 (name unreadable)
C-I-133
P-171
Jamie B. (?), 4630 White Rock Drive, Las Vegas, NV 89121 (name
unreadable)
C-I-134
P-172
(name and address unreadable)
C-I-134
P-173
(name and address unreadable)
C-I-135
P-174
(left blank)
C-I-135
P-175*
Geoff Holton, 2332 Grant Street, Berkeley, CA 94703
C-I-136
p-ne
Richard Glasman, 2212 18th Avenue South, Seattle, WA 98144
C-I-136
P-177"
Kathleen Glasman, 2212 18th Avenue South, Seattle, WA 98144
C-I-137 J
Q
Pam Dunn, Harrison, OH
C-I-138
R
Thomas A. Schneider, Ohio Environmental Protection Agency
C-I-145
S
Michael W. MacMullen, U.S. EPA Region 5, Planning and Management
Division
C-I-147
'Postcards were received by the DOE on July 5, 1994.
C-4-8
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FEMP-OU4RQD-8 FINAL
December 1994
Issue 1 - Public Participation Process
(a) A formal request was made by Maud NaroII, State of Nevada, Department of
Administration, State Clearinghouse, on the behalf of the Nevada Test Site (NTS)
Citizens Advisory Board (CAB) to extend the public review period for the Operable
Unit 4 FS/PP-DEIS for at least 60 days. The CAB was recently formed and held its
first organizational meeting on March 8, 1994. Because of the key role the CAB
will play in advising the DOE-NV about stakeholder concerns, the requested
extension to the public comment period would allow the CAB adequate time to
address the Operable Unit 4 document. (Commentor: L)
(b) On May 17, 1994, a formal request was made by William L. Vasconi, Acting
Chairman, NTS CAB to extend the public review period for the Operable Unit 4
FS/PP-DEIS. The NTS CAB had the opportunity to meet with representatives of
the Fernald Environmental Management Project on May 11, 1994. The CAB stated
that this meeting was the first time it had an opportunity to receive any information
about the Operable Unit 4 FS/PP-DEIS. Because the CAB had not yet reviewed the
Operable Unit 4 documents and the May 20, 1994 deadline for public comments was
near, the. extension of time was necessary in order that the CAB may provide
substantive input into the process. (Commentor: N)
Response: (a) The United States Department of Energy (DOE) considered the request for extension
of the public review period to be in accordance with the provision of the National
Oil and Hazardous Pollution Contingency Plan, 40 CFR 300.430(f)(3)(i)(C) as
follows:
"Upon timely request, the lead agency [DOE] will extend the public
comment period by a minimum of 30 additional days; . . "
The DOE recommended that a 30-day extension, as opposed to the 60-day
extension, be granted in an effort to minimize schedule impacts, as well as providing
adequate time for the CAB to review the Operable Unit 4 document. In accordance
with Sections XVIII.B.5 and XVIII.D of the Amended Consent Agreement (1991),
the DOE requested concurrence from the EPA for the 30-day schedule extension to
the public review period. The EPA verbally concurred with the DOE 30-day
request for schedule extension on April 18, 1994, and followed up with a written
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FEMP-OU4ROD-B FINAL
December 1994
concurrence on April 29, 1994. The DOE issued formal notification of the 30-day
extension to the State of Nevada on May 3, 1994. This documentation can be found
in the Administrative Record.
(b) The DOE considered the CAB request for extension of the public review period to
be in accordance with the provision of the National Oil and Hazardous Pollution
Contingency Plan, 40 CFR 300.430(f)(3)(i)(C) as follows:
"Upon timely request, the lead agency [DOE] will extend the public
comment period by a minimum of 30 additional days; . . "
On May 20, 1994, the DOE granted an additional 30-day extension to the public
review period for the Operable Unit 4 FS/PP-DEIS. In accordance with Sections
XVIII.B.5 and XVIII.D of the Amended Consent Agreement (1991), the DOE
requested concurrence from the EPA for the 30-day schedule extension to the public
review period. The EPA provided written concurrence on the DOE 30-day
extension request on May 26, 1994. This documentation can be found in the
Administrative Record.
Issue 2 - Characterization of Silo Residues
During the March 21, 1994 Operable Unit 4 public meeting, questions were raised by Mr. Lou
Bogar, a resident of the City of Hamilton Ohio, about perceived discrepancies in the isotopic uranium
data reported for some of the silo residues. He also expressed concerns about the inorganic chemical
data for the silo residues. His specific concerns were as follows:
(a) Why does the analytical data on the silos presented report Uranium 235/236? Do
die silos contain uranium-236 (U-236)?
(b) There seems to be a discrepancy in the ratio of U-234 to U-238. The ratio of these
isotopes should be close to unity. The U-234/U-238 ratio for Silo 2 appears to be
correct however, the ratio for Silo 1 does not appear to be right.
(c) Is there a foil list of inorganic constituents for Operable Unit 4? Why isn't gold
listed as one of the analytes? Are there other elements, for which analysis was not
done, that may impact the vitrification process? In particular, what about rare earths
(the lanthanide series of elements)? Could these affect vitrification?
C-4-10
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FEMP-OU4ROD-8 FINAL
December 1994
(Commentor: C)
In addition, on June 24, 1994, DOE received significant comments from a member of the Nevada
Test Site Citizens Advisory Board (CAB). The CAB expressed the following four concerns over the
physical characteristics of the untreated silo residues and the treated waste form:
Based on the presence of RCRA regulated metals and organics in the waste, we are
concerned that the waste contains both hazardous and radioactive constituents.
(d) Please list the radionuclide and inorganic and organic chemical constituents of the
waste.
(e) Please identify the concentration of each constituent.
(f) Please identify the risk resulting from each constituent.
(g) Please describe how the proposed treatment and disposal mechanism address both
the radionuclide and chemical constituents of the waste.
(Commentor: O)
Response: (a) The Silos do not contain U-236. U-236 is a by-product of nuclear reactor
processing. The residues in the silos were generated exclusively from the chemical
processing of pitchblende ores and uranium concentrates to extract uranium.
Consequently, the residues in silos would not contain U-236.
The U-23S analysis was done using the standard radiochemistry technique of alpha
spectroscopy. Because the energies emitted by U-23S and U-236 are very close in
intensity, it is difficult for the laboratory to individually resolve between U-23S and
U-236 activity concentrations. As a result it is accepted laboratory convention to
report radiochemical results for these isotopes as U-235/236. The analytical data for
U-23S concentrations in the silos were reported from the laboratory using this
convention. This was not intended to imply that the silos contain U-236.
(b) In his comments made during the March 12, 1994 Operable Unit 4 Public Hearing,
Mr. Bogar pointed out that there appeared to be some anomalies in the isotopic
uranium data presented during that meeting. The data provided during the public
meeting represented average activity concentrations calculated from individual
C^-ll
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FEMP-OU4ROD-8 FINAL
December 1994
sample results contained in Volume 2 of the Operable Unit 4 Remedial Investigation
Report (available for review in the PEIC). Through process knowledge it is known
that the K-65 Silos contain natural uranium which resulted from the processing of
pitchblende ores and uranium concentrates. As such, the activity concentration ratio
of U-238 to U-234 in any sample obtained from the silos should be approximately 1.
In the data presented for Silo 1, however, the ratio of U-238 to U-234 is 0.8,
implying that the uranium contained in Silo 1 may be enriched.
This apparent anomaly is caused by a combination of two factors: the use of
average activity concentrations to represent activity concentration ratios and apparent
errors in the U-234 activity concentrations reported by the laboratory for four of the
Silo 1 samples. While average activity concentrations are adequate for gross
estimates of the silo contents, using activity concentration ratios calculated from
these average activity concentrations is inappropriate, due to the heterogeneous
nature of the silo contents (it should also be noted that averaging of the data can
propagate the inherent uncertainty in the analytical data for individual samples).
Instead, the activity concentration ratios of U-238 to U-234 should be addressed on a
sample-by-sample basis.
Review of the individual sample data (contained in Volume 2 of the Operable Unit 4
RI Report) will indicate that die ratios of U-234 and U-238 are close to unity as
expected for natural uranium (within the limits of the total propagated uncertainty)
for 16 of the 20 samples taken. The remaining four samples demonstrated higher U-
234 values, which yielded U-238 to U-234 ratios in the range of 0.4 to 0.6. This
knowledge should have been sufficient to reject the analytical results for these four
samples. The sample results, however, had already been validated using standard
EPA protocols and die determination had been made to publish and use all validated
analytical results. While this decision could have been overturned, it was further
determined that these apparently anomalous U-234 analytical results for these four
samples had no impact on the risk assessment for Operable Unit 4 and, as a result,
would have no impact on the evaluation of remedial action alternatives within the
Operable Unit 4 Feasibility Study.
C-4-12
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FEMP-OU4ROD-8 FINAL
December 1994
(c) Volume 2 of the Operable Unit 4 Remedial Investigation Report presents a full
listing of all analytical data collected during the remedial investigation. The data
presented in the public meeting on March 21, 1994 were taken from the Operable
Unit 4 Remedial Investigation Report. These data primarily provide critical
information used in the risk assessment process to determine the nature and
magnitude of potential chemical hazards and/or cancer risk posed by the contents of
the silos. Treatability studies were conducted using actual silo residues to determine
the effectiveness of the vitrification process in stabilizing these materials (the
Operable Unit 4 Treatability Study Report for the Vitrification of Residues from
SDos 1, 2, and 3 is available for review in the PEIC). Analysis was performed on
the silo residues during the treatability studies to provide information pertinent to
determining the effectiveness of vitrification.
The DOE does have historical data on the gold content of the K-65 residues. The
vitrification process can be affected if there are large amounts of noble metals such
as gold present. However, the gold present in the silo residues does not pose a
problem as evidenced by the results of the vitrification treatability studies.
"Rare earths" or elements in the lanthanide series are known to improve the
durability of glass [reference, Volf, M.B. 1984, Chemical Approach to Glass (glass
Science and Technology: Vol 1). Elsevier, New York]. Analysis was conducted for
some "rare earth" elements such as cerium and lanthanum during the treatability
studies.
(d, e) The material contained in Silos 1 and 2 (K-65 material), and Silo 3 is by-product
material or residue resulting from the processing of uranium ore and is specifically
exempt from regulation as solid waste under RCRA 40 CFR §261.4(a)(4). The
State of Nevada has expressed similar concerns over the regulatory classification of
the Operable Unit 4 remedial wastes. A detailed discussion of these regulatory
issues is presented under Issue 4 - State of Nevada Regulatory Concerns.
A complete list of radionuclide, inorganic and organic chemical constituents of the
Silos 1, 2 and 3 wastes and their respective concentrations can be found in Tables
C-4-13
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FEMP-OU4ROD-8 FINAL
December 1994
A. 1-1, A. 1-5, A. 1-6, A. 1-7, A.2-1 and A.2-6 in Appendix A of the FS Report for
Operable Unit 4 (FS/PP-DEIS).
(f) Appendix D, Section D.2.0 of the FS Report for Operable Unit 4 (FS/PP-DEIS)
presents a summary of risk characterization results from the Operable Unit 4
Baseline Risk Assessment, as reported in the Remedial Investigation Report for
Operable Unit 4. The Baseline Risk Assessment was performed, in accordance with
available EPA guidance for conducting CERCLA risk assessments and methodology
described in the EPA-approved Risk Assessment Work Plan Addendum for
performing risk assessments at the FEMP. The complete list of radionuclide,
inorganic and organic chemical constituents of the Silos 1, 2 and 3 wastes were
evaluated along with information describing their toxicity, mobility and
environmental persistence. The baseline risk characterization indicates that baseline
conditions do not meet acceptable public health risk criteria.
Appendix D, Section D.3.0 of the FS Report for Operable Unit 4 (FS/PP-DEIS)
evaluates the short-term and long-term risks associated with implementing the
various remedial alternatives considered for Operable Unit 4. The detailed analysis
of die Operable Unit 4 remedial action alternatives is presented in Section 4.0 of the
FS Report for Operable Unit 4 (FS/PP-DEIS), where each alternative is evaluated
relative to the nine criteria of the NCP. Two of these criteria are short-term
effectiveness and long-term effectiveness.
The short-term effectiveness criterion addresses the effect of an alternative during
the construction and implementation phase until the remedial action objectives are
achieved. The evaluation considers the effects on human health and the environment
posed by operations conducted during the remedial action. The long-term
effectiveness criterion evaluates the extent to which an alternative achieves an overall
reduction in risk to human health and the environment after the remedial action
objectives have been met.
The risk assessment presented in Appendix D supports the application of these
criteria through the Section 4.0 evaluation of human health risks resulting from
potential short-term and long-term exposures associated with the Operable Unit 4
C-4-14
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FEMP-OU4ROD-8 FINAL
December 1994
remedial action alternatives. This includes the preferred remedy for disposing of the
treated Operable Unit 4 residues at the NTS.
(g) Appendix C, Section C.3.0 of the FS Report for Operable Unit 4 (FS/PP-DEIS)
presents a summary of all the vitrification treatability study tests which were carried
out in support of the Operable Unit 4 RI/FS process at the FEMP. The tests were
completed as specified by the EPA-approved Operable Unit 4 Treatability Study
Work Plan for the Vitrification of Residues from Silos 1, 2, and 3 (DOE 1992b).
The purpose of these tests was to allow the performance of vitrification of the Silos
1, 2, and 3 residues to be compared to other remediation technologies for the silo
residues. The criteria upon which this comparison was to be based were the
teachability of the waste form, the waste volume reduction achieved, and the
reduction in radon emanation from the waste.
The Toxicity Characteristic Leaching Procedure (TCLP) results for the vitrified
wastes demonstrated the effectiveness of glass as a durable leach resistant waste
form for Operable Unit 4 remedies. Leachate concentrations of hazardous metals
were below regulatory limits for all of the glasses made in these tests, including the
leachate concentration of lead which was reduced about 500 times less than from the
untreated waste. Radionuclides (in particular, Ra-226) were found to leach from the
glasses at the same rate as the major glass constituents, indicating the absence of
selective leaching of radionuclides.
Appendix C, Table C.3-13 of the FS Report for Operable Unit 4 (FS/PP-DEIS)
reports the specific gravity of the vitrified waste along with the calculated volume
reduction. The volume reduction is based upon the difference between the volume
of the final glass product (including additives) and the initial volume of the waste in
its current state. The waste volume was calculated using the wet, compacted
density, which is assumed to be the most representative of the material in its current
state. Significant volume reductions ranging from SO percent to 68 percent are
achieved through vitrification of the waste. In summary, the final waste volume
ranged from 32 percent of the initial waste volume in the best case to only SO
percent of the initial waste volume in the worst case.
C-4-15
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FEMP-OU4ROD-8 FINAL
December 1994
The radon emanation rate from the vitrified K-65 material ranged from 0.01 to 0.06
pCi/m2/s, more than two orders of magnitude less than the EPA limit of 20 pCi/nr/s
for radon emanation from uranium mill tailings. The measured radon emanation
rate from the glass is approximately equal to the emanation rate from natural
building materials such as brick and concrete, even though the radium content of the
waste glass is 103 to 10* times greater than that of natural building materials.
The NTS has established waste acceptance criteria which consider disposal site
characteristics consistent with an appropriate level of protectiveness to human health
and the environment. The Operable Unit 4 remedial waste will comply with these
waste acceptance criteria and the NTS will also perform evaluation to assure that the
acceptance criteria are met.
Issue 3 - Public Participation During Post-RI/FS Activities
The current FEMP Community Relations Plan does not adequately define the public's role, nor its
nature and extent of opportunities for participation during post-RI/FS activities. During the Operable
Unit 4 formal public comment period, members of the public and the Ohio EPA requested formal
definition of their level of participation during the Remedial Design and Remedial Action processes.
Members of the community expressed a desire to continue their same level of involvement in post-
RI/FS activities, as defined by the current Community Relations Plan for the RI/FS program.
(Commentors: A, B, D, G, J and R)
Response: The DOE is both actively and expeditiously pursuing the revision of the current FEMP
Community Relations Plan to include post-RI/FS public involvement activities throughout the
Remedial Design and Remedial Action processes. Until a comprehensive Community Relations Plan
is finalized by the DOE, an Interim (post-RI/FS) Community Relations Plan has been prepared as
guidance to Fernald personnel on public involvement activities. A revised Community Relations Plan
addressing post-RI/FS public involvement activities will be issued by September 1994.
Issue 4 - State of Nevada Regulatory Concerns
The State of Nevada and a member for the Nevada Test Site Citizen's Advisory Board have expressed
concerns over the regulatory classification of the Operable Unit 4 remedial wastes, as discussed in the
Operable Unit 4 Feasibility Study/Proposed Plan - Draft Environmental Impact Statement. More
specifically, the State of Nevada suggests that the Operable Unit 4 remedial wastes are "mixed
C-4-16
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FEMP-OU4ROD-8 FINAL
December 1994
wastes" [i.e., Resource Conservation and Recovery Act (RCRA) hazardous and radioactive waste]
rather than "by-product material" as defined by the Atomic Energy Act (AEA), Section 11(e)(2),
excluded from being a RCRA hazardous waste. The CAB stated that, "Based on the presence of
RCRA regulated metals and organics in the waste, we are concerned that the waste contains both
hazardous and radioactive components." Accordingly, the State of Nevada contends that the
hazardous components of the Operable Unit 4 wastes are subject to regulation and control by an EPA-
delegated state having such authority. (Commentors: E, O)
Response: The State of Nevada's comment concerns the classification of K-65 and Silo 3 material;
specifically with respect to its regulation as mixed waste. The following response first discusses in
general the issue regarding the classification; secondly, the response addresses specific State of
Nevada concerns described in the letter.
(a) General Discussion
The material contained in Silos 1 and 2 (K-65 material), and Silo 3 is by-product material
or residue resulting ftom the processing of uranium ore and is specifically exempt as
defined ftom regulation as solid waste under RCRA 40 CFR §261.4(a)(4). The referenced
exclusion applies to ". . . source, special nuclear or by-product material as defined in the .
. . AEA. . The AEA in part defines by-product as: ". . .the tailings or waste produced
by the extraction or concentration of uranium or thorium ftom any ore processed primarily
for its source material content" [AEA Section 11(e)(2)]. Since a material must first be a
solid waste in order to be a hazardous waste, and since the material is excluded from
regulation as solid waste, die subject material cannot be considered hazardous waste.
The silos contain only residues from the chemical extraction (beneficiation) of uranium
from ores; no other solid or hazardous wastes were added to the silos or to the residues.
Therefore, the contents of Silos 1, 2, and 3 are pure "by-product materials" by definition,
and not solid wastes or hazardous wastes subject to regulation under RCRA. The metals
found in the material were present in the natural ore, and were unintentionally extracted
from the parent ore along with the uranium during the process of beneficiation, becoming
more concentrated in the residue after the uranium was removed. The presence of
naturally occurring metals is expected in by-product material, and does not invalidate
either the definition or the exclusion. No metals from a non-ore source were added to the
stream at any point in the beneficiation process; also, no hazardous waste or waste
C-4-17
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FEMP-OU4ROD-8 FINAL
December 1994
constituent was added or created at any time during the beneficiation process. The fact
that several metals in the material fail the RCRA toxicity characteristic leaching procedure
(TCLP) does not cause the material to become subject to RCRA regulation due to a
hazardous waste characteristic, since the metals are not from an external source, but are
associated with the parent material (whose residues, including any ancillary metals, are
excluded from the definition of solid waste).
(b) Specific State of Nevada Comments and Responses
1. Comment: The comment refers to \ . .thorium mill tailing waste, which is admitted
to be mixed waste. .
Response: The comment is unclear, since there is no reference to any admission that the
material is mixed waste. The FS/PP-DEIS does not claim the material is mixed waste.
Rather, the residues in the silos are by-product material from the processing of ore
material for its source material, primarily uranium. The by-product material is not itself a
mixed waste, nor is it mixed with a solid or hazardous waste which would cause the
material to be considered a mixed waste. As stated in the document, while they are not
considered applicable as ARARs for the management of this material, various sections of
RCRA have been included in the Operable Unit 4 FS/PP-DEIS as relevant and appropriate
requirements for the management of this material during CERCLA remediation, due to the
similarity of this material to RCRA characteristic hazardous waste. The adoption of
various RCRA ARARs in the CERCLA documents does not confer or waive authorities
agencies may have to regulate the silo material under RCRA.
2. Comment: "In 1987, DOE promulgated regulations (10 CFR §962.1) stating that
RCRA hazardous waste, mixed with by-product material falling under the category
defined in the AEA [42 USC 2014(e)(1)], would be subject to regulation ..."
"However, the by-product material falling under the category given in 42 USC
2014(e)(2) that was mixed with RCRA hazardous waste, . . . would not be subject to
regulations by EPA. . ". . .under the Federal Facility Compliance Act (FFC Act),
Congress defined mixed waste to mean "waste that contains both hazardous waste and
source, special nuclear, or by-product material. . This definition shows no
distinction between the two categories of by-product material mentioned above. Hence,
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FEMP-OU4ROD-8 FINAL
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the attempted exemption from hazardous waste regulations of the hazardous components
of mixed waste containing by-product material . . . has been invalidated."
Response: The DOE Final Rule in 10 CFR §962, promulgated in the May 1, 1987
Federal Register (52 FR 15937) for clarification of the term "by-product material," was
limited in scope to by-product material as defined under 42 USC 2014(e)(1) meaning
"radioactive material . . . yielded in, or made radioactive by exposure to the radiation
incident to the process of producing or utilizing special nuclear material." An example
would be reactor fuel reprocessed for its enriched uranium. This rule does not affect
materials that are defined as by-product material under Section 11(e)(2) of the AHA
("tailings or wastes produced by the extraction or concentration of uranium or thorium
from any ore processed primarily for its source material content"). The silo material
falls into this second category.
DOE Order 5400.3A further clarifies the DOE interpretive rule referenced above:
"DOE interprets these definitions to mean that whenever any hazardous waste
identified or listed in 40 CFR §261 is inadvertently mixed [emphasis added]
with any source material, special nuclear material, or by-product material, the
hazardous waste component is subject to regulation under Subtitle C of
RCRA. The May 1, 1987 Federal Register notice did not affect materials that
are defined as by-product material under Section 11(e)(2) of the AEA."
DOE Order 5820.2A contains definitions consistent with the above. Chapter IV,
Management of Waste Containing AEA 11(e)(2) By-product Material and Naturally
Occurring and Accelerator Produced Radioactive Material, specifies:
"By-product 11(e)(2) . . . mixed [emphasis added] with the Resource
Conservation and Recovery Act hazardous chemicals, shall be managed
consistent with both the Resource Conservation and Recovery Act and 40
CFR Part 192."
The FFC Act, DOE Order 5400.3A, and DOE Order 5820.2A are consistent in their
interpretation of the definition of mixed waste. The FFC Act simply reiterates that
hazardous waste mixed with source, special nuclear, or by-product material is subject to
dual regulation under both the AEA and RCRA, and has no bearing on Operable Unit 4
by-product material, since it is not mixed with a solid or hazardous waste (see General
Discussion). The K-65 and Silo 3 material consists of only by-product material as
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defined under Section 11(e)(2) of the AEA, and is therefore subject to the solid waste
exclusion under RCRA.
3. Comment: "... EPA delegated to the states regulatory control over all mixed wastes
without regard to specific radionuclide content. . . consistent with the expression of
Congressional intent in defining mixed waste under the FFC Act (see 51 FR, July 3,
1986, 24504-24505)."
Response: In the referenced July 3, 1986 Federal Register notice, EPA is requiring
that states seeking authorization to regulate under RCRA the "hazardous component" of
radioactive mixed waste revise their programs Of necessary) and demonstrate statutory
authority to regulate said "hazardous component." This notice was issued prior to the
DOE interpretive rule of May 1, 1987. Although "hazardous component" is not
expressly defined, the notice is consistent with previous definitions, and implicitly
restates the definition of mixed waste as "wastes containing both hazardous waste and
radioactive waste." Again, this Federal Register notice does not detract from the stated
position, since the Operable Unit 4 silo material consists solely of by-product material,
and is not mixed with a solid or hazardous waste that would be subject to state
regulation.
In summary, the Operable Unit 4 silo materials are expressly by-product material excluded from
RCRA regulation under 40 CFR §261.4(a)(4), on the basis of "tailings or waste produced by the
extraction or concentration of uranium or thorium from any ore processed primarily for its source
material content" [AEA Section 11(e)(2)].
NOTE: While not applicable as an ARAR for the management of this material, various sections of
RCRA have been included in the FS/PP-DEIS as relevant and appropriate requirements for the
management of this material during CERCLA remediation, due to the similarity of this material to
RCRA characteristic hazardous waste. The proposed alternative for remediation of this material
includes treatment by vitrification, which will remove the "toxicity characteristic" due to the
inadvertent presence of various metals in the material. The adoption of various RCRA ARARs in
the CERCLA documents does not accede the authority of RCRA to regulate the silo material; these
ARARs, among others, are selected on the basis of existing regulatory standards and management
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practices to be followed during remediation to ensure adequate protection of human health and the
environment.
Issue 5 - Off-Site Transportation of Waste to Nevada Test Site
Several members of the local community expressed concerns related to the transportation of the
Operable Unit 4 treated wastes from the FEMP to the Nevada Test Site (NTS). One individual
preferred rail shipments over truck transportation, citing that truck transportation is much more
dangerous. Others requested more details on transportation (i.e., packaging specifications, and
special handling requirements and precautions) and details related to notification when shipments will
occur. (Commentors: A, F and Q)
Response: The preferred remedy for Operable Unit 4 requires a combination of rail and truck
transportation for the shipment of treated silo residues off site for burial at the NTS. Currently, there
are no direct rail lines into the NTS. The treated material would be transported from the FEMP by
rail to either a point near Las Vegas, Nevada, or one of the areas north of Las Vegas. From either
location, the waste containers carrying the treated material would be transferred to trucks for
transportation over roads to NTS. Consistent with regulatory requirements, the DOE will provide
proper notification to all affected parties, including emergency response teams, when off-site
shipments begin.
Additionally, the DOE is engaged in a program to optimize a container design to meet specific
performance requirements for a shipping/burial container and to provide additional protection to
workers and the public, for the eventual transport and disposal of the treated Operable Unit 4 wastes
to be conducted between the FEMP and the NTS. One of the program's goals are focussed upon the
viability of utilizing recycled contaminated scrap metal and other forms of metal for the fabrication of
waste containers.
The success of the container investigation will be measured on the basis of achieving a balance of key
design parameters and requirements such as:
• vitrified product mixture design
• final waste form of vitrified product
• waste loading of vitrified product
• waste additives of vitrified product
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• packaging design
• shielding of package
• shipping limitations
• United States Department of Transportation (DOT) requirements
• NTS Waste Acceptance Criteria
• cost
The optimized container design will be modelled in an effort to minimize the estimated short-term
risks posed to public by transporting the Operable Unit 4 wastes in the container.
Issue 6 - Monitoring of Remedial Actions
Several members of the local community and the Ohio EPA expressed concerns that "real-time"
monitoring should be implemented during the entire remedial action process. It was recommended
that the implementation of "real-time" monitoring should be integrated into short-term remedial
actions such as process controls, project specific health and safety procedures, emergency alarm
systems, standard operating procedures, and emergency response procedures, as well as, long-term
actions involving disposal and maintenance. Additionally, it was requested that information gained
from "real-time" monitoring and related activities should be made readily available to the public.
(Commentors: A, B, D, G, H, J and R)
Response: As part of the remedial design activities for the Operable Unit 4 remedial actions, a
preliminary and final safety assessment will be conducted by DOE to establish the safety basis and
design objectives for the construction and the operation of all remedial facilities. The safety basis
includes those measures (i.e., procedures, training, monitoring equipment) necessary to ensure that
facilities will be constructed and operated in a safe manner and in compliance with applicable or
relevant and appropriate requirements.
It is the DOE policy in its conduct of operations to require facility operations procedures to be
developed and adhered to during all remedial actions. Training of personnel to those procedures will
be paramount to ensure safe conduct of all operations. The FEMP has developed and maintains the
necessary emergency plans and procedures to adequately define the emergency management program,
provide guidance for all emergency responders, proper notification of the public, ensure adequate
monitoring and performance for critical systems, and to meet all regulatory requirements.
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The use of "real-time" monitoring is an integral part of this process and will vary in degree for each
system or action to be consistent with the safety assessment recommendations and comply with
applicable or relevant and appropriate requirements. For example, some systems may require 24-
hour "real-time" monitoring (i.e., fire protection, meteorological stations, perimeter air monitoring
stations, radon treatment system) while others may only require "real-time" monitoring during
normal operations (i.e., air emissions controls, waste water discharge, vitrification process controls,
disposal facilities etc.). These features will all be developed and included in the remedial design and
remedial action packages for review by the public, EPA, and Ohio Environmental Protection Agency
(OEPA). Likewise, "real-time" monitoring data will be made available to the public through the
Public Environmental Information Center.
Issue 7 - Impacts to Sites of Archeological and Historical Importance
The Ohio Historical Preservation Office (OHPO) expressed two areas of concern for the identified
Operable Unit 4 remedial actions. Due to the FEMP site's proximity in an archeological sensitive
area, the first area of concern is the potential for impacts to archeological sites. Secondly, under the
current criteria and regulatory guidelines, the FEMP site itself is eligible for inclusion in the National
Register of Historic Places, thus the proposed demolition of the silos, or any other structure or
facility, could have an adverse effect on the FEMP site. The OHPO recommends the development of
a programmatic agreement to address these sitewide and Operable Unit 4-specific historic preservation
concerns. (Commentor: I)
Response: It is recognized that the FEMP site does lie in an archaeologically rich area and sitewide
remedial activities will result in many ground disturbing and demolition activities. The DOE has
effectively coordinated with the OHPO on several projects at the Fernald she in the past. Therefore,
until the programmatic agreement has been developed between DOE and the OHPO, individual
activities (e.g., the construction of support facilities) will continue to be coordinated with die OHPO.
In response to the second area of concern, it is further recognized that die FEMP site as a whole has
recently been determined to be eligible for inclusion on the National Register of Historic Places.
Therefore, appropriate steps will be taken to coordinate with the OHPO all activities involving the
demolition of structures. The DOE will be pursuing a programmatic agreement with the OHPO in
the near future. However, until such an agreement can be put in place, DOE will be coordinating
with the OHPO office on an individual project-by-project basis.
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Appropriate coordination activities associated with the remediation of Operable Unit 4 and the
demolition of structures on the site will be carried out with the OHPO.
Issue 8 - Future Land Use at the FEMP
One member of the public expressed concern over any future development of the FEMP site (i.e.,
industrial park) which would attract large concentrations of humans, in the event environmental
problems would happen to develop in the future (i.e., similar to Love Canal). (Commentor: F)
Response: The DOE, EPA, and OEPA are closely working with the local community (i.e., FRESH)
to provide technical guidance to participating community members, in an effort to logically reach a
balanced decision regarding the most feasible future land use(s) for the FEMP site. The Operable
Unit 4 soil remediation cleanup levels were established with the assumption that in the future, the
federal government would maintain ownership of the Operable Unit 4 area.
Issue 9 ~ Impact to Rtwurts
Members of the public expressed concern over the potential impact from the remedial actions to
natural resources surrounding the FEMP site (i.e., wetlands, migratory birds, etc.), and the mitigative
measures being taken by the DOE to minimize their effect. (Commentors: B and F)
Response: The end-use of the FEMP site is currently under consideration by the Fernald Citizens
Task Force. This task force, based on input from the public and various stakeholders, will make a
recommendation to DOE as to what the end-use of the Fernald site should be. This comment will be
forwarded to the task force for their consideration. The taslr force's recommendation will play a key
role in determining what happens at the site after remediation.
Depending on the types of environmental impacts that occur during remediation, it is possible that
habitats may need to be created as mitigative measures. The specific issue of the need for creating
wetlands is currently being evaluated by DOE and Fernald Environmental Restoration Management
Company (FERMCO) and will be discussed with the stakeholders and formally addressed in the
Operable Unit 5 (Environmental Media) Feasibility Study Report and Record of Decision.
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Issue 10 - EPA Promulgarion of Residual Soil Standards for Radionuclides
One local resident inquired whether the residual soil radiation levels, which the EPA has not yet
published in the Federal Register (originally scheduled to be published in March 1994), could
possibly impact the remediation decisions in Operable Unit 4. (Commentor: C)
Response: Residual soil standards for radionuclides are currently being finalized by the EPA. The
EPA has issued a draft proposal which recommends the establishment of an effective dose limit of IS
mrem/year from residual soil radiation. Until the standards are finalized and promulgated by the
EPA, it is uncertain whether they will impact Operable Unit 4. Radionuclide cleanup levels have
been established for Operable Unit 4 which approach background concentrations for nearly all
radionuclides. When the residual soil standards for radionuclides are promulgated by the EPA, a
review of their impact upon the Operable Unit 4 soil remediation will be conducted. Soil cleanup
levels for Operable Unit 4 will be modified as directed by the EPA.
Issue 11 - Air Emissions from Remedial Actions
One local resident, who lives downwind of the FEMP site, expressed concerns over the particulate
matter and off-gases which could be emitted through the exhausts of the Operable Unit 4 vitrification
process. Specific concerns were noted related to the performance of comprehensive site-wide air
modeling which includes the Operable Unit 4 vitrification facility contributions to sitewide emissions
and the quantification of subsequent risks to the local "downwind" community. (Commentor: K)
Response: Air pathway monitoring focuses on the airborne pollutants that may be carried from the
Fernald site as a particulate or gas and how these pollutants are distributed in the environment. Stack
and building vent emissions are obvious sources of pollutants, but dust from construction and
remediation activities, waste handling, and wind erosion are also important potential sources. The
form and chemical makeup of pollutants influence how they are dispersed in the environment as well
as how they may deliver radiation doses. Airborne pollutants are subject to whatever weather
conditions exist.
The meteorological data gathered at the FEMP site are primarily used to evaluate climatic conditions
at the site. Wind speed and direction, rainfall, and temperature play a role in predicting how
pollutants are distributed in the environment. The Fernald Environmental Monitoring Program
routinely uses atmospheric models to determine how airborne effluents mix and disperse; these
models, in turn, are used to assess the impact of operations on the surrounding environment, in
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accordance with DOE requirements. Based upon modeling results, risks to the public are calculated
based upon exposure from the pollutants emitted from the FEMP site. The 1992 Fernald Site
Environmental Report provides detailed breakdown of sitewide emissions, doses to the public, and
their associated risks. This report is updated annually and may be available in the Administrative
Record.
To date, computer modeling for expected radionuclide emissions from the proposed vitrification
facility has not been conducted due to insufficient engineering design data. However, during remedial
design, when these design data become available, this information will be entered into the appropriate
air models to determine compliance with 40 CFR §61 Subpart H for radionuclides, including radium
under the Clean Air Act. In addition, Ohio Administrative Code (OAC) 3745-31-05(A)(3) requires
the use of Best Available Technology (BAT) to control process emissions. Compliance with the
requirement to employ BAT will be determined by evaluating, according to the Ohio Air Toxics
Policy (OATP), emission data collected from performance testing of the Operable Unit 4 vitrification
facility.
Modeling will be conducted on the vitrification facility both prior to startup and during operation.
The preliminary modeling will provide estimates of dose levels based on engineering design and
expected removal efficiencies. Corroborative modeling conducted during operation will be based on
actual data collected during stack performance testing, and will verify engineering design and
compliance with the regulatory standard. Risks associated with these dose levels will be evaluated
and compared to the other alternatives. Upon comparison a determination will be made to implement
design criteria to minimize risk associated with the vitrification facility or if necessary to amend the
selected alternative to one which poses less of a risk to the surrounding community.
Air emission modelling specific to the Operable Unit 4 vitrification processing facility will be
performed as part of the remedial design process, to ensure that the vitrification facility is designed to
meet these air emission ARARs and pertinent DOE Orders. In addition, portable air monitors will be
strategically located around the perimeter of field activities during construction of remedial facilities.
The air monitors will provide real time data regarding the effectiveness of controls to mitigate fugitive
dust emissions.
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Issue 12 - Determination of Risk Levels
A local resident questioned the reason the CERCLA elected to use such small risk levels as 10* (one
in a million). In addition, the differences in methodologies like Health Effects Assessment Summary
Tables (HEAST) and Biological Effect of Ionizing Radiation result in "vast orders of magnitude"
differences in estimated risks. (Commentor: C)
Response: In accordance with the NCP (40 CFR 300), Operable Unit 4 is required to comply with
the requirement that the excess risk, posed to humans exposed to carcinogenic materials in Operable
Unit 4, would not be greater than one in ten thousand to one in a million. The lower bound of the
range, one in a million (10*) incremental risk, is the most desired level of residual risk to be posed
by a clean-up action. This risk refers not to "fatal" cancer risk but the risk of the induction of
incremental cancers, over and above the normal risk of contracting cancer, during one's lifetime.
Operable Unit 4 is also legally required to utilize the methodologies defined by the United States
Environmental Protection Agency for calculating the cancer risk posed by Operable Unit 4.
Issue 13 - Compliance with DOT Transportation Regulations
The U.S. Department of Transportation (DOT) provided two comments regarding compliance with
DOT regulations.
(a) The first comment was related to classification of the materials as Low Specific
Activity (LSA) and stated, "We [DOT] believe the expected physical form of the
materia] transported will result in the radiological risk to the public being equal to or
less than most LSA shipments transported in the Country. However, from Volume
Two, Appendix A, Table A.1-1, it appears that the activity per gram of material for
some of the package contents might exceed the limits for LSA materials in 49 CFR
173.403(n)."
(b) The second comment expressed concern with the sampling and analysis to be
performed prior to shipment. The comment stated "After material vitrification, the
external radiation dose rates will clearly be the indications of the most significant
radiological hazards of the materials during transportation. However, since the
identity of the radionuclides and the activity of the content in each package is
required by the regulations, documentation with technical reasoning will be needed
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to relate the results of pre-vitrification radioassays to the contents of the packages."
(Commentor M)
The initial classification and container selection of the vitrified materials as LSA was
used to perform cost estimates for the remedial alternatives evaluated in the FS for
Operable Unit 4. These cost estimates were developed with an intended accuracy of
plus SO percent/minus 30 percent as required by CERCLA. Therefore these cost
estimates were considered adequate for alternative evaluation. Since the initial
distribution of the FS/PP-DEIS, the FEMP has initiated a study which will further
specify the DOT classification of the vitrified material and container types required
for shipment of the vitrified material. The final selection of container type is
contingent upon several factors, including; the Curie content of the container, its
classification under DOT regulations, the ability of the container to reduce external
dose rate, and the acceptance of the container by the Nevada Test Site.
(b) Demonstration of compliance with regulations is the basis for the sampling and
analysis program to be developed for Operable Unit 4 remediation. Sampling and
analysis will be performed on the vitrified gems 1) to assure compliance with waste
disposal requirements, 2) to demonstrate success of waste treatment, 3) to assure
compliance with DOT requirements, 4) and to complete waste characterization of the
vitrified materials. Specific parameters for testing will be determined in the Project
Specific Sampling and Analysis Plans to be prepared during Remedial Action. The
selection of parameters for analysis will include those which will demonstrate
compliance with the activity limitations for containers per DOT regulations.
Issue 14 - Consideration of Disposal Sites for the K-65 Material
On June 24, 1994, DOE received significant comments from a member of the Nevada Test Site
Citizens Advisory Board (CAB). The CAB stated that the Operable Unit 4 FS/PP-DEIS documents
did not discuss the full range of possible alternatives (e.g., disposal at Hanford, reprocess to recover
materials, dispose of all material at the NTS). The member of the CAB further questioned "...Why
were these options rejected? What is the full list of options initially considered and why was each
option rejected?"
(Commentor: O)
Response:
(a)
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Response: Identification, screening, and evaluation of potentially applicable technologies and process
options are key steps early in the FS process. The primary objective of this phase of the FS is to
develop an appropriate range of remedial technologies and process options that will be developed into
preliminary remedial alternatives. The criteria for identifying potentially applicable technologies are
provided in EPA guidance and in the NCP. There is strong statutory preference for remedies that
will result in a permanent solution; a significant decrease in toxicity, mobility, or volume; and
provide long-term protection as identified in Section 121 of CERCLA, as amended. The primary
requirements for the final remedy are that it be both protective of human health and the environment
and comply with applicable or relevant and appropriate regulatory requirements.
The Operable Unit 4 FS/PP-DEIS presented information to support the selection of the most
appropriate remedial alternative. The broad range of alternatives considered for remediation in the
FS/PP-DEIS were developed in accordance with EPA guidance by following a series of logical steps
that involved developing, in succession, more specific definitions of potential remedial alternatives.
The steps included the following:
• Development of contaminant- and media-specific remedial action objectives (RAOs) and
preliminary remediation goals (PRGs).
• Identification of general response actions (GRAs).
• Identification of volumes and/or areas of waste media to be addressed.
• Identification and screening of remedial technologies and process options.
• Evaluation and screening of process options within each technology.
• Assemblage of a wide range of remedial alternatives using the selected process options
within each remedial technology.
• Evaluation of initial screening to determine which alternatives will be analyzed more fully
in the detailed analysis phase of the FS.
The detailed analysis of alternatives was performed in Section 4 of the FS on those alternatives which
were retained through the preliminary screening of alternatives step described above. The detailed
and comparative analysis consisted of the analysis and presentation of the relevant information needed
to allow decision makers to select a remedial alternative.
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The Operable Unit 4 FS/PP-DEIS considered several disposal options for each of the on-property and
off-site disposal technologies evaluated for the K-65 material as follows:
On-Pronertv Disposal Technology
• Engineered Disposal Facility (Below-grade)
• Above-grade Disposal Vault
Off-Site Disposal Technology
• New Facility within 483 km (300 mi) of the FEMP site
• New Facility Adjacent to the Site
• Permitted Commercial Disposal Site
• Nevada Test Site
In addition, in-situ and no-action alternatives were considered and evaluated as potential disposal
alternatives. Sections 2.6.7.2 and 2.6.7.3 of the Operable Unit 4 FS discuss these representative
options and the results of their preliminary screenings. Subsequently, repromulgation of 40 CFR Part
191 led to changes in the list of relevant and appropriate requirements affecting on-property disposal
as discussed in Attachment C.II.
It is the DOE Defense Waste Management Policy at the Nevada Test Site, "...to approve generators
and to receive, store and dispose of radioactive wastes generated by DOE defense programs in a
manner consistent with DOE Order S820.2A, "Radioactive Waste Management," and applicable
federal, state, and local regulations and requirements."1 Chapter in of DOE Order 5820.2A
provides that low-level waste should go to a DOE low-level waste disposal site, such as the NTS.
This policy ensures that low-level wastes will be handled properly in accordance with applicable
standards and DOE guidelines. Exemptions from the DOE Order to allow shipments to commercial
disposal facilities can be granted by the U.S. Department of Energy Assistant Secretary for
Environmental Management on an ad hoc basis. Fernald has made shipments of waste in the past to
the Nevada Test Site and to the commercial facility operated by Envirocare, Inc. in Clive, Utah.
'U.S. Department - Nevada Field Office, June 1992, Nevada Test Site Defense Waste Acceptance
Criteria. Certification, and Transfer Requirements. Publication NVO-325, Rev. 1, Page 1.
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In this case, however, the Operable Unit 4 vitrified silo wastes from Fernald do not meet the waste
acceptance criteria for existing commercial facilities. The U.S. Department of Energy Office of
Environmental Restoration asked for and is in the process of receiving a determination by the U.S.
Department of Energy Office of Waste Management that the silo wastes constituted a small quantity
of by-product material under Chapter m of DOE Order S820.2A and therefore, may be disposed at a
DOE low-level waste disposal site, such as the Nevada Test Site. Also, it has been a long-standing
DOE policy that "defense related wastes" would be disposed at the Nevada Test Site and non-defense
related waste disposed at Hanfbrd.
That option, which is the preferred alternative, has been evaluated in this environmental impact
statement as a potential alternative for waste disposal, along with a potential option for commercial
disposal. Disposal at another DOE site, such as Hanford, was considered by DOE to be less feasible
than shipment to the NTS, given past experience with shipping legacy wastes from Fernald to the
NTS, which has been ongoing since 1985. In addition, an appropriate disposal facility is not
currently available at Hanford to receive the Operable Unit 4 waste.
The reprocessing of silo wastes to recover radiological or inorganic constituents was determined not
to be feasible due to poor treatability test results involving chemical separation techniques.
It should be noted that all of the Operable Unit 4 remedial wastes (i.e., Silos 1, 2 and 3 residues,
contaminated soil and debris) were considered for disposal at the NTS. However, it was determined
that only treated silo residues should be disposed at the NTS under the Operable Unit 4 FS/PP-DEIS
(although disposal of contaminated soil and debris is to be determined in subsequent RODs).
The selection of the NTS for disposal of Operable Unit 4 waste is supported by a process option
evaluation presented in Appendix B (Description of Technologies and Process Options) of the FS/PP-
DEIS. This evaluation concluded that based on considerations such as geology, demographics, levels
of precipitation, and depth to groundwater the NTS provided the best location for disposal. Also, the
results of treatability studies conducted on the vitrified waste form indicate that the vitrified waste
fully satisfies current NTS waste acceptance criteria and in general would provide a high level of
long-term protectiveness when disposed at the NTS.
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Issue 15 - FEMP Waste Disposal Program
On June 21, 1994, DOE received a package of 174 postcards from Citizen Alert. Three additional
postcards were received on July 5, 1994. The majority of the postcards were from concerned citizens
of Nevada expressing their comments related to the shipment and disposal of Fernald waste at the
NTS. One of their comments stated that, "...the more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radionuclides, should be kept on-site in
containers adequate to protect the local populace. Nevadans should not be required to accept
additional risk on top of that already present at the Nevada Test Site." (Commentors: P1-P177)
Response: As part of the FEMP Waste Disposal Program, disposal of waste at the NTS is only one
of several disposal locations being considered for waste resulting from the remediation of the Fernald
site. Other disposal locations include both on-site disposal and commercial facilities.
The overall remediation of Fernald is expected to generate over 2.6 million cubic yards of waste
requiring treatment and/or disposal. Of the estimated 2.6 million cubic yards, 1.4 million cubic yards
are to be managed at the Fernald site, 900,000 cubic yards are to be shipped to commercial facilities,
and 300,000 cubic yards may be shipped to the NTS (including approximately 5580 cubic yards of the
Operable Unit 4 remedial wastes). Therefore, only about 10 percent of the waste from the
remediation of Fernald might be shipped to the NTS. Additionally, these shipments would occur over
a projected 30-year period.
Currently, Fernald is shipping low-level waste to the NTS at a rate of about 18,000 cubic yards of
waste per year (based on the most recent 6 year average). The projected rate for disposal of the
Fernald remedial waste at the NTS is estimated at a rate of approximately 10,000 cubic yards per
year, with die highest estimate for a single year being approximately 16,000 cubic yards for 1995.
Furthermore, the 300,000 cubic yard estimate is a highest case estimate which, in reality, may not
happen. Fernald is making an effort to minimize waste generation and to explore other disposal
options, thereby minimizing waste requiring shipment to the NTS, as well as other locations.
Disposal of waste at the NTS is utilized only when these options have been evaluated and determined
unfeasible. These minimization efforts include recycling, decontamination for free-release of
materia], volume reduction through treatment, disposal of the waste on-site, and use of commercial
disposal facilities.
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Despite these efforts, the Operable Unit 4 FS/PP-DEIS has concluded after a detailed evaluation that
approximately 5580 cubic yards of silo residues are more appropriately disposed at the NTS. This is
driven by several factors, including the location of the Femald site over a sole-source aquifer (State of
Ohio regulations prevent the establishment of a disposal facility over a sole source aquifer); the close
proximity of the site to large populations and agricultural land; and the lack of commercial disposal
facilities which may accept these wastes. As discussed in the Operable Unit 4 FS/PP-DEIS, these
wastes include the treated residues from Silos 1, 2, and 3.
The State of Ohio recognizes that the final disposition of some Fernald wastes may be on site. In a
letter written to the U.S. EPA, the State of Ohio said: "Large volumes of contaminated construction
and demolition debris, soil, fly ash and bottom ash, and possibly some solid waste will have to be
disposed onsite at Fernald."
The disposal of some wastes at the NTS is one part of a balanced waste management effort for the
Fernald remedial activities. Although Femald is committed to the minimization of wastes and finding
alternative disposal options for its wastes, Fernald proposes to rely on the NTS for disposal of certain
wastes.
Issue 16 - Evaluation of Transportation Risks
On June 21, 1994, DOE received a package of 174 postcards from Citizen Alert. Three additional
postcards were received on July S, 1994. The majority of the postcards were from concerned citizens
of Nevada expressing their comments related to the shipment and disposal of Fernald waste at the
NTS. One of their comments stated that, "Transportation risks need to be thoroughly evaluated".
(Commentors: P1-P177)
Response: The FS/PP-DEIS for Operable Unit 4, Section 4, contains a complete detailed analysis of
all the remedial alternatives evaluated for off-site transportation of wastes, which included both long-
term and short-term risks. The preferred remedy for Operable Unit 4 involves the transportation of
the treated silo residues to the NTS by a combination of rail and truck. The material would be
shipped exclusively by use of rail from the FEMP to Las Vegas, Nevada [a distance of 3S62 km
(2270 mi)], then by truck from Las Vegas to the NTS [179 km (111 mi)].
Hie FS/PP-DEIS for Operable Unit 4, Appendix D, contains a detailed discussion of the long-term
and short-term risks associated with each remedial alternative which underwent detailed analysis. The
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RADTRAN IV computer code was used to evaluate potential short-term risks, including risks to the
public during the transportation of the vitrified Silos 1, 2 and 3 material to the Nevada Test Site.
Through Sandia National Laboratory's TRANSNET system, RADTRAN IV simulates the
transportation route, the length of time members of the public are exposed to radiation, and the dose
equivalent delivered for the trip. This exposure is to members of the public sharing the road with the
truck, people living along the rail and truck route, and people encountering the truck at truck stops.
The alternatives call for packaging the treated material in metal boxes meeting U.S. Department of
Transportation packaging requirements of 49 CFR Part 173. The radiological impacts associated with
the transportation of the waste to the NTS for disposal are summarized in Table C.4-2.
TABLE C.4-2
IMPACTS TO THE PUBLIC DURING TRANSPORTATION OF
VITRIFIED SILOS 1, 2 AND 3 WASTE TO THE NTS
1
Transportation to the Nevada Test Site
I ESTIMATED IMPACT
Vitrified Silos 1 and 2
Material
Vitrified Silo 3
Material
Routine Transport
RME Individual dose (mrem)
0.0085
0.00014
Risk -ILCRk
8.32xl0"10
1.71xl0"u
Transportation Accidents
Public dose from radioactive
material releases following truck
accident, (person - rem)
1.9xl0"5
3.8x1a4
Public dose from radioactive
material releases following train
accident, (person - rem)
0.026
0.0053
Truck Associated Injuries'
0.013
0.0068
Truck Associated Fatalities"
0.0014
0.00074
Train Associated Injuries'
0.15
0.077
Train Associated Fatalities'
0.038
0.020
'Nonradiological impacts.
*ILCR - Incremental Lifetime Cancer Risk Above Background.
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The estimated dose exposure and subsequent risks were calculated and reported as an incremental
lifetime cancer risk (ILCR) to the public from the transportation of the vitrified Silos 1, 2 and 3
material to the Nevada Test Site. Consistent with the goals of CERCLA, it is desirable to have the
risks resulting from remediation to fall within all ILCR range of 1 x 10* to 1 x 10"4 above
background. For example, if a member of the public has an additional 1 chance in 1,000,000 of
contracting cancer due to exposure to radiation during transportation, the probability of developing
cancer is expressed as a 1 x 1Q* (1 in 1,000,000) risk. As presented in Table C.4-2, all short-term
risks from exposure to radiation meet these criteria.
In addition to risks from the radiological exposure from the transportation of Silos 1, 2 and 3 material
to the NTS, accidental injuries and fatalities are predicted to occur because trucks and/or trains would
be used for material transportation to the Nevada Test Site. The following risk coefficients below
were used to evaluate non-radiological risks to truck drivers and rail crews:
Driver/Crew Truck Rail
injury/mile 4.1 x 10"1 4.6 x 1Q*
death/mile 2.1 x 10* 4.6 x 10"*
Likewise, the following risk coefficients presented below were used to evaluate non-radiological risks
to the public:
Publfc Truck Rail
injury/mile 1.2 x 10"7 6.8 x 1Q*
death/mile 1.3 x 10"1 1.8 x 10*
It should be noted that the risk coefficients for truck and rail transport are not strictly comparable,
since far more waste is transported per mile of rail transport than per mile of truck transport. These
risks parameters were used consistent with standard risk calculation methodologies as identified in the
Final Risk Assessment Work Plan Addendum, (June 1992),2 which referenced the forementioned
^U.S. Department of Energy, June 1992, "Risk Assessment Work Plan Addendum," U.S.
Department of Energy - Fernald Field Office, Fernald, Ohio.
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published statistics by the U.S. Department of Transportation Federal Highway Administration' and
U.S. Department of Transportation Federal Railroad Administration/
As before, RADTRAN IV computer code was utilized to calculate the short-term impacts of injuries
and fatalities. These impacts are also presented in Table C.4-2 for the transportation of Silos 1, 2 and
3 to the Nevada Test Site.
RADTRAN IV also assesses the impacts from accidental releases of the radioactive material in the
transport containers. The code assesses the total impacts for eight accident severity categories. It
assesses collective radiological impacts to the public from direct radiation exposure from
contamination on the ground, inhalation of contaminants in a plume and resuspended from the
ground, direct radiation exposure from contaminants in a plume, and ingestion of food grown in the
contaminated area. The impacts from a single truck and train accident are included in Table C.4-2.
Issue 17 - Socioeconomic Impacts to the Waste Receptor Community
On June 21, 1994, DOE received a package of 174 postcards from Citizen Alert. Three additional
postcards were received on July 5, 1994. The majority of the postcards were from concerned citizens
of Nevada expressing their comments related to the shipment and disposal of Fernald waste at the
NTS. One of their comments stated that, "Socioeconomic impacts on the receptor community should
be thoroughly evaluated and balanced against the desires of Ohio to move Fernald waste."
(Commentors: P1-P177)
Response: The importance of evaluating the socioeconomic impacts of the Operable Unit 4 Remedial
Action Alternatives on affected off-site locations is recognized by DOE. It is DOE's view that this
issue has been adequately evaluated in the Operable Unit 4 FS/PP-DEIS.
Section 4.0 of the Operable Unit 4 FS/PP-DEIS provides a thorough discussion of the alternatives.
For the alternatives that consider disposal at the NTS, impacts on socioeconomics were evaluated.
3U.S. Dept. of Transportation Federal Highway Administration, Office of Motor Carriers, 1986,
Accidents of Motor Carriers of Property. Publication No. FHWA-MC-88-008, DOT, Washington,
DC.
4U.S. Dept. of Transportation Federal Railroad Administration, Office of Safety, 1988,
Accident/Incident Bulletin. Publication No. 157, DOT, Washington, DC.
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Population demographics, land use of areas adjacent to the site, and potential risks to the surrounding
population are discussed. In addition, impacts on groundwater, soil and geology, biotic resources,
etc., are also presented.
Additional discussion of the NTS is also provided in Appendix B of the Operable Unit 4 FS/PP-DEIS,
Description of Process Options and Technologies. This discussion provides additional detail on the
natural and socioeconomic characteristics of the NTS and the surrounding area. This information
formed the basis for the impacts presented in Section 4.0 of the Operable Unit 4 FS/PP-DEIS.
Additionally, on August 10, 1994, DOE published a Notice of Intent to prepare a site-wide EIS for
NTS (S9 FR 40897). This notice invites the public to participate in the scoping process for the NTS
EIS.
Issue 18 - Disposal of DOE Waste at the Nevada Test Site
On June 24, 1994, DOE received comments from a member of the Citizens Advisory Board for
Nevada Test Site Programs which expressed concerns over the current decision process for
considering DOE waste for disposal at the NTS. More specifically, the comment stated as follows:
"The shipments of waste from Fernald are the first of potentially many other shipments to the NTS.
Rather than making decisions on a piecemeal basis, we want to see the full picture before we are
asked to make decisions on individual pieces. That is, we want to first consider the total impact of all
of the waste that is being considered for disposal at the NTS. Following that, we want to consider
each individual piece." (Commentor: O)
Response: A Notice of Intent to prepare a site-wide EIS for the NTS was published on August 8,
1994. The purpose of this Notice is to invite the participation of federal, state and local agencies,
affected Indian tribes, and other interested persons in the process DOE will follow to solicit public
comments on the proposed scope and content of the NTS EIS. The site-wide EIS will address the
impacts of all waste disposal activities at the NTS. Shipments of waste generated from the cleanup of
Operable Unit 4 are not proposed to begin until after the expected completion of the NTS site-wide
EIS.
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Issue 19 - Funding for Technical Oversight and Impact Mitigation
On June 24, 1994, DOE received comments from the Citizens Advisory Board for Nevada Test Site
Programs which expressed their belief that:
(a) funds should be provided for technical oversight of waste management activities.
(b) the State of Nevada and affected Counties are entitled to impact mitigation payments
as compensation for costs arising from management of this material.
(Commentor: O)
Response: (a) The first issue regards funding for technical oversight. DOE currently has
a program established for providing such funds. This program is detailed in an
"Agreement in Principle, with the State of Nevada, one of several such agreements
between DOE and the states in which DOE facilities are located. This agreement includes
the provision of funding for technical oversight by the State of Nevada for waste
management activities at the NTS.
(b) The second issue is related to providing impact mitigation payments for management
of waste in Nevada to the State of Nevada and affected counties. Mitigation payments are
associated with actions whose implementation will have significant impact on human health
and the environment. Since no significant impacts are expected to result from the
transportation and disposal of the vitrified Operable Unit 4 waste at the Nevada Test Site,
no mitigation payments for management of the waste in Nevada are anticipated at this
time.
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C.5.0 SUMMARY OF COMMENTS NOT RESULTING IN ISSUES
Commentors A, B, D, G, H, and J inquired as to the possibility of covering the silos and ensuring
pollution prevention measures are implemented during remediation. Through the remedial design
process, appropriate measures will be evaluated, utilized, and monitored to maintain air emissions
resulting from all remedial actions at ot below the regulatory requirements.
Commentors A and H wanted assurance that waste from other sites would not be brought to Fernald's
vitrification facility to be treated nor stored at the FEMP for future disposition. At this time, no plans
have been made to treat waste from other DOE sites through the Operable Unit 4 Vitrification Facility
or store materials at the FEMP. However, as part of a treatability study under the Uranium Soils
Integrated Demonstration program, DOE is considering a program that would involve importation of
uranium-contaminated soil samples from Portsmouth, Ohio to be tested at Fernald and returned to the
point of origin. This study would be conducted as an extension of the current Minimum Additive
Waste Stabilization (MAWS) program, which is part of Operable Unit 4 remediation program. These
tests are an essential component of FEMP's ability to conduct necessary research in support of DOE
technology development
The purpose of doing this test work is to make use of the investment which DOE has already made in
equipment and experience at Fernald; to produce valuable remediation information for a nearby Ohio
site; and to avoid duplication of the resources already available at Fernald.
The pilot-scale soil decontamination work at the FEMP is part of DOE's Uranium Soils Integrated
Demonstration, a DOE Office of Technology Development program aimed at developing and applying
new and enhanced technologies by demonstrating them at one test site.
Currently, a proposed test plan is being circulated for review within DOE and FERMCO management
to solicit comments on approach, feasibility and acceptability. No action has been taken or will be
taken without stakeholder input.
Commentors D and G wanted to suggest the possibility of setting up a trust fund for monitoring and
maintenance cf the on-property disposal facilities. A trust fund would not be a viable option due to
the maimer in which money is budgeted and allocated to the FEMP cleanup. The United States
Congress annually reviews and approves the funding that the FEMP will receive through the DOE for
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remediation activities. A trust fund which would cover the cost of future routine operations and
maintenance would not be viable under the current budgetary process.
Commewor A asked how the vitrified silo residue waste form could emanate radon at the same rate as
building materials, when the waste itself is much more radioactive. She also requested clarification
on the interim storage process. The glass matrix of the vitrified Operable Unit 4 waste form retains
radon much more efficiently than porous building materials such as concrete and masonry.
Therefore, the Operable Unit 4 vitrified material releases radon at a similar rate of building materials
despite the greater quantity of radon emanating radionuclides contained within the vitrified waste
form.
Contaminated soil and debris would either be processed in accordance with the selected Operable Unit
5 (Environmental Media) and Operable Unit 3 (Production Area) remedy identified in the Operable
Unit 5 and Operable Unit 3 ROD or placed in an interim storage facility to await the finalization of
the disposal decisions for soils and debris under Operable Unit 5 and Operable Unit 3. The interim
storage would be managed pursuant to the approved work plan for Removal Action 17 - (Improved
Storage of Soil and Debris).
The decision regarding the final disposition of the remaining Operable Unit 4 contaminated soil and
debris has been placed in abeyance to take full advantage of planned and in-progress waste
minimization treatment processes. Further, this FEMP remedial management strategy enables the
proper integration of disposal decisions on a sitewide basis. As planned treatment facilities become
available under Operable Units 3 and 5 remedial actions, full consideration would be given to
applying these systems to the inventoried contaminated materials from Operable Unit 4. Following
the application of available waste minimization processes, the remaining Operable Unit 4
contaminated soil and debris would be disposed consistent with the selected remedies for Operable
Units 5 and 3, respectively.
Commentor D wanted to know if the 250 acres calculated to be disturbed during the implementation
of the preferred alternative for Subunit 2C included loss of habitat. The 250 acres discussed in the
Feasibility Study Report for Operable Unit 4 represents the cumulative sitewide acreage of land that
will be disturbed as a result of the implementation of all five operable unit's preferred remedial
actions. An estimated 220 acres out of the total 250 acres would be lost in the long term, with the
remaining 30 acres only rendered temporarily unusable during the implementation of the sitewide
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remedial actions. Therefore, only 220 acres would be permanently committed as a result of
implementing these remedial alternatives.
The State of Nevada (Commentor E) noted that, . . the cost estimates of long-term storage/disposal
of mixed waste at the NTS were not properly accounted for in the Draft EIS. The assumptions, for
example, under which storage/disposal of mixed waste at the NTS could be considered "free'' when
compared to a commercial facility, were not presented in the document." The cost for disposal of
FEMP waste at the NTS aEfi incurred by the FEMP. NVO-325 (Nevada Test Site Defense Waste
Acceptance Criteria, Certification, and Transfer Requirements), Section 3.S discusses the methods of
payment which generators will use to cover the cost of disposal operations for their waste at the NTS.
Specifically, NVO-325 states ". . .disposal charges are based upon the estimated volumes listed on
their (generator's) Three-Year Waste Shipment Forecast' multiplied by the corresponding disposal
charge per cubic foot. . ."
The "Three-Year Waste Shipment Forecast" is prepared annually by the generator and it estimates the
quantity of waste to be shipped to NTS by that generator each year for the next three years. These
forecasts are then used by the NTS to project operating costs for operations related to disposal of the
waste for the upcoming years. Therefore, although the NTS disposal site is a non-commercial, non-
profit government facility, the cost for operations is funded by the generators and is not provided
"free-of-charge." It should be noted that, as stated in the response to Issue 4, the Operable Unit 4
by-product material for disposal at the NTS is not mixed waste.
Commentor B questioned how NEPA was being addressed within these documents. More specifically,
how NEPA values were being integrated into the CERCLA process for the Operable Unit 4 FS/PP-
DEIS. When the Operable Unit 4 EIS process was initiated, it was DOE's policy to integrate the
NEPA requirements into the procedural and documentation requirements of CERCLA whenever
practicable. On June 13, 1994, the Secretary of Energy modified DOE's approach to National
Environmental Policy Act (NEPA) compliance for actions taken under the authority of CERCLA. As
a general policy, DOE will now rely on the CERCLA process for review of remedial actions to be
taken under CERCLA, incorporating NEPA values into CERCLA documents to the extent
practicable. DOE may choose, however, to integrate the NEPA and CERCLA processes for specific
proposed actions. For Operable Unit 4 at the FEMP, DOE has chosen to prepare integrated
CERCLA/NEPA documents. This decision was based on the longstanding interest on the part of
local stakeholders to prepare an EIS on the restoration activities at the FEMP and on the recognition
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that the draft document was issued and public comments received. Therefore, an integrated
Feasibility Study/Proposed Plan - Final Environmental Impact Statement (FS/PP-FEIS) has been
completed which evaluates alternatives for the treatment and disposal of radioactive residues contained
in storage silos at FEMP.
In accordance with both CERCLA and NEPA processes, these documents are made available to the
public for comment. Public involvement is an important factor in the decision-making process for site
Temediation. Public comments will be considered in the selection of remedy for each operable unit,
which will be presented in a ROD. Applying the integrated approach for CERCLA and NEPA, DOE
plans to prepare and issue a single ROD to be signed by both DOE and EPA. The contents of the
documents prepared for the remedial actions at the FEMP are not intended to represent a statement on
the legal applicability of NEPA to remedial actions conducted under CERCLA.
Commentor Q provided twenty comments on the Proposed Plan. Some of these comments were
addressed in the issue discussions presented in Section C.4.0 of this document. The remaining
comments were basically requests for clarification of the technical content of the document and did not
have significant impact on the document. The comments are distinguished by the letter and the
response to die comments immediately follows.
(a,l) Comment: The responses to Comments "a" and "1" were similar in content and, therefore,
have been combined. The comments are related to the differences in cost and
implementation between alternatives with the same treatment technologies. The
commentor stated that "...there are variances in the capital cost for the same treatment
alternatives with the only difference being on-site versus off-site disposal. What is the
source of this variance?" Furthermore the commentor stated: "...comparison of remedial
alternatives, state differences in implementing identical treatments with different disposal
options. Is this difference related to transportation issues for off-site rather than on-site?
Please explain these differences. Also Subunit C lists no treatment for all alternatives;
please demonstrate why no treatment is acceptable."
Response: The variances of the capital costs are primarily due to the difference in the
disposal methods. The on-site disposal alternative includes the capital costs associated with
die construction of a disposal vault. The off-site alternative has no capital cost associated
with the construction of the disposal vault, but does include capital costs associated with
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the transportation and disposal of the waste at the off-site disposal facility. The
implementation of these alternatives is also affected by the same factors.
No treatment response actions were utilized in the development of alternatives for Subunit
C waste (i.e., soils and debris). This decision is consistent with the FEMP site-wide waste
management strategy. This strategy is designed to coordinate the disposal of similar waste
between operable units. From a site-wide perspective, the estimated quantity of soils and
debris requiring management by Operable Unit 4 in comparison with the total estimated
quantity of soils and debris to be managed by Operable Units 5 and 3 respectively, is
quite small. Therefore, as opposed to Operable Unit 4 developing its own treatments
methods for soils and debris, the disposition of these wastes will be integrated with the
disposal methods and any treatment methods developed by Operable Units 3 and 5.
(b,d) Comment: The responses to Comments "b" and "d" were similar in content and,
therefore, have been combined. These comments are related to post-remediation
monitoring and site reviews for alternatives which include on-property disposal. The
commentor asked: "...EPA would review on-property disposal every five years in
accordance with CERCLA requirements. Who and how often would a review be
performed in other years?" and also asked: "Post remediation O&M cost are estimated
over a thirty year period. What about the remaining years for which this material will
require monitoring?"
Response: The EPA requires a five-year review under the CERCLA as follows "...if a
remedial action is selected that results in hazardous substances, pollutants, or contaminants
remaining at the site above levels that allow for unlimited use and unrestricted exposure,
the lead agency shall review such action no less often than every five years after initiation
of the selected remedial action." The on-property disposal alternatives for Operable Unit 4
include the five-year reviews. The on-property disposal facility for the Operable Unit 4
materials would be designed to preclude the need for active operation, maintenance, and
monitoring. However, during the active operational phase of the overall FEMP site
remedial activities (approximately 30 years), the disposal facility will be monitored. It is
anticipated that such operations, maintenance, and monitoring and associated costs would
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not be warranted (i.e., no water infiltration will have been observed) beyond that
timeframe.
The Operable Unit 4 selected remedy has adopted preliminary soil cleanup levels with
exhumed soils being placed into on-property storage, pending the establishment of final
remediation levels and a disposition strategy through the Operable Unit 5 Record of
Decision (ROD). The Draft Operable Unit 5 ROD is scheduled for submittal to the
USEPA and OEPA on July 2, 1995. Since this soil disposition strategy has been adopted,
it is not considered appropriate to specify in the Operable Unit 4 ROD the long-term
operation, maintenance and monitoring requirements for any residual concentrations of
hazardous substances in soils in the Operable Unit 4 footprint.
The Operable Unit 5 ROD will establish final remediation levels for soil and the associated
long-term operation, maintenance, monitoring and institutional requirements for the site.
The scope and duration- of these requirements will be consistent with the contemplated
future land use for the FEMP property and the final remediation levels documented in the
Operable Unit 5 ROD. Active operation, maintenance and monitoring for the soils staged
in the interim storage facility are contemplated as part of the Operable Unit 4 remedy.
(c) Comment: "There is no mention of retri[e]vability of the materials which would be
disposed of in the on-site disposal vault. Is this option being considered, and if not, why?"
Response: The on-property disposal facility is designed with an intruder barrier and
permanent markings to inhibit purposeful or inadvertent human intrusion of the facility's
engineered protective features and to eliminate water infiltration. This design is utilized to
provide permanent disposal of the wastes and does not include a means to readily retrieve
the waste. Designing a means to easily retrieve the waste would compromise the integrity
of the cap and would present an easier access for intrusion into the disposal facility.
(e) Comment: "Alternative 2B and 4B have an identical post remediation cost, with
Alternative 4B being untreated. Please explain how cost can be the same for treated versus
untreated materials disposed in an on-site vault?"
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Response: Post-remediation cost cover the costs associated with the monitoring and
maintenance of the disposa] facility. The monitoring and maintenance requirements and
the disposal facilities for both alternatives are the same. Therefore, the post-remediation
cost associated with these activities are also the same.
(f) Comment: "There is discussions of interim storage. What is the estimated time for this
interim storage?"
Response: The use of interim storage is identified for Subunit C alternatives waste only.
Interim storage would be utilized only if the waste could not immediately be managed by
the remedial alternatives selected for Operable Units 3 and S. If interim storage is
required, the duration of the storage would be contingent upon the schedule for
implementation of the preferred remedy identified in the Operable Units 3 and 5 ROD.
The interim storage would not exceed the date for final remediation of the FEMP site
which is currently estimated to be completed in 30 years.
(g) Comment: "Alternative 2C states that the contaminated materials would be placed in bulk
(without packaging) into the on-site disposal vault. Please expand on why this material
would not be packaged and state the advantages/disadvantages of packaged versus
unpackaged."
Response: The soils and debris considered for disposal into the disposal vault would be
contaminated with relatively low levels of contamination. The disposal facility for the
contaminated material from Alternative 2C would be designed to be protective of the
environment without the use of packaging. The use of bulk disposal eliminates the
unnecessary cost of the packaging and also reduces the cost of construction by requiring a
much smaller disposal facility.
(h) Comment: "It is stated that non-porous materials will be released from the site as
uncontaminated per DOE Order 5400.5. Will this material be checked for contamination
prior to release or just assumed to be uncontaminated and release?"
Response: As per DOE Order 5400.5, any material which has been used or stored in a
radiation area is to be considered potentially contaminated. Prior to free-release of any
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potentially contaminated material, the material will be surveyed to determine whether the
removable or total surface contamination is within specific limits as established in DOE
Order 5400.5, NRC Regulatory Guide 1.86, and FEMP site procedures. The
establishment of these limits is based on the primary objective to prevent an effective dose
equivalent to the public in excess of 100 mrem per year. This standard is considered
protective of public health and the environment.
Comment: "Will wastewater generated during remediation be treated for non-radioactive
contaminates prior to discharge in the Great Miami River? To what extent will radioactive
and non-radioactive elements be removed prior to discharge?"
Response: All waste water generated at the FEMP, including waste water generated
during Operable Unit 4 remedial activities, is subject to compliance with the FEMP
National Pollution Discharge Elimination System (NPDES) permit. The NPDES permit
limits the amount of contaminants, both radioactive and non-radioactive, which may be
discharged through waste water effluent into the environment. In compliance with the
NPDES permit, all waste water generated from the remedial activities for Operable Unit 4
will be treated to comply with the FEMP NPDES permit standards.
Comment: "A material variance in the cost associated with Subunit C exist between 3C.1
and 3C.2 with the only apparent difference being 3C.1 disposal at NTS and 3C.2 at
Envirocare in Utah. Please explain this variance and if this is partially due to more
stringent requirements at NTS, should these more stringent requirements also be required
at a commercial facility? Which requirements is more protective? It is also stated that an
exemption from DOE Order 5820.2A (this is transposed as 5280.2A in document, page
56) is needed to dispose at a commercial facility; has this been granted?"
Response: The variance in the cost between Alternative 3C.1 and 3C.2 is primarily due to
the elimination of packaging for the Permitted Commercial Disposal Facility as opposed to
the use of packaging for the NTS. The elimination of the purchase cost of the packaging
and the reduction of required transportation significantly decreases the costs of Alternative
3C.2 as opposed to 3C.1. The NTS currently does not accept waste in bulk form (i.e.,
unpackaged railcar) and therefore, the disposal alternative for the NTS does not recognize
the same cost savings. Because both disposal facilities operate within their permits, and
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the environments in which they are located are similar, both disposal facilities are
considered equally protective.
An exemption from DOE Order S820.2A, which excludes the use of commercial disposal
facilities for DOE waste, has not been specifically pursued for the disposal of Operable
Unit 4 remedial wastes. The evaluation of the alternatives in the FS/PP-DEIS, indicated
that other alternatives were preferred over the alternatives which included the Permitted
Commercial Disposal Facility. Therefore, a request to grant an exemption from this DOE
Order was not required. However, exemptions from this order have been granted and
commercial disposal facilities have been utilized for other FEMP wastes.
(k) Comment; "Will notification of these shipments be given to the areas involved in the
transportation routes for both rail and truck, and what precautions for protection will be
employed?"
Response: Response to this comment is provided in Issue 5 on page C-4-20.
(m) Comment: "Is there a potential for failure of the vitrified material has the radionuclides
trap[p]ed continue to decay, and if so, what is that risk?"
Response: The weathering behavior of volcanic glass (a natural analog to the Operable
Unit 4 vitrified product) can provide some measure of the long-term stability and durability
of the vitrified product. Only very thin weathering rinds develop on volcanic glass over a
period of several million years. The slowness in the overall degradation of a glass grain
suggests that the diffusion coefficient or teachability index would remain relatively
unchanged over time. Data on the long-term stability of vitrified material are not
available, and the life expectancy of the vitrified product is difficult to estimate from short-
term leach rates. However, on the basis of the longevity of volcanic glass and diffusion
calculations, the vitrified product would be expected to withstand direct environmental
exposure for thousands of years. Furthermore, past studies have shown that the decay of
radioactive materials do not affect the durability of the vitrified product.
(n) Comment: "It states that the capital cost associated with the on-site disposal facility has
been removed. Where is (will) this cost be accounted for?"
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Response: This comment refers to a sentence in the Proposed Plan (page 67, line 6)
which was erroneous and scheduled to be deleted from the text. However, this deletion
was inadvertently overlooked and the sentence was left in the text. The capitol cost of the
on-site disposal facility is included in the total estimated cost of the preferred remedy.
This cost is identified in Table 9-1 of this document.
Comment: "Line 14, page 67 reads "... results in significant a reduction in the
volume...," this would read better if the "a", preceded significant/rather than follow."
Response: This comment is duly noted. However, it has no significant impact on the
document.
Comment: "Please define the following statement (line 16, page 67) utilize permanent
solutions to the maximum extent practical. What viable permanent solutions presentiy
exist?"
Response: The intent of the statement"... permanent solutions to the maximum extent
practical..." alludes to the fact that, based on available technology, this remedy provides
the most feasible and permanent solution for the remediation of Operable Unit 4. A
potential remedial alternative's ability to achieve long term permanence is one of nine
criteria used to evaluate a remedy in terms of the risk remaining at the site after response
objectives have been met. The primary focus of this evaluation is the extent and
effectiveness of the controls that may be required to manage the risk posed by treatment
wastes.
As discussed in the Operable Unit 4 Feasibility Study and Proposed Plan, the preferred
remedy (removal, vitrification of the waste and offsite disposal at the Nevada Test Site)
would be the most effective based on treatability studies conducted on the silo residues
which demonstrated that vitrification would be effective in reducing radon emanation,
radionuclide teachability, and significantly reducing the residue volume by approximately
50 percent. Off-site disposal at the NTS would provide a greater certainty than on-
property disposal over the long term that the treated residues would not affect human
health and the environment.
C-5-10
-------
FEMP-OU4ROD-8 FINAL
December 1994
Comment: "Basis for stating long-term environmental impacts of permanent disposal at
NTS are minor and no long-term impacts of biota expected from disposal activities at
NTS. It is stated that to reduce U-238 to essentially background is not feasible; it also
states that it is assumed that the federal government retain ownership of the FEMP site to
consider clean-up protective. While I do not have a problem with these statements, it does
bother me that no formal statement has been made publicly concerning this. These two
statements present future land use constraints which must be addressed. Why hasn't the
DOE adopted a formal position concerning this issue and communicated this to both the
Fernald Citizens Task Force and the community?"
Response: The DOE and the EPA recognize that future land use for die FEMP site is
currently under consideration by the Fernald Citizens Task Force and is actively involved
in and supports this effort. However, due to the stipulations of the Amended Consent
Agreement, Operable Unit 4 is required to put forth a remedy for cleanup of soils within
the operable unit boundary prior to completion of the Fernald Citizens Task Force effort.
As discussed in the Proposed Plan, Section 5.4.1, the preferred remedy for Operable Unit
4 requires cleanup of contaminated soils to the proposed remediation levels presented in
Table 5-2. In addition to this, it is indicated that these cleanup levels for soils may be
adjusted to lower values, if necessary, to insure protectiveness of human health and the
environment. The level of protectiveness required by the soils will be dictated by the final
land use selected for the entire FEMP site, including that for Operable Unit 4, by the
Citizens Task Force, and the ongoing feasibility study modelling efforts being performed
by Operable Unit 5. Factoring in the Fernald Citizens Task Force recommendations,
Operable Unit 5 will evaluate and determine the final cleanup levels required for soils on a
site-wide basis. Accordingly, the Operable Unit 4 FS/PP-DEIS recommends that the
decision for final disposition of the contaminated soils be put in abeyance until the Record
of Decision for Operable Unit 5 is issued, at which time the final soils cleanup levels will
be established.
Comment: "Line 13, page 76 reads"...would bot be...", should that read "...would not
be..."?
C-5-11
-------
FEMP-OU4ROD-8 FINAL
December 1994
Response: This comment is duly noted. However, it has no significant impact on the
document.
(s) Comment: "It states the on-site, above-grade disposal facility would be designed for a
1000 year life with no active maintenance. What is the half-lives or duration for which the
radionuclide and chemical contaminants are a threat to the environment; do they exceed
1000 years? Also explain why no active maintenance is assumed for 1000 years?
Response: The half-lives of the radioactive constituents in the Operable Unit 4 waste
range from 3 to 4 days for Radon-222 to over 1.4 x 1010 years for Thorium-232 well in
excess of 1000 years.
On-site disposal of contaminated soils and debris in an above-grade disposal facility was
evaluated in the Operable Unit 4 Feasibility Study (FS) and also presented in the Proposed
Plan (PP). For purposes of the FS/PP, this disposal facility would be designed for a life
of 1000 years. This vault would be designed to preclude the need for long-term active
maintenance for the duration of its design life of 1000 years. An assessment of the risks
to human health, presented in Appendix D of the Operable Unit 4 FS, indicates that for the
extended trespasser the residual risk from soil remaining in Operable Unit 4 in addition to
risks posed by disposal of contaminated soils and debris in this facility would be well
within the required risk range of 1 x 10"4 to 1 x 10*. However, it should be noted that the
final disposition of soil and debris will be determined by the Records of Decision (RODs)
for Operable Units 3 and 5. In accordance with the requirements of CERCLA, the
Operable Units 3 and 5 RODs will define the appropriate level of protectiveness required
for final disposition of Operable Unit 4 debris and contaminated soil respectively.
(t) Comment: "Has an exemption to the Ohio solid waste facility requirement been requested,
and if not when will such a request be made? Also line 28, page 79, would read better if
"the" or "a" were added to precede disposal. (For disposal facility on the FEMP site.)
Resnonse: Operable Unit 4 will not be creating a new solid waste disposal unit for
management of Operable Unit 4 remediation waste as part of the Operable Unit 4 preferred
remedy. Rather, the decision to treat/dispose of Operable Unit 4 wastes on site will be
part of the Operable Units 3 and 5 RODs, since the disposition of Operable Unit 4
C-5-12
-------
FEMP-OU4ROD-8 FINAL
December 1994
demolition debris and soils for remediation will be deferred to those respective operable
units. Therefore, compliance with the Ohio siting requirement is not germane to the
Operable Unit 4 FS/PP-DEIS.
Discussions with the EPA and OEPA have taken place regarding exemptions and possible
waiver to this requirement. At this time, the issue of technical exemption under Ohio
statute, versus ARAR waiver by EPA has not been resolved.
The editorial comment on the text contained in Line 28, Page 79, has been noted.
However, it does not have any impact on the document.
The Ohio EPA (Commentor R) noted that DOE should attempt to incorporate pollution
prevention activities whenever possible during the design and operation of the OU4
remedial action system. In addition, the Ohio EPA commented that all available methods
to reduce or eliminate discharges from the treatment system should be considered during
the design of the system. It is DOE policy, in accordance with Executive Order 12856,
whenever feasible to apply pollution prevention and waste minimization principles into the
design and operation of all its facilities. The DOE is committed to employing all available
methods and techniques to minimize waste and/or eliminate discharges from remedial
treatment systems in a manner protective of human health and the environment.
The Ohio EPA (Commentor R) stated that, ... "The OU4 Proposed Plan is the culmination
of efforts by U.S. DOE, Ohio EPA, and U.S. EPA to understand and develop a plan for
mitigating releases to the environment from OU4. The alternative selected in the Proposed
Plan will address potential and actual releases in a manner protective of human health and
the environment." The DOE acknowledges the Ohio EPA comment and believes that the
implementation of the preferred alternative identified in the Proposed Plan will address the
remediation of the Operable Unit 4 area in a manner protective of human health and the
environment.
The US EPA, Planning and Management Division (Commentor S) stated that, ..."the only
comments on the record from our agency are those previously supplied to you by our
Waste Management Division. At this point in time, given the requirements of NEPA and
its implementing regulations, those comments will have to suffice as our agency's
C-5-13
-------
FEMP-OU4ROD-8 FINAL
December 1994
comments. Provided that the comments previously provided by our Waste Management
Division are complied with, and further provided that facility in question is subsequently
operated in full accordance with applicable local, State, and Federal requirements, it
appears unlikely at this time that any significant adverse impacts on the environment can
reasonobty be foreseen." The DOE previously addressed the US EPA Region 5, Waste
Management comments on the Operable Unit 4 FS/PP-DEIS in May 1994. These
comments were satisfactorily resolved with the US EPA Waste Management Division at
that time. Section 11 of this responsiveness summary details the significant changes
required by the resolution of the US EPA Waste Management Division comments.
C-5-14
-------
FEMP-OU4ROD-8 FINAL
December 1994
ATTACHMENT C.I
WRITTEN AND ORAL COMMENTS
-------
FEMP-OU4ROD-8 FINAL
December 1994
{This page intentionally left blank}
-------
List of Tables
C.I.I Introduction
FEMP-OU4ROD-8 FINAL
December 1994
TABLE OF CONTENTS
Page
c-I-ii
C-I-l
-------
FEMP-OU4ROD-8 FINAL
December 1994
LIST OF TABLES
Page
C.I. 1-1 Formal Oral and Written Comments Received C-I-l
c-I-ii
-------
FEMP-OU4ROD-8 FINAL
December 1994
C.I WRITTEN AND ORAL COMMENTS
C.I.I INTRODUCTION
The written comments received on the Operable Unit 4 FS/PP-DEIS during the March 7, 1994 -
June 19, 1994 comment period and the verbal comments received during the March 21, 1994 public
meeting at The Plantation in Harrison, Ohio are contained in this appendix. In addition, all late
comments received as of July 5, 1994 are included in this appendix. Each specific comment letter,
oral statement, and submitted attachments are referenced by an alphabetic identifier as noted in
Table C.I. 1-1. These comments are a formal part of the Administrative Record for this action.
TABLE C.I.1-1
FORMAL ORAL AND WRITTEN COMMENTS RECEIVED
ITEM
COMMENTOR
PAGE
NUMBER
SliiHI
A
Norma Nungester, resident and FRESH member
C-I-8
B
Vicky Dastillung, resident and FRESH Vice President
C-I-19
C
Lou Bogar, resident, Hamilton, Ohio
C-I-20
D
Edwa Yocum, resident and FRESH Secretary
C-I-28
j KHtMlL WRjjj©!
¦MP
E
Maud Naroll, State of Nevada, State Clearinghouse (April 18, 1994)
C-I-31
F
Jack and Roberta Warndorf, resident, Okeana, Ohio
C-I-34
G
Edwa Yocum, resident and FRESH Secretary, Harrison, Ohio
C-I-35
H
J. E. Walther, resident, Hamilton, Ohio
C-I-36
I
Martha J. Raymond, Department Head, Technical Review Services, Ohio
Historic Preservation Office
C-I-38
J
Lisa Crawford, resident and FRESH President
C-I-40
K
Lawrence L. Stebbins, resident, Hamilton, Ohio
C-I-41
L
Maud Naroll, State of Nevada, State Clearinghouse (April 5, 1994)
C-I-43
M
James K. O'Steen, Director, Office of Hazardous Materials Technology, U.S.
Department of Transportation
C-I-45
N
William L. Vasconi, Acting Chairman, Nevada Test Site Citizens Advisory
Board
C-I-47
0
Nevada Test Site Citizens Advisory Board
C-I-48
P-l
Nichole Davis, 1600 E. University #151, Las Vegas, NV 89119
C-I-49
P-2
Shellie Michael, 2800 S. Eastern #717, Las Vegas, NV 89109
C-I-49
C-I-l
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-3
Lynn Rohl, P.O. Box 12303, Las Vegas, NV 89112
C-I-50
P-4
Ted Mucha, 301 Orland #8, Las Vegas, NV 89107
C-I-50
P-5
Mark Michael, 2800 S. Eastern #717, Las Vegas, NV 89109
C-I-51
P-6
Kathleen Guise, 4124 Seville St., Las Vegas, NV 89121
C-I-51
P-7
Jo Anne Moran, 3128 E. Flamingo #203, Las Vegas, NV 89121
C-I-52
P-8
Catherine A. McLaughlin, 1721 Howard Ave., Las Vegas, NV 89104
C-I-52
P-9
Nancy Gott, 3212 Brahns Dr., Las Vegas, NV 89102
C-I-53
P-10
Rebecca Webber, 5070 River Glen Dr. #457, Las Vegas, NV 89103
C-I-53
P-ll
Tanya Carr, 2032 Shadow Brook Way, Las Vegas, NV 89014
C-I-54
P-12
Jim Macklin, 5178 Silverheart Ave., Las Vegas, NV (no zipcode provided)
C-I-54
P-13
Cindy Weatherby, 1760 N. Decatur #69, Las Vegas, NV 89108
C-I-55
P-14
Rebecca Heider, 6941 W. Forest Vista St., Las Vegas, NV 89117
C-I-55
P-15
Troy Weatherby, 1760 N. Decatur #69, Las Vegas, NV 89108
C-I-56
P-16
Abraham Hartman, 1872 Pasadena Blvd., Las Vegas, NV 89115
C-I-56
P-17
Vicki Cassman, P.O. Box 72634, Las Vegas, NV 89170
C-I-57
P-18
Art Goldberg, 14810 Living Desert Dr., Las Vegas, NV 89119
C-I-57
P-19
Jillian Beth Wright, 6435 lorn Bark Lane (address provided incomplete)
C-I-58
P-20
Linda Strange, 4830 Nara Vista Way #102, Las Vegas, NV 89103
C-I-58
P-21
Ronnie Strange, 4830 Nara Vista Way #102, Las Vegas, NV 89103
C-I-59
P-22
Mindy Brummett, 6397 Spring Meadow Dr., Las Vegas, NV 89103
C-I-59
P-23
LaLori Rossi, 1929 Franklin Ave. (address provided incomplete)
C-I-60
P-24
Taryn Cunningham, 7383 Newcrest Cir., Las Vegas, NV 89117
C-I-60
P-25
Tiffany Brummett, 6397 Spring Meadow Dr., Las Vegas, NV 89103
C-I-61
P-26
Janet Zimmerman, 1912 Spangle Dr., Las Vegas, NV 89108
C-I-61
P-27
Janene Zimmerman, 1912 Spangle Dr., Las Vegas, NV 89108
C-I-62
P-28
Patricia Bishop, 1400 S. Casino Ct. #19, Las Vegas, NV 89104
C-I-62
P-29
Daniel J. Fedor, 185 Swaab, Las Vegas, NV 89115
C-I-63
P-30
Michael Carrigan, 7217 Tempest PI., Las Vegas, NV 89128
C-I-63
P-31
Renee Halm, 1000 King Richard, Las Vegas, NV 89119
C-I-64
P-32
Tubiola Lopez, 1508 Living Desert Dr., Las Vegas, NV 89119
C-I-64
P-33
Doreina Saenz, 2111 Fairfield #6, Las Vegas, NV 89102
C-I-65
P-34
Jerome Brenberg, 5668 Divot PI., Las Vegas, NV 89130
C-I-65
P-35
Ravon Rodriguez, 538 Kolson Cr. #"A" (address provided incomplete)
C-l-66
C-I-2
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FEMP-OU4ROD-8 FINAL
December 1994
1 ITEM
COMMENTOR
PAGE
NUMBER
[ P-36
Carmen E. Rodriguez, 538 Kolson Cr. f A" (address provided incomplete)
C-I-66
P-37
Kimba Rutledge, 399 Steelhead Lane, Las Vegas, NV 89110
C-I-67
P-38
Sheila Rutledge, 399 Steelhead Ln., Las Vegas, NV 89110
C-I-67
P-39
S. Humhe, 9285 Sunten Ct., Las Vegas, NV (address provided incomplete)
C-I-68
P-40
Michelle Lynn Berry, 370 E. Harmon Apt. E310, Las Vegas, NV 89109
C-I-68
P-41
L. Jean McCoy, 6710 Wild Horse Rd., Las Vegas, NV 89108
C-I-69
P-42
Tammy Smith, 6710 Wild Horse Rd., Las Vegas, NV 89108
C-I-69
P-43
Henry B. (?), 1982 N. Rainbow #194, Las Vegas, NV 89108 (name
unreadable)
C-I-70
P-44
Stan Greene, 7845 La Cienega, Las Vegas, NV 89123
C-I-70
P-45
Frances Bruno, 486 Sierra Vista Dr. #24 (address provided incomplete)
C-I-71
P-46
Betty Hay, 1241 South 7th St., Las Vegas, NV 89104
C-I-71
P-47
David Geerts, 3940 S. Algonquin Dr. #83, Las Vegas, NV 89119
C-I-72
P-48
John Engle, 4441 Escondido St. Apt. #4205 (address provided incomplete)
C-I-72
P-49
Alison Orr, 7053 Cheerful Circle, Las Vegas, NV 89117
C-I-73
P-50
David Gohas, P.O. 46204, Las Vegas, NV 89114
C-I-73
P-51
Finu Norris-Coray, 4801 Spencer #56, Las Vegas, NV 89119
C-I-74
P-52
Elizabeth Petit, 2362 N. Green Valley Parkway #141P, Henderson, NV 89014
C-I-74
P-53
Sonja Swenson, 4444 Midway Lane, Las Vegas, NV 89108
C-I-75
P-54
Ron Schaefer, 3950 Mountain Vista #146, Las Vegas, NV 89121
C-I-75
P-55
Victoria Pinkston, 1771 Charnut Lane (address provided incomplete)
C-I-76
P-56
Kathy Granousky, 3355 Dakota Way, Las Vegas, NV 89109
C-I-76
P-57
Emilee Rogers, 1105 Washington (address provided incomplete)
C-I-77
P-58
Michael LoCorriere, 7201 W. Girard Drive, Las Vegas, NV 89117
C-I-77
P-59
Sheri LoCorriere, 7201 W. Girard Drive, Las Vegas, NV 89117
C-I-78
P-60
Breck Nester, 24252 Sparrow, El Toro, CA 92630
C-I-78
P-61
Dana Robbins, 5028 S. Rainbow #101, Las Vegas, NV 89118 ,
C-I-79
P-62
Huy Phan, 3719 Central Park Circle, #4 (address provided incomplete)
C-I-79
P-63
Sandra Travez, 30 Tierra Buena Drive, Las Vegas, NV 89110
C-I-80
P-64
Steve Zahn, 8305 Greshen, Las Vegas, NV (no zipcode provided)
C-I-80
P-65
Lisa Nunaq, 1009 Spire CNYN, Las Vegas, NV 89128
C-I-81
P-66
Tim Jaqua, 3273 E. Flamingo #102, Las Vegas, NV 89121
C-I-81
C-I-3
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-67
Shelli McKenney, 4640 Victoria Beach Way, Las Vegas, NV (no zipcode
provided)
C-I-82
P-68
Carmen Davis, 6666 W. Washington #463, Las Vegas, NV 89107
C-I-82
P-69
Nasreen Bakhtary, 2165 E. Rochelle #71, Las Vegas, NV 89119
C-I-83
P-70
Maribel McAdory, 2529 Pacific Avenue, Las Vegas, NV (no zipcode provided)
C-I-83
P-71
Merlinda Gollegos, 5625 W. Flamingo #2005, Las Vegas, NV 89103
C-I-84
P-72
Chad Hunt, 8222 Beaverbrook Way, Las Vegas, NV 89123
C-I-84
P-73
Barb Brentz, 1015 Franklin Avenue, Las Vegas, NV 89104
C-I-85
P-74
Mayte Villanueva, 1805 Evelyn Avenue, Henderson, NV 89015
C-I-85
P-75
James Min, 5315 Heatherbrook Circle, Las Vegas, NV 89120
C-I-86
P-76
David Johnson, 3632 Hamlin, Las Vegas, NV 89030
C-I-86
P-77
Laura Yada, 4770 Gym Road, Las Vegas, NV 89119
C-I-87
P-78
Shannon Conners, 1213 Sloop Drive, Las Vegas, NV 89128
C-I-87
P-78
Sherri Caron, 3913 Courtside, Las Vegas, NV 89105
C-I-88
P-80
Stevi Carroll, 6505 Burgundy Way, Las Vegas, NV 89107
C-I-88
P-81
Margaret Bean, 3060 Ramrod, Las Vegas, NV 89108
C-I-89
P-82
Patrice L. Harvey, 7412 Summer Crest Lane, Las Vegas, NV 89129
C-I-89
P-83
Robin Wayne, 3400 Turquoise Road, Las Vegas, NV 89108
C-I-90
P-84
George A Bean, 3060 Ramrod Street, Las Vegas, NV 89108
C-I-90
P-85
Robert Pierson, 2974 Liberty Avenue, Las Vegas, NV 89121
C-I-91
P-86
Tim Bartlett, 4504 Fireside Lane, Las Vegas, NV 89110
C-I-91
P-87
Selma and Chuck Umnuss, 8504 Glenmount Drive, Las Vegas, NV 89134-
8648
C-I-92
P-88
Rob Marchant, 650 Whitney Ranch, Henderson, NV (no zipcode provided)
C-I-92
P-89
Jeff Van Ee, 2092 Heritage Oaks, Las Vegas, NV 89119
C-I-93
P-90
Tiffany Braun, 1635 Westwind Circle (address provided incomplete)
C-I-93
P-91
Jeffrey M. Steinbeck, 294 Davis Hill Court, Henderson, NV 89014
C-I-94
| P-92
Catherine Tillman, 3107 Lamega Drive, Henderson, NV 89014
C-I-94
| P-93
Madelaine Dayton, 2253 Castleberry, Las Vegas, NV 89115
C-I-95
P-94
Lori Johnson, 274 Camino Verde, Henderson, NV 89014
C-I-95
P-95
Sharlyn Anderson, 551 Eiger Way #1312, Henderson, NV 89014
C-I-96
P-96
Kathleen Womack, 5652 S. Latigo, Las Vegas, NV 89119
C-I-96
P-97
S. Gomez, 4255 Tamanis #286, Las Vegas, NV 89119
C-I-97
C-M
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FEMP-OU4ROD-8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-98
Melony Haynes, 1308 N. Jones, Las Vegas, NV 89108
C-I-97
P-99
Michele Gilbreth, 2391 Callahan Avenue, Las Vegas, NV 89119
C-I-98
P-100
Mary E. July, 5250 E. Lake Mead #26, Las Vegas, NV 89115
C-I-98
P-101
Grace K. Tao, P.O. Box 60384, Boulder City, NV 89005
C-I-99
P-102
Julia L. Winkler, 1127 E. Toni Avenue #18, Las Vegas, NV 89119
C-I-99
P-103
John Heormey, 419 Desert Inn Road, Las Vegas, NV (address provided
incomplete and last name hard to read)
C-I-100
P-104
James Holmes, 604 Freeman (address provided incomplete)
C-I-100
P-105
Merlyn Huguet, 2021 Peyton, Las Vegas, NV 89104
C-I-101
P-106
Barbara Roth, 112 Temple Drive, Las Vegas, NV 89107
C-I-101
P-107
John Wells, 6983 Antell Circus, Las Vegas, NV (address provided incomplete)
C-I-102
P-108
A1 Roth, 112 Temple Drive, Las Vegas, NV 89107
C-I-102
P-109
Louis Lavietes, 3401 E. Bonanza Road (address provided incomplete)
C-I-103
P-110
Jeff Cooley, 8257 Bermuda Beach Drive, Las Vegas, NV 89128
C-I-103
P-lll
James P. Foster, 817 Lauren Patt, Henderson, NV 89104
C-I-104
P-112
Giovanni Duley, 6251 Viewpoint Drive, Las Vegas, NV 89115
C-I-104
P-113
Trisa Higgins, 1075 Legato Drive, Las Vegas, NV 89123
C-I-105
P-114
Maggie Breki, 3237 E. Flamingo, Las Vegas, NV 89121 (last name hard to
read)
C-I-105
P-115
Joel Delmendo, 3138 Gaucho Drive, Las Vegas, NV 89008 (zip code hard to
read)
C-I-106
P-116
Katherine Garder, 5050 Tamanas #267, Las Vegas, NV 89119
C-I-106
P-117
Jason Benatz, 6317 Hobart, Las Vegas, NV 89107
C-I-107
P-118
Ebony Samerkand, 549 Kristin Lane, Henderson, NV 89015
C-I-107
P-119
Stacy Smith, 4223 Grove Circle #4, Las Vegas, NV 89119
C-I-108
P-120
Sanena Shelling, 1445 E. Rochelle (address provided incomplete)
C-I-108
P-121
Gerald F. Cuetkovic, 135 Grandview Drive, Henderson, NV 89015
C-I-109
P-122
Judy Cuetkovic, 135 Grandview Drive, Henderson, NV 89015
C-I-109
P-123
Michael Cuetkovic, 135 Grandview Drive, Henderson, NV 89015
C-I-l 10
P-124
Mrs. G. Michakel, 4079 El Segundo Avenue, Las Vegas, NV 89121-1703
C-I-110
P-125
Willene De Langis, 758 Willow Avenue, Henderson, NV 89015
C-I-lll
P-126
Donald A. De Langis, 758 Willow Avenue, Henderson, NV 89015
C-I-l 11
P-127
Robert Tonelli, 1004 University Ridge, Reno, NV (no zipcode provided)
C-I-l 12
C-I-5
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FEMP OU4ROD 8 FINAL
December 1994
ITEM
COMMENTOR
PAGE
NUMBER
P-128
Ruth Lindahl, 9457 S. Las Vegas Blvd. S. #93, Las Vegas, NV 89123
C-I-l 12
P-129
Melody Derrick, 330 S. 10th St., Las Vegas, NV 89107
C-I-l 13
P-130
Doug Jablin, 3559 Markan St., Las Vegas, NV 89121
C-I-l 13
P-131
Anthony Bondi, 135 Albert Avenue St. E. #16, Las Vegas, NV (no zipcode
provided)
C-I-l 14
P-132
T. Jones, Box 73215, Las Vegas, NV 89170
C-I-l 14
P-133
John A. Loeffler, P.O. Box 832, Searchlight, NV 89046
C-I-l 15
P-134
Christopher Mercer, 2517 Huber Hts., Las Vegas, NV 89128
C-I-l 15
P-135
Kurt Buchida, 325 Maryland Parkway, Las Vegas, NV 89101
C-I-l 16
P-136
Liz Marion, 6824 Adobe Court, Las Vegas, NV 89102
C-I-l 16
P-137
Dennis A. Dewitt, Box 5371, Reno, NV 89513
C-I-l 17
P-138
Brenda Weksler, 7904 Marbella Circle, Las Vegas, NV 89128
C-I-l 17
P-139
Cheryl Frossa, 3450 Erva St. #101, Las Vegas, NV 89117
C-I-l 18
P-140
Harriet R. Gagliano, 2713 Gilmary Avenue, Las Vegas, NV 89102
C-I-l 18
P-141
Kathy Poma, 2113 Fountain Springs Drive, Henderson, NV 89014
C-I-l 19
P-142
Stacey Hallenberg, 2245 Maple Rose Drive, Las Vegas, NV 89134
C-I-l 19
P-143
Kelli Koerwitz, 909 Willowtree, Las Vegas, NV 89128
C-I-l 20
P-144
Trish Taylor, 2113 Fountain Springs Drive, Henderson, NV 89014
C-I-l 20
P-145
Heather Davis, 2031 E. Windmill Lane, Las Vegas, NV 89123
C-I-121
P-146
Marilyn Benoit, 3461 Pointe Willow, Las Vegas, NV 89120
C-I-121
P-147
Richard Lewnau, 2950 S. Decatur D-3, Las Vegas, NV 89102
C-I-l 22
P-148
Susan Thornton, 1412 Golden Spur Lane, Las Vegas, NV 89117
C-I-l 22
P-149
Lee Dazey, 72 Keystone Avenue, Reno, NV 89503
C-I-123
P-150
Pete Mastin, P.O. Box 92, Verdi, NV 89439
C-I-l 23
P-151
Tracie K. Lindeman, P.O. Box 1672, Fallon, NV 89407
C-I-l 24
P-152
David L. Platerio/Tosa-wi-e, P.O. Box 822, Elko, NV 89803
C-I-124
P-153
Jo Ana Garrett, P.O. Box 130, Baker, NV 89311
C-I-125
P-154
Margaret Norman, 2332 Grant Street, Berkeley, CA 94703
C-I-l 25
P-155
Judy Treichel, 3926 Bushnell Drive #71, Las Vegas, NV 89103
C-I-126
P-156
Lorry C. Johns, 2090 Westwind Road, Las Vegas, NV 89102
C-I-l 26
P-157
Steve Frishman, 208 N. Hwy. 95A, Yerington, NV 89447
C-I-127
P-158
William Rosse Sr., HC61 Box 6240, Austin, NV 89310-9301
C-I-l 27
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[ITEM
COMMENTOR
PAGE j
NUMBER
| P-159
Corbin Hanuf (?), P.O. Box 1255, Nevada City, CA 95959 (name was hard
to read)
C-I-128
P-160
Shawn Black, 650 Whitney Ranch #1423, Las Vegas, NV (no zipcode
provided)
C-1-128
P-161
Lawrence Skinner, 1604 E. Evans, Las Vegas, NV 89030
C-I-129
P-162
Mary L. Johns, 2090 Westwind Road, Las Vegas, NV 89102
C-I-129
P-163
Bob Fulkerson, 725 McDonald Drive, Reno, NV 89503
C-I-130
P-164
Carla Baker Wallace, 3245 Mallard, Las Vegas, NV 89107
C-I-130
P-165
Louise (?), 4255 Tamarus #217, Las Vegas, NV 89119 (name was hard to
read)
C-I-131
P-166
Margaret (?), 1526 Darryl Avenue, Las Vegas, NV 89123
C-I-131
P-167
(?), 1526 Darryl Avenue, Las Vegas, NV 89123 (name unreadable)
C-I-132
P-168
(?), 1381 E. University Avenue (address incomplete and name unreadable)
C-I-132
P-169
(?), 4801 Spencer #56, Las Vegas, NV 89119 (name unreadable)
C-I-133
P-170
(?), 1431 E. Charleston, Las Vegas, NV 89104 (name unreadable)
C-I-133
P-171
Jamie B. (?), 4630 White Rock Drive, Las Vegas, NV 89121 (name
unreadable)
C-I-134
P-172
(name and address unreadable)
C-I-134
P-173
(name and address unreadable)
C-I-135
P-174
(left blank)
C-I-135
P-175*
Geoff Holton, 2332 Grant Street, Berkeley, CA 94703
C-I-136
P-176*
Richard Glasman, 2212 18th Avenue South, Seattle, WA 98144
C-I-136
P-177"
Kathleen Glasman, 2212 18th Avenue South, Seattle, WA 98144
C-I-137 j
Q
Pam Dunn, Harrison, OH
C-1-138
R
Thomas A. Schneider, Ohio Environmental Protection Agency
C-I-145
S
Michael W. MacMullen, U.S. EPA Region 5, Planning and Management
Division
C-I-147
"Postcards were received by the DOE on July 5, 1994.
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rntor A
Nungester: (Questions & formal oral, March 21, 1994)
3 6
a few nor* of ua from Ohio EPA. H«'r* hiring some '
more staff, so hopefully that will be a little more
proactive to your needs and help you out as far as
information you might need. So like I said, feel
i
free to contact me outside of this at the office or
wherever. Thanks.
NR. STEGNER: Thank you. What we'll
do now is, we'll have an informal question and
answer session. It might be best if you use a
microphone back there. If you don't feel
comfortable, just stand up and shout it. We have a
recorder here tonight. Please just state your name
and the question, and we'll let the panel pick it
up. So whoever wante to be first, feel free.
MS. NUNGESTER: I'm Norma
Nungester. I'm a Pernald resident, and a member of
Fresh. I have a question of Dennis Nixon. He made
the statement that I don't agree with, and I
wondered if he could clarify for me. He said that
when you vitrify waste, it reduces radon emanation
to that of building materials. To my
understanding, when you vitrify radionuclides, that
thay still are vary, very hot.
mr. nixon: That's corrict. Tha
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A (Cont.)
concentrate, due that reduction, is the radon
generation fro* the treated waste itself that is
significantly reduce. The radon is actually held
up, and the surface area is significantly reduced.
Did you get every other word?
You're exactly right, that due to
that fact that there's a significant voluae
reduction, you actually concentrate the
radionuclides, so you have a higher concentration
of say uraniua in a set voluae, but the radon
itself is iuch less. The generation or the
eaanation froa the vitrified waste is auch less
than in its natural fora.
MS. NUNGESTER: Okay, thank you.
MS. YOCUM: Edwa Yocua, Fresh aeaber
and a resident of the Fernald area. Z was asking a
question', this concerns Subunit C2 on your
pr«f«rr»d alternative deaolition reaoval on
property disposal. When you were talking about the
OU4 NKPA coapliance with the substantive cuaulative
impact up to 250 acres of surface disturbance, does
that aean that would be what would be part of where
the waste will be put?
MR. WOODS: Yeah. Agtilt, Wt IflOfcld
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at an LRA and assumed on-site disposal.
MS. YOCUM: Okay.
MR. woods: And that acreage would
incur areas where waste would be disposed of.
MS. YOCUM: Okay. Then, you also
are talking about the loss of 220 acres of
habitat. Is that included in the 250 acres?
MR. MOODS: Yeah. That 250 would be
a total that would occur during the short ter«, in
other words, during excavation activities. Once
reaediation is coapleted, we would look at
approxiaately 220 acres being peraanently
coaaitted, so yes. that's correct.
MS. YOCUM: Okay, all right, that's
what I wanted to know.
MS. NUNGESTER: Can you expand on
that peraanently coaaitted? I Biased soaething.
Peraanently coaaitted for what, waste disposal
facility?
MR. HOODS: Yeah, correct.
MS. NUNGESTER: Not for the waste
itself but for the --
MR. HOODS: Far the facilltiea that
would house the waste.
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December 1994
Commentor A (Cont.)
29
1 MS. NUNGESTER: That's the inground
2 facility, the upgrade vault, ai you io aay?
3 MR. WOODS: Cornet.
4 MS. NUNGE'STER: Now can you give me
5 an explanation of what is in an upgrade vault?
6 MR. HOODS: The alternatives that we
7 used for the evaluation utilized the vault concept,
8 which would be a portion of the waste being
9 disposed of below grade, and, you know, basically a
10 portion above. There would be facilities that the
11 waste could be retrieved froa, and what we used was
12 the calculation of the area.
13 MS. NUNGESTER: Disposal Beans
14 permanent ?
15 MR. HOODS: Yes.
16 MS. NUNGESTER: But now you're
17 talking interia?
18 MR. HOODS: Hell, what I'a saying is
19 the design of the facility wasn't as laportant as
20 the area that the facility could include. Designs
21 are going to be finalized as we go through the
22 reaedial process.
23 MS. NUNGESTER: Hell, this is
24 another thing, when you go tKfOUfh Ihl IA Ifli
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that's where the final decision and designs are
actually sade --
MR. HOODS: Correct.
MS. NUNGESTER: -- how can you coae
out with a Record of Decision before you actually
know what the vault is going to look like and if it
is really going to do the job?
MR. HOODS: Ho, you cannot reach a
Record of Decision until, you know, we've gone
through the full analysis of what the vault will be
designed like and how it will work. Hhat we did is
utilize the alternatives that were available at
that tiae for the purpose of the evaluation, which
is really the beat we can do. He can't foresee.
MS. NUNGZSTER: Okay. As of today?
MR. HOODS: That's correct, that's
correct. As we go through the various operable
units and decisions are Bade as to the final design
of the vaults and changes are aade to the area,
that aay be required. He'll update the analysis
and provide it in the future integrated doeuaents
for the other operable units.
MS. NUNGISTBR: Okay. So then our
decisions of the -- So your ilfcaritftfclvd fOt fell!
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December 1994
~nit 4 can change by the time after arriving at a
decision?
MR. NIXON: We wen specific with
the lubunlt wastes the Record of Decision. For
Operable Unit 4, specifically the Record of
Decision, the proposed plan in the future Record of
Decision will be that the Subunit C waste is — you
remember us talking about being held in abeyance or
delayed operable units, the Subunit C waste will be
handled in accordance with the Records of Decisions
for Operable Unit 3 and Operable Unit 5,
respectively. Okay.
So as far as our Record of Decision,
essentially we carry it through the removal of the
soil, interim storage of that soil in accordance
with Removal Action 17, which is the management of
those soils, demolition of the structures and
storage of that debris in interim until 0U3 comes
up with a final decision for the debris.
0U5 will have a final decision on how
the soils will be treated, and those all integrate
very well. When we atart that remediation proceas,
we have those soils excavated and stored, at
that tiae 0p«r«bl« Unit 3 tfld i llfiflfdl Of
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A (Cont.)
* 2
I
Decisions will be in place, and we'll have very
good Integration.
At that point we'll be able to
deliver -- Theoretically, we'll be able to take the
soils out and take those to a Operable Unit S
facility for treatment. They'll be disposed of in
accordance with their Record of Decision, and that
nay or aay not be on-site disposal.
HS. NUNGESTER: Okay. You're
saying, you're taking the debris, the structure,
the equipaent, the surface soil, you're putting
thea all in the underground vaults?
MR. NIXON: Operable Unit 4 is
delaying that decision. That's going to be
actually be stored in an interia fashion
HS. NUNGESTER: Okay
MR. NIXON: -- until OU5 and 0U3
have records of deciaion. Now, their Record of
Decision aay vary well be that we will treat soil
by washing it and disposing of that on site.
MS. NUNCESTIR: Right, but it
doesn't aay that, that it's going to ba interia
jntil Unit 9 la considered.
mr. NIXON; The proposed pllfl dOtl
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A (Cont.)
4 3
clearly state, as well as the Record of Decision
will clearly state those, that Integration.
MS. NUNGESTER: It does?
MR. NIXON: Yes, it does.
MS. NUNGESTER: Okay. Well, I know
on the proposed plan booklet on page 43 talks about
that specific issue.
MR. NIXON: Right.
MS. NUNGESTER: If anybody has that
book, and they want to look at it, they can, but I
don't believe it says -- It says something about
that it will be combined with 5, Unit 5, but it
does not say that would be interim disposal until
5 .
MR. NIXON: Disposal, it is interim
storage.
MS. NUNGBSTSR: Or storage, but they
use "disposal" as the word throughout the whole --
MR. NIXON: In the proposed plan,
the proposed plan has, for Subunit C wast*, it has
a selected or preferred alternative which is
on-site disposal Identified, and the reason that's
in th«r« Is because on-site and off-site disposal
was so close we had to select the one for th» like
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Commentor A (Cont.)
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evaluating the full alternative from start to
finish. Okay.
Later in the docuaent it talks about
the integration effort that will occur with OU3 and
OU5, and puts -- holds that decision in abeyance
for final disposal of those debris and soil until
0U3 and OU5 have their Records of Decision.
MS. ALLEN: The confusion could be
the fact sheet on page 12 states that the soil
debris will be disposed of on site.
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6 1
NR. STEGNER: Is Lee Bolva r still
here?
UNIDENTIFIED SPEAKER: Ha left.
MR. STEGNER: Sob, do you have
something to say?
UNIDENTIFIED SPEAKER: I'll turn It
in later.
MR. STEGNER; Bob Gessal -- Godsel,
I'm maxry? Going vary wall ao far. Toa Wagner,
Citizana Talk Forca? Okay. Ha hava an opan aika,
folks, if inyon« want* to aaka a coaaent.
MS. NUNGBSTER: You want ay address,
too?
MR. STEGNER: Not necessary, as long
as we have your naaa.
MS. NUNGESTER: Noraa Nungaster,
Farnald resident and Fresh group. I hava several
coanents. First of all, I want to cover again what
was stated in th« question and answer period. I
think between the draft ROD and the final ROD we
need a public coaaant official tiae, and you need
to foraaliza this. On down hare below you say the
public involveaant, public involveaant, that aeans
nothing to us. You n*«d to foraaiix* fchit.
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December 1994
lentor A (Cont.)
62
And you also naad mora details on
your RD/RA work plan. Wa want to know aora datails
on transportation. We want to be notified whan
you're transporting this stuff and talk about the
¦atarials that are actually In the K-65 when
they're vitrified and whan you start to ahlp them
out to Nevada.
Also this stuff that ataya on aite,
I'd like to know how they will be Monitored, and
for how long of a period they're going to be
¦onltored. Z guess I just want to express that we
want a guarantee that real-tiae aonitorlng will be
uaed.
Also a suggestion, how about covering
thoae ailoa when you start working on thea? I
think this Is one of the aost iaportant things you
could do for the coaaunity. I think that's about
it. I'a trying to read ay notes that are chicken
scratch here.
Oh, one aore thing. I'd like to be
diligent on referring large quantities of waste
froa other sites. He don't want anything brought
in hare froa other plants to vitrify with our
aaterlal or to be put under the storage areas.
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Commentor B
Vicky Dastillung: (Formal oral, documented by Johnny Reising. DOE. March 4.1994)
What capabilities do we have to do "real-time monitoring?"
Who has the authority to "shut down" the operation if the
"monitoring" levels are high?
FRESH wants more public input on the RD/RA process (real "nitty gritty" of how
things will be done).
How has NEPA been addressed? Where and how do we bring this out in the
document (Proposed Plan)?
Vicky does not believe the last bullet on page 12 of the Proposed Plan fact sheet is
correct. (Her point is that we cannot pre-suppose that on-property disposal will be
the result; it must be evaluated with Operable Units 3 and 5.)
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mentor C
Bogar: (Formal oral, March 21, 1994)
unit, then.
UNIDENTIFIED SPEAKER: Okay. I'll
discuss It with you.
UNIDENTIFIED SPEAKER: I'm Lou
Bogart. I'm a resident of Ross. I have some
technical questions. In looking at data tables for
Operable Unit 4, one of the things that strikes me
is that you always report uranium 254/236. Does
that mean there's U-236 there? If so, I don't
believe it because U-236 doesn't exist in nature.
Secondly, the ratio of U-234 to U-238
in many cases look very odd, odd in the sense that
in nature and in this ore and in the raffinate the
234, 238 ratio ought to be very close to unit. For
example, when in the table that you've given a
handout, the Silo 1 number looks pretty wrong. The
Silo 2 number is more acceptable.
And the reason I think that's
important is because you're going to focus the
clean-up levels on U-238. I don't quite know how
you're going to do that without doing some very
sophisticated isotopic analysis. But in any case
those numbers don't look right, and you see that in
¦any, many tables.
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Commentor C (Cont.)
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5 1
On the inorganic chemicals, is there
somewhere in all the OU4 documentation a list of
all of the inorganic constituents? For example, I
note that in most of the recent documents you don't
list gold. Now you can. There is about, about
four times as much gold in this material as
silver.
Just as a side light for my own
amusement, I calculated this afternoon. There's
about $2.3 million worth of gold in those two
silos, and that may not be important, but what
other elements are not reported which may have some
impact on the processing of the material by
vi tri f ication?
For example, there should be a fair
burden of rare earths, the whole lamprophyllite
series should be in these ores, and 2 don't see any
of that being reported. Anybody have an answer for
that one?
NR. NIXON: Hell, you had about five
questions, so I'll start in the beginning. One was
23S to 236, those are analyzed and reported the
same. You are correct. He don't feel there is any
uranium-236 in the residues. It'i A good point.
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Commentor C (Cont.)
1 Whether the ratio between U-234 and U-238 la
2 correct, I do not have the answer to that, but we
3 can diicun that and get back with you within the
4 next couple of daya.
5 MR. BOGART: How about a complete
6 list of
7 MR. NIXON: Complete list, the
8 remedial investigation did do a complete list of
9 the organics, inorganics. Whether gold was
10 evaluated, I'm not sure. I'm looking at my team.
11 MR. BOGART: You were supplied gold
12 by TLCP.
13 MR. NZXON: But we also do a full
14 HSL, Hazardous Substance List, which gold would not
15 be part of. So I'm not sure whether gold was
16 particularly reported in the Rl.
17 MR. BOGART: How about rare earths?
18 NR. NIXON: I couldn't answer that,
19 either. We've got a copy of the remedial
20 investigation here. Whether these fellows can
21 quickly find answers to those questions or again we
22 can get back with you.
23 Amy Engler I know is sitting out here
24 somewhere taking very good notes, and wa'll ftipond
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I 53
to any of the questions which we don't have answers
to tonight. We've coamitted to have answers back
within 48 hours f roa this evening.
MR. BOGART: Well, I -- not *o auch
for ayself, but I think for the general public.
MR. NIXON: Any question that is
raised even in the informal conference will be
addreaeed in the reaponsiveneti.
UNIDENTIFIED SPEAKER: Can we use
that fold aa collateral, can we use that? You said
there's like S2 Billion worth of gold. Can we use
that as collateral soaehow?
MR. SOSAXT: It's going to cost 90
Billion bucks, aaybe we can aake it 88 aillion
bucks. On page 21 or whatever this thing is
called, the proposed plan, the spiral-bound thing,
on page 12 about the aiddle of the page is an
initiation of a discussion about risk.
And this is the area that concerns me
the greatest, because although you point out
that -- And Z presuae in all cases you're talking
about fatal cancers because there are, of course,
nonittkl cmctrs alio. And that's not terribly
clear in anything that's written.
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FEMP-OU4ROD-8 FINAL
December 1994
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: s ¦»
Risk from exposure, the radiation
naturally occurring in the environment is about 1
in 100 primarily from radon; however, incremental
risks targeted by the upper end of EPA range means
if all persons within a population of 10,000, 1
person might get cancer from the exposure, and
cancer is expected from all other causes. I think
the whole business of risk assessment needs to be
put into some kind of context.
If you look at the latest NCRP
guidance, 115 and I guess 116, you can talk about
risk in terms of about 4 or 5 times 10 to the minus-
10 and you do the hocus-pocus chemists like to do.
And that turns out the average resident from
natural radon, that risk becomes about one half
times 10 to the minus 2 and the range is 0 to 90
years old. And when 90 years old, Z guess cancer
is the last thing I'm going to worry about.
But in any event, you make the
statement that the normal cancer risk is about 10
to the minus 2, and then you proceed to march down
the road of things that are 2 to 4 to 5 orders of
magnitude smaller, and it's never put in context.
And I think these documents need to dlaeufll vhifc
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Commentor C (Cont.)
1 are we paying for, and that becomes a real
2 problem. I don't know how many people feel
3 comfortable with a 10 to the minus 6 risk, and I'm
4 not real sure that that's a fatal cancer risk.
5 There is a problem with the
6 methodology of using the health effect summary
1 table slope factor thing as opposed to methodology
8 that's used by people who do the beer studies and
9 the NCRP studies because we're talking about vast
10 orders of magnitude differences.
11 Now, the last comment I gueas, I'd
12 like to see something in these documents that more
13 clearly explains why the CERCLA process has elected
14 to use such abominably small risk estimates.
15 My last comment perhaps goes to EPA
16 back in 1986, was a bad year for me, EPA published
17 a notice of intent that they were going to
1 a promulgate residual regulation standards. Zt is
19 now 1994, and, to the best of my knowledge,
20 residual radiation level standards have not been
21 promulgated.
22 In 1993 in a GAO report to Congress
23 somebody in EPA said that in March of 1994 they
24 war* going to finally publllh riiidllll ridlltlOH
SPANGLER REPORTING SERVICES
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December 1994
Commentor C (Cont.)
5 6
1 | standards, not publish them, but they would take
2 than to ONB, which would be the fist step In
3 getting them published -- well, not the first step,
4 but a key step in getting then published in the
5 Federal Register.
6 March 1994 is now. My concern Is, is
7 there one part of EPA working on residual radiation
8 level standards which say very well iapect on the
9 clean-up levels that are being talked about here
10 for the clean-up of OU4?
11 MR. NIXON: Has there any response?
12 MR. SARCA: Yeah, I can answer that
13 froa ay understanding. One of the people involved
14 froa the EPA perspective that works with ae, he's
15 been coaaenting that he's Involved in working on
16 soae of those standards. Hill they directly iapact
17 this investigation, I don't know. Z don't think
IB so. Hearing aoa* of the nuabers, Z think they aay
19 even be aoving towards the sid« of being equally as
20 conservative, could be sore conservative.
21 I don't know what the final will come
22 out with. when they do coae out of the nuabers,
23 they'll go to budget and aove forward froa there.
24 I do know fchafc they ar* bting worktd OH. Ofll fil
SPANGLER REPORTING SERVICES
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57
the people froa ay office is doing that right now.
I don't know the exact state.
UNIDENTIFIED SPEAKER: If aeaory
¦ervei, I think that the gold Lou waa talking about
waa contained In the pitch blend or whatever it waa
that caai over froa Africa that the United States
bought and duaped Into the K-65 silos. I heard or
read that aoaewhere. You Bight want to check that
out.
MR. NIXON: It is in the K-65
material, yea.
MR. BOGART: It all caaa froa one
aine.
UNIDENTIFIED SPEAKER: The reason
they took that pitch was they wanted to strike
gold?
MR. BOGART: No, radiua and gold.
UNIDENTIFIED SPEAKER: As far as I'a
concerned, it can be vitrified.
MR. BOGART: The question was, what
else is there?
UNIDENTIFIED SPEAKER: Okay. I just
have another question. When you said they were
filling the silos, especially 1 and 2, did fctlly
SPANGLER REPORTING SERVICES
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Commentor D
Edwa Vocum: (Formal oral, March 21. 1994)
FEMP-OU4ROD-8 FINAL
December 1994
concentrate* due that reduction, is the radon
generation fro* the treated waste itself that is
significantly reduce. The radon is actually held
up, and the surface area is significantly reduced.
Did you get every other word?
You're exactly right, that due to
that fact that there's a significant voluae
reduction, you actually concentrate the
radionuclides, so you have a higher concentration
of say uraniua in a set voluae, but the radon
itself is auch less. The generation or the
eaanation froa the vitrified waste is auch less
than in its natural fora.
MS. NUNGESTER: Okay, thank you.
MS. YOCUM: Edwa Yocua, Fresh aeaber
and a resident of the Fernald area. Z was asking a
question, this concerns Subunit C2 on your
preferred alternative deaolition reaoval on
property disposal. Whan you were talking about the
OU4 nepa coapliance with the substantive cuaulative
impact up to 250 acres of surface disturbance, does
that aean that would be what would be part of where
the waste will be put7
MR. HOODS: Yeah. Agtin, Ml loOiild
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FEMP-OU4ROD-8 FINAL
December 1994
3e
at an LRA and assumed on-site disposal.
MS. YOCUM: Okay.
MR. WOODS: And that acreage would
incur areas where waate would be disposed of.
MS. YOCUM: Okay. Then, you also
are talking about the loss of 220 acres of
habitat. Is that included in the 250 acres?
MR. WOODS: Yeah. That 250 would be
a total that would occur during the short term, in
other words, during excavation activities. Once
remediation is completed, we would look at
approximately 220 acres being permanently
committed, so yes, that's correct.
MS. YOCUM: Okay, all right, that's
what I wanted to know.
MS. NUNGESTER: Can you expand on
that permanently committed? I missed something.
Permanently committed for what, waste disposal
facility?
MR. WOODS: Yeah, correct.
MS. NUNGESTER: Not for the waste
itself but for the —
NR. WOODS: Tor the facilities that
would house the waste.
SPANGLER REPORTING SERVICES
PHONE (513) 381-3330 TAX (513) 381-3342
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D (Cont.)
i 6 3
Thank you.
NR. STEGNER: Thank you, Nona.
Edwa?
MS. YOCUM: Edwa Yocua. Sob* of
this will sound rapatitious, but I'a aaklng for a
public coaaant pariod batwaan tha ROD'S, tha draft
and final; and wa naad an official public coaaant
pariod aftar tha RA procan. And alao I'a asking
for a public coaaant pariod batwaan tha baginning
and coaplation of raaadiation. And than, too, whan
diaaantling tha K-65 alios and also tha 3 and 4,
I'd lika to hava a protaetiva covar ba usad around
tha silos.
And as far as I raad in thara, that
EPA would ba raviawing tha vault or tha disposal
sitas avary fiva yaars, I'd lika to know tha
dafinition of "raviawing," and I would lika
continuous aonitoring and aaintananca of on-sita
disposal vaults or at laast ona tiaa a yaar as long
as thay'ra on sita. And also, who would ba paying
for this aonitoring and aaintananca? And this way
I racoaaand a trust fund for aonitoring and
aaintananca of tha disposals.
MR. STfOMfR< Thank you, Id*a. Opill
SPANGLER REPORTING SERVICES
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FEMP-OU4ROD-S FINAL
December 1994
IOI MtUd STW! OF NEVADA JOHN p COMSAUX
Omnm— Dimf*
Commentor E
DEPARTMENT OF ADMINISTRATION
Capital Cample*
Ciimr City. S9710
Na (702) M7-3MJ
(70S) M7-40M
April 18, 1994
Mr. Kan Morgan
Public Information Director
ATTN: Fi/PP-DEIS coaaants
Farnald riald offica
U.S. Departaent of Energy
Post OffiCS Box 391703
Cincinnati, Ohio 43239-8709
nil faraald Bnvironaental Xapaot Stataaent, Oparabla Onit 4
Paraald, Ohio
Daar Mr. Morgan:
Thank you for providing tha State of Nevada the opportunity
to review tha Departaent of Energy'a Feasibility Study/Propoaad
Plan Draft Environaairtal Impact Stataaant (EI8) for Ramadial
Aotlon at Oparabla Unit (OU) 4 of tha Farnald Environmental
Management Project (PIMP). As you know, tha draft SIS assesses
tha potantlal anvironaantal iapaota of reaoving and treating ailo
materials and surrounding anvironaantal madia at DOE*a rarnald
plant in Ohio and ssnding these treatad natarials to tha Navada
Taat Sit»*(NTS) for final disposal, following ara tha atata'a
conaentaon thia propeaal.
as va understand tha propoaad action, DOE ia taking tha
poaition that tha thorium Bill tailing waata, which is adaittad
to ba nixed waata, ia not eubjeot to Environnantal Pretaction
Aganoy (EPA) or stata'of Navada ragulatory control. For tha
raasone specified below, wa baliava this poaition ia not correct.
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December 1994
Commentor E
In 1987 DOE promulgated regulation* (10 CFR 962.1)
stating that RCRA hatardous vast*, mixed with byproduct
material falling under the category defined in the Atomic
Energy Act (42 USC 2014(e)(1), would be subject to
regulation (i.e. the haaerdous components of tha nixed
waste) by EPA and EPA-delegated Statae. However, the
byproduct material falling under the category given in 4 2
use 2014(e)(2) that warn mixed with RCRA hacardoue waste,
while oonstltuting a mixed waste, would not be subject to
reguletion* by EPA and or EPA-delegated States. We note
promulgation of these regulations and associated
restrictions were carried out prior to the passage of the
Federal Facility compliance Act of 1992 (PPCAct).
As you know, under the PPCAct, Congreee defined mixed
vasts to maan "waste that contains both hazardous waste snd
source, special nuclear, or by-product material subjeot to
tha Atomic Energy Act of 1954." This definition shows no
distinction between the two categories of byproduct material
mentioned above. Hence, the attempted exemption from
haiardoua waste regulations of the haiardous components of
mixad wasts containing byproduct material from EPA\State
regulatory control, has baen Invalidated.
• We also note that EPA has delegated to the states
regulatory control over all mixed wastes without regard to
specific radionuclide content, which is consistent with the
expression of Congressional intent in defining mixed wasts
under the FPCAct (See 61 FR, July 3, 1916, 24904-24509).
Based on thess points, it is the State of Nevada's position
that the regulatory issuss described in tha above mentioned Draft
EXS have not baan adequately addressed.
wa also note that the cost estimatee of long-term
storage/disposal of mixed waste at the KTS were not properly
accountad for in tha Draft BIS. The assumptions, for example,
under which storage/disposal of mixed waste at tha NTS could be
considered "free" whan oomparad to a commercial facility, were
not presented in the document.
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FEMP-OU4ROD-8 FINAL
December 1994
Commentor E
In a related matter, we are still waiting for a response
concerning our request for an extension of the comment period for
the subject Draft CIS. As you may recall, we recently requested
the extension to facilitate stakeholder involvement activities in
southern Nevada.
Thank you for the opportunity to connent on th« above
mentioned Draft BIS.
MN/jbV
cc: Governors office
Affected State Agencies
Nevada Congressional Delegation
Carol M. Borgstrom DOEHQ\NEPA
Joseph Flore, DOB/fJV
Donald R. Ella, DOE/HV
Sincerely,
Maud Naroll
State Clearinghouse
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FEMP-OU4ROD-8 FINAL
December 1994
Commentor F
COMMENT SHEET
DOE is interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan-Draft Environment Impact Statement tor Remedial Action at Operable Unit 4 Please use the space provided
nelow to write your comments, then told, staple or tape, and mail this form We must receive your comments on
or Detore the close or the public comment period on April 20. 1994 If you have questions about the comment
! period, piease contact Ken Morgan, the DOE Public Information Officer at Fernald. at (513) 648-3131
Due to its proximity to the Great Miami River, this land is part of the
migratory flyway. Ducks, geese and other migratory birds fly over
this area or use it as their residence many months of the year.
Presently, technology exists in landfill management using rubber ( neoprene)
liners to minimize water seepage. This technology could be incorporated into the
Femald area to create ponds and wetlands. Controlled water levels in ponds,
reservoirs and wetlands could be regulated by the pumps and wells that are now
in place and being used in the aquifer clean-up.
Hazardous waste should be taken out by rail since the tracks are in place.
Handling this waste by transporting it by truck is much more dangerous.
I would discourage industrial development or development that would attract
large concentrations of humans in case problems would happen to develop in the
future. We cannot afford to have another Love Canal. Our area has had its fair
share of negative press and peace of mind and good health is our wish for all.
Name. <3 fiC £ A. .to (-0CX r ^ ^ ^ P"
Address. 4-44 \ CO. ^5- .Rc).
City/Staie/Zip:
Phone
3S-
MAILING LIST ADDITIONS:
Please add my name to the Fernald Mailing List to receive additional information on the cleanup progress at the
Fernald Environmental Management Project: ,
YE9>C NO
« _ _ — — — — _ — — _
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Commentor G
FEMP-OU4ROD-8 FINAL
December 1994
COMMENT SHEET
DOE :s interested in your comments on the cleanup alternatives being considered in the Feasibility Study/Proposed
Plan-Drart Environmental Impact Statement tor Remedial Action at Operable Unit 4. Please use the space provided
heiou to wrue \our comments. :nen fold, staple or tape, and mail this form. We must receive vour comments on
or setore the ciose or the public comment period on Aprii ^0. 1494 If you have questions about the comment
period, please contact Ken Morgan, the DOE Public Information Officer at Fernaid. ai (5 I V) 648-3131
V j.VY\ a. CLrrrryiQ'-X^l "tj/yg,
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Phone:
(
5 - / c? $1.
MAILING UST ADDITIONS:
Please add my name to the Fernaid Mailing List to receive additional information on the cleanup progress at the
Fernaid Environmental Management Project:
YES NO
C-I-35
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FEMP-OU4ROD-8 FINAL
December 1994
Commentor H
March 25, 1994
3686 Cincinnati-Brookville Road
Hamilton, Ohio 45013
Mr. Ken Morgan
Director, Public Information
U.S. Department of Energy Field Office
P. O. Box 398705
Cincinnati. Ohio 45239-8705
SUBJECT: PUBLIC COMMENTS ON PROPOSED PLAN FOR REMEDIAL ACTION
OPERABLE UNIT 4 FEMP SILOS 1. 2 AND 3 CONCERNING PREVENTION
OF OFTSITE MIGRATION OF AIR POLLUTION AND NOISE
Dear Mr. Morgan:
In order to prevent offsite contamination with respirable airborne cancer producing toxic
gases, vapors, fumes and particulate matter from Remedial Actions at Operable Unit 4. it is
suggested that at a sijnjeiuja the following recommendations be adhered to regardless of
which cleanup alternative ia selected:
1. Construction of a fail safe containment facility maintained at negative
air pressure (similar to a glove box) to house all vitrification, bulk
reduction and/or cement stabilization equipment and associated HEPA
filters, scrubbers, and gas treatment, etc. as well as all par-lca^in^
operations.
2. Use of real time alarm system with backup must be used to detect failure of
equipment including each and every filter and scrubber unit. Air returned
to the environment must be cleaned.
3. Use of real time alarm system with backup to detect any toxic chemical
contaminated air leaking into the total containment facility from
malfunctioning equipment and packaging operations. Contaminated air
must be cleaned before being released into the environment. Dilution of
highly toxic chemicals into the environment can not be tolerated as a
solution.
4. All alarm systems must be checked and calibrated daily and back up
alarm systems in place and operative at all times. Preventive
maintenance of all equipment must be done at required scheduled intervals
and checked by management.
5. To properly oversee the vitrification, bulk reduction, cement
stabilization and packaging remediation operations, a member of
management from Fluor Daniel, D.O.E. and US EPA must all be present
at all to quickly resolve any problems that are certain to come up,
and to make certain that established safety procedures are followed to the
letter.
6. Should contaminated air be detected entering the environment from
whatever source, a complete shut down of the offending operation would be
in order until corrected and Fernald neighbors be immediately notified
through site perimeter public address speakers and news media,
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FEMP-OU4ROD-8 FINAL
December 1994
Commentor H
-2-
7. Toxic chemicals or mixed toxic waste by any other name must not be
brought into the Femald Site to further contaminate it from anywhere
else for any purpose whatsoever be it for testing, pilot runs, temporary
or permanent storage, decontamination vitrification, bulk reduction or
cement stabilization, etc.
8. State-of-the-art engineering noise controls should be incorporated in
the design of facilities and equipment used so that no noise from
remedial actions is heard downwind offsite. Noise resulting from the
release of high pressure air or steam into the atmosphere must be
attenuated through appropriate engineering controls.
9. Shipment of toxic wastes should be made to Nevada Test Site as soon
as possible. Temporary storage of safely encapsulated toxic waste,
contaminated soil and debris should be south of the production area
as far from the heavily traveled Route 126 (Cincinnati-Brookville Road)
as is feasible.
Please include the above as part of the formal Public Comment for Remediation of Operable Unit
4 FEMP Silos 1, 2 and 3.
Thank you for your help.
Sincerely,
J. E. Walther
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FEMP-OU4ROD-8 FINAL
December 1994
Ohio Historic P'e9ervation Office
Ohio r«isioncai Canier
1982 Veima AvenuB
Coiumous Chio aJ2"*-2-j97 Commentor I
514/297-2470
can: 297-2548
OHIO
HISTORICAL
SOCIETY
March 24, 1994 SiN'CE 1B8S
Mr. K.en Morgan
Public Information Director
ATTN: FS/PP-DEIS Comments
Femaid Field Office
U.S. Department or" Energy
Post Office Box 398705
Cincinnati. OH -5239-8705
Re. Femaid Environmental Management Plan
Butler and Hamiiton Counties. Ohio
Dear Mr. Morgan.
This is in response to correspondence from Carol M. Borgstrom of the Department of Energy
dated February 24. 1994 (received March I) regarding the above referenced project (a copy of
ihe correspondence was also submitted through the State Clearinghouse and received March 7.
1994). The comments of the Ohio Historic Preservation Office sOHPO) are submitted in
accordance with provisions of the National Historic Preservation Act of 1966. as amended (16
U.S.C. 470 [36 CFR 800]); the U.S. Department of Energy serves as the lead federal agency.
V.W staff has reviewed this project, and I offer the following comments.
OHPO has two areas of concern for the proposed clean-up at the Femaid facility. This
particular pari of the clean-up involves proposed demolition of storage siios in Operable Unit
- Additional actions are under considerauon for several other operable units in the waste
storage area. The first area of concern is the potential for impacts to archaeological sites.
The Fernald facility is located in an archaeologically sensitive area and several archaeological
studies have been completed for other actions related to the ciean-up in ana around the
Femaid facility. Until a programmatic agreement has been developed, each project will
require coordination with this office for archaeological resources. Coordination is anticipated
regarding the proposed demolition of the silos providing us sufficient information to make a
recommendation for archaeological investigations. At this time we have not determined that
any archaeological work is needed for any of the proposed or future actions in the waste
storage area. The coordination should provide detailed mapping, descriptions of the soils (to
-etermine if any areas within the project area are relatively undisturbed), descriptions of the
proposed actions including ancillary work areas and any temporary storage areas, and
pnotographs of the facilities.
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FEMP-OU4ROD-8 FINAL
December 1994
Mi. K.en Morgan
Marcn 24. 1994
Pace 2
Commenlor I
The second area of concern relates to the Fernaid facility as an integrated sencs of
urchitecmral structures and facilities. It is our position, under guidelines provided by the
Advisory Council on Historic Preservation, the National Council of State Historic Preservauon
Officers, and the Department of Defense, that the Fernaid Facility is eligible tor inclusion m
:he National Register of Historic Places. !t is our position that the facility includes all of the
structures and facilities within the 1000 plus acre tract. The Femald facility is eligible
because of the important role it played in support of United States defense programs during
the Cold War. thus, the facility is a significant part of one of the most important aspects of
our history.
The proposed demolition of the silos, or any other structure or facility, could have an adverse
effect on the Fernaid facility. Coordination with this office is required prior to the
implementation of any plan or acuon resulting in demolition or changes to any structure or
facility. OHPO recommends the development of a programmauc agreement to address
historic preservauon concerns. Once we nave established the context for the Fernaid facility
and the limits of the contributing structures and facilities, then specific recommendations can
be made regarding proposed actions such as the proposed demolition of the silos. In the
interim, it is our recommendation that the silos should be regarded as contributing structures
ana we should proceed under the assumption that the proposed demolition will have an
adverse effect on a district eligible for inclusion in the National Register of Historic Places.
Coordination with this office is recommended to begin preparing the necessary documentation
for this action.
In summary. OHPO recommends changes to the Draft Environmental Impact Statement to
include coordination with this office under provisions or the National Historic Preservation
Act.
Any questions concerning this matter should be addressed to David Snyder or Julie Quxnlan at
(6141 297-2470. between the hours of 8 am. to 5 pm. Thank you for your cooperation.
Sincerely.
Martha J. Raymond/ Department Head
Technical and Review Services
MJR/DMS:ds
xc: Carol M. Borgstrom. Department of Energy
State Clearinghouse (OH940225-X763-36.471)
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December 1994
Cnmmenlor J
April 17, 1394
TO: Ken Morgan, Public Relations, U.S. DOE, FEMP
fftOM: Lisa Crawford. President. F.R.E.S.H., INC.
SUBJECT: O.U. 4 Comments on Proposed Plan
Listed below are my comments on the O.U. 4 Proposed Flan:
1.) DOE should Include ana or develop real-time monitoring fcr
discharges to tha environment resulting from remedial Actions.
Z.) Information obtained from real-time monitoring and any other
monitoring activities should be provided to the public.
3.) DOE should incorporate pollution prevention activities
whenever possible during the design and operation of thu QU 4
remedial action system.
4.) DOE mutt make certain that the public has involvement and it
will continue during the RD/RA. DOE must commit to continued
puJblic involvement during thia period.
®.) DOE must revise the site community relations plan Co meet the
need for continued public Involvement during the RD/RA.
6.) DOE must and will keep the public abreast of ail decisions and
any changes that occur during this period.
If you have queetiona, please feel free to contact me. Thank you.
LC:eac
cc: files
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FEMP-OU4ROD-8 FINAL
December 1994
Commentor K
3944 Si lax Dr.
Hani 1 ton. CH 45013
April 20. 1994
Mr. K. L. Morgan
Public Information Officer
DOE Field Offlce.Kernald
U. S. Department of Energy
P. 0. Box 388705
Cincinnati. Ohio 45239-0705
After reviewing the Proposed Plan for Remedial Aotions at Operable Lnit
4 at Fernaid. I would like voice to you some, of my concerns as a
resident who Uvea downwind of thr. proposed activity.
I would like to know if there have been any air pollution models run
which show the distribution of the contamination that will be caused as
a result of these activities. Not screening types models, but
specifically, comprehensive models which take into consideration
terrain, wind speed, weather conditions, mixing height and the
deposition patterns.
My major concern is the emission of radium (not radon) in the cxhnust.
gases and fugitive gases from the proposed vitrification facility.
One of the important considerations for risk based calculations is that
E)da Elementary School, the Hoss Middle School, and the Rosa Senior High
School are all in the direction of the prevailing wind pattern.
I would like to recommend that comprehensive air pollution modeling be
done on the facility's Impact to the area's air quality. I would like
to see the vitrifloation unit's risk from fugitive and exhaust emissions
quantified. I would like to see tiow the vitrification unit will impact
the site's overall risk to thfi community. Lastly. I would like to see
the impact that this will have on the site's radionuclide air emissions
specifically with respect to radium emissions into the air.
I make these comments in good faith, and trust they will be received as
a good faith effort to improve the implementation of the proposed
C-I-41
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Commentor K
FEMP-OU4ROD-8 FINAL
December 1994
action, ana tMat no effort will ho made by any party ;o affect my
employment at t.ha rEMP.
Respectfully yours.
Lawrence L. Stebbins
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December 1994
IOB "iliCA STATE OF ,NEVADA
G«< ttnmr
Commentor L
DEPARTMENT OF ADMINISTRATION
Capitol Camples
Canon Clry, Nevada 89710
Fax (702) 607-3983
(702) 687-4065
April 5, 1994
Mr. Kan Morgan
Public Information Director
ATTN: FS/PP-DEIS Comments
Fernald Field Office
U.S. Department of Energy
P.O. Box 398705
Cincinnati, Ohio 45239-8705
RE: Fernald Environmental impact Statement, Operable Unit 4
fernald , Ohio
Dear Mr. Morgan:
Thank you for providing the State of Nevada the opportunity
to review the Department of Energy's Feasibility Study/Proposed
Plan Draft Environmental Impact Statement (EIS) for Remedial
Action at Operable Unit (0U) 4 of the Fernald Environmental
Management Project (FEMP). As you know, this "Draft EIS"
assesses alternatives for the removal, treatment, and disposal of
radioactive material at DOE's Fernald site near Cincinnati, Ohio.
The proposed action analyzed in the Draft EIS is to assess
the potential environmental impacts of DOE's preferred
alternative, which is to remove silo materials and surrounding
environmental media, stabilize the product through vitrification,
and send the treated material to the Nevada Test Site (NTS) for
final disposal. According to information provided to officials
from DOE's Nevada Operations Office (DOE/NV), if the proposed
action is implemented, over 300,000 cubic yards of radioactive
waste would be disposed of at NTS. Disposal activities would
cover a period of approximately thirty years.
C-I-43
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FEMP-OU4ROD-8 FINAL
December 1994
Commentor L
As you know, comments on the Draft EIS are due on April 20,
1994. However, for the reason discussed below, we believe the
comment due date should be extended to facilitate a mare
comprehensive stakeholder involvement process for the citizens of
Nevada•
Recently/ a group of concerned Nevadans, affected Indian
Tribes, and local government officials along with officials from
the State and DOE jointly participated in the establishment of a
Site Specific Advisory Board for DOE/NV's Environmental
Restoration and Waste Management Program at the NTS. The group
is officially titled The Citizens Advisory Board for NTS Programs
(CAB) . This new CAB for NTS programs held its first
organizational meeting on March 8th, 1994.
Because the CAB will likely play a key role in advising
DOE/NV about stakeholder concerns involving major program
decisions such as those proposed in the above mentioned document,
we believe it is of paramount importance that the CAB be given
the opportunity to discuss the possibility of requesting a
briefing on the proposed action and alternatives discussed in the
Draft EIS.
You night recall that such a briefing was provided by DOE
officials and contractors from FEMP to officials fron DOE/NV and
the State of Nevada. Granting our request for an extended
comments period of at least 60 days would allow the cab to
address this issue at its next meeting, which is scheduled for
April 20, 1994.
We await your prompt decision concerning this request.
MN/jbw
cc: Members, Citizens Advisory Board NTS Programs
Governors Office and Affected State Agencies
Nevada Congressional Delegation
Carol M. Borgstrom DOEHQ\NEPA
Nick C. Aquilina, DOE/NV
Joseph Flore, DOE/NV
Donald R. Elle, DOE/NV
Sincerely,
Maud Naroll
State Clearinghouse
C-I-44
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor M
o
LIS Ofxrtmtn
al baniocf tenors
AdmWtfreflen
APR 2 I 1994
Nr. Ken Morgan
Public Information Director
ATTN: F*/PP-D*IS Couwntl
Farnald Fitld Offioe
U.a. Department of Snargy
P.O. BOX 391705
Cincinnati, OH 45230-070®
Dear Nr. Morgani
This latter is In reeponae to the February 34, 1994 letter fro*
Na. Carol N. Borgstroa, Direotor, Offioa of NBPA Overaight,
Department of aneroy to Ne. Kathlean C. DaMetar, Aaeiatant
Chief Council, National Highway Traffic saraty AAainiatration,
Dapartaent of Transportation (DOT). Ma. DaMatar forwarded that
lattar to tha Raaaaroh and Spaoial program* Adainlatratlon
(RJBPA), tha Fadaral aaenoy primarily raaponalbla for hasardoue
matarlals tranaportation regulations. That lattar solicited
review and oonaents on tha Feasibility Study (P0), tha Propoaad
Plan (PP), and tha Draft Invlronmentsl Impact Statement (DBXfl)
dooumente for mediation or Operable Unit 4 of tha Farnald
Invironmantal Managemant Project (TKMP) . Our review ha a
foouaad on elamenta aaaoolated with tha tranaportation of
radloaotlva materials resulting from tha remediation
actlvitiaa.
Tha reviewed dooumanta ara olaarly of • gentral natura at this
aarly phaae of tha program, and do not raflaot all dataila suoh
aa radiosssay methods, matarlals olaseif 1 oat ion, and packaging
raquired for oomplianoa with tha tranaportation regulation* •
Thara war* no atatementa about any a* pact ad naad for exemptions
from tha requirementa of DOT regulationa which ara authorised
under Titla 49, Coda gf Federal Ragulationa (CFR), Part 107i
rathar, it ia atatad tKwt all enipmenta will ba mad* in full
oonplianca with DOT ragulationa.
In the davalopaant of future documentation for tha FCNP, it ia
auggastad that tachnloal attention ba given to two nlnor
oonoarna we aaw in the FB/DII8. First, In Volume Ona, aaction
2.5.7.1, Paga 2-70, it waa stated that all materlala
tranaportad would Meet tha definition of Low apeolrlo Activity
(LfiA) radloaotlva Materlala aa defined In 49 OF* 17). 403 (n).
We bellave tha axpeetid physical for* of tha material
tranaportad will result in tha radiological risk to the public
C-l-45
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor M
being egual to or leas than aaet Lf A ahlpaente transported In
the Country. However, froe Voluse Two, Appendix A, Table A.l-
l, it appears that tha aotlvity par graa of material far ae»e
of tha paekage oontante eight exceed tha limit* for LBk
¦*terlale in 48 Cf» I7j.40i(n). tha aeoond concern la eoaevhat
related to th« aotlvity par graa laaua. m voiuae One, flaotion
4.3.3, Pege 4-1S, it la noted that "eaapllng of tha vitrlfiad
vaata for* would ba Halted to aeaeuraaent of floaa rata".
After Mtarlal vitrification, tha external radiation dose rata*
vili elaarly ba tha indioatlone of tha aoat eignlfleant
radiologleal haiarde of tha eat*rials during transportation.
However, einos tha identity of tha radionuolIdea and tha
activity of tha sontant in each peokege la required toy tha
regulatlona, doouaentation with technical reeeonlng will ba
naadad to ralata tha raaulta of pra-vitrlfloatlon radioaesaya
to tha contanta of tha paokagee.
Proa our Halted review of the early phaee planning docuaantt,
it appeared that there waa not auoh indorsation about non-
radioactive hazardous materials tranaportatlon ooapllanoe
laauee, or about hacardoua waetee aubjeot to both Dot and
Bnvlronaental Protaotlon Agency reguletiona. Compliance with
thoae reguietione aheuld net be dlffioultr the radiological
haaarda appear to ba of greatest concern.
Sxoept ror the two alnor oonoerna aentloned above, the reviewed
documenta appear to be eatiafactory with respect te hacardoua
¦aterlale tranaportatlon.
sinoeybly,
rJ'iMb K. O'iteen, Direotor
Office of Keiardoue Materiale
Technology
cwi Carol N» Borgatroe
C-I-46
-------
, v, FEMP-OU4ROD-8 FINAL
Commenlor N December 1994
May 17, 1994
Mr Ken Morgan
Director, Public Information
U.S. Department of Energy, Fernald Field Office
P.O. Box 39705
Cincinnati, Ohio 45239-8705
SUBJECT; DOCUMENTS COMPRISING THE FINAL FEASIBILITY
STUDY/PROPOSED PLAN . ENVIRONMENTAL IMPACT
STATEMENT FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4,
THE FERNALD ENVIRONMENTAL PROJECT (DOE/ElS-0195d)
Dear Mr. Morgan:
The Nevada Test Site (NTS) Citizens Advisory Board (CAB) had the opportunity to meet
with representatives of the Ftrntid Environmental Project at our May U, 1994 meeting.
The CAB is comprised of representatives from the public, citizens groups, Native
Americana, local governments and others. Fernald staff provided a useful brief describing
proposed shipments of radioactive material to the NTS. They and NTS Department of
Energy (DOE) personnel at the meeting noted, however, that the deadline for comments to
the EIS is May 20. 1994.
The May 11, 1994 meeting was the first time that the CAB had an opportunity to receive any
information about the proposed shipments. The CAB has still not reviewed the documents.
We would, therefore, have less than i week to review the EIS. The CAB is, therefore,
requesting an extension of time to review the documents and provide substantive input to the
process.
The shipments of radioactive waste from Fernald are tbe first of potentially many other
shipments to the NTS. It is important, therefore, for the CAB to review the Fernald EIS
proposal.
The CAB and citizens of Nevada taut that you will gram an extension of time for the review
of the EIS documents.
Sincerely,
7 . ,v
William L. Vasconi, Acting Chairmpn
Citizens Advisory Board
rn583.vis
cc: lames Sarit, Region V
Environmental Protection Agency
C-l-47
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor O
On June 24, 1994, the DOE received by facsimile transmission, the following four comments/issue
statements on the behalf of the Nevada Test Site Citizens Advisory Board (CAB), from an individual
who identified herself by telephone as Katherine Yuracko, a member of the CAB. As directed by
Katherine Yuracko during the telephone conversation, the facsimile was redacted by DOE to only
include verbatim the substantive comments/issue statements pertinent to the Operable Unit 4 FS/PP-
DEIS.
06-24- ;99«a id: 30 512 736 56S0 US DEPT o' ENERQV D.O 2
ee-24-19S4 11:23 702 2951113 OOC/ERO „ __
VU»hC»4 * iKTit *0* 44T P.'%T
brand lax inwumHim memo 7071 >
i
Kl'Xy (lif.ti'm.
c*
c«.
Offl.
¦*«»« -
"" -Jir-iM 3
1. Tlit shipment! of wane from FemuUi are the first of potentially many other shipment] to
the NTS. Rather than making decisions on a piecemeal basis, we wain to see the full
picture before we arc asked to make decisions on individual pieces. Thai is. we want to
first consider the tout I impact of all of the waste that it being considered for disposal at
the NTS. Following that, we want to consider each individual piece.
2. The documents reviewed do not discuss the full range of possible alternatives. F..g.:
• dispoial at Hanford
• reprocess to recover materials
• dispose of all material at the NTS
Why were these opdoni rejected? What is (he full list Of Options initially considered and
why was each option rejected?
3. We believe that:
• funds should be provided for technical oversight of waste management activities
< the Stale of Nevada and affected Counties are entitled to impact mitigation
pay menu as compensation for costs arising from management of this material
4. Based on the presence of RCRA regulated metals and organics in the waste, we are
concerned that the waste contains both hazardous and radioactive constituents.
a. Please list the radionuclide and inorganic and organic chemical constituents of the
waste.
b. Please identify the concentration of each consutuent.
c. Please identify I he risk resulting from each constituent,
d. Please describe how the proposed treatment and disposal mechanisms address
l>oih the radionuclide and chemical constituents of the waste.
C-I-48
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FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177)
Keep Feraald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
pn x accept additional risk on top of that already present at the
K > Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name A/1 /c*
eT. ts~/ / 1/ A/l/ ST/f^
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(2) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
NamcJZkiliLjlkM!
C-I-49
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
P(4)
, ^ PO P) n./ L) ?s
Address—
po £>M Alto* JL/ef i/tfjATiAJV #7'/7Z
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name ^ f /S y
AriHrwcc - S . 7'J> O
C-I-50
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name_
Ao )&i\i U iiJ KM
p(6)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
Address.
y/ 3.*/ Jjvik Jf.Las V
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,(XX) cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
p(T) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
moveFi
¦) U/MIjI ) //J
7 E:iJLrrusn*y)
Address <¦
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
OaihtrtnL V'HcLL.ctJ) I > n
^ n& 4^. W a- a//
C-I-52
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
Address, 3Zi2 feyyti/u.c i>rv LU Ail1 (0
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fern aid waste.
Name
C-I-53
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Pd 1) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste^
~
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
accept additional risk on top of that already present at the
P(13) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. .
Naine^
AAW ('7&o »v u ^rAtc^4^ Lai iMv tficrf
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
P(14)
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move FemaM waste.
Name Qj> ? r 'Lty , rU -2 .
C-I-55
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Neva dans should not be required to
P(15) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Femald waste.
Nam. TKar
^ /V- Fsc/LT-t/A (7c
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
a*h~./*72, H-\JD ^ M v
C-I-56
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
PM7) accept additional risk on top of that already present at the
1 ' Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Femald waste.
Nan»g \/i
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(18) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name. fVW-
/mn Ots^r-ft- ( vwjjPI//?
C-I-57
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
P(19) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name Q,\\.r^ ^
3 ^ \ rs f 0 N3 ^ ^£
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(20) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name / ^ -Sfrr) a {\J>
AMrt«s U S10 l\lo rr< \Ji Vfe< LL/
C-I-58
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(2i) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move F«
efxrald wa$te. f )
Name
OMn Uj ^/oz.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(22) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. ,
Lry//r irfu y
Name.
Address.
C'o~.Q*y S/3/Y,la £,C
C-I-59
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Pf23) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Femal&waste.
Nam*
Aririrftre / A"£Zf S7
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(24) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Ktelvr.Cgd-C!\g. I Fh
C-l-60
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(25) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
(/an spewa /Vtofow Pi \ .m. kw
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name_ —'Tlfcivf Z: ^ rruwn
Arirlrrec ! ^ T)r ¦ UV, NV 'T*? /C-&
C-I-61
-------
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea Che local populace. Nevadans should not be required to
accept additional risk on cop of chat already present at the
P(27) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Address,
l_V.' , .'ONJ-
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated4nd balanced against, the desires of Ohio to
movkFero»d waste./ )l^ • L „ /!***
C-I-62
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P,7I]. accept additional risk on top of that already present at the
{ Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name Dm ;&/ ct
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name /J/^LSh
aMt*** /nnn KZ/vt- A£Cf-)/>Av7. L,is. /Vis
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald. waste. / /J
Name
Address / 0 r
C-I-64
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(33) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name S ?)r<- inv3-
*/61 <02
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(34) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Ferftald waste. /
•" A -vV -
C-I-65
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup E1S.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Neva dans should not be required to
pn accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald- waste.
Name.
Address.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(36) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
C-I-66
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
accept additional risk on top of that already present at the
P(37) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Na
Nt/
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(38) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
Address.
3?f 7a. Mi/to*
C-I-67
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Com.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
pRoA accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. ^
Name ( S)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(40) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
\>rwhg//e- J-mn
?.7£ £ i~fr\ £ nor a; / Vr//
2 7/ C>
C-I-68
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (M77 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
P(4l) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name c
Arfrfr^c £ 7/0 :aJ j • LjJ. AJi/
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(42) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste, p
nW/;
^ 7/0 W'u/ k&r
C-I-69
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commmtor P (1-177 Cont.)
P(43)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balaxygfed against the desires of Ohio to
move Fermdd wa$te~
Name.
*-oxjcJ
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(44) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
AH^c 1 8 V S Lrt- C (S .J C 6jSl t- k
C-I-70
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Conl.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(45) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
F(46) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.//
Namcj|^^
/
C-I-71
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Mam* /o TS
AAtf»€« S9Yt> flsC- ^£3 /Asi/ft/is/iv
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(48) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. -p /" /
C-l-72
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald
Name
AiMn»g€
//JO** ^
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(50) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
AAhtsr Pc ¥l6>M7<7/ L_IS ^7!)^
C-I-73
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Nam* h'"* ^
AH,W <7 / (/ t\/L t ^
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
' accept additional risk on top of that already present at the
I Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. o
P(S1) ;
I
C-I-74
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
' tea the local populace. Neva dans should not be required to
P(53) j accept additional risk on top of that already present at the
, Nevada Test Site.
I
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Oh±o to
move Fernald waste.
Name O Is- ¦» £ 0 -v
AiMi»w /-a/. Q. V- aJV (^*3/
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(54) j tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste..
3^0 /W U Cfa Oft ^
C-I-75
-------
P (1-177 Com.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
accept additional risk on top of that already present at the
Nevada. Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. _ ,. ,
^Vic-tofiQ P,
Addies*
ill Chirntd- In.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name. GrriVUTLa ^ ^
Pv-^-Ar^
C-I-76
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
mnrinting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
! tect the local populace. Nevadans should not be required to
i accept additional risk on top of that already present at the
| Nevada Test Site.
I
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. .. r
\cooer^
' v_,OCV,Vv/V0-i
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Corn.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name C
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
P(60)
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move fernald waste..
J' /It3Sry"
^ / /org. C.g
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
C-I-78
-------
Commentor P (I-177 Cont.)
FEMP-OU4ROD-8 FINAL
December 1994
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
1 nuclides, should be kept on-site in containers adequate to pro-
1 tect the local populace. Nevada ns should not be required to
1 accept additional risk on top of that already present at the
; Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name •' f > > „
AHriw*. . u-./- 1 ^
Keep Fernald Waste On-site in Ohio-
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(62) tect toe local populace. Nevada ns should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name Phn*
Address 5213—rr.nlbn* £hnP ^- -*¦ /)
C-I-79
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
1 tect the local populace. Nevadans should not be required to
P(63) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald wasjtp. ^ t
Name ' 1' ¦ ' ^ ' 1 .
-A ¦ . I
Keep Fernald Waste On-site in Ohio-
Comments on the Fernald Cleanup EIS.
j ® The more than 300,000 cubic yards of radioactive waste
! consisting of uranium, thorium and radium among other radio-
i nuclides, should be kept on-site in containers adequate to pro-
I tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name CcAvvX
A Mr**
C-I-80
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
, consisting of uranium, thorium and radium among other radio-
1 nuclides, should be kept on-site in containers adequate to pro-
P(65) j tect the local populace. Nevadans should not be required to
i accept additional risk on top of that already present at the
1 Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move F&rnald waste..
Name
Aiiiw.. <0DC .Kj V
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
1 tect the local populace. Nevadans should not be required to
P(66) I accept additional risk on top of that already present at the
; Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
moveFejuald waste.
/ T^
a**-.*?-73 -P Fla/yn^-j HiOz
_____
C-I-81
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
P(67) accept additional risk on top of that already present at the
i Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
\licHnno u;w L-.U. lU>-
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
i nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(68) accept additional risk on top of that already present at the
I Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
t Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Ftiraald waste. r\
k,„./ UA-Or'C n I tJuj.o
—Ll/ AJl'V^/Oy
C-i-82
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-^
Comments on the Fernald L^
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(69) accept additional risk on top of that already present at the
; Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. - j j /
Name.
,3/AC £ eocAtUt -# 7/ /l/ AU 29/rf
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radlo-
, nuclides, should be kept on-site in containers adequate to pro-
' tect the local populace. Nevadans should not be required to
P(70) I accept additional risk on top of that already present at the
i Nevada Test Site.
i
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste, , /
Mn.r/DeJ
am*** SS^? ' j V
7 7 ?
C-I-83
-------
FEMP OU4ROD 8 FINAL
December 1994
Commcntor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
, consisting of uranium, thorium and radium among other radlo-
1 nuclides, should be kept on-site in containers adequate to pro-
pyl) i tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. >.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
1 accept additional risk on top of that already present at the
P(72) | Nevada Test Site.
I
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. , / a
Mam* —
Address Qmrrlmdz tv/to/
C-I-84
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
i nuclides, should be kept on-site in containers adequate to pro-
1 tect the local populace. Nevadans should not be required to
P(73) ; accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move FernalcLy/aste.
Name
AAAr**v 10 \ S fW L as q s, iVi U < C a
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup BIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
! tect the local populace. Nevadans should not be required to
P(74) i accept additional risk on top of that already present at the
| Nevada Test Site.
1
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. ,
m \ ,'xuC-L.a to ¦-< b
Act; tic>ci>6es
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(75) ; accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
iTT TV]
^ )r k fr\y* S I'/
jOL
Mi*trb°ikiT>ofs CiT L\J
Keep Fernald Waste On-site in Ohio-
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(76) accept additional risk on top of that already present at the
, Nevada Test Site.
I
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
n™ *~"\VU A M tV' 70^
Address.
C-I-86
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
I tect the local populace. Nevadans should not be required to
P(77) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
' / / 1 "
Adrift - •
P(78) i
i
i
C-I-87
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
: nuclides, should be kept on-site in containers adequate to pro-
P(79^ tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name < (—Os*T" O
A Mr*** BP I ^ (loPrTS (OF Z_ V A! i/
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
( ' Nevada Test Site.
!
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste., /")
Nan*
Address,
%/¦ L'.'j U' tJi',?Vo f
C-I-88
-------
FEMF-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
P(8l) | accept additional risk on top of that already present at the
i Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. ^
.H—. 3QM a/S PffOi
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(82) tect the local populace. Nevadans should not be required to
i accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fem|kr waste. /
Name / L '
' >V . CjJ Hi/
Address.
C-I-89
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
( consisting of uranium, thorium and radium among other radio-
i nuclides, should be kept on-site in containers adequate to pro-
P(83) | tect the local populace. Nevadans should not be required to
, accept additional risk on top of that already present at the
1 Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Femald .waste. j
Name (/' )/l( Q ;
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(84) | tea the local populace. Nevadans should not be required to
! accept additional risk on top of that already present at the
1 Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. _
Name.
Address.
iGhcp sr~lAsV&iK /W
C-I-90
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
i consisting of uranium, thorium and radium among other radio-
' nuclides, should be kept on-site in containers adequate to pro-
P(85) ! [he local populace. Neva dans should not be required to
! accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fern aid, waste. r/J .
yi&tScAJ ,
n -m m.'—
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
; • The more than 300,000 cubic yards of radioactive waste
„ consisting of uranium, thorium and radium among other radio-
( 1 nuclides, should be kept on-site in containers adequate to pro-
! tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
! remain waste.
Address.
fare's ^ %T/(d
C-I-91
-------
Commentor P (1-177 Cont.)
FEMP OU4ROD-8 FINAL
December 1994
P(87)
P(88) |
i
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site In containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
m SjEUyrr.*- U/» t- C ftuc.K Ory)fVL/-c^
AAfaww ^ nM oqnT C\J /J 1/ F 9/Jf -sZxj
Keep Fernald Waste On-site in Ohio;;
Comments on the Fernald CleailUfj £15.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
C-I-92
-------
FEMP-OU4ROD-8 FINAL
December 1994
P(89)
I
f
P(90)
(1-177 Cnnt.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Address.
Name
AHrifWW '-'v. l ;V.~ /t"
C-I-93
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(91) | accept additional risk on top of that already present at the
i Nevada Test Site.
I
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Ip-tfrty M nb&Ch
cws Ml Of- tjJ rxj/A
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. - ,
Nam» />, j
Adrift ^ /lv ///
P(92)
C-l-94
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
i nuclides, should be kept on-site in containers adequate to pro-
| tect the local populace. Nevadans should not be required to
p(93) i accept additional risk on top of that already present at the
| Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. A, „ . 0.
Maim
CHSVW&Y ' S -V!.'
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
p/04, tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
' Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name £'-f- /;
C-I-95
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
Pf95) tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. ,a .
M— Ahan ^! i rvK-sno
Piof*
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(96) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. ^ ^ , .
Name-
ioOMAifC
C-I-96
-------
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio-
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(97) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald^vftsteri „ •,. A —>
S. C/jKcx
Name.
^IS1—>
<1 * r. ,ii , i i ¦ ¦ i t
i i , o .n
Address I n , ; UP , Yi u 3^/cT
C-I-97
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(99) accept additional risk on top of that already present at the
i Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Mn'.HFlS- /-TiLfcEETH
AHtea_—23J 'VllAi-MfJ >
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
dm nm i accept additional risk on top of that already present at the
P(1UU) 1 Nevada Test Site.
I
I
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste^_
Address.
e Fernald waste._ ,f
• / i I'/r y
^ /(/*.(&
C-I-98
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
PC 101) j tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Sice.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. . ^r-
C' ia*>
Name-
Address.
/ (?. &0)tr 60?Ajj/^7^
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
pn 021 accept additional risk on top of that already present at the
' Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
NimeOuU'a. i¦ lOmtder ¦
C-I-99
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move FerpaM waste.
Nmm hcfrrri gj-r
Address.
otfAi /M /U'J
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
i consisting of uranium, thorium and radium among other radio-
P(104) nuclide, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
Address—^
tree.xways
C-I-100
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
i nuclides, should be kept on-site in containers adequate to pro-
P(105) ; tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
/v/7^ ly. j~>v. $7j/
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
P(107)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
aid waste.
(0
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commenlor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
i nuclides, should be kept on-site in containers adequate to pro-
1 ten the local populace. Neva dans should not be required to
P(109) | accept additional risk on top of that already present at the
; Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name ^ ^4 l/f
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
P(H0) nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste, /
Name . / A —71
^0. Mfjy r*v
C-l-103
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
1 tect the local populace. Nevadans should not be required to
P(l11) accept additional risk on top of that already present at the
| Nevada Test Site.
I
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste-, ^
r
AddreM {rfC/SfAJ 3z77 &•*>>/
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(112) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
' ' '' " " A ^ '
^ "g ^ ¦iF-.HiTT -/: ¦ as -
C-I-104
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
| nuclides, should be kept on-site in containers adequate to pro-
P(ll3) 1 tect 1116 loca* Populace. Nevadans should not be required to
' accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
Address.
tors kjJiOJO OlsisJL LV rJJ &ll23
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(ll4) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move
Name.
i Fernald waste. ~ ,
/ t>' Nt/ Sf/cQ/
Address—^ — - - •
Z7
C-l-105
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
, consisting of uranium, thorium and radium among other radio-
1 nuclides, should be kept on-site In containers adequate to pro-
P(115) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. . i
Name Jy 1 IT? £HCjQ
Address,
¦3I38 GrfiUCHO tX. ) /K vFfrfcm/Mi)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
"— Cx\rr\cr
L-V Kl \/ ¥ *1 W *)
C-I-106
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
Pdi7^ accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste, q ,
Name.
Address.
&?(7 i\)(J
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(118) tect loca* Populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald wastt j
Name.
Address,
!
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
j tea the local populace. Nevadans should not be required to
Pci 1 n\ accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
® Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fgrnald waste. .
.w? StoiH"
AHfcm_VZii—Qrrg/i Cs. Hi/ LU t/t/ M/rf
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(120) accept additional risk on top of that already present at the
I Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
id waste.
Address.
C-I-108
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. n j
Name
Keep Fernald Waste On-site in Ohio-
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Neva dans should not be required to
P(122) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
NameT~li C.Ugt 1 C -^r {
Address_12l^ G> fivJ pip-, rfc f) ft'f P-S Q jn
I
I
P(121)
C-I-109
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
PM accept additional risk on top of that already present at the
n Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Namit tfWL\\tk±\ C^L02or\rU,
(frA/AtvXvuw Qfl* yurvjUtS/*, aa- w/r
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(124) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
—pnyr-A.-mraAJ
—_ w & /)/Ij y0
C-I-l 10
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
p 125. tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Sice.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. /~\ ^ ^
Name.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(126) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fonald waste. « -
Name
Address £7^>S ((/tJ/n& /7^AV/^/-^YV Ji'y*
C-I-lll
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(127) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move-funald waste. D D
une I —a—
Name.
Address.
lis,^
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(128) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. - p
>w. -KL.sk Lttei&JUf
7 7j2^ "ikx* ^-^-3
C-I-l 12
-------
FEMP OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(129) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name ?
^ 33-o^JOA.y L.i/.tJV
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(130) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
i *
Name
('¦ ,/LrL* q U W
C-I-l 13
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
i nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
P(13D accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. f~s
>w Aa/thm* £So*Qi
Bs AUVXT AVZ. / V rM
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(132) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name ""T"#
la '!< -?4(70
C-I-l 14
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio-
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(133) tea the local populace. Neva dans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Mam, 0 O U W\ A , (— O t g-V-
AH^c P,C>* S
Keep Fernald Waste On-site in Ohio-
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Feniald waste.
CPasnPneg. ucec
C-I-115
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(135) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
L\l 2RIOI
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
pyl?) tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Address. IA14 Qrlrb? LV Af., 71b?.
C-I-116
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(137) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name ^ ^
Add^, w* a ^
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(138) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Nami- t
.XH— -w;W tiAKfcU a r/>c '-¦/
C-I-117
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commenlor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
: nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
P(139) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
M j-u nr>
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
P(141' accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name_
fhrrio^,
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(142) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Ferpaftijwaste. II rf r
Name r-
Address.
C-I-119
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. ,
Name At'/*
^si/St
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(144) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name %ciD/{j
C-I-120
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
P(145) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. \ I
m w/UJla
Address.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
^mOr0F 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
P(146) i won-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. - , s-—) ,
A* in/-
Name
Address ^3A/(r>/ $Vl£0
C-I-121
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(14T) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Nam*- 'CWavA- LflU)rtPU»
Address.
ZS50 &• TioceW 0-3 LA) W
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(148) tect the local populace. Nevadans should not be required to
accept addidonal risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Nam*
Address (¥( *** 8*''7
C-I-122
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(149) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move F'
Name,
Add
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(1S0) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
Pr-fr
/>e. hW; A/S Wit
C-I-123
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(15l) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name K- LltOfc£JV\M0
Address f-0 Ufl7 CMi-fitt MV gWOI
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
p(152) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
0 Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. /
t>rvir> l. 7>lat^r/o/ro-<*;¦ e—
C-I-124
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(153) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Femald waste.
Vairw
ahh— Ml/ S93! I
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(154) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Na°» Mfrpnt H'riKM
AHrfrftw Sfitil fr. fakelto M 14-m
C-I-125
-------
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(155) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald ^aste. / /'
-Jt/xA/ Tre-ic/ie/
39j/~ A//.sbnJ]Dr it 7/ laiZms j//
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
Ptl56) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Naiw- I ot'V-j ^
AfiHfTtg /££ ZfV aJl/ 6*7Ol
C-I-126
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
P(157) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move
Ur/i/ A 1ft. 3*??/#- ??*/
C-I-127
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(159) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fern^kl waste.
Name
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
P(16U) Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
AHrfTtMK L t ^ v4 K- Q-fi A civ /Q ~i-2. /.U.jlVl/
C-I-128
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
pyl) tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. . j a _
Li* Jaa+*—
Address
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(162) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
Fema
2L
Address.
C-I-129
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
P(163) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Femald waste.
K,— M fu/fasm
Address.
72S Mcikm/i Or. fa.*.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup HIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(164) tea the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. _
Name C.ft £Lfl M d
<5 - flTa/ihrqt L .(>. L'LK Wci
C-I-130
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(165) tea the local populace. Neva dans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Address.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(166) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and.balanced against the desires of Ohio to
move Fernald waste. -~7f~ .
~ ni
A /Sl-Hf fdVf/^/
C-I-131
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tea the local populace. Nevadans should not be required to
P(167| accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald
'CF&rfc (
Address,
f&G Vim /A*, /2Z
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(168) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fei
Name
A Alms* /Z&f.UA V/
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(169) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move!
Name.
Address.
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more Chan 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(l7l) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. ^
Name
Addrcss. 46 3 O bsLjh. "SZcJi
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(172) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald wast.
fa*). i/l~~ . . OK.
l2i
C-I-134
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site In Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Nevadans should not be required to
P(173) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste. . n . s .
Namc^L
\Q Vn ^ y \n \
Address_^t ,
'r
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
i nuclides, should be kept on-site in containers adequate to pro-
i tect the local populace. Nevadans should not be required to
P(174) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name
AHrfires
C-I-135
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(l 75) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name.
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
P(l 76) tect the local populace. Nevadans should not be required to
accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name_
Address.
¦lvtl
C-I-136
-------
FEMP-OU4ROD-S FINAL
December 1994
Commenlor P (1-177 Cont.)
Keep Fernald Waste On-site in Ohio..
Comments on the Fernald Cleanup EIS.
• The more than 300,000 cubic yards of radioactive waste
consisting of uranium, thorium and radium among other radio-
nuclides, should be kept on-site in containers adequate to pro-
tect the local populace. Neva dans should not be required to
P(177) accept additional risk on top of that already present at the
Nevada Test Site.
• Transportation risks need to be thoroughly evaluated.
• Socioeconomic Impacts on the receptor community should be
thoroughly evaluated and balanced against the desires of Ohio to
move Fernald waste.
Name,
C-I-137
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor Q
The following comments/issues were submitted by Pam Dunn, Harrison, Ohio. The comments/issues
were retyped and alphabetically identified by DOE in order to facilitate developing comment
responses. The original hand written comments have also been included as matter for the record.
(a)
(b)
(c)
(d)
(e)
(f)
June 20, 1994
Mr. Ken Morgan
U.S. Dept. of Energy Fernald Field Office
P.O. Box 398705
Cincinnati, OH 45239-8705
RE: Comments Proposed Plan For Remedial Action OU4.
• In reviewing the Proposed Plan for OU4 there are variances in the capital cost for the
same treatment alternatives with the only difference being on-site versus off-site
disposal. What is the source of this variance?
• It is stated that EPA would review on-property disposal every five years in accordance
with CERCLA requirements. Who and how often would a review be performed in the
other years?
• There is no mention of retri[e]vability of the materials which would be disposed of in
the on-site disposal vault. Is this option being considered, and, if not, why?
• Post-remediation O&M cost are estimated over a thirty-year period. What about the
remaining years for which this material will require monitoring?
• Alternatives 2B and 4B have identical post-remediation cost, with Alternative 4B being
untreated. Please explain how cost can be the same for treated versus untreated
materials disposed in an on-site vault.
• There is discussions on interim storage. What is the estimated time for this interim
storage?
C-I-138
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor Q (Cont.)
(g)
(h)
(i)
0)
00
(I)
(m)
(n)
(o)
• Alternative 2C states that the contaminated materials would be place in bulk (without
packaging) into the on-site disposal vault. Please expand on why this material would not
be packaged and state the advantages/disadvantages of packaged versus non-packaged.
• It is stated that non-porous material will be released from the site as uncontaminated per
DOE Order 5400.5. Will this material be checked for contamination prior to release or
just assumed to be uncontaminated and released?
• Will the wastewater generated during remediation be treated for non-radioactive
contaminates prior to discharge in the Great Miami River? To what extent will
radioactive and non-radioactive elements be removed prior to discharge?
• A material variance in the cost associated with Subunit C exist between 3C.1 and 3C.2
with the only apparent difference being 3C.1 Disposal at NTS and 3C.2 at Envirocare in
Utah. Please explain this variance and if this is partially due to more stringent
requirements at NTS, should these more stringent requirements also be required at a
commercial facility? Which requirements is more protective? It is also stated that an
exemption from DOE Order 5820.2A (this is transposed as 5280.2A in document, Page
56) is needed to dispose at a commercial facility; has this been granted?
• Will notification of these shipments be given to the areas involved in the transportation
routed for rail and truck, and what precautions for protection will be employed?
• Table 6-1 comparison of remedial alternatives, state differences in implementing identical
treatments with different disposal options. Is this difference related to transportation
issues for off-site rather than on-site? Please explain these differences. Also, Subunit C
lists no treatment for all alternatives; please demonstrate why no treatment is acceptable.
Is there potential for failure of the vitrified material has the radionuclides trap[p]ed
continue to delay, and if so, what is that risk?
It states that the capital cost associated with the on-site disposal facility has been
removed. Where is (will) this cost be accounted for?
Line 14, Page 67 reads results in significant reduction in the volume...This would read
better if the "a" preceded significant/rather than follow.
C-I-139
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor Q (Cont.)
(P)
(q)
(r)
(s)
(t)
• Please define the following statement (Line 16, Page 67) utilize permanent solutions to
the maximum extent practical. What viable, permanent solutions presently exist?
• Basis for stating long-term environmental impacts of permanent disposal at NTS are
minor and no long-term impacts of biota expected from disposal activities at NTS. It is
stated that to reduce U-238 to essentially background is not feasible; it also states that it
is assumed that the federal government retain ownership of the FEMP site to consider
clean-up protective. While I do not have a problem with these statements, it does bother
me that no formal statement has been made publicly concerning this. These two
statements present future land use constraints which must be addressed. Why hasn't the
DOE adopted a formal position concerning this issue and communicated this to both the
Fernald Citizens Task Force and the community?
• Line 13, Page 76, reads "... would bot be ...", should that read "... would not be ..." ?
• It states the on-site, above-grade disposal facility would be designed for a 1000 year life
with no active maintenance. What is the half-lives or duration for which the radionuclei
and chemical contaminants are a threat to the environment; do they exceed 1000 years?
Also, explain why no active maintenance is assumed for 1000 years.
• Has an exemption to the Ohio Solid Waste Facility requirement been requested, and if
not, when will such a request be made? Also, Line 28, Page 79 would read better if
"the" or "a" were added to precede disposal. (For disposal facility on the FEMP site.)
Should you have any questions concerning these comments, feel free to contact me at the
address given below:
Submitted by
Pam Dunn
7781 New Haven Rd.
Harrison, Ohio 45030
cc:
Mr. John Applegate
F.R.E.S.H., Inc.
File
C-I-140
-------
FEM P-OU4ROD-8 FINAL
December 1994
Commentor Q (Cont.)
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Commentor Q (Cont.)
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FEMP-OU4ROD-8 FINAL
December 1994
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C-I-142
-------
Commentor Q (Cent.)
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FEMP-OU4ROD-8 FINAL
December 1994
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C-I-143
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor Q (Cont.)
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fft TXaEAi.oa^ yj?g. uJtiic hi idti TAfhottur L: i>U) fjprn/cx/ rov74m,yQrt"S75 A^jt *
"dif^-r 7o rt\f rXx/i/o/O/X^o-^: Oo -av^/ ev Fvrrl /(Y;ft ua^/L<, J rfkt> +xs/a/'<0
U)H^/ fOg Af7H?^ fl\Aittf?e*MNu£ /'«> MAC T&L JOW *f&UT S
7
hO ^«r/riA7/o/0 7b7/
r=n! falO if ctrf Ulill I'd •& is- rtfifllsr*
frto J L.xn.1 iiO hrfLQ !\f-~nfX—»P TTy/^ or /? ^A-y? -rt» ff^r/^rur
falr.'/wy QWtt/fc f&7?P -iff-.)
v^ou. 4i^ moupejo;/)* ^tcr CMfffmVS: r&l H&zr ~?<5
owOr-r .;
•f
•- v, '•?»*'>• "X"'».*¦;¦
¦• -, > .v -v
",: v
fM- Hxiil fyif-J-AI*
.* "it
>-
C-I-144
-------
FEMP-OU4ROD-8 FINAL
December 1994
Commentor R
512 ~36 665C
JS OEPT Qt ENERGV
P
OheEWl
« jleof Ohio Environmental PriMtctlon Agency
\H-3mq.
L» - >• . !r
Southwttt District onice
40 Soutn Main Strow
Oayloo. Ohio 45402-2060
(513) 286-6357
FAX (513! 2B6-£404
'•I1/? LO J 55 '£lj
Gaorga V. Volnoveh
Governor
April 19, 1994
RE: PUBLIC COMMENTS
O.U.4 PROPOSED PLAN
Mr. Ken Morgan
Public Relations
U.S. DOE FEMP
P.O. Box 398705
Cincinnati, OH 45329-8705
Dear Mr. Morgan:
The purpose of this letter is to provide official comments on the
Operable Unit 4 Proposed Plan:
1. The OU4 Proposed Plan is the culmination of efforts by U.S.
DOE, Ohio EPA, and U.S. EPA to understand and develop a plan
for mitigating releasee to the environment from OU4 . The
alternative selected in the Proposed Plan will address
potential and actual releases in a manner protective of
human health and the environment.
2. DOE should commit to including and/or developing real-time
monitoring for discharges to the environment resulting from
remedial actions including any treatment system. DOE should
attempt to incorporate any new developments in real-time
monitoring from the Office of Technology Development. Data
obtained from real-time monitors and any additional
monitoring activities should be provided to the Ohio EPA and
public in a tlitrely manner.
3. DOE should attempt to incorporate pollution prevention
activities whenever possible during the design and operation
of the OU4 remedial action system. All available methods to
reduce or eliminate discharges from the treatment system
should be considered during the design of the system.
4. doe must onsuro the public that their involvement will not
be diminished during Remedial Design and Remedial Action
(RD/RA). DOE should commit to continued public involvement
during RD/RAjwithin the Record of Decision for 0U4.
5. DOE should revise the site Community Relations Plan to
address the need for continued public involvement during the
RD/RA. Ohio EPA looks forward to working with DOE to revise
this document.
C-I-145
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FEMP-OU4ROD-8 FINAL
December 1994
Commentor R (Cont.)
Sl3 733 6650
US DEPT Of ENERCV
Ohio EPA Comments 0U4 PP
April 19, 1994
Page 2
If you have any questions about these comments please contact me.
Sincerely,
Thomas A. Schneider
Project Manager
TAS
cc: Lisa Crawford, FRESH
Jack Van Kley, Ohio AGO
Jim Saric, usepa
Ken AlKema, FERMCO
LiBa August, Geotrans
Jean Michaels, PRC
Jenifer Kwasniewski, OEPA/DERR
Jeff Hurdley, OEPA/Legal .
Robert Owen, ODH
C-I-146
-------
Commentor S
FEMP-OU4ROD-8 FINAL
December 1994
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVAOO
CHICAGO. IL 60604-3990
AEH.V TO 'Mt ATTENTION Qf.
MS. Randi Allan
KB-19J
Department of Energy
Post Office Box 39*704
Cincinnati, Ohio 45239-8704
Dear Ms. Allan
This will confirm the substance of our recent telephone
conversations concerning this Agency's review of the Department
of Energy's proposal for implementing activities including re-
activation of certain power generating facilities at the Femauld
site.
As discussed with you, the Draft Environmental Impact Statement
(EIS) for this project was never received in this Branch, in
this regard, the Planning and Assessment Branch has been desig-
nated as the official contact point within Region v for provision
of comments on Federal projects as required pursuant to Section
309 of the clean Air Act and/or the National Environmental Policy
Act. The official eonaent period for this Fernauld project ex-
pired 45 days from the date a notice of the EIS's availability
was published in the Federal Register. In the meantime, however,
the document was received, reviewed, and commented upon by staff
of our waste Management Division with regard to those aspects of
the project for which Waste Management Division has special
concern.
Given expiration of the official IOTA comment period for this
project's EIS, the only comments on the record from our Agency
are those previously supplied to you from our Waste Management
Division. At this point ill time, given the requirements of NEPA
and its implementing regulations, those comments will have to
suffice as our Agency's comments. Provided that the comments
previously provided by our Waste Management Division are complied
with, and further provided that facility in question is subse-
quently operated in full accordance with applicable local, State,
and Federal requirements, it appears unlikely at this time that
any significant adverse impacts on the environment can reasonably
be foreseen.
C-I-147
-------
Commentor S (Cont.)
FEMP-OU4ROD-8 FINAL
December 1994
-2
He loofc forvard to receipt of the project's forthcoming Final
CIS. Our Agency's conanents on the Final SIS will b« provided on
a timely basis. If you have any questions, please do not
hesitate to contact ae at 312/686-7J42.
Sinearclv voura.
Ichael W. Mac Mullen
Michael W. Mac Mullen
Senior Environaental Scientist
Planning and Assessment Branch
Planning and Management Division
C-I-148
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FEM P-OU4ROD-8 FINAL
December 1994
ATTACHMENT C.II
ERRATA SHEETS AND CHANGES TO THE FEASIBILITY
STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT
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FEMP-OU4ROD-8 FINAL
December 1994
{This page intentionally left blank}
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FEMP-OU4ROD-8 FINAL
December 1994
TABLE OF CONTENTS
Page
C.n.l Repromulgation of 40 CFR § 191 C-II-1
C.II.2 Errata Sheets to the Operable Unit 4 Feasibility
Study/Proposed Plan - Draft Environmental Impact Statement C-II-3
C-n-i
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FEMP-OU4ROD-8 FINAL
December 1994
C.II ERRATA SHEETS AND CHANGES TO THE FEASIBILITY
STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT
The FS/PP-DEIS for Operable Unit 4 was released for public comment in March 1994. The DOE
reviewed all written and oral comments submitted during the public comment period. Upon review of
these comments, it was determined that no significant changes to the remedy, as was originally identified
in the FS/PP-DEIS, were necessary. However, it should be noted that the repromulgation of 40 CFR
§191 by the EPA, did result in minor changes in the comparative analysis of alternatives presented in the
FS/PP-DEIS. Likewise, in May 1994 five final concerns were received from the EPA on the Operable
Unit 4 FS/PP-DEIS. In responding to these five concerns, Table D.3-5 in Appendix D of the Operable
Unit 4 FS/PP-DEIS was revised. The revised table is included in this Attachment. The following
discussion addresses the nature and extent of these changes.
C.H.l REPROMULGATION OF 40 CFR S191
Repromulgation of the 40 CFR §191 requirements for Management and Disposal of Spent Nuclear Fuel,
High-Level, and Transuranic Wastes has caused changes to be made to the ARARs as described in the
Draft Final FS/PP-DEIS, conditionally approved by the EPA on February 9, 1994. DOE chooses not
to submit revision pages to the FS/PP-DEIS; all changes to the ARARs for that document and any
impacts from the repromulgation are discussed in this section of the Draft ROD. Since the
repromulgation resulted in relevant and appropriate, rather than applicable requirements, the
repromulgation of 40 CFR §191 will not impact the proposed off-site alternative for disposition of the
K-65 material. However, the on-property disposal alternatives (Alternatives 2A/Vit and 2A/Cem) that
were previously retained, having passed the threshold criteria of the detailed analysis, are no longer able
to meet the threshold criteria of compliance with ARARs, and are consequently dropped from further
consideration. Subsequently, all references to Alternative 2A are therefore deleted from reference in the
text of the ROD, and in the Appendix A.
The only relevant and appropriate requirement from 40 CFR §191 that is retained as an ARAR in this
ROD (Appendices A and B) for the proposed alternative is 40 CFR §191.03(b), which establishes dose
limits for management and storage of the K-65 material. However, since this ARAR is relevant and
appropriate, rather than applicable, it will pertain only to the on-Dropertv portions of the remediation.
Background
The United States Department of Energy - Fernald Field Office (DOE-FN) received conditional approval
C-II-1
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FEMP-OU4ROD-8 FINAL
December 1994
of the Draft Final FS/PP-DEIS for Operable Unit 4 from USEPA on February 9, 1994. Included in the
FS/PP-DEIS applicable or relevant and appropriate requirements (ARARs) was a reference to 40 CFR
§191, "Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear
Fuel, High-Level, and Transuranic Wastes". This reference to 40 CFR §191 was modified in the
Operable Unit 4 FS/PP-DEIS, submitted in February 1994 in response to the conditional approval letter,
to reflect the changes to the regulation that occurred upon its repromulgation on December 20, 1993.
It still accommodates the specific direction previously provided by the USEPA regarding incorporation
of the 40 CFR §191 requirements as an ARAR/TBC ("Operable Unit 4 Screening Dispute Resolution
U.S. DOE Fernald", Catherine McCord, USEPA, to Andy Avel, DOE, dated October 18, 1990). The
final rule became effective on January 19, 1994, during final revision of the Operable Unit 4 FS/PP-
DEIS, and agency comments did not address the repromulgation of the rule. This fact was discussed with
the USEPA, and a DOE position paper on the incorporation of 40 CFR §191 as an ARAR for Operable
Unit 4 remediation was submitted to the USEPA for concurrence. The USEPA disagreed with the draft
position proposed by DOE, and responded with a directive to incorporate the substantive elements of the
repromulgated rule into the ROD, with an option to resubmit change pages to the FS/PP-DEIS
("Application of 40 CFR §191 to OU #4", Jim Saric, USEPA, to Jack Craig, DOE, dated April 25,
1994). DOE elected not to revise the FS/PP-DEIS, but rather to describe in this section of the ROD
changes to the table of ARARs and associated impacts on selection or implementation of remedial
alternatives that have occurred between the time the Draft Final FS/PP-DEIS was conditionally approved,
and the submittal of the ROD to the USEPA and OEPA. The list of ARARs in the Draft ROD, and
proposed approach to compliance with the substantive elements thereof, once approval by the USEPA
is obtained, will be the final approved list of applicable or relevant and appropriate requirements for final
remediation of Operable Unit 4.
Impacts of Repromulgation
Since 40 CFR §191 cannot be considered a legally "applicable" class of ARAR for this CERCLA
remediation, §191 is not applicable to any Operable Unit 4 waste streams. Since compliance with only
applicable requirements is required to be demonstrated for off-site remedial alternatives proposed under
CERCLA, these requirements will not impact the proposed off-site alternative for disposal of the treated
K-455 material at the NTS.
DOE previously included 40 CFR §191 Subpart A as a relevant and appropriate requirement, and Subpart
B as to be considered (TBC) criteria for management of K-65 material in accordance with guidance
received from the USEPA. Subpart A of §191, entitled "Environmental Standards for Management and
c-n-2
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FEMP-OU4ROD-8 FINAL
December 1994
Storage" includes public dose rate standards for protection of the public from radiation hazards posed by
spent nuclear fuel, high-level, or transuranic waste material. The repromulgation of the Final Rule did
not materially affect the sections of Subpart A referenced in the Operable Unit 4 FS/PP-DEIS; the
Subpart A requirement referenced in the Operable Unit 4 FS/PP-DEIS remains unchanged in the table
of ARARs as a relevant and appropriate requirement for the on-property portion of the remedial activities
to be conducted on the K-65 material.
Prior to repromulgation, Subpart B requirements were in remand, and were therefore considered TBCs
in the FS/PP-DEIS submitted to the agencies. Since Subpart B of §191, entitled "Environmental
Standards for Disposal", has been repromulgated, the USEPA has directed that sections must now be
considered as relevant and appropriate requirements for any on-property disposal alternatives. Since it
could not be demonstrated that the on-property disposal of treated K-65 material would comply with
specific requirements of this Subpart, those alternatives involving on-property disposal (Alternatives
2A/Vit and 2A/Cem) were no longer able to meet the threshold criteria of compliance with these ARARs,
and were consequently dropped from further consideration. All descriptions to Alternative 2A are
therefore deleted from reference in the text of the ROD, and in the Appendix A.
A new Subpart C of §191 "Environmental Standards for Groundwater Protection", was created by the
repromulgated rule. As with Subpart B, this new Subpart pertains only to disposal systems. The
elements of this Subpart must now be considered as relevant and appropriate requirements; however,
since the on-property disposal alternatives to which this Subpart pertains were dropped from further
consideration on the basis of non-compliance with Subpart B requirements, and since Subpart C will not
pertain to any off-site disposal alternatives, these requirements will not be included in the Appendix A
or B tables of ARARs. Subpart C will have no effect on the selected alternative, which includes off-site
disposal.
C.n.2 ERRATA SHEETS TO THE OPERABLE UNIT 4 FEASIBILITY STUDY/PROPOSED PLAN-
DRAFT ENVIRONMENTAL IMPACT STATEMENT
In the course of obtaining EPA's approval of the Operable Unit 4 Feasibility Study/Proposed Plan-Draft
Environmental Impact Statement, several iterations of specific comment responses were required to fully
address five remaining EPA concerns.
On May 9, 1994 the EPA approved the Final Operable Unit 4 Feasibility Study Report and Proposed Plan
based upon the satisfactory resolution of five remaining concerns. Only the resolution of one of the five
C-H-3
-------
FEMP-OU4ROD-8 FINAL
December 1994
remaining concerns resulted in an action by the DOE, which involved the revision of two pages to the
Operable Unit 4 Feasibility Study Report/Proposed Plan-Draft Environmental Impact Statement.
In the May 9, 1994 approval letter, the EPA noted that previously agreed upon changes related to the
Operable Unit 4 FS, Appendix D, Table D.3-5 were not made in the revised final document per
resolution. Specifically, the surface area (SA) values presented for the Dermal Contact While Bathing
pathway in Table D.3-5, were not reflected in the Final Operable Unit 4 Feasibility Study/Proposed Plan-
Draft Environmental Impact Statement document. In addition, the EPA noted that footnote "h" of Table
D.3-5 was incorrect; the referenced pages were not consistent with the cited EPA document.
The following DOE response was accepted by the EPA on this matter:
"This table (D.3-5) was derived from the OU4 Baseline Risk Assessment, but the latest
change for this dermal exposure pathway was not made for this table. This will have no
impact on the OU4 FS risk assessment as the only contaminant which was considered for
the groundwater pathway was U-238. Since radionuclides are not evaluated for dermal
absorption pathways, this parameter change will not change the risk values."
In accordance with this resolution the DOE issued the following revised pages to Table D.3-5, which
included the corrected surface area value of 23,000 cm3 and the corrected footnote "h".
C-II-4
-------
TABLE D.3-5
(Continued)
Pathway Parameters
Trespassing
Child
Age 6-18
Expanded
Trespasser
Child
Age 6-18
Expanded
Trespasser
Adult
18-50
RME
On-Property
Farmer
Age 1-70
CT On-Property
Resident
Farmer
Age 1-70
On-Property
Resident
Child
Age 1-6
Off-Property
Resident
Farmer
Age 1-70
Inhalation of Volatiles Released from Household Water Uses
IR (m3/hr)
N/A
N/A
N/A
0.63
0.63
0.63
0.63
ET (hr/d)
N/A
N/A
N/A
0.25"
0.17h
0.33"
0.25h
EF (d/yr)
N/A
N/A
N/A
350d
275b
350**
350"
ED (yr)
N/A
N/A
N/A
70
9e
6
70
BW (kg)
N/A
N/A
N/A
70
70
15
70
AT-Noncancer (d)'
N/A
N/A
N/A
25550
3285
2190
25550
AT-Cancer (d)*
N/A
N/A
N/A
25550
25550
25550
25550
Incidental Ingestion of Soil/Sediment
IR (g/hr)
0.1
0.1
0.1
0.18
0.122
0.2
N/A
FI (unitless)
0.25
0.1
0.05
1
1
1
1
EF (d/yr)
52
110
40
350d
275b
350**
350"
ED (yr)
12
12
32
70
9*
6
70
BW (kg)
43
43
70
70
70
15
70
AT-Noncancer (d)f
4380
4380
11680
25550
3285
2190
25550
AT-Cancer (d)g
25550
25550
25550
25550
25550
25550
25550
See footnotes at end of table.
-------
TABLE D.3-5
(Continued)
Pathway Parameters
Trespassing
Child
Age 6-18
Expanded
Trespasser
Child
Age 6-18
Expanded
Trespasser
Adult
18-50
RME
On-Property
Farmer
Age 1-70
CT On-Property
Resident
Farmer
Age 1-70
On-Property
Resident
Child
Age 1-6
Off-Property
Resident
Farmer
Age 1-70
Dermal Contact While Bathing
SA (m2)
N/A
N/A
N/A
2.3h
2.3h
0.8h
2.3h
PC (cm/hr)
N/A
N/A
N/A
CSV
CSV
CSV
CSV
ET (hr/d)
N/A
N/A
N/A
0.25h
0.17h
0.33h
0.25h
EF (d/yr)
N/A
N/A
N/A
350d
275"
350d
350d
ED (yr)
N/A
N/A
N/A
70
9*=
6
70
BW (kg)
N/A
N/A
N/A
70
70
15
70
AT-Noncancer (d)f
N/A
N/A
N/A
25550
3285
2190
25550
AT-Cancer (d)«
N/A
N/A
N/A
25550
25550
25550
25550
Dermal Contact With Soil/Sediment
SA (m2)
0.41
0.41
0.57
0.57
0.5
0.2
0.57
DA (cm/m2)
1
1
1
CSV
CSV
CSV
CSV
ABS
CSV
CSV
CSV
CSV
CSV
CSV
CSV
EF (d/yr)
52
110
40
350"
275"
350"
350d
ED (yr)
12
12
32
70
9*=
6
70
BW (kg)
43
43
70
70
70
15
70
AT-Noncancer (d)f
4180
4180
11680
25550
3285
2190
25550
AT-Cancer (d)f
25550
25550
25550
25550
25550
25550
25550
6
«n c
js
I *
z
See footnotes at end of table. $ ^
-------
TABLE D.3-5
(Continued)
Pathway Parameters
Trespassing
Child
Age 6-18
Expanded
Trespasser
Child
Age 6-18
Expanded
Trespasser
Adult
18-50
RME
On-Property
Farmer
Age 1-70
CT On-Property
Resident
Farmer
Age 1-70
On-Property
Resident
Child
Age 1-6
Off-Property
Resident
Farmer
Age 1-70
Inhalation of Dusts, Volatiles, and Radon
DR (mrem/hr)
CSV
CSV
CSV
csv
CSV
CSV
N/A
ET Indoors (hr/d)
N/A
N/A
N/A
18.3
19.8
22
N/A
ET Outdoors (hr/d)
4
2
1
5.7
4.2
2
N/A
EF (d/yr)
52
110
40
350
275
350
N/A
ED (yr)
12
12
32
70
9
6
N/A
BW (kg)
43
43
70
70
70
15
N/A
Ingestion of Vegetables and Fruit
IR (g/d)
N/A
N/A
N/A
122
78"
101.5'
122
FI (unitless)
N/A
N/A
N/A
1
1
1
1
EF (d/yr)
N/A
N/A
N/A
350d
275"
350d
350d
ED (yr)
N/A
N/A
N/A
70
9®
6
70
BW (kg)
N/A
N/A
N/A
70
70
15
70
AT-Noncancer (d)f
N/A
N/A
N/A
25550
3285
2190
25550
AT-Cancer (d)'
N/A
N/A
N/A
25550
25550
25550
25550
Ingestion of Meat
3
2
Z
c
1R (g/d)
FI (unitless)
EF (d/yr)
ED (yr)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
75
1
350d
70
50b
I
275b
9"
29
I
350"
6
75
1
350"
70
3
a
See footnotes at end of table.
-------
TABLE D.3-5
(Continued)
Pathway Parameters
Trespassing
Child
Age 6-18
Expanded
Trespasser
Child
Age 6-18
Expanded
Trespasser
Adult
18-50
RME
On-Property
Farmer
Age 1-70
CT On-Property
Resident
Farmer
Age 1-70
On-Property
Resident
Child
Age 1-6
Off-Property
Resident
Farmer
Age 1-70
BW (kg)
N/A
N/A
N/A
70
70
15
70
AT-Noncnacer (d)f
N/A
N/A
N/A
25550
3285
2190
25550
AT-Cancer (d)»
N/A
N/A
N/A
25550
25550
25550
25550
Ingestion of Milk
1R (L/d)
N/A
N/A
N/A
0.3
0.2b
0.9
0.3
FI (unitless)
N/A
N/A
N/A
1
1
1
1
EF (d/yr)
N/A
N/A
N/A
350"
275"
350"
350"
ED (yr)
N/A
N/A
N/A
70
9*
6
70
BW (kg)
N/A
N/A
N/A
70
70
15
70
AT-Noncancer(d)'
N/A
N/A
N/A
25550
3285
2190
25550
AT-Cancei^d)*
N/A
N/A
N/A
25550
25550
25550
25550
'Parameter values obtained from Final RI Report for Operable Unit 4 (November 1993), Table D.3-12.
bSpecial guidance from EPA Region V.
cDrinking water consumption rate of 1.4 L/day from NRC (Nuclear Regulatory Commission), 1977, U.S. Nuclear Regulatory Commission Regulatory Guide 1.109; NCRP
(National Council on Radiation Protection) Report No. 76.
''Guidance from EPA (1991a), OSWER Directive: 9285.7-01B.
'Guidance from EPA (1991b), Interim Final, OSWER Directive: 9285.6-03. 3
'Calculated as the product of ED (years) x 365 days/year. ijj
'Averaging time for carcinogens calculated as the product of 70 years x 365 days/year. 6
hEPA (1992a), "Dermal Exposure Assessment: Principles and Applications, EPA/600/8-91/01 IB. g! *
¦Guidance from EPA (1989), Interim Final, p. 6-36. g jjj
13 a
* F
See footnotes at end of table.
-------
FEMP-OU4ROD-8 FINAL
December 1994
ATTACHMENT C.IH
FINAL ENVIRONMENTAL IMPACT STATEMENT DISTRIBUTION LIST
-------
FEMP-OU4ROD-8 FINAL
December 1994
{This page intentionally left blank}
-------
FINAL ENVIRONMENTAL IMPACT STATEMENT FEM P-OU4ROD-8 FINAL
DISTRIBUTION LIST December 1994
FEDERAL AGENCIES AND CONGRESS
NAME/LOCATION PHONE/FAX
Cheryl Allen 312-353-6196
United States Environmental Protection Agency
Region V (P-19J)
Superfund Community Relations Section
77 W. Jackson Blvd.
Chicago, IL 60604
The Honorable Tom Bevill
Chairman, Subcommittee on Energy and Water Development
Committee on Appropriations
Member, U.S. House of Representatives
2362 Raybura
Washington, D.C. 20515
The Honorable James H. Bilbray
Member, U.S. House of Representatives
2431 Rayburn
Washington, D.C. 20515
The Honorable James H. Bilbray 702-792-2424
Member, U.S. House of Representatives
1785 E. Sahara, Suite 445
Las Vegas, Nevada 89104
The Honorable Michael Bilirakis
Ranking Minority Member
Subcommittee on Energy and Power
Committee on Energy and Commerce
Member, U.S. House of Representatives
2322 Rayburn
Washington, D.C. 20515
The Honorable John A. Boehner 513-894-6003
Member, U.S. House of Representatives
5617 Liberty Fairfield Road
Hamilton, Ohio 45011
C-ffl-1
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION PHONE/FAX
The Honorable John A. Boehner
Member, U.S. House of Representatives
1020 Longworth
Washington, D.C. 2051S
The Honorable Richard Bryan 702-388-6605
United States Senator
300 Las Vegas Boulevard, Suite 402
Las Vegas, Nevada 89101
The Honorable Richard Bryan
United States Senate
364 Russell
Washington, D.C. 20510
Jonathan Deason, Director (18 Copies)
Office of Environmental Affairs
Attn: Lilian Stone
U.S. Department of the Interior
1849 C. Street, NW, Room 2340
Washington, D.C. 20240
The Honorable Ronald V. Dellums
Chairman, Committee on Armed Services
Member, U.S. House of Representatives
2120 Rayburn
Washington, D.C. 20515
Ms. Kathleen C. DeMeter
Assistant Chief Counsel/General Law
National Highway Traffic Safety Administration (NCC-30)
Room 5219 Nassif Building
400 7th Street, SW
Washington, D.C. 20590
The Honorable John D. Ding ell
Chairman, Committee on Energy and Commerce
Member, U.S. House of Representatives
2125 Rayburn
Washington, D.C. 20515
c-ra-2
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION PHONE/FAX
The Honorable John D. Dingell
Chairman, Subcommittee on Oversight and Investigations
Committee on Energy and Commerce
Member, U.S. House of Representatives
2323 Rayburn
Washington, D.C. 20515
The Honorable Pete V. Domenici
Ranking Minority Member
Subcommittee on Energy Research and Development
Committee on Energy and Natural Resources
United States Senate
312 Dirksen
Washington, D.C. 20510
The Honorable J. James Exon
Chairman, Subcommittee on Nuclear
Deterrence, Arms Control & Defense
Intelligence Committee on Armed Services
United States Senate
528 Hart
Washington, D.C. 20510
Mr. Robert Fairweather
Chief, Environmental Branch
Office of Management and Budget
725 17th Street, NW
Washington, D.C. 20503
The Honorable Wendell H. Ford
Chairman, Subcommittee on Energy
Research and Development
Committee on Energy and Natural Resources
United States Senate
312 Hart
Washington, D.C. 20510
The Honorable John H. Glenn 513-684-3265
United States Senator
550 Main Street, Room 10407
Cincinnati, Ohio 45202
C-ffl-3
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION PHQNE/FAX
The Honorable John Glenn
Chairman, Committee on Government Affairs
United States Senate
503 Hart
Washington, D.C. 20S10
The Honorable John Glenn
United States Senate
503 Hart
Washington, D.C. 20510
The Honorable Tony P. Hall 513-225-2843
Member, U.S. House of Representatives
Federal Building, Room 501
200 West Second Street
Dayton, Ohio 45402
The Honorable Tony P. Hall
Member, U.S. House of Representatives
2236 Rayburn
Washington, D.C. 20515
Herbert Harback 606-874-0539
Army Corps of Engineers
Louisville District
Louisville, Kentucky 40201
The Honorable J. Dennis Hastert
Ranking Minority Member
Subcommittee on Environment, Energy, and Natural Resources
Committee on Government Operations
Member, U.S. House of Representatives
2453 Rayburn
Washington, D.C. 20515
The Honorable Mark O. Hatfield
Ranking Minority Member
Subcommittee on Energy and Water Development
Committee on Appropriations
United States Senate
711 Hart
Washington, D.C. 20510
C-m-4
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION PHONE/FAX
Kevin Heanue 202-366-0100
Office of Environment
Department of Transportation
400 7th Street, SW
Washington, D.C. 10590
Sheila Huff 312-353-6612
Department of Interior
230 South Dearborn Street, Room 3422
Chicago, Illinois 60604
G. Jablonowski
United States Environmental Protection Agency
Region V (AT-18J)
77 W. Jackson Boulevard
Chicago, Dlinois 60604-3590
312-886-0169
FAX 312-886-0617
The Honorable J. Bennett Johnston
Chairman, Subcommittee on Energy and Water Development
Committee on Appropriations
United States Senate
136 Hart
Washington, D.C. 20510
The Honorable J. Bennett Johnston
Chairman, Committee on Energy and Natural Resources
United States Senate
304 Dirksen
Washington, D.C. 20510
Elaine Kaiser 202-927-5750
Interstate Commerce Commission
12th Street and Constitution Avenue
Washington, D.C. 20423
C-III-5
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION PHONE/FAX
Ms. Marilyn W. Klein 202-366-0358
Senior Policy Analyst
Economic Studies Division
Federal Railroad Administration
Room 8302 Nassif Building
400 7th Street, SW
Washington, D.C. 20590
Dr. William Klesch
Office of Environmental Policy (CECW-PO)
Office of Chief of Engineers
Army Corps of Engineers
Pulaski Building, Room 7116
20 Massachusetts Avenue, NW
Washington, D.C. 20314-1000
Don Klima 202-606-8503
Director, Eastern Office
Advisory Council on Historic Preservation
Old Post Office Bldg., Suite 809
1100 Pennsylvania Ave., NW
Washington, D.C. 20004
Bill Kurey 614-469-6923
U.S. Fish and Wildlife Service
6950-H American Parkway
Reynoldsburg, Ohio 43068
The Honorable Jon Kyi
Ranking Minority Member
Subcommittee on Military Application of
Nuclear Energy Panel
Committee on Armed Services
Member, U.S. House of Representatives
2440 Rayburn
Washington, D.C. 20515
Ugene Lehr 202-366-4861
Chief, Environmental Division
U.S. Department of Transportation
Room 9217
400 7th Street, SW
Washington, D.C. 20590-0001
C-ffl-6
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION PHONE/FAX
The Honorable Trent Lott
Ranking Minority Member
Subcommittee on Nuclear Deterrence Arms
Control & Defense Intelligence
Committee on Armed Services
United States Senate
487 Russell
Washington, D.C. 20510
The Honorable David Mann 513-684-2723
Member, U.S. House of Representatives
1014 Vine Street
2210 Kroger Building
Cincinnati, Ohio 45202
The Honorable David Mann
Member, U.S. House of Representatives
503 Cannon
Washington, D.C. 20515
Mike MacMullen (ME-19J) 312-886-7342
Planning and Assessment Branch
Planning and Management Division
U.S. Environmental Protection Agency - Region V
77 W. Jackson Blvd.
Chicago, Illinois 60604-3590
Ross McKay 202-646-2717
Federal Emergency Management Agency
500 C Street, SW
Washington, D.C. 20472
The Honorable Howard M. Metzenbaum 513-684-3894
United States Senator
10411 Federal Building
Cincinnati, Ohio 45202
C-m-7
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION PHONE/FAX
The Honorable Howard M. Metzenbaum
United States Senate
140 Russell
Washington, D.C. 20510
J. Michaels 312-856-8700
PRC Environmental Management, Inc.
233 N. Michigan Ave., #1621
Chicago, IL 60601
Hie Honorable Carlos J. Moorhead
Ranking Minority Member
Committee on Energy and Commerce
Member, U.S. House of Representatives
2322 Rayburn
Washington, D.C. 20515
The Honorable John T. Myers
Ranking Minority Member
Subcommittee on Energy and Water Development
Committee on Appropriations
Member, U.S. House of Representatives
2372 Rayburn
Washington, D.C. 20515
The Honorable Sam Nunn
Chairman, Committee on Armed Services
United States Senate
228 Russell
Washington, D.C. 20510
James K. O'Steen, Director
Office of Hazardous Materials Technology
U.S. Department of Transportation
400 7th Street, SW
Washington, D.C. 20593
C-m-8
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION
PHONE/FAX
The Honorable Rob Portman
513-732-2948
Member, U.S. House of Representatives
350 East Main Street
Batavia, Ohio 45103
The Honorable Rob Portman
Member, U.S. House of Representatives
238 Cannon
Washington, D.C. 20515
The Honorable Harry Reid
United States Senate
324 Hart
Washington, D.C. 20510
The Honorable Harry Reid 702-474-0041
United States Senator
500 East Charleston Boulevard
Las Vegas, Nevada 89104
Mr. Vic Rezendes
Director, Energy Issues
Community and Economic Development Division
General Accounting Office Building
Room 1842
441 G St, NW
Washington, D.C. 20548
The Honorable William V. Roth
Ranking Minority Member
Committee on Government Affairs
United States Senate
346 Dirksen
Washington, D.C. 20510
Mr. Richard E. Sanderson
Director, Office of Federal Activities
U.S. Environmental Protection Agency
Room 2119, Waterside Mall, A-104
401 M Street, SW
Washington, D.C. 20460
C-UI-9
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
Region V - 5HRE-8J
77 W. Jackson Blvd.
Chicago, Illinois 60604-3590
The Honorable Dan Schaefer
Ranking Minority Member
Subcommittee on Oversight and Investigations
Committee on Energy and Commerce
Member, U.S. House of Representatives
2322 Rayburn
Washington, D.C. 20515
The Honorable Philip R. Sharp
Chairman, Subcommittee on Energy and Power
Committee on Energy and Commerce
Member, U.S. House of Representatives
331 Ford
Washington, D.C. 20515
The Honorable Floyd Spence
Ranking Minority Member
Committee on Armed Services
Member, U.S. House of Representatives
2120 Rayburn
Washington, D.C. 20515
The Honorable John M. Spratt
Chairman, Subcommittee on Military Application of
Nuclear Energy Panel
Committee on Armed Services
Member, U.S. House of Representatives
1536 Longworth
Washington, D.C. 20515
NAME/LOCATION
PHONE/FAX
James A. Saric, Remedial Project Director
U.S. Environmental Protection Agency
312-886-0992
FAX 312-353-4788
C-IU-10
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION PHONE/FAX
The Honorable Mike Synar
Chairman, Subcommittee on Environment, Energy,
and Natural Resources
Committee on Government Operations
Member, U.S. House of Representatives
B371-B Rayburn
Washington, D.C. 20515
Mr. Charles Terrell
Environmental Specialist
Ecological Science Division
Soil Conservation Service
6159-S
P.O. Box 2890
Washington, D.C. 20013
The Honorable Strom Thurmond
Ranking Minority Member
Committee on Armed Services
United States Senate
232A Russell
Washington, D.C. 20510
The Honorable Barbara F. Vucanovich 702-255-6470
Member, U.S. House of Representatives
6900 Westcliff, Suite 509
Las Vegas, Nevada 89128
The Honorable Barbara F. Vucanovich
Member, U.S. House of Representatives
2202 Rayburn
Washington, D.C. 20515
The Honorable Malcolm Wallop
Ranking Minority Member
Committee on Energy and Natural Resources
United States Senate
312 Dirksen
Washington, D.C. 20510
C-III-11
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FEMP-OU4ROD-8 FINAL
December 1994
FEDERAL AGENCIES AND CONGRESS (Continued)
NAME/LOCATION PHONE/FAX
Pearl Young (5 Copies^ 202-260-5076
Office of Federal Activities
U.S. Environmental Protection Agency
Room 2119, Waterside Mall, A-104
401 M Street, SW
Washington, D.C. 20460
C-III-12
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FEMP-OU4ROD-8 FINAL
December 1994
STATE, COUNTY, AND MUNICIPAL AGENCIES
NAME/LOCATION PHONE/FAX
The Honorable Louis W. Blessing Jr. 513-385-5302
Ohio House of Representatives
3672 Springdale Road
Cincinnati, Ohio 45251
Les Bradshaw 702-482-8134
Nye County Nuclear Waste Repository Project
Commissioners Building
St. Patrick's Street
Tonopah, NV 89049
Richard Dole 513-367-2111
City of Harrison
300 George Street
Harrison, Ohio 45030
Lee Fisher 614-466-4320
Ohio Attorney General
30 East Broad Street
Columbus, Ohio 43266
The Honorable Michael A. Fox 513-896-1865
Ohio House of Representatives
State House
77 South High Street
Columbus, Ohio 43266
Guy Guckenberger 513-632-5797
Hamilton County Commissioners
138 East Court Street, Room 603
Cincinnati, Ohio 45202
Phil Harris 513-285-6090
Ohio Environmental Protection Agency FAX 513-285-6404
401 East 5th Street
Dayton, Ohio 45402-2911
Laura Hegge 513-285-6357
Ohio Environmental Protection Agency
401 East Fifth Street
Dayton, Ohio 45402
Steve James 614-848-6234
Ohio Department of Health
Box 118, Bureau of Radiological Health
Columbus, Ohio 43266
C-m-13
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FEMP-OU4ROD-8 FINAL
December 1994
STATE, COUNTY, AND MUNICIPAL AGENCIES (Continued)
NAME/LOCATION
PHONE/FAX
J. Kwasniewski
Ohio Environmental Protection Agency
1800 Water Mark Drive
Columbus, Ohio 43266
614-644-2322
The Honorable Barry Levy
Ohio State Senate
2 North Main Street
Frost and Jacobs
Middletown, Ohio 45042
513-422-2001
Irene Lewis
Disaster Services Agency
141 Court St.
Butler County Courthouse
Hamilton, Ohio 45011
513-844-8020
Paul J. Liebendorfer
702-687-4670
Bureau of Federal Facilities
Division of Environmental Protection
State of Nevada
333 W. Nye Lane
Carson City, NV 89710
Liore MacCarone 513-821-1092
Hamilton County Civil Defense
2377 Civic Center Drive
Cincinnati, Ohio 45231
Mr. John Marshall, Administrator 614-265-6306
Ohio Department of Natural Resources FAX 614-262-1143
Division of Wildlife
Attn: Environmental Section
1840 Belcher Drive
Columbus, Ohio 43224
The Honorable Robert J. Miller 702-687-5670
Governor of Nevada
State Capitol
Carson City, Nevada 89710
Ronald P. Miller 513-632-8461
Hamilton County Regional Planning
138 East Court Street, Room 802
Cincinnati, Ohio 45202
C-m-14
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FEMP-OU4ROD-8 FINAL
December 1994
STATE, COUNTY, AND MUNICIPAL AGENCIES (Continued)
NAME/LOCATION PHONE/FAX
Graham E. Mitchell 513-777-0212
Ohio Environmental Protection Agency FAX 513-285-6249
401 East 5th Street
Dayton, Ohio 45402-2911
Jerry Monahan 513-244-5843
Greater Cincinnati Building and Construction
1550 Chase Avenue
Cincinnati, Ohio 45223
Maud Naroll 702-687^065
Nevada State Clearinghouse
Department of Administration
Capital Complex
123 West Nye Lane
Carson City, NV 89710
Mr. Gordon D. Proctor, Administrator 614-466-2307
Ohio Department of Transportation
Office of Planning and Environmental Services
25 South Front Street
Columbus, Ohio 43215
M. Proffitt 513-285-6073
Ohio Environmental Protection Agency FAX 513-285-6404
401 East 5th Street
Dayton, Ohio 45402-2911
Martha J. Raymond, Department Head 614-297-2470
Technical Review Services FAX 614-297-2546
Ohio Historic Preservation Office
Ohio Historical Center
1985 Velma Avenue
Columbus, Ohio 43211-2497
Mr. Tom Schneider, Fernald Project Manager 513-285-6055
Ohio Environmental Protection Agency FAX 513-285-6404
401 East 5th St.
Dayton, Ohio 45402-2911
C-I1I-15
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FEMP-OU4ROD-8 FINAL
December 1994
STATE, COUNTY, AND MUNICIPAL AGENCIES (Continued)
NAME/LOCATION
Charles E. Shumann
Hamilton County
1632 Central Parkway
Cincinnati, Ohio 45210
PHONE/FAX
513-651-9437
Sally Southard 513-887-3247
Butler County Commissioners
130 High Street
Hamilton, Ohio 45011
Peter Sturdevant
Hamilton County Department of Environmental Services 513-651-9437
Air Quality Management
1632 Central Parkway, Room 201
Cincinnati, Ohio 45201
The Honorable George V. Voinovich 614-466-3555
Governor of Ohio
77 South High Street, 30th Floor
Columbus, Ohio 43266
Mr. Larry Weaver 614-466-0698
State/Federal Funds Coordinator
State Clearinghouse
Office of Budget and Management
30 East Broad Street, 34th Floor
Columbus, Ohio 43266-0411
The Honorable Cheryl Winkler 513-574-2577
House of Representatives
5355 Boomer Road
Cincinnati, Ohio 45247
C-in-16
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FEMP-OU4ROD-8 FINAL
December 1994
CONCERNED GROUPS AND ORGANIZATIONS
NAME/LOCATION PHONE/FAX
John Applegate 513-281-7160
University of Cincinnati
College of Law, Room 415
Cincinnati, Ohio 45221
Richard Arnold
P.O. Box 73
Pahrump, NV 89041
Daniel G. Baker 513-738-1234
Delta Steel Corporation
10860 Paddys Run Road, Box 39040
Harrison, Ohio 45239
Citizens Alert
P.O. Box 5339
Reno, Nevada 89513
Peggy Collins 513-868-9053
League of Women Voters of Hamilton/Fairfield Area
5299 Dee Alva Drive
Fairfield, Ohio 45014
Leroy E. Euvrard, Jr. J.D. 513-738-0245
Safety and Environmental Staff
2345 Joyce Lane
Okeana, Ohio 45053
Lisa Crawford
Fernald Residents for Environmental Safety and Health
10206 Crosby Road
Harrison, Ohio 45030
Sam Goodson 803-740-5334
Albright and Wilson Inc.
10818 Paddys Run Road, Box 39066
Cincinnati, Ohio 45239
Dee Irons 803-649-7963
NUS Corporation
900 Trail Ridge Road
Aiken, SC 29803
C-m-17
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FEMP-OU4ROD-8 FINAL
December 1994
CONCERNED GROUPS AND ORGANIZATIONS (Continued)
NAME/LOCATION
PHONE/FAX
Daryl G. Kimball, Research Analyst
Physicians for Social Responsibility
1000 16th Street, NW
Washington, D.C. 20006
Pam Kingfisher
Native Americans for a Clean Environment
918-458-4322
FAX 918-458-0322
Box 1671
Tahlequah, Oklahoma 74465
Robin M. Madison
Rath eon Services Nevada
P.O. Box 95487
Las Vegas, NV 89193-5487
Patrick J. Malloy, Executive Director
Radioactive Waste Campaign
625 Broadway, 2nd Floor
New York, New York 10012
Dr. James Reisa 202-334-3060
National Academy of Sciences FAX 202-334-2752
2010 Constitution Avenue NW
Washington, D.C. 20418
William Rosse, Sr.
HC 61, Box 6240
Austin, NV 89310-9301
Robert M. Schwab 513-738-4825
FAT&LC
Box 126
Ross, Ohio 45061
Anthony Sears 513-738-8559
Morgan Township Trustees
1616 Bebb Park Lane
Okeana, Ohio 45053
Rev. Dr. Velma Shearer 513-836-9654
Church of the Brethren, District of Southern Ohio
124 Chestnut Street
Englewood, Ohio 45322
C-in-18
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FEMP-OU4ROD-8 FINAL
December 1994
CONCERNED GROUPS AND ORGANIZATIONS (Continued)
NAME/LOCATION PHONE/FAX
Donald H. Thiem 513-892-3740
Ross Township Trustees
3175 Hamilton Scipio Road
Hamilton, Ohio 45013
William L. Vasconi, Chairman 702-295-3751
Citizens Advisory Board for Nevada Test Site FAX 702-295-3616
6565 W. Atwood Ave.
Las Vegas, Nevada 89108
Gloria Walker 513-281-8683
League of Women Voters of the Cincinnati Area
103 Wm. H. Taft Road
Cincinnati, Ohio 45219
Dr. Gene E. Willeke 513-529-5814
Miami University
Institute of Environmental Sciences
Oxford, Ohio 45056
C-m-19
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FEMP-OU4ROD-8 FINAL
December 1994
CONCERNED CITIZENS
NAME/LOCATION
NAME/LOCATION
Ed and Agnes Ashbrook
Lesley Cusik
9521 Haddington Ct.
483 Mahogany Road
Cincinnati, Ohio 45251-2365
Oliver Springs, TN 37840
Dennis Bechtel
Dirk and Vicky Dastillung
319 Encima Ct.
3088 Hamilton Scipio Road
Henderson, NV 89014
Hamilton, Ohio 45013
Louis C. Bogar
Pam Dunn
2080 Smith Road
7781 New Haven Road
Hamilton, Ohio 45013
Harrison, Ohio 45030
Gerald L. Bradley
Kendall Garing
SW Region Water District
522 Azalea Drive
3640 Old Oxford Road
Rockville, Maryland 20850
Hamilton, Ohio 45013
Edwena Heitfield
Christopher Brown
9680 Howard Road
9457 S. Las Vegas Blvd. #93
Harrison, Ohio 45030
Las Vegas, NV 89123
James Henderson
Harry Bryson
6712 Reggie Circle
5728 Wooded Acres Drive
Las Vegas, NV 89107
Knoxville, Tennessee 37921-3919
Mr. Ron Kirk
Curtis and Sandy Butterfield
Department of Energy
4535 Morgan Ross Road
Oak Ridge Operating Office
Hamilton, Ohio 45013
200 Administration Drive
Oak Ridge, Tennessee 37830
Jim Chandler
P.O. Box 64
Melvin and Jean Knollman
Hamersville, Ohio 45130
7513 Willey Road
Hamilton, Ohio 45013
Marvin and Doris Clawson
586 Charlberth Drive
Marilyn J. Littlepage
Hamilton, Ohio 45013
1851 Balzac Drive
Las Vegas, NV 89115
Diane Cravotta
P.O. Box 91971
Ms. Julie Mason
Henderson, NV 89009-1971
Tetra Tech Co.
4700 King Street
Ken and Lisa Crawford
Suite 500
10206 Crosby Road
Alexandria, Virginia 22302
Harrison, Ohio 45030
c-m-20
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FEMP-OU4ROD-8 FINAL
December 1994
CONCERNED CITIZENS (Continued)
NAME/LOCATION
NAME/LOCATION
Lathia McDaniels
Valarie Rush
2396 Valley Drive
407 Sycamore, #2
Las Vegas, NV 89108
Trenton, Ohio 45067
Gerda McFarland
Carol A. Schroer
9035 Winton Road
9886 Hamilton Cleves Road
Cincinnati, Ohio 45231
Harrison, Ohio 45030
Bob and Betty McKay
Spencer R. Seymour
2 New Haven Drive
2218 Park Avenue
Harrison, Ohio 45030
Cincinnati, Ohio 45206
Maggie B. Merritt
Steve and Peggy Shafer
63 Branch Hill Drive
8188 West Mill, Apt. 258
Harrison, Ohio 45030
Cleves, Ohio 45002
Donald and Kathleen Meyer
Evelyne Shaver
11785 Edgewood Road
9740 Baughman Road
Harrison, Ohio 45030
Harrison, Ohio 45030
Richard Nocilla
Edward B. Silberstein, M.D.
823 Spyglass Lane
3530 Verger Lane
Las Vegas, NV 89107
Cincinnati, Ohio 45237
Kathy Furlong
Rosa Silver
2209 Birch Drive
PAI
Hamilton, Ohio 45014
1050 East Flamingo Road, Suite 367
Las Vegas, NV 89119
Norma J. Nungester
8574 Mount Hope Road
Connie Simkins
Harrison, Ohio 45030
P.O. Box 333
Panaca, NV 89042
Mary O'Brien
P.O. Box 8402
Lawrence Stebbins
Pah rump, NV 89041
3944 Silax Drive
Hamilton, Ohio 45013
John B. Price
5474 Nottingham Place
Joanne S. Stockill
Fairfield, Ohio 45014
4625 Kay Place
Las Vegas, NV 89107
E. Paul Richitt, Jr.
3575 W. Badura Ave.
Angela Supe
Las Vegas, NV 89118
3922 Patty Drive
Okeana, Ohio 45053
C-III-21
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FEMP-OU4ROD-8 FINAL
December 1994
CONCERNED CITIZENS (Continued)
NAME/LOCATION
William L. Vasconi
6565 W. Atwood Ave.
Las Vegas, NV 89108
J. E. Walther
3686 Cincinnati-Brookville Road
Hamilton, Ohio 45013
Jack and Roberta Wamdorf
4441 Race Lane Road
Okeana, Ohio 45053
Edwa Yocum
9860 Hamilton Cleves Road
Harrison, Ohio 45030
{Catherine L. Yuracko
5708 Stallion Ave.
Las Vegas, NV 89108
C-III-22
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FEMP-OU4ROD-8 FINAL
December 1994
ATTACHMENT C.IV
PUBLIC MEETING TRANSCRIPT
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December 1994
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FEMP-OU4ROD-8 FINAL
December 1994
TABLE OF CONTENTS
Page
Public Meeting (March 21, 1994), Harrison, Ohio C-IV-1-1
Nevada Test Site Community Advisory Board Meeting (May 11, 1994), Las Vegas, Nevada C-IV-2-1
C-IV-i
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1
US DEPARTMENT OF ENERGY
PUBLIC MEETING
MONDAY, MARCH 21, 1994
THE PLANTATIONS, HARRISON, OHIO
SPANGLER REPORTING SERVICES
PHONE (513) 381-3330 PAX (513) 381-3342
C-IV-1-1
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MR. 5TEGNER: Good evening. Thank
you for coining. My name is Gary Stegner. I work
at the Department of Energy at Fernald. Tonight
we're going to be discussing Operable Unit 4, which
are the silos, Silos 1 through 4 including the
basic five silos.
Briefly, very briefly, the way we're
going to set the evening up is, if you look at the
agendas on your chair, we'll start off with a
series of presentations which should last about a
total of about 45 minutes.
Following the presentations we'll
have an informal question and answer section. This
is Informal as distinguished from the formal
comment period that will follow. During the
informal session, it will be a give and take with
the panel and any of the other experts who we might
have out thera in the audience to answer your
questions ragarding Operable Unit 4. We do want to
keep focuaad as much as possible on Operable Unit
4 .
Following the informal questions and
answers, what wa'll do is take a break for about 10
or 15 minutes. Then we'll come back, and than
SPANGLER REPORTING SERVICES
PHONE (513) 381-3330 FAX (513) 381-3342
C-IV-1-2
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we'll have the formal comment period. The formal
comment period is for the record. You know, it is
something that will be included in our
Responsiveness Summary, and it will be included in
the Record of Decision for Operable Unit 4.
Before I introduce the panel tonight,
a few logistical announcements. People will
remind, I think everyone is registering at the door
as they come in. If you want to make a formal on
the record comment, please designate that when you
sign in. The way I will do that is, following the
break when we begin that, I will go through there
and find out the number of people who want to and I
will call them up.
Don't think that you have to come up
here to the microphone tonight to make your formal
comments because there are comment cards on your
chairs. Also you can give those to me after the
meeting. You can send thea to Amy at the
Department of Energy at Fernald, and you can also
just write out your comments and send them to us at
the Department of Energy at Fernald. We ask that
you have those to us by April 20th, however.
I think there is lee wftttr aoaeplace
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in this room. Rest room are out the door there.
There's also a pop machine if you want to get
something to drink during the break. We encourage
you to take the handouts that we have scattered
throughout the room, if you want to find out more
about Operable Unit 4.
So let me get on with introducing our
panel tonight. We have Randi Allen/ who is the
Operable Unit Four Manager for the Department of
Energy here tonight. Wilf Pickles, her counterpart
with FERMCO, the manager there. We have Ed
Skintik, Regulatory Compliance for the Department
of Energy. His counterpart, Eric Woods, FERMCO
reformatory programs; and also Dennis Nixon, the
Assistant Unit 4 Director. So without further ado,
I will turn it over to Randi Allen.
MS. ALLEN: We also have Eric Woods
who works for FERMCO. All I'm going to do here
real quick ii, in case there's anybody in the
aud. ence that is not that familiar with Fernald,
I'm just going to introduce you to the operable
units, and then turn it over to Dennis Nixon. He's
going to 90 through some details on Operable Unit
4 .
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Sure everybody has seen this before.
This is just to show you the location of the
Fernald. It's a 1,050 acre site located about 17
or 18 miles northwest of Cincinnati. What I'd like
to do here real quick is just run through the other
operable units to you, and then I'd like to present
a schedule. We're going to have a similar meeting
for all the other operable units in a little bit of
a later time scale here. I'll show that to you in
a minute.
Operable Unit 1, which you see in the
orange, is the waste pits, and Operable Unit 2 is
called other waste units. That's the flyash piles,
the south field, the sanitary field, and lime and
sludge fields. Operable 3, that's a bigger
operable unit. That's all the facilities located
on the site. Operable Unit 4 is obviously the
silos, one of the smaller units. And Operable Unit
5 is everything else not shown on the grid,
environmental media, the soils, and the ground
well.
Here's a schedule for the other
operable units. As you can see, in the yellow is
the period between like whenever you see the
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remedial investigation report, that's when the
documents are beginning to become available for
review by the public. Operable Unit 4 down there,
we're right now between the feasibility stage,
proposed plan. We've initiated preparation of a
Record of Decision.
Some places you see the feasibility
study, and shortly thereafter the US EPA, the DOE
headquarters, and the Ohio EPA will review and
comment on the document and approve the document.
It becomes available for the public to review, and
they'll have this type of evening for each one of
the other operable units.
This is the process we go through to
get in the file remediation. Actually, this is a
pretty simple version of it, if you can believe
it. Right now in Operable Unit 4 we are right here
in beginning preparation of the Record of
Decision. So we're getting ready in the near term
to Issue the Record of Decision of Operable Unit 4
that gets submitted to the US EPA and Ohio EPA in
June of this year.
After that, once we have reached an
agreement on what that Record of Decision flhoilld
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say, the comments you provide on this proposed plan
are incorporated into that document. So once we
issue that Record of Decision, we will begin final
remediation.
At this time what I'd like to do is
introduce Dennis Nixon, and he is going to run
through the documents you guys have been asked to
review.
MR. NIXON: Good evening. What I'm
going to do, present this evening, is a brief
history of Operable Unit 4 and how we got to where
we're at today. As Randi said, Operable Unit 4 is
one of five operable units at Pernald. It's
located on the western portion of the site next to
Paddy's Run Creek. This is an areal shot of the
operable unit area.
There's a geographic area
encompassing the four waste storage silos. K-65
silos, which you'll see to the south, here Silos 1
and 2 contain the K-65 residues. Silo 3 ii ••
contains the cold metal oxide material. Silo 4 is
empty and was never used.
The operable unit also consists of a
radon treatment system and underground decant flump
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tank that was used in the process o£ filling the
silos, the surfaces soils, subsurface soils, and
the berm soils, as well as any perched water that
nay be encountered during the final remediation.
The silos were constructed in 1951
and 1952 for use as interim storage vessels for
defensive program waste that was being produced at
that time at the Melloncrock Chemical Works in St.
Louis.
I have a group of shots on the
construction I'll just run through. This is a -- I
believe the foundation being prepared for Silos 4,
3, 2, looking south. The silos were constructed
Silos 1 and 2 were constructed In the winter
months, which caused some problems within the
construction, causing problems with shutting down
the concrete pours which resulted later in cold
joints, which when they stopped pouring the
concrete, which we'll show you In later pictures,
that later would form cracks in the sides of the
silos.
Silos 1 and 2 during the construction
phases, shot looking to the west during
construction. The silos wert filled AuflAQ Up fell!
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1950. If you'll notice the cracks on the south
face where thoae cold joints in the conatruction
occurred. Eaaentially due to those cracks, there
later was an asphaltic cover. Here again the
cracks in the sides of the silos looking to the
north, Silo 1, 2, and 3.
In 1964 those cracks were sealed with
a Gunite material, and then an asphaltic sealant
was placed on that, and the first of two beras were
added. The beras were added not only for -- They
were mainly added for structural stability. They
were also there to provide some shielding due to
the radiation that was given off by the silo
material. The decant sump tank, which was a buried
tank, this is the -- an access way, a corrugated
pipe that was used to access that tank after the
berm was added.
And this is an areal shot of the
original berm. Again, the K-65 silo is here. In
1983 that berm, the original berm, had resided, and
we had another berm added in 1983 due to the
erosion problems. Furthermore, in 1987 these dome
caps were placed on the K-65 silos to enhance the
structural integrity ot the done itself. fhi fOftIR
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was added to insulate the silos and to assist in
the radon problem, which we'll talk about a little
later.
Again, in 1991 — I'll talk about the
history, is the clay that was added. We had a
removal action in 1991. Due to the radon concerns,
the chronic radon emissions, as well as concerns of
the silos collapsing and releasing material, we
added a one-foot layer of bentonite clay to the
residues.
As ' I said, the material was added up
until 1958 in the silos. The majority of the
material, as I said, was processed at -- the K-65
material was processed at the Melloncrock Chemical
Works in St. Louis. Essentially, they had a
problem in St. Louis with storage. So we
constructed the silos at Fernald for storage of
that material. It was shipped from Melloncrock as
well as Lake Ontario Ordinance Works to the Fernald
si te.
You can see here the incoming drums
that were received at the site. Those drums were
slurried in the drum handling building. They were
reslurried, pumped in thi lilO. fhftfc ftfttlfill Mil
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allowed to ait over night, essentially, and the
liquid was decanted off into the decant sump tank
that I spoke of earlier.
As well, some K-65 material was
processed at Fernald in our refinery. Those
raffinates were pumped in a liquid form through the
trench that you see here running east west to Silo
2.
The Silo 3 material was all processed
on site here in our refinery at Fernald. Those
raffinates were unlike the K-65 material, would
calcine at a very high temperature and would rot,
and would pneumatically convey through the same
trench to the pipe in Silo 3.
The K-65 material generally takes the
form of a wet clay material ranging from gray to
brown. It is defined as technically as 11E2
by-product natftrial under the Atomic Energy Act,
which makes that an exception from the RECRA
regulations, even though we do consider RECRA as a
helpful and appropriate requirement.
The material in K-65 silos generally
the contaminates of concern are radium, thorium,
and lead-210. Due to that radium contanfe, the
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residues give off a considerable amount of radon
gas, which again was the reason for the removal
action to add the one-foot layer of bentonite clay
in 1991.
There are elevated concentrations in
the residues, the untreated residues, of barium and
lead. There are very low concentrations of PCB and
trlbutyl phosphate used that probably occurred
during the processing at the refinery or at the
Melloncrock Chemical Works.
Total volume of material, including
Silos 1 and 2, including the bentonite clay is
roughly 8,900 cubic yards. In your packets you
have tables from the remedial investigation, the
actual characteristics of the residues themselves.
I won't go over those tonight.
The Silo 3 material is called cold
natal oxidaa. Ac I said, thoae are a dry powdery
material like a talcum powder, again defined
technically as 11E2 by-product material, the much
lower concentrations of radium nuclides in the Silo
3 materials.
The predominant contaminates of
concern here are the thorium-230, uranium, and
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lead-210 again. The Silo 3 material also leaches
rare earth metals listed here. Little to no
organics in the Silo 3 material due to that high
temperature calcine process.
And here the total volume of Silo 3
material, approximately 5,000 cubic yards, for a
total residue volume of roughly 13,000 cubic yards
to be processed in our final remediation. Again, I
have the tables of the characteristics of that
waste.
In addition to the residues, Operable
Unit 4 will remediate surface soils, contaminated
surface soils, contaminated berm soils, the
subsurface soils below and surrounding the silos,
and again any perched water that is encountered
during the final remediation.
As Randi said, we are in the process
of a remedial investigation feasibility study. We
currently have completed our remedial
investigation. It is conditionally approved by the
US EPA. The feasibility study and the proposed
plan have been completed, and again are
conditionally approved by the US EPA.
We are at the phase that we ari
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getting the public comments, public involvement in
our proposed plan, and responding to the comments.
We are making progress with our Record of Decision
based on this proposed plan. It's due to the
agency in June of this year. That will include a
Responsiveness Summary which will respond to the
questions and comments that are raised tonight and
in other meetings or other discussions, formal
comments.
And then after that Record of
Decision, hopefully by October, November time frame
of this year, we'll have a Record of Decision.
We'll be moving forward into the remedial design
and remedial action phases of the project.
All of the points are Important that
we make and go into detail with later. The
documents that have been prepared today are fully
integrated with the NEPA process and act as the
site's draft of the Environmental Impact
Statement.
In the feasibility study, we
evaluated a full range of alternatives, you know,
lternatives that included on-site and off-site
isposal, various treatment options/ and the DOB
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proposed alternative, preferred alternative, is as
follows:
Essentially, the major components of
that preferred alternative are to remove the
residues from the silos, stabilize those residues
by the use of vitrification and dispose of those --
that vitrified waste off site at the Nevada test
site .
Again, we evaluated a full range of
alternatives, and those alternatives were evaluated
under the nine criteria which were provided by
CERCLA. We're currently involved with the
modifying criteria, which ia to get the public
involved. Again, the major components, to remove,
treat, and dispose of the materials in the silos;
but in addition to that, we're going to be
demolishing. After the residues are removed and
treated, we'll be denolithing and decontaninating
the silos themselves, the remediation facilities
required.
We'll be excavating any contaminated
soils, that's surface and subsurface soils, the
perched ground water. And then, of course, the
disposal of the soils and debris will be consistent
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with the Operable Unit 3 and Operable Unit 5
Records of Decision, respectively. They will not
be finally disposed of with this operable unit.
As for the cost of this action, the
cost is roughly $90 million from start to finish,
which is made up of the capital cost for the
facility as well as various remediation costs and
operations and maintenance costs.
This is the schedule. Essentially,
we are at the end of the proposed plan period. We
are entering into the Record of Decision. We have
a draft Record Decision right now at the DOE
headquarters that's being reviewed. We have
initiated some work on the remedial design work
plan based on this proposed plan.
Following the Record of Decision, we
will go into full-blown remedial design, and then,
of course, remedial action will follow. The
construction you see here, the construction phase,
will be roughly through March of 1997.
We'll initiate the remedial
operations shortly thereafter, and the facilities
will operate roughly until the year 2,000. After
tjie operations are complete, this is the period in
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which we demolish and decontaminate the facilities
that were used to treat and stabilize the
materials.
There are a couple of key questions,
my last couple of slides here, that need to be
answered. Why remove the silo waste at all? I
think everyone that's involved with this, this
project, will agree that the silo materials need to
be taken out of the silos and put into a safe
configuration.
The silos have questionable
structural integrity. There is the potential,
always the potential, for a continued leakage from
the silos, proposes an unacceptable risk to both
the off-site residents as well as any future
trespassers for the site.
After they've been removed, why
vitrify these wastes? Vitrification is a very
i t' « a proven technology, and due to our extensive
rehabilitative studies, we found it to be a very
good treatment technology for the K-65 silo
materials. The silo K-65 materials have high
silica contents which is very conducive to this
process.
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There is significant volume
reduction. There is up to a 60 percent reduction
when vitrifying the K-65 materials. We have
significant reduction of radon emanation rate.
Essentially, once the material has been vitrified,
it has the radon flux of the common building
materials like bricks and wood.
It also reduces the leachability of
metals that are in the material. For example,
those metals we are concerned with listed here, the
untreated waste, the leaches in excess of the RECRA
maximum allowable concentration; after
vitrification all well below the regulatory
limits. Radon emanation rate, very high for the
untreated waste, and it is obviously a significant
reduction there.
That's all 1 have for you this
evening. I'd like to Introduce Eric Woods, who's
going to talk in detail on the process in which we
integrated the CERCLA and NEPA in these documents.
MR. WOODS: Good evening. What I'd
like to do is provide a short presentation on
CERCLA/NEPA integration, basically focusing on
three things: a little bit about fcht hiltflfV 6f
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NEPA compliance at the site, and then look at the
Operable Unit 4 feasibility study and proposed
plans specifically and kind of walk through how we
are integrating NEPA into these documents, and
then, lastly, provide a summary of the Operable
Unit 4 environmental impacts and the cumulative
environmental impacts.
So we're all on the same page with
respect to NEPA, NEPA is the National Environmental
Policy Act signed into law in January of 1970. The
goal of NEPA was to provide a national policy on
protection of the environment, and one of the
specific aspects of NEPA in order to accomplish
this goal is that it established a process by which
federal agencies, such as the Department of Energy,
will need to consider environmental impacts when
they made decisions.
This is formally known as the
Environmental Impact Statement Process, what we're
going through here for Operable Unit 4, and a very
important aspect of that is the public involvement
aspect.
The first Environmental Impact
Statement proposed at the Fernald site wftf ft
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renovation EIS. When the site mission changed from
production to remediation, the need for this
document went away, and the Department of Energy
subsequently canceled the renovation EIS.
As I said, the mission was changing
at that point from production to remediation, and
there was still the need to address NEPA for the
clean-up activities that were being planned at that
time. Therefore, the Department of Energy issued a
second notice of intent in May of 1990. This was
followed by scoping meetings in June, and this
«
basically announced that it intended to prepare an
Environmental Impact Statement for the Operable
Unit 4 remedial activities.
This document was designed or was
planned to do a couple of things. Mainly, it was
to look at the environmental impacts of the
Operable Unit 4 alternatives, specifically, and
reach a decision for OU4 and OU4 only.
However, because it was the lead EIS
or the first of five integrated documents to be
prepared at the site, it was also to address
cumulative impacts, and we'll walk through the
document and I'll show where and how wa've doAA
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that.
I'll mention that the remaining
operable units, 1, 2, 3, and 5, will also be
prepared as documents at a lower level, and we'll
make decisions for those operable units
speci f ically.
I think a key question is, why did we
integrate, why not do an individual EZS process and
an individual Rl/FS process? The main reason is
there's a similarity between the two. The Rl/FS
process under CERCLA, there's an awful lot of the
same things we need to do with the EIS under NEPA.
Primarily, NEPA evaluates the site, the
alternatives to reach an end goal, and it does
mention some of the criteria we look at. In the
end it identifies preferred alternatives. These
are similarities in the two.
There are some differences, primarily
in the way the alternatives are evaluated, and
where these differences occur is where we simply
utilize the CERCLA framework and infuse or
integrate NEPA into the documentation.
This does several things for us. It
avoids duplications, the duplications of priparing
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two separate documents. It also minimizes the
potential for inconsistencies, and it's consistent
with DOE policy.
Looking specifically at the Operable
Unit 4 documentation, I want to point out the
various parts of the document where NEPA has been
infused or integrated. The first place is right up
front in the Executive Summary in the introduction
in Chapter 1.
We provided a discussion of
CERCLA/NEPA or NEPA/CERCLA integration, basically
what role the various documents play, why we do
this, how the remaining operable units will
follow. This just gives an overview of the
process.
The next place where we have
integrated NEPA is in Chapter 4. This is really
the most important part of the document from the
NEPA perspective. This is where we identify
environmental impacts that we anticipate for the
alternatives that have been identified.
Basically, as you go through the
altarnativaa, there is a short-term effectiveness
discussion and a long-term effectiveneis diflCUflfliOA
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for each alternative. Under short-term we provided
an analysis of the environmental impacts
anticipated during remedial activities. And then
in the long-term effectiveness section, we provided
an analysis of environmental impacts that are
anticipated after remedial activities are
complete.
When we evaluate environmental
impacts, these are some of the criteria we look
at. As you go through the document, you will see
short-term environmental impacts, just this is a
format of the evaluation you will see. Rather than
talk through these, I thought I would provide some
photographs to kind of illustrate what we're
talking about.
This slide illustrates several
things. This is Paddy's Run. Obviously, water
quility if rtlftted to Paddy's Run, Also the belton
king fisher and the various habitats of biotic
resources which evaluate wildlife, wildlife
habitat, any species that may be listed at the
state or federal level protected.
Also flood planes, there are flood
planes we must deal with along the Great Miami
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River. There's also flood planes along Paddy's
Run. Flood planes extend to various points on the
banks of Paddy's Run depending on what the
topography is like in that area.
Another example of biotic resources
is this overhead. This is along the eastern
portion of the site, and this basically shows a
typical field or pasture type habitat we have, and
as we went through the cumulative Impact analysis
and for the purposes of that analysis looked at the
possibility of on-site disposal, this was typically
the kind of habitat that we identified being
disturbed.
Another important aspect is cultural
resources. Cultural resources could be historic or
prehistoric artifacts, such as projectiles or some
of the ceremonial pieces that are identified on
this overhead. They also could be structures such
as homes that this area is very rich in cultural
resources, and we have an active program to insure
that we don't impact these types of things.
This is another shot of the flood
plana araa. This Is along the Great Miami River.
You can see the site in the distance. Xfc's UPiidi
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down. The flood planes obviously extend in the
flat, cultivated fields adjacent to the Great Miami
River, and what we're concerned about when we look
at flood planes is basically changing elevations.
A flood, if it were to occur, either
a hundred-year flood or a 500-year flood, it's
typically accustom to proceeding a certain distance
from the river, in the case of Paddy's Run from the
stream. If we change elevations significantly, the
water can no longer go where it was accustomed to
going and will magnify down stream floods.
Kind of hand in hand with the flood
planes are wetlands. This is a typical wetland
that we have on site, basically this drainage ditch
with the cat tails. We have about 35 acres of
wetland on the Fernald site, and approximately 10
to 15 fall under this category of drainage ditch
wetlands. There's a larger area of forested
wetlands in the northern part of the site, which
are a little bit higher quality than this.
When we look at impacts in the
Operable Unit 4 document, both specific and
cumulative related to all of the operable units,
drainage ditch wetlands are primarily wetlands that
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could be impacted. Wetlands on site are shown in
red. This is a large area of forested wetlands I
was speaking about.
We're taking steps, as we did very
early on in the process, to avoid this wetland
area. However, if we cannot avoid this area, we're
developing a strategy to compensate for the loss of
wetlands. We're going to be negotiating that with
the Army Corps of Engineers and various other
agencies. So those are just some of the kinds of
things we look at as we go through our impact
analysis.
4
Back to the document itself, also in
Chapter 4, at the end of Chapter 4, we have several
short sections that we've added to comply with NEPA
guidelines. These are irreversible, irretrievable
commitment of resources and several others. So
that essentially takes care of the body of the
feasibility study.
As I said, this document is
functioning for the Environmental Impact Statement
at the site. So the other aspect of it is
cumulative aspects that occur in Appendix I in the
feasibility study. We've taken remedial
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alternatives, the latest information we had
available, and provided an analysis of the impacts
related to the overall remediation of the site.
Obviously, we're going to be
proceeding through the RI/FS process for the other
operable units. Decisions will be made for those
other operable units, and that -- the decisions
that are made at the very -- from the LRA's that
we've utilized for our evaluation in Appendix I.
Zf that happens, we'll update this analysis and
provide it for future feasibility studies for
submittance for other operable units.
Looking at some of the impacts we
anticipate for OU4 specifically, alternative, as
Dennis discussed, was renoval, vitrification of the
contents of the silos, removal and on-property
disposal contingent upon decisions in OU3 and 5 for
storage.
Basically, there's an overall
beneficial impact for eliminating or controlling
the source or potential source of contamination of
the silo, contents in the silos. On the negative
¦ids, the excavation of the Operable Unit 4 area
and the potential excavation for on-site disposal
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facility will result in leas than 15 acres of the
site being disturbed in the short tern. Depending
on the decisions that are made in Operable Unit 3
and 4, a portion of these could be committed in the
long-term for disposal. Also potential for a small
area of wetlands to be disturbed as a result of the
excavation activities. Again, we're looking into
compensating for the loss of these wetland areas.
And minor increases in traffic due to
goods and materials, fill material, being brought
on to the site. This is on the order of ten trips
per day for the life of the remedial activity. And
those we've identified as substantive. There are
others, some of the other categories are evaluated
and discussed in the document as well.
As far as cumulative impacts go,
again, an overall beneficial impact due to the
elimination of sources of contamination. Due to
the potential sources to the air, water, and soil,
again, we're looking at all five operable units
being remediated.
So we've got a larger area that will
be disturbed during that activity up to 250 acres.
And, again, the LRA's that we use for thii
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evaluation primarily looked at on-site disposal.
So this is somewhat of a worst case scenario.
Hand in hand with the disturbances at
the site, a portion of habitat, such as the field
habitat I showed in the overhead previously, and
some forested areas in the northern part of the
site would be disturbed.
He do have -- Probably the most
important impact we need to identify is, we do have
the potential to lose most of the wetland areas on
the site. He are trying to work with the various
crews to insure or to the extent possible avoid the
wetland areas. Hetlands that we do lose due to
excavation or commitment of land, we will begin to
compensate or mitigate the loss of those areas.
In the area of socioeconomics, which
looks at impacts from the action to the local or
area economy infrastructure such as public
services, we do expect a significant amount of
material to be purchased in the area.
And in addition, we've done a lot of
evaluation as to the level of work force at the
¦Ite, and we expect the level to stay fairly
consistent through the life of the renedl&l
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activities. Therefore, socioeconomic® in the short
term should be primarily beneficial. And as we
complete remedial activities, the need for a lot of
the work force will decline, which could result in
minor socioeconomics after the activities are
complete.
That concludes my presentation, and
I'll turn it over to Randi Allen.
MS. ALLEN: I just have a couple
slides here. These are the last three slides in
your package, and I promise I'm not going to go
through all of those. Sitting up there looking out
at you guys, looks like not a moment too soon I'm
winding up this packet here.
This is really what we've gone
through in Operable Unit 4 so that we could relate
what we are intending to do with the residue to
advlflt you out there. Initially starts back when
we submitted the document to US EPA and Ohio EPA,
the document and the EIC.
Essentially, what we've gone through
here is beginning really in October, we have tried
to fleet with the public to tell them what is in the
proposed plan and the feasibility study, end hlVA
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gone through really risk assessment, ground water,
and different little round tables I guess.
And when we get down to the bottom of
this first slide, this is pretty much when we
started the distribution of this document. Because
it's an EIS the distribution of this document was
2,500 copies or something along that. This takes
us pretty much to where we are now. This is March
7th, this is just notifying this is an EIS
feasibility study.
The last sheet here will take us to
where we are now, to March 21st. And as I think
Dennis has told you, April 20th is the date that we
are asking for everybody's comments. You can give
us some comments this evening if you'd like to,
written or verbal comments. And I think the last
chapter in the proposed plan, there's -- also you
can send it, there's the address for submitting
your comments to the US DOE, Ken or Gary, or you
can send them out to Jim Saric.
What we're going to do at that point
in time is prepare a responsiveness study. When we
submit our Record of Decision down here on June
10th to US EPA, that RespoflSlvenafll IvlAftlfy tflll 6l
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part of that document. So that's your opportunity
to see how we responded to your comments.
This last one down here, there's been
quite a few questions on what kind of public
Involvement do we have from this point on. Now,
they have revised the Community Relation Plan in
1986 and 1969. And it takes us pretty much up to
the Record of Decision point; is that right, Gary?
NR. NIXON: That's right.
MS. ALLEN: So what we need to do,
in the next three months I think the Public
Relations Department will be sending out some
questionnaires and folders to members of the
community to get some communication, when we get
into remedial design what part do you want to play,
how involved do you want to be to, do you want to
continue to have round tables.
We need to get some communication and
revise that plan. I think this is a pretty
standard format for all of the operable units once
they get to the feasibility study point as we go
through the round tables and have a public
meeting.
At thi. tin* what I'd likl tfl dfl ll
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ask Jim Saric from US EPA and Tom Schneider from
the Ohio EPA if they'd like to make some comments.
MR. SARIC: I guess when I look at
the meeting we're having here tonight, the proposed
plan for Operable Unit 4 silos, I kind of sat back
and started thinking about some of the first times
I was involved in this project in 1987 for a few
months. And then I went and was working for EPA on
another Department of Energy project and came back
several years ago in '91, and the K-65 silos were
an issue of a very heated debate. They were a very
strong public concern.
I think if it was the one symbol of
the Fernald site that was representative, it was
the K-65 silos, and a very significant source of
contamination, a very significant source of concern
for all of us Involved.
And I think today we're really at a
key pivotal point, a crossroad, where DOE is
proposing a remedy, one which we've looked at and
reviewed several times as well as Ohio EPA. And
we've looked at various options, and we think we've
got one that's very reliable, a very good option
for handling thli material.
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And, you know, we're hopefully going
to be able to move forward. We're encouraging you
to cone forward with comments on this thing, and
then you'll have the Record of Decision coming in
in June which will basically begin finalizing this
decision. Obviously, if you look at some of the
earlier slides, there's still a lot more work to be
going on.
I mean, this is a decision on what
we're going to do, and now it's actually let's go
out and do it, remove the silo waste or whatever
the action. This will continue, and there's a lot
of work to be done, and I think the dates in 2,000
are, you know, ongoing as far as when activities
will be completed in 2,000 or 2,002.
So I guess, personally, I think we're
at a big crossroad here, and I guess it's important
really to understand what action is being taken,
and I encourage all your comments to give. If
you've got any questions, please ask any of us,
myself or Tom Schneider, and we can go over those
things with you. Thanks.
MR. MITCHELL: At the last meeting I
showed a new table of organization for the ntw
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officers for the facility over the site, and Tom
Schneider has been selected as the Fernald
Coordinator, and this is his first meeting.
MR. SCHNEIDER: Well, I just want to
reiterate what Jin said. I think he said it very
clearly. We're at a very significant point in the
process. You know, we've all came a long way, and
you're all to be congratulated for having stuck it
out so long.
We're finally at the decision point.
We've spent all this tine investigating this site,
now we're making the decision. Now is not the time
to give up on your involvement, and now is probably
the time to make your comments count the most.
Your comments on this plan and the future proposed
plans is really where you have a chance to make a
substantial difference.
We along with US EPA participated in
the review of these documents and the proposed
remediation, but we're always open to your
suggestions and comments. So like I said, we look
forward to your comments on this document. If you
have questions, we'll be here to answer them.
in the future there will bl prflblbly
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a few more of ua from Ohio EPA. We're hiring some
more staff, so hopefully that will be a little more
proactive to your needs and help you out as far as
information you might need. So like I said, feel
free to contact me outside of this at the office or
wherever. Thanks.
MR. STEGNER: Thank you. What we'll
do now is, we'll have an informal question and
answer session. It might be best if you use a
microphone back there. If you don't feel
comfortable, just stand up and shout it. We have a
recorder here tonight. Please just state your name
and the question, and we'll let the panel pick it
up. So whoever wants to be first, feel free.
MS. NUNGESTER: I'm Norma
Nungester. I'm a Fernald resident, and a member of
Fresh. I have a question of Dennis Nixon. He made
the statement that I don't agree with, and I
wondered if he could clarify for me. He said that
when you vitrify waste, it reduces radon emanation
to that of building materials. To my
understanding, when you vitrify radionuclides, that
they still ara very, very hot.
MR. NIXON: That's correct. Th«
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concentrate, due that reduction, is the radon
generation from the treated waste itself that is
significantly reduce. The radon is actually held
up, and the surface area is significantly reduced.
Did you get every other word?
You're exactly right, that due to
that fact that there's a significant volume
reduction, you actually concentrate the
radionuclides, so you have a higher concentration
of say uranium in a set volume, but the radon
itself is much less. The generation or the
emanation from the vitrified waste is much less
than in its natural form.
MS. NUNGESTER: Okay, thank you.
MS. YOCUM: Edwa Yocum, Fresh member
and a resident of the Fernald area. I was asking a
question, this concerns Subunit C2 on your
preferred alternative demolition removal on
property disposal. When you were talking about the
OU4 NEPA compliance with the substantive cumulative
Impact up to 250 acres of surface disturbance, does
that mean that would be what would be part of where
the waste will be put?
mr. WOODS: Yeah. Again, w$ lookfld
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at an LRA and assumed on-site disposal.
MS. YOCUM: Okay.
MR. WOODS: And that acreage would
incur areas where waste would be disposed of.
MS. YOCUH: Okay. Then, you also
are talking about the loss of 220 acres of
habitat. Is that included in the 250 acres?
MR. WOODS: Yeah. That 250 would be
a total that would occur during the short term, in
other words, during excavation activities. Once
remediation is completed, we would look at
approximately 220 acres being permanently
committed, so yes, that's correct.
MS. YOCUM: Okay, all right, that's
what I wanted to know.
MS. NUNGESTER: Can you expand on
that permanently committed? I missed something.
Permanently committed for what, waste disposal
facility?
MR. WOODS: Yeah, correct.
MS. NUNGESTER: Not for the waste
itself but for the --
MR. WOODS: For the facilities that
would house the waste.
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MS. NUNGESTER: That's the inground
facility, the upgrade vault, as you so say?
MR. WOODS: Correct.
MS. NUNGESTER: Now can you give me
an explanation of what is in an upgrade vault?
MR. WOODS: The alternatives that we
used for the evaluation utilized the vault concept,
which would be a portion of the waste being
disposed of below grade, and, you know, basically a
portion above. There would be facilities that the
waste could be retrieved from, and what we used was
the calculation of the area.
MS. NUNGESTER: Disposal neani
permanent ?
MR. WOODS: Yes.
MS. NUNGESTER: But now you're
talking interim?
MR. WOODS: Well, what I'm saying is
the design of the facility wasn't as important as
the area that the facility could include. Designs
are going to be finalized as we go through the
remedial process.
MS. NUNGESTER: Well, this is
another thing, when you 90 fchfOU^K thl ftA ftlld
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4 C
that's where the final decision and designs are
actually made
MR. WOODS: Correct.
MS. NUNGESTER: -- how can you come
out with a Record of Decision before you actually
know what the vault is going to look like and if it
is really going to do the job?
MR. WOODS: No, you cannot reach a
Record of Decision until, you know, we've gone
through the full analysis of what the vault will be
designed like and how it will work. What we did is
utilize the alternatives that were available at
that tine for the purpose of the evaluation, which
is rea'lly the best we can do. We can't foresee.
MS. NUNGESTER: Okay. As of today?
MR. WOODS: That's correct, that's
correct. As we go through the various operable
units and decisions are made as to the final design
of the vaults and changes are made to the area,
that may be required. We'll update the analysis
and provide it in the future integrated documents
for the other operable units.
MS. NUNGESTER: Okay. So then our
decisions of the -- So your AlfctfAAfclvil fflf fehl
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Unit 4 can change by the time after arriving at a
decision?
MR. NIXON: We were specific with
the subunit wastes the Record of Decision. For
Operable Unit 4, specifically the Record of
Decision, the proposed plan in the future Record of
Decision will be that the Subunit C waste is — you
remember us talking about being held in abeyance or
delayed operable units, the Subunit C waste will be
handled in accordance with the Records of Decisions
for Operable Unit 3 and Operable Unit 5,
respectively. Okay.
So as far as our Record of Decision,
essentially we carry it through the removal of the
soil, interim storage of that soil in accordance
with Removal Action 17, which is the management of
those soils, demolition of the structures and
storage of that debris in interim until 0U3 comes
up with a final decision for the debris.
OU5 will have a final decision on how
the soils will be treated, and those all integrate
very well. When we start that remediation process,
when we have those soils excavated and stored, at
that time Operabla Unit 3 in4 § ftl66fdl Of
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Decisions will be in place, and we'll have very
good integration.
At that point we'll be able to
deliver — Theoretically, we'll be able to take the
soils out and take those to a Operable Unit 5
facility for treatment. They'll be disposed of in
accordance with their Record of Decision, and that
may or may not be on-site disposal.
MS. NUNGESTER: Okay. You're
saying, you're taking the debris, the structure,
the equipment, the surface soil, you're putting
then all in the underground vaults?
MR. NIXON: Operable Unit 4 is
delaying that decision. That's going to be
actually be stored in an interim fashion
MS. NUNGESTER: Okay
MR. NIXON: -- until OU5 and OU3
have record* of decision. Now, their Record of
Decision may very well be that we will treat soil
by washing it and disposing of that on site.
MS. NUNGESTER: Right, but it
doesn't say that, that it's going to be interim
until unit 5 is considered.
MR. NIXON: The proposed plaA dOflfl
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clearly state, as well as the Record of Decision
will clearly state those, that integration.
MS. NUNGESTER: It does?
MR. NIXON: Yes, it does.
MS. NUNGESTER: Okay. Well, I know
on the proposed plan booklet on page 43 talks about
that specific issue.
MR. NIXON: Right.
MS. NUNGESTER: If anybody has that
book, and they want to look at it, they can, but I
don't believe it says -- It says something about
that it will be combined with 5, Unit 5, but it
does not say that would be interim disposal until
5 .
MR. NIXON: Disposal, it is interim
storage.
MS. NUNGESTER: Or storage, but they
use "disposal" as the word throughout the whole --
MR. NIXON: In the proposed plan,
the proposed plan has, for Subunit C waste, it has
a selected or preferred alternative which is
on-site disposal identified, and the reason that's
in there is because on-site and off-site disposal
was so close we had to select the one for the sake
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evaluating the full alternative from start to
finish. Okay.
Later in the document it talks about
the integration effort that will occur with 0U3 and
OU5, and puts — holds that decision in abeyance
for final disposal of those debris and soil until
OU3 and OU5 have their Records of Decision.
MS. ALLEN: The confusion could be
the fact sheet on page 12 states that the soil
debris will be disposed of on site.
MR. NIXON: There is an aj^a in the
fact sheet on page 12, the last paragraph I
believe.
MS. NUNGESTER: Then, this shows
more of a reason why the public should have a
comment period before -- after -- in between the
ROD'S and even during the remedial, the RA, then,
to understand it. Thank you.
MR. STEGNER: Other questions?
UNIDENTIFIED SPEAKER: I have one,
and it goes to back to when you were talking about,
Randi about, the community and stake holders or
public or whatever we're called these days, plays a
part in this process. I'll echo what Edwft juifc
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said. We give our comments, then there's a Record
of Decision. You respond to our comments/ and you
follow this thing down.
But what if we don't like your
responses, you know, I don't see another — I guess
as a stakeholder, which is kind of an okay word
these days, I guess I have a little bit of a
problem with that because once I give you my
comments on this as of April 20th, I don't get to
say nothing else, and if you don't like what you
choose or I don't like the way you responded to ray
comments, you know, how am I going to be able to
come back and say I don't like this?
MS. ALLEN: Just like with any other
primary document, we submit them to US EPA, and
that same document also goes over to the PEIC, and
I'm assuming that the Record of Decision will be
like any other document in that once it hits the
PEIC, you guys are invited and welcome to comment
on the document and provide comments over to Gary
and Ken.
UNIDENTIFIED SPEAKER: And they
would be considered as official comments? Because
as I read this thing here, it doesn't indicate that
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at all.
MS. ALLEN: It also doesn't in the
remedial investigation report, but if you can
remember —
UNIDENTIFIED SPEAKER: I guess what
we're asking for is that we need to be walked
through this process, you know. Once the Record of
Decision is made, we need to be talked to before
your remedial design stuff. He need to be involved
in that remedial design stuff.
Then we need to talk about the
remedial action stuff, and it's going to create a
lot of work for people, but we're afraid if we're
not walked through that process that we're going to
end up at the end with an alternative that people
in this community are really going to be upset
wi th.
MS. ALLEN: I think that's where the
input on the edition that's coming out of the
public relations group is going to be critical
because it doesn't take us past the point we are
right now, and I think we need to get some kind of
idea of what kind of part you guys want to play in
that.
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MR. PICKLES: Really the FS and
proposed plans for Unit 5 is coming out/ you do
have a comment period. I assume from your comments
about what we're doing in the -- are you satisfied
with the issue; is that right?
UNIDENTIFIED SPEAKER: Well, I mean
some of us might be. I can't speak for everyone in
this room, but, you know, at the same time we're
going to walk through this process of designing how
we're going to do this, I want to know what's going
on and what's happening so I can verbally say I
don't like this or I like this or this isn't right
or whatever.
You know, I don't want to say, yeah,
yeah, I'm all for your alternative here, this
sounds great, let's do it, and then you don't talk
to me until the year 2,000, and I don't like what
you did.
You know, I think, you know, if we're
going to stick through this process as we've done
for ten years, and I guess we'll do it for the next
how many ever, we want to make sure that we're
making good and tough decisions as we move along
here so when we get done, we have a cohtlivt
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decision in this community that we can live with
what is left here.
NR. STEGNER: I think it's safe to
say that we'll be involving you throughout the
whole entire process, walking you through the
process, you and the Citizens Task Force.
UNIDENTIFIED SPEAKER: We need to
see that as being a real life thing. Somewhere on
here it needs to be written in here we'll talk to
the public, we'll seek public input, we'll
whatever. That needs to be added in here somewhere
because we don't see that in here right now.
MS. ALLEN: Well, we almost have to
because I'm already getting asked questions right
now that I can't answer until remedial design. As
far as long term during final remediation, I don't
have the answers right now. So I mean, this
process going to have to continue through final
clean-up because I just can't answer the questions
right now.
UNIDENTIFIED SPEAKER: On February
1st the Ohio EPA issued a notice of deficiency and
closure. Were those deficiencies ever corrected?
mr. nixon: which closure plant
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UNIDENTIFIED SPEAKER: On Unit 4,
the one you just gave us an elaborate presentation
on.
MR. NIXON: I believe there might be
some confusion there. Can the State of Ohio clear
that up? RECRA Unit 4 Solid Waste Unit possibly,
it is not this operable unit.
UNIDENTIFIED SPEAKER: Not this
operable unit?
MR. SCHNEIDER: That's correct.
UNIDENTIFIED SPEAKER: So two
different hazardous waste units on this facility?
MR. SCHNEIDER: This isn't a
hazardous waste unit.
UNIDENTIFIED SPEAKER: Could we ask
them to stand when they speak?
MR. SCHNEIDER: We're saying
Operable Unit 4 is it not a hazardous operable
waste unit, not Operable Unit 4. I don't know what
exact letter you may have there, but we can talk
about it. I think it's probably a RECRA unit.
UNIDENTIFIED SPEAKER: It was issued
February 1st out of your office, 1994.
MR. SCHNIEDER: Must be a RECRA
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unit, then.
UNIDENTIFIED SPEAKER: Okay. I'll
discuss it with you.
UNIDENTIFIED SPEAKER: I'm Lou
Bogart. I'm a resident of Ross. I have some
technical questions. In looking at data tables for
Operable Unit 4, one of the things that strikes me
is that you always report uranium 254/236. Does
that mean there's U-236 there? If so, I don't
believe it because U-236 doesn't exist in nature.
Secondly, the ratio of U-234 to U-238
in many cases look very odd, odd in the sense that
in nature and in this ore and in the raffinate the
234, 238 ratio ought to be very close to unit. For
example, when in the table that you've given a
handout, the Silo 1 number looks pretty wrong. The
Silo 2 number is more acceptable.
And the reason I think that's
important is because, you're going to focus the
clean-up levels on U-238. I don't quite know how
you're going to do that without doing some very
sophisticated isotopic analysis. But in any case
those numbers don't look right, and you see that in
many, many tables.
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On the inorganic chemicals, is there
somewhere in all the OU4 documentation a list of
all of the inorganic constituents? For example; I
note that in most of the recent documents you don't
list gold. Now you can. There is about, about
four times as much gold in this material as
silver.
Just as a side light for my own
amusement; I calculated this afternoon. There's
about $2.3 million worth of gold in those two
silos; and that may not be important; but what
other elements are not reported which may have some
impact on the processing of the material by
vi trification?
For example; there should be a fair
burden of rare earths; the whole lamprophyllite
series should be in these ores, and I don't see any
of that being reported. Anybody have an answer for
that one?
MR. NIXON: Well; you had about five
question*; so I'll start in the beginning. One was
235 to 236; those are analyzed and reported the
same. You are correct. We don't feel there is any
uranium-236 in the residues. It'fl & good pOlflfc.
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Whether the ratio between U-234 and U-238 Is
correct, I do not have the answer to that, but we
can discuss that and get back with you within the
next couple of days.
MR. BOGART: How about a complete
list of
MR. NIXON: Complete list, the
remedial investigation did do a complete list of
the organics, inorganics. Whether gold was
evaluated, I'm not sure. I'm looking at my team.
MR. BOGART: You were supplied gold
by TLCP.
MR. NIXON: But we also do a full
H5L, Hazardous Substance List, which gold would not
be part of. So I'm not sure whether gold was
particularly reported in the RI.
MR. BOGART: How about rare earths?
MR. NIXON: I couldn't answer that,
either. We've got a copy of the remedial
investigation here. Whether these fellows can
quickly find answers to those questions or again we
can get back with you.
Amy Engler I know is sitting out here
somewhere taking very good notes, and we'll respond
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to any of the questions which we don't have answers
to tonight. We've committed to have answers back
within 48 hours from this evening.
MR. BOGART: Well, I -- not so much
for myself, but I think for the general public.
MR. NIXON: Any question that is
raised even in the informal conference will be
addressed in the responsiveness.
UNIDENTIFIED SPEAKER: Can we use
that gold as collateral, can we use that? You said
there's like $2 million worth of gold. Can we use
that as collateral somehow?
MR. BOGART: It's going to cost 90
million bucks, maybe we can make it 88 million
bucks. On page 21 or whatever this thing is
called, the proposed plan, the spiral-bound thing,
on page 12 about the middle of the page is an
initiation of a discussion about risk.
And this is the area that concerns me
the greatest, because although you point out
that -- And I presume in all cases you're talking
about fatal cancers because there are, of course,
nonfatal cancan also. And that's not terribly
clear in anything that's written.
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5 4
Risk from exposure, the radiation
naturally occurring in the environment is about 1
in 100 primarily from radon; however, incremental
risks targeted by the upper end of EPA range means
if all persons within a population of 10,000, 1
person might get cancer from the exposure, and
cancer is expected from all other causes. I think
the whole business of risk assessment needs to be
put into some kind of context.
If you look at the latest NCRP
guidance, IIS and I guess 116, you can talk about
risk in terms of about 4 or 5 times 10 to the minus-
10 and you do the hocus-pocus chemists like to do.
And that turns out the average resident from
natural radon, that risk becomes about one half
times 10 to the minus 2 and the range is 0 to 90
years old. And when 90 years old, I guess cancer
is the last thing I'm going to worry about.
But in any event, you make the
statement that the normal cancer risk is about 10
to the minus 2, and then you proceed to march down
the road of things that are 2 to 4 to 5 orders of
magnitude smaller; and it's never put in context.
I think these documents need to AllCUII whit
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are we paying for, and that becomes a real
problem. I don't know how many people feel
comfortable with a 10 to the minus 6 risk, and I'm
not real sure that that's a fatal cancer risk.
There is a problem with the
methodology of using the health effect summary
table slope factor thing as opposed to methodology
that's used by people who do the beer studies and
the NCRP studies because w«'re talking about vast
orders of magnitude differences.
Now, the last comment I guess, I'd
like to see something in these documents that more
clearly explains why the CERCLA process has elected
to use such abominably small risk estimates.
My last comment perhaps goes to EPA
back in 1986, was a bad year for me, EPA published
a notice of intent that they were going to
promulgate residual regulation standards. It is
now 1994, and, to th$ best of my knowledge,
residual radiation level standards have not been
promulgated.
In 1993 in a GAO report to Congress
somebody in EPA said that in March of 1994 they
were going to finally publlflh fflliiutl ridlltlGTl
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standards, not publish them, but they would take
then to 0MB, which would be the fist step in
getting them published -- well, not the first step,
but a key step in getting them published in the
Federal Register.
March 1994 is now. My concern is, is
there one part of EPA working on residual radiation
level standards which nay very well impact on the
clean-up levels that are being talked about here
for the clean-up of 0U4?
MR. NIXON: Was there any response?
MR. SARCA: Yeah, I can answer that
frosi my understanding. One of the people involved
from the EPA perspective that works with me, he's
been commenting that he's involved in working on
some of those standards. Will they directly impact
this investigation, I don't know. I don't think
so. Hearing some of the numbers, I think they may
even be moving towards the side of being equally as
conservative, could be more conservative.
I don't know what the final will come
out with. When they do come out of the numbers,
they'll go to budget and move forward from there.
I do know that they are being worked on. OAI fil
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the people from my office is doing that right now.
I don't know the exact state.
UNIDENTIFIED SPEAKER: If memory
serves, I think that the gold Lou was talking about
was contained in the pitch blend or whatever it was
that came over from Africa that the United States
bought and dumped into the K-65 silos. I heard or
read that somewhere. You might want to check that
out.
MR. NIXON: It is in the K-65
material, yes.
MR. BOGART: It all came from one
mine.
UNIDENTIFIED SPEAKER: The reason
they took that pitch was they wanted to strike
gold?
MR. BOGART: No, radium and gold.
UNIDENTIFIED SPEAKER: As far as I'm
concerned, it can be vitrified.
MR. BOGART: The question was, what
else is there?
UNIDENTIFIED SPEAKER: Okay. I just
have another question. When you said they were
filling the silos, especially 1 and 2, did fehly
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5 a
transport it through a pipe?
MR. PICKLES: Yes, ma'am.
UNIDENTIFIED SPEAKER: That's not
what I recall. If my memory serves me correctly,
some of that material may have been put in that
way, but I remember the workers saying at different
times that they also carted barrels out there from
the silos.
MR. NIXON: Most of the material in
Silos 1 and 2 were in a drum form that came from
Melloncrock Chemical Works in St. Louis. Those
drums were taken to the drum handling building
between Silos 2 and 3. The drums were dumped and
then mixed into a slurry with water and pumped into
the silo and then allowed to settle. The water was
decanted off into the decant sump tank, and then
that water was used to reslurry additional material
coming from off site.
The material -- The majority of the
material, that was processed here on site, because
we did process both at the Melloncrock Chemical
Works as well as soma of the material being
processed here, K-65 material being processed at
the sit* in our Rtfinery llaftfc 2 and
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That material as it was processed
from the production area at Fernald, it was
transported hydraulically in a slurry through that
underground trench, through the pipe back to Silo
2. But the majority of the material was in drum
form and reslurried at the silos.
UNIDENTIFIED SPEAKER: I think that
should have been mentioned in your report there,
you know. It says, from the way I read it,
everything went through that pipe and everything,
which it wasn't really.
MR. NIXON: I tried to talk to that
point in showing that one areal shot where you can
see all of the large numbers of drums that were
being stored by the silos. That is the incoming
material that was coming in from Melloncrock in St.
Louis and then reslurried at the site.
MR. STEGNER: Thank you. Let's take
our break now and reconvene for the formal comment
period.
(A brief recess was taken.)
(All panel members except Mr. Stegner stepped
down. )
mr. stegner: This is the beginning
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, _____
60
of the formal comment section where your comments
will be entered to the Responsiveness Summary in
the Record of Decision. We will do this as we have
some folks who have signed up to make comments.
You do not have to sign up to make comments. You
can have an open mike at the end. There's only
about four or five folks here that indicated they
wanted to make comments.
Again, you do not have to use this
forum to make the official comments. You can
submit comments on one of these cards and leave
them here at the end of the meeting or you can
submit comments to the Department of Energy at the
Public Affairs office. We also ask before you
leave, if you don't mind, to fill out the
evaluation forms we have sitting on all of the
chairs.
The first person we have is Kevin
Sorrel. I guess can Kevin's not here.
UNIDENTIFIED SPEAKER: There's some
folks still out here in the hallway.
MR. STEGNER: You want to check out
there.
unidentified SPEAKER: Not there.
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MR. STEGNER: is Lee Bolver still
here?
UNIDENTIFIED SPEAKER: He left.
NR. STEGNER: Bob, do you have
something to say?
UNIDENTIFIED SPEAKER: I'll turn it
in later.
NR. STEGNER: Bob Gessel — Godsel,
I'm sorry? Going very well so far. Ton Wagner,
Citizens Task Force? Okay. We have an open mike,
folks, if anyone wants to make a comment.
MS. NUNGESTER: You want my address,
too?
MR. STEGNER: Not necessary, as long
as we have your name.
MS. NUNGESTER: Norma Nungester,
Fernald resident and Fresh group. I have several
comments. First of all, I want to cover again what
was stated in the question and answer period. I
think between the draft ROD and the final ROD we
need a public comment official time, and you need
to formalize this. On down here below you say the
public involvement, public involvement, that means
nothing to us. You need to formalist that.
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62
And you also need more details on
your RD/RA work plan. We want to know more details
on transportation. We want to be notified when
you're transporting this stuff and talk about the
materials that are actually in the K-65 when
they're vitrified and when you start to ship them
out to Nevada.
Also this stuff that stays on site,
I'd like to know how they will be monitored, and
for how long of a period they're going to be
monitored. I guess I just want to express that we
want a guarantee that real-time monitoring will be
used.
Also a suggestion, how about covering
those silos when you start working on them? I
think this is one of the most important things you
could do for the community. I think that's about
it. I'm trying to read my notes that are chicken
scratch here.
Oh, one more thing. I'd like to be
diligent on referring large quantities of waste
from other sites. We don't want anything brought
in here fron other plants to vitrify with our
material or to be put under the storage areas.
SPANGLER REPORTING SERVICES
PHONE (513) 381-3330 FAX (513) 381-3342
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Thank you .
NR. STEGNER: Thank you, Norma.
Edwa?
MS. YOCUM: Edwa Yocum. Some of
this will sound repetitious, but I'm asking for a
public consent period between the ROD'S, the draft
and final; and we need an official public comment
period after the RA process. And also I'm asking
for a public comment period between the beginning
and completion of remediation. And then, too, when
dismantling the K-65 silos and also the 3 and 4,
I'd like to have a protective cover be used around
the silos.
And as far as I read in there, that
EPA would be reviewing the vault or the disposal
sites every five years, I'd like to know the
definition of "reviewing," and I would like
continuous monitoring and maintenance of on-site
disposal vaults or at least one time a year as long
as they're on site. And also, who would be paying
for this monitoring and maintenance? And this way
I recommend a trust fund for monitoring and
maintenance of the disposals.
MR. STKQNfll! Thank you, Idwt. Opin
SPANGLER REPORTING SERVICES
PHONE (513) 381-3330 FAX (513) 381-3342
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MEETING CONCLUDED AT 8:45 P.M.
SPANGLER REPORTING SERVICES
PHONE (513) 381-3330 FAX (513) 381-3342
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CERTIFICATE
I, LISA CONLEY, RPR, the undersigned, a notary
public-court reporter, do hereby certify that at
the tine and place stated herein, I recorded in
stenotypy and thereafter had transcribed with
computer-aided transcription the within (65),
sixty-five pages, and that the foregoing transcript
of proceedings is a coaplete and accurate report of
ay said stenotypy notes.
MY COMMISSION EXPIRES: LISA CONLEY, RPR
JULY 28, 1994. NOTARY PUBLIC-STATE OF OHIO
SPANGLER REPORTING SERVICES
PHONE (513) 381-3330 FAX (513) 381-3342
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December 1994
{This page intentionally left blank}
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FEM P-OU4ROD-8 FINAL
December 1994
SUMMARY OF MEETING MINUTES
COMMUNITY ADVISORY BOARD FOR THE
NEVADA TEST SITE
DATE:
TIME:
PLACE:
SUBJECT:
May 11, 1994
7:00 P.M. - 9:30 P.M.
THE ALEXIS PARK RESORT
LAS VEGAS, NEVADA
PROPOSED SHIPMENT OF FERNALD, OHIO LOW-LEVEL
RADIOACTIVE WASTE TO THE NEVADA TEST SITE
SPEAKERS:
For the Government:
Page
Jack Craig
9
Joe Fiore
7
Dennis Nixon
9
Layton O'Neill
13
David Rast
6
For the CAB Members:
William Vasconi, Chairperson
Dennis Bechtel
Chris Brown
Lathia McDaniels
Richard Nicolla
E. Paul Richitt, Jr.
Joanne Stockill
Katherine Yuracko
18
5
8
7
6
11
6
11
Ex Officio Members:
Joe Fiore
Paul Liebendorfer
7
7
For the Public:
Don Hendricks
Jerry Sieren
Michael Verriiii
John Walker
12
15
15
10
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December 1994
ATTENDEES:
DOE AFFILIATES:
Jack Craig, USDOE/FN
Leah Dever, DOE/NV
B. Dozier, REECO
J. E. Evered, FERMCO
Sharon Faurer, DOE/HQ
Joe Fiore, DOE/NV
Wendy A. Griffin, DOE/NV
Patricia Herrin, REECO
Warren Hooper, FERMCO
Steve Housen, FERMCO
Allene Kitchen. DOE
Joe Kitchen, DOE/NV
David Loiek, DOE/FN
Darwin J. Morgan. DOE/NV
Dennis A. Nixon, FERMCO
Don Ofte, FERMCO
Layton O'Neill, DOE/NV
Brian Perkins, REECO
David Rast, DOE/FN
Myrie Rice. IT Corp.
Kevin Rohrer. IT Corp.
James Saric, USEPA/Region V
Bonnie Thompson. DOE/NV
Pam West-Thompson, RSN
Donald Wruble. PAI
Runore Wycoff. DOE/NV
CAB MEMBERS:
Name
Address
Richard Arnold
2300 W. Bonanza Rd.
Las Vegas, NV 89106
Dennis Bechtel
319 Encima Ct.
Henderson, NV 89014
Chris Brown
P.O. Box 1681
Las Vegas, NV 89125
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December 1994
James Henderson
Marilyn Littlepage
Lathia McDanieis
Richard Nocilla
E. Paul Richitt, Jr.
Joanne Stockill
Bill Vasconi
(Chairperson)
Katherine Yuracko
EX-OFFICIO MEMBERS
Paul Liebendorfer
Joseph N. Fiore
PUBLIC CITIZENS: Name
George Blankenship
Jim Buchanan
6712 Reggie
Las Vegas. NV 89107
1851 Balzac Dr.
Las Vegas. NV 89115
2396 Valley Dr.
Las Vegas, NV 89108
823 Spyglass Ln.
Las Vegas, NV 89107
3575 W. Badura Ave.
Las Vegas, NV 89118
4625 Kay Place
Las Vegas, NV 89107
6565 West Atwood
Las Vegas, NV 89108
5708 Stallion Ave.
Las Vegas, NV 89108
333 W. Nye Ln.
Carson City, NV 89710
P.O. Box 89193-8518
Las Vegas, NV 89193
Address
P.I.C. 1820 Grant
Denver, CO 80203
2021 Girard #8E
Albuquerque, NM 87106
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December 1994
Sydney Gordon
Don Hendricks
Rob Santa Maria
Tom Schneider
Gerald Sieren
Michael Verrilla
John B. Walker
4295 E. Reno Ave.
Las Vegas. NV 89120
609 N. Crestline Dr.
Las Vegas, NV 89107
368 Pleasantview Dr.
Lancaster, NY 14086
40 South Main St.
Dayton, OH 45402
3439 Andalusia PI.
Las Vegas, NV
2985 Montessouri St.
Las Vegas, NV 89117
Capitol Complex
Carson City, NV 89701
REPORTED BY: Wendy J. Pullium, PAI
Transcriber
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December 1994
CALL TO ORDER:
The meeting was cailed to order at 6:10 p.m.
The purpose of the evening's meeting was for two presentations. The first
presentation was furnished by representatives of the U.S. Department of Energy
Fernald Field Office located in Cincinnati, Ohio. The second presentation was
presented by the Waste Management Division. U.S. Department of Energy, Nevada
Opertations Office.
Each presentation was followed by a question and answer session from the NV/CAB
and the public.
Joe Fiore announced that the state of Nevada had made a request in response to a
draft Environmental Impact Statement issued by Fernald which described the
activities which result in waste being transported to the Test Site, and the request
involved extending the public comment period on that document for 60 days to give
the Community Advisory Board of the Nevada Test Site Programs (NV/CAB) an
opportunity to understand the situation better. In response to that, Fernald agreed to
extend the comment period by 30 days. The original closing date for comments was
April 20th; it is now May 20th. This meeting was being held in time for comments to
be put together in the next nine days.
FERNALD'S PRESENTATION:
Dave Rast from the Fernald Field Office gave a summary on the proposal to transport
and dispose of low-level radioactive waste at the Nevada Test Site's radioactive waste
management site. The waste will be generated in the cleanup and environmental
restoration of the DOE's closed uranium production facility near Fernald, Ohio. If the
proposed and subsequent actions are implemented, approximately 300,000 cubic
yards of radioactive waste will be disposed of at the NTS. Disposal activities would
cover a period of approximately 30 years. Copies of the slides presented are
attached.
QUESTIONS AND ANSWERS:
At this time, each Board member introduced him/herself and then proceeded with
their individual questions and/or comments.
DENNIS BECHTEL: First. ! would like to thank you for sharing information
about the site. I had the opportunity to visit Fernald several years ago as a member
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December 1994
of the EMAC board. Could you possibly translate your numbers, your 300.000 cubic
yards and your annual figures in numbers of shipments, and what they might mean?
DAVE RAST: We get approximately 18 cubic yards of waste on the average on
a shipment. If I do the simple math and just divide it by 20, that is 15,000.
DENNIS BECHTEL: So that's potentially what? Three thousand trips a year,
and you are looking at FY96 here? (No response given.)
JOANNE STOCKILL: What kind of shipments are you talking, rail or truck?
DAVE RAST: Truck. Currently the only mode of transportation we have off site
is truck shipments. We have been looking at rail shipments. Currently, the rail at
Fernald is light gauge rail and cannot support heavy shipments, and we have some
local rail in the area that is in need of repair before I would attempt to effect any
shipments by rail.
JOANNE STOCKILL: Is that true of the 600,000, you are going to put in
commercial sites?
DAVE RAST: Yes.
DENNIS BECHTEL: Follow up on the question I had. When you plan your
shipping campaign, what sort of coordination do you do with state and governments
and particularly the state of Nevada? How do you handle that?
DAVE RAST: Currently, we haven't done any coordination from Fernald in
emergency, preparedness. DOE established a radiological response team and
divides the contaminant into areas for response in a case of a transportation
emergency. We also effect training for our shippers. We also have a designated
route for which drivers are to transport shipments. They also have a designated call-
in time; they have to report at least once every 24 hours. Many of the trucks are
being equipped with satellite tracking equipment. The drivers also have all the
emergency contact information in their transportation file within a packet and the bill
of lading transportation documents.
DENNIS BECHTEL: Where would those designated routes be in Nevada?
Would they be interstates?
DAVE RAST: Interstates where possible. You can't get to the Nevada Test Site
via interstates. They usually come across 95 over 15. up 15 and back out 95.
DENNIS BECHTEL: So right through Las Vegas?
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December 1994
DAVE RAST: Yes, sir
LATHIA MCDANIELS: Can you tell me what steps are implemented to insure
that we don't accidently get mixed low-ievel waste shipped to us?
DAVE RASP: To insure that we don't get mixed waste transported to the
Nevada Test Site, there is an extensive characterization and certification program
established by the Nevada Field Office. That certification program is defined in their
Waste Acceptance Criteria Document, NVO-325. We adhere to the conditions
established in that document.
We perform a review of our waste on a waste stream by waste stream basis.
We also maintain control of containers; maintain control of who has access to waste
disposal facilities such as our dumpsters on site have locks on them. Only
designated personal have the ability to put trash into a dumpster, or to put any kind
of material into a waste container. We are implementing even tighter controls now on
waste containers.
We do do sampling analysis of some materials, characterizing them under the
RCRA regulations to check for hazardous constituents, to make sure they are not a
mixed waste. We maintain those characterization files at the site. They have been
reviewed by the representatives from the Nevada Field Office and also from the
Nevada Department of Environmental Protection on some of our waste streams.
LATHIA MCDANIELS: But there is no outside agency that has the hands-on
ability to review while you are doing it?
DAVE RAST: Before we are allowed to ship to Nevada Test Site, they review
the characterization files for the waste streams. Before that waste stream is approved
for acceptance, they review it.
LATHIA MCDANIELS: When you say "they," who?
DAVE RAST: Nevada DOE field office.
JOE FIORE: We adhere to a very rigorous waste acceptance process. That
includes formal submittal of applications from waste generators. But to specifically
answer your question, part of that process involves oversight by the State of Nevada,
Division of Environmental Protection. So that's the independent non-DOE part of the
thing.
PAUL LIEBENDORFER: I will say, we probably made a significant impact on all
the waste that is shipped out here from--not just Fernald but the other places as
well--on the level of quality of the waste.
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December 1994
LATHIA MCDANIELS: Are you satisfied (Paul Liebendorfer) that we are not and
we will not be getting any mixed low-ievel waste?
PAUL LIEBENDORFER: Within the documents we have seen so far.
LATHIA MCDANIELS: Outside of the documents; your personal feelings?
PAUL LIEBENDORFER: I think at this point in time, there has been nothing
raised. Maybe I should take a step back. There was a shipment that came in a
couple years ago of thorium waste that we had great concerns about because of
what we perceived to be a lot of inadequate documentation to support the position.
We went around for about eight or ten months on that.
I actually went back, and they did some resampling of some containers that
were left there, and observed the days worth of sampling and the evaluation, and
insisted on additional information to be presented to be included in the waste
package to support their position. After conclusion of that particular round, we felt
that they, at that point in time, did have the ability to demonstrate that those
documents coming back in, that, thorium waste, were in fact, not a mixed waste.
They have implemented a process that we don't look at every waste stream. We are
able to audit any waste stream we request.
Obviously, we cannot go to every site and look at every package, so we have
got to the point where DOE conducts an audit and we audit DOE.
RICHARD NOCILLA: I have been wondering if apart from the tradition of
bringing your waste to the NTS, is there another disposal site?
DAVE RAST: We have disposed of waste at the Envirocare Facility in Utah and
recently made some additional shipments to a facility. Currently, under the current
DOE regulations, the Nevada Test Site is the assigned disposal site for Fernald.
Now, we are working on petitions to get the exemptions to dispose of low-level waste
at commercial disposal sites.
CHRIS BROWN: What kind of half lives do the various radionuclides that you
mentioned have?
DAVE RAST: The primary radionuclides that we have on site are uranium and
thorium. I think the uranium is ten million years and thorium is a billion.
CHRIS BROWN: And do you all make highly enriched or low enriched?
DAVE RAST: We only made low enriched uranium. We have some material
that is for sale that is approximately 20-percent enrichment. We have limited
quantities of that. Approximately, I think 50 pounds of the 20-percent enrichment
material which is currently on the block for sale, and more than likely it will be sold.
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December 1994
The highest enrichment we typically dealt with was 1.25 percent, wmch is about
half a percent over normal.
CHRIS BROWN: The relation of this process of choosing the NTS and being
designated to the PEIS process, I am curious because, it has up to six possible sites
for low-level waste to be sent throughout the complex, i'm wondering if Fernald
would give consideration to a site more proximate to it through the PEIS process?
DENNIS NIXON: I believe he is referring to potential sites that could be
constructed in close proximity to the Fernald site, and we have essentially found that
not to be implementable at this time and cost effective for the small quantity of waste.
CHRIS BROWN: Three hundred thousand cubic yards is not a small amount.
DENNIS NIXON: The proposed action is only 13,000 cubic yards. The 300.000
is the total volume for the site.
CHRIS BROWN: Well, out of all the numbers you tnrew out at us, which 13,000
cubic yards?
DAVE RAST: Operable Unit 4 residues is the proposed action right now.
CHRIS BROWN: So. are you going to tier following EIS's on each of the
operable units, and if so when will we be seeing those?
DENNIS NIXON: This is the 13,000 for this action with Operable Unit 4, and we
talked about reducing that to 6,000.
DAVE RAST: Each of the follow-up operable units has an accumulative effect.
As you get to the decision point in each of the other operable units, they will tier that
effect into environmental assessment for each of the operable units, and those will be
coming out at the dates that you see the arrow pointed to at this time.
CHRIS BROWN: So, if your presentation talks about the accumulative impact,
the answer, we are only dealing with 13,000, which really isn't relevant. We are
dealing with the whole thing. These things are coming out one after the other in the
space of a year here, except for Operable Unit 3 which is going to take a few more.
We are basically talking about the whole volume, not just the 13,000.
JACK CRAIG: The document you have now is for Operable Unit 4. It is only
making a decision on the 13,000 cubic yards. Like you said, there will be follow-up
documents that will also finalize the decision on the other operable units.
If. through this process, all the leading alternatives are selected, you will get a
chance to look at each one of those individually. And, those will add up to 300,000 if
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December 1994
the leading alternatives are selected, but you will get a chance to comment on each
one of those as they come out. But this document you are looking at now is only
making a decision on the 13,000 cubic yards.
The other number that leads up to the 300,000, you will be able to comment on
that later through the submittal of the following-up documents.
JOHN WALKER: I haven't heard any discussion about the alternatives for on-
site disposal. Even though it is not the preferred alternative, it is an alternative that
you did examine. Would you like to discuss those alternatives? The alternatives for
keeping it all at Fernald on site.
DENNIS NIXON: I think that what I'm addressing here is just the proposed
action, which is again the 13,000 cubic yards which is Operable Unit 4. There are
various reasons why. We evaluated a full range of options and alternatives for both
on-site and off-site disposal, various treatment options, etc. We chose the NTS
because it performed the best out of all the alternatives that we evaluated, and these
are the reasons why the NTS was rated better over on-site disposal.
Also there are some real show stoppers when it comes to on-site disposal with
this waste whether it's hydrology which Dave has covered; the climate, we have a lot
of rainfall compared to what we would get in the desert here; the demographics of
the area, there is a large population in close proximity of the site; the land use
scenario is an agricultural land use, so there is a greater possibility of intrusion on the
waste that was disposed of on site.
These things are resolved at the NTS. It is an arid climate; there is a very low
population; there is very low probability of future intrusion on the waste; it's probably
not going to be farmed in the future; the hydrology, geology, ail that is very favorable
to disposal of this waste at NTS.
JOHN WALKER: But there are some doable engineering systems where you
can keep the waste on site a long period of time; is that correct?
DENNIS NIXON: That is correct. However, it does not completely pass the
threshold criteria which we iook at in the evaluation of the alternative. For one, it
does not comply with all applicable, relevant, and appropriate requirements which are
essentially the regulations that are applied to our site.
JOHN WALKER: I just want to make the point that there are alternatives to the
preferred action that just didn't seem discussed at all.
DENNIS NIXON: We fully evaluated on-site disposal. This is the list of
alternatives we evaluated in the Feasibility Study. For the Silo 1 and 2 material, or K-
65 material, we have to evaluate no action, which obviously is a good solution for this
particular operable unit.
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We evaluated on-property disposal with various treatments, stabilization options
as well as off-site disposal here and the NTS. We have not identified another off-site
disposal facility that was available to this waste stream.
For the Silo 3 contents, essentially the same alternatives were evaluated.
Subunit C. being the debris and soils on other structures, etc., was review and
evaluated and that will be disposed of on site most probably assuming that the
ODerable Unit 5 waste is selected for on-site disposal.
KATHERINE YURACKO: Well, this is what I wanted to see, but now I want to
know why are the only possibilities on site in Nevada?
DENNIS NIXON: Well, these are the alternatives. We listed and reviewed and
evaluated a lot more alternatives than this, but not all alternatives passed the
threshold criteria, which was to be protective and to be able to comply with all the
applicable, relevant, and appropriate requirements such as disposal at another
commercial site. We cannot identify a commercial site such as the Envirocare Site.
We cannot meet their acceptance criteria.
DENNIS BECHTEL: How much does cost effectiveness enter into it?
DENNIS NIXON: Well, I don't want to say it's low on the totem pole, but it is
certainly less important than the threshold criteria and being protective of the human
health and the environment. It is also the most cost-effective alternative.
PAUL RICHITT: With respect to the on site, what is the alternate plan used for
Fernald Site after you finish remediation?
DENNIS NIXON: We have a citizen s advisory board at Fernald that is
determining that very issue. We have not determined what the final land use for
Fernald is.
PAUL RICHITT: Because you vitrify the waste, you reduce volume, you are
going to stabilize it so it can't migrate. You are going to bring it to the Test Site; the
whole premise is to say the waste materials will be held and stable. If that is the
case, depending on what you are going to put the Fernald Site to, you may have the
same benefit by leaving it on site and not have to worry about transportation where
you may introduce additional problems. So, is your basis for decision made before
you have an alternate-use determination on the Fernaid Site?
DENNIS NIXON: We don't believe so. Again, on-site disposal does not pass
the threshold criteria, and we cannot meet all the applicable, relevant, and
appropriate areas. We cannot insure that we--in the long term over a thousand-year
period--that we would not have intrusion due to the land use and the demographics
of the area.
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December 1994
JOANNE STOCKILL: Is there any assurance there would not be intrusion at the
Nevaaa Test Site in a thousand years?
DENNIS NIXON: No, there is not. However, it is less likely.
BILL VASCONI: Are there any questions to be addressed from the audience?
DON HENDRICKS: Several months ago EPA took the position to DOE that the
K-65 waste as well as some other high-thorium waste should be classed as greater
than Class C waste. If by definition, you take that at face value, that means you
should not dispose of those wastes in near-surface repositories. This doesn't quite
seem to go along with that.
I would also assume that because you have reduced the volume and you have
upped the concentration, which makes it even more significant.
DENNIS NIXON: That is true. The vitrification reducing the volume makes a
more dense waste form, it does concentrate the radionuclides. I would just say that
this waste is not high-level waste, it is not transuranic waste. It's categorized as
1 le(2) by-product material. Even though the EPA Region V has applied 40 CFR 191,
which is the regulation which controls high-level and transuranic waste, that was felt
to be that our waste was enough like-due to the long-lived content and long lived
alpha emitters-like the radium and thorium and uranium series, that we should
consider that in our decision for the waste stream, and which we did in the
document.
CHRIS BROWN: In terms of projected disposition at varies places, some on
site, some commercial and some NTS, how does that work out in terms of radioactive
hazardous materials, etc.
DENNIS NIXON: I think that all the waste that Dave spoke of was low-level
radioactive waste
DAVE RAST: All the waste that is projected in that is low-level radioactive.
CHRIS BROWN: The commercial stuff, is there any chance it will be sent to an
incinerator?
DAVE RAST: Most of the material that we are looking at disposing of .
commercially is not amiable to incineration. It's soils, it's a sludge material out of
our waste pits; it will need some drying. Most of the drying technique that we are
looking at is either a (unintelligible) drier or we found compaction and super
compaction is a much more effective drying technique than incineration. Incineration
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December 1994
is very expensive. Any kind of thermal treatment chews up massive amounts of
energy, and you can run a 5,000-ton press a lot more energy effectively than you can
an incinerator.
JOANNE STOCKILL: ! wanted to ask Joe, should this shipment go to the Test
Site, where would it be and how wouid it be stored? Would it be in Area 5?
JOE FIORE: Yes. It would be treated as low-level waste as it is defined bv our
current DOE Orders, and the bulk of it would go to Area 5 or Area 3 which is nearby.
KATHERINE YURACKO: I'm now confused as to what this stuff is we are
talking about. Did you say this stuff was regulated under the 40 CFR 191?
DAVE RAST: No. 40 CFR 191 was applied as a relevant and appropriate
regulation to be considered. It is not a high-level waste product. It is a by-product
from a leaching operation. The US/EPA Region V felt that if we wanted to dispose of
that material on site, in our management of that material, we would have to follow the
191 guidelines.
KATHERINE YURACKO: Knowing nothing more than EPA Region V, that
sounds reasonable to me. How does the facility you're talking about putting it in at
the Test Site compare with a 40 CFR 191 facility?
JOE FIORE: We have done some performance assessments, Kathy, consistent
with both 40 CFR 191 and the DOE Order, and I think we have some preliminary
results. I'm not certain I know them or I can explain them very well. Layton, do you
know what the preliminary results are?
LAYTON O'NEILL: Yes. They showed that the situation that we have will satisfy
the 40 CFR 191, and we need more data to affirm that.
JOE FIORE: Let me explain. The Order we are applying for our low-level waste
disposal, the Order that we must meet is that for low-level radioactive waste
performance assessments described in a DOE Order, but that is the prescriptive role
to meet. The consideration of 40 CFR 191, I believe, is a more rigorous requirement
and I think we are trying to demonstrate that we also meet that, but it is not a
requirement that we do meet that for disposal of low-level waste.
KATHERINE YURACKO: But it sounds like the only reason it can't go is at
Fernald is because they require that they comply with 40 CFR 191, and so it is
coming here because there is no requirement in Nevada to comply with 40 CFR 191.
Have I understood that right?
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December 1994
DENNIS NIXON: That is not entirely true. There is another regulation, an OAC
(Ohio Administrative Code) regulation, which would pronibit the location of a disposal
cell over a sole source aquifer, which we would not comDiy with as well with this
particular sighting of a disposal cell for this type of waste.
KATHERINE YURACKO: Let's say this is 40 CFR 191 waste. We have got
40 CFR 191 facilities all over this country. Can t we put this in one of them?
DENNIS NIXON: I'm not familiar with the locations of those facilities.
KATHERINE YURACKO: Well, there is this kind of waste elsewhere; right?
Isn't this similar to mill tailing waste we have got all over the country?
DENNIS NIXON: No, I don't believe so.
KATHERINE YURACKO: It's originated under the same regulations.
DENNIS NIXON: Right.
KATHERINE YURACKO: We have facilities constructed around this country
under this regulation. But you are saying that none of those can take this waste?
DENNIS NIXON: Right.
JOHN WALKER: I don't think there are any facilities under 191. I think WIPP is
the only facility that they are looking at for 191. I think 191 was thrown out or set
aside on Yucca Mountain. They are trying to fix a standard for Yucca Mountain, but
191 is only being applied to WIPP at this point, which is transuranic waste, which is
long-lived much like uranium.
KATHERINE YURACKO: Then WIPP is an alternative for this?
JOHN WALKER: No.
KATHERINE YURACKO: I am not getting what this waste is.
DENNIS NIXON: I think this is a very important issue that we have discussed
hundreds of times over the last two years. The reality of the matter is that this waste
is not 40 CFR 191 waste even though the US/EPA Region V has told us to consider it
as relevant and appropriate. The DOE does not agree with that position and has put
forward a position paper that would identify that they do not concur with that position.
However, the ARARs (Applicable, Relevant ana Appropriate Requirements) that we
are required to work on under CERCLA they are addressed by the Agency. We
cannot negotiate those. Those are not subject to any kind of negotiation. We do not
C-IV-2-14
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FEMP-OU4ROD-8 FINAL
December 1994
consider this 191 waste. It is clearly not high level, it is clearly not transuranic, which
is the intent of that regulation.
The reason why it was aDpiied to this waste is because it has greater than 100
nanocuries per gram of long-lived alpha-emitting radionuclides like uranium, radium,
and thorium series. Those are enough like what is governed in 40 CFR 191 for
Region V to make it relevant and appropriate in their minds.
MICHAEL VERRILLI: I have some questions about containerization of the
material. How is that done? Is the material containerized there and then placed at
the Test Site in the containers, or is it removed and then placed in other containers?
The current shipments.
DENNIS NIXON: It is all containerized at the Fernald Site. It is not removed
from the container before it is disposed.
MICHAEL VERRILLI: What kind of health hazards would those pose in the
event of a breach of a container on a public highway?
DENNIS NIXON: Not being a health physicist, I'm not going try to take a guess
on the health hazards. Most of the material we ship and most of the material that is
transported to the Nevada Test Site has material that has fixed contamination or it's a
nonsmearable, nonreleasable contaminant.
MICHAEL VERRILLI: So it is a contaminant that you would have to have long
exposure to be damaged?
DENNIS NIXON: Right. And uranium, itself, is not a high radiological risk.
MICHAEL VERRILLI: The disposal at the Test Site itself, is it buried, is it above
ground?
DENNIS NIXON: It is shallow-land burial.
JERRY SIEREN: A private citizen. One of the major news services this morning
reported, I think it was the Review Journal, that the State of Ohio has become the
leading candidate to host a commercial low-level radioactive waste disposal site. And
the reason they have become the leading candidate is because the state of Michigan
has been thrown out of the Midwest States Compact, because it refused to host the
low-level radioactive waste site, and Ohio is the next largest producer of low-level
radioactive waste in that Compact. A representative from the State of Ohio
Environmental Protection Agency was quoted in the newspaper article, stating that
the site would be located in Southern Ohio farm country due to lack of political clout
in that area.
C-TV-2-15
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FEMP-OU4ROD-8 FINAL
December 1994
That was just introductory. My question: Was this site that is being considered
now be iccated in the state of Ohio and presumably deemed acceptable for low-level
rad waste, was it considered for the OU4 waste? And if not, why not, and could it be
considered for that rad waste?
DENNIS NIXON: We considered a regional disposal alternative. If you look
at the OU4 documents, that was one of the unsighted low-level waste disposal cells
within 300 miles of Fernald and was evaluated as an option. The current low-level
waste repository for Ohio has gotten the honor to site within their state is part of the
Compacts' low-level waste disposal sites under the Low-Level Waste Policy Act. And
just by virtue of that Act and within the terms of that Act, DOE is prohibited from
using those sites.
JERRY SIEREN: Is the site in Utah? Envirocare?
DENNIS NIXON: It's not a Compact site.
JERRY SIEREN: It does accept commercial low-level rad waste?
DENNIS NIXON: Yes, it does. But it's a private site.
A 10-minute break was called for after the Fernald segment and the group
reconvened at 8:30 p.m.
WASTE MANAGEMENT DIVISION'S PRESENTATION:
Layton O'neill gave a slide presentation on the DOE Nevada Operations Office, Waste
Management Division's current low-level radioactive waste management program.
Photographs of Nevada Test Site Area 5 and Area 3 waste disposal facilities and
practices, and subsurface monitoring wells and holes, were shown and described.
Research results showing surface water does not seep below 20 feet down from the
surface, and so does not travel down to the 800-foot deep water table, were
described.
QUESTIONS AND ANSWERS:
KATHERINE YURACKO: First of all, I have a lot of questions, and I frankly
don't think we are going to get through all of this tonight. I'd like to start off with one
if I can. I heard that Ohio thinks this is 1 le(2) material, and my comment earlier was
DOE has lots of 1 le(2) material, has lots of He(2) disposal sites around the country.
Now, Layton was kind enough to direct our attention to Chapter IV of 5820.2A which
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FEMP-OU4ROD-8 FINAL
December 1994
addresses 11e(2) material, and I'd like to read--l was skimming that--and in Chapter
IV, Section 3a(1), it states right here, "disposal sites should be identified and
developed as needed in support of DOE remedial actions, and will normally be
located in the state in which the wastes were generated." So, I still don't understand
what's going on here.
LAYTON O'NEILL: Well, I will tell you what we did. When we started getting
into this 11e(2) waste proposals to come to Nevada Test Site, we wrote a letter to
Headquarters and said, provide us guidance because there is not enough in the
document on that Chapter, So we are waiting to hear from Headquarters on further
guidance on what they want us to do. That's all I can answer you. We don't have
proper guidance from Headquarters on what to do with that material.
KATHERINE YURACKO: I guess one of the things I am still hung up on is this
notion that the only two possibilities were on site and Nevada, and then it couldn't go
on site because this was 11 e(2) material, and so Nevada was the only alternative.
But how about doing an evaluation of other 11 e(2) disposal sites?
11e(2) is CFR 192. There are a number of facilities in this country that are
regulated under the 40 CFR 192 that are taking DOE material, and so I'm just
confused on this.
DENNIS NIXON: I'm not sure which sites you are particularly referring to. We
have identified no other sites that could accept this material now. Not because it's
11E2. Just being a low-level waste, it is not a mill tailing,
KATHERINE YURACKO: Well, that's what I'm confused about. I mean, I was
told it's I1e(2), and now you are saying it's not really so, and it can't go into an
11e(2) facility. Have you done an examination? There are lots of those facilities.
Let's take Grand Junction. Have you done an examination of putting this material in
the Grand Junction facility?
DENNIS NIXON: No, we have not. However, Dave can address those other
disposal sites.
DAVE RAST: Most of the other sites and everything for UMTRA disposal are for
native North American mill tailings; and in particular, once you look at mill tailings that
came off of those sites, and they were taken out and used throughout the country
verses the leachate from the K-65 materials. In that process there is a higher
concentration of radium in those products than we find within the UMTRA mill tailings.
So, all the performance assessments done for the UMTRA disposal sites are not
driven to the levels of the material that we have in the silos.
KATHERINE YURACKO: So this facility on the Nevada Test Site is more
protective than a 40 CFR 192 facility?
C-IV-2-17
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FEMP-OU4ROD-8 FINAL
December 1994
DAVE RAST: Yes. Given the information of the performance of the ceils that
we have and we have looked at the NTS, yes.
DENNIS BECHTEL: I do have a general question for Layton. How did you
happen to pick the sites? It seems like they are right on the boundary of the Test
Site; Area 3 and Area 5, the low-level sites.
LAYTON O'NEILL: It was picked in 1953. It is fortuitous, according to my
knowledge and information, about what happened to the NTS. They searched
around in the United States for a number of years to find a place to test weapons,
and they finally settled on the Nevada Test Site, and they said this is a good piace to
test weapons.
I understand about five years ago, or maybe ten, they reinitiated that
investigation, and went out again and looked all over the United States to find out
where the best place would be to test nuclear weapons, and they ended up with the
Nevada Test Site again. Now, we were fortuitous in picking the location we did,
because, it is a long ways to the ground table, and I think the early guys knew a little
something about that. So, we just bought into that. As I told you, we knew
something about the depth to water from the other wells.
Area 5 is 800 feet to the water table. And there are a couple of studies that
were done right near to us, radiation migrations studies, that were done where we
pumped water out of a well 100 feet from an original detonation, and we pumped on
it for 14 years. And the first thing we saw was at the end of two years of continuous
pumping day and night on that well, we saw tritium coming across, and we pumped
on it again and the tritium got to its maximum concentration at five years, and then it
started to decay away again.
The people that studied the ground water at NTS say that it moves something
like 11 feet a year, and that's ail it moves. We forced moving it by pumping down on
it and keeping that pumping going for 14 years. So, it is absolutely a good place,
and it's very dry underneath us.
In the Area 3 area, the water table is at 1300 or 1500 feet below the surface of
the land. So, we think fortuitously they are both good locations, and we looked into
that when we started Area 3. I told you we picked an area where the detonation was
at least 500 feet above the ground water table, and so we know we have got 500 feet
of basically unbothered soil beneath; if nothing else, it is probably compressed by the
weapons tests.
BILL VASCONI: Realizing the site characteristic studies and the fact that it is
bound to be a better piace than along the Miami River back in Ohio, my question
would be, you do have an ample supply of holes at the Test Site to have your
dumps, and I'm sure it can get shipped here. Is there any benefit to be derived from
the state of Nevada for bringing in the waste?
C-IV-2-18
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FEMP-OU4ROD-8 FINAL
December 1994
LAYTON O'NEILL: Well. I think that depends on who you talk to. For mixed
waste, the state of Nevada was gaining $20 a ton for the cement blocks we were
putting in the ground. That's pretty good business for the state of Nevada. They
couid aiso do that for other waste, I believe. They could charge a tariff on the DOE if
they so chose to.
BILL VASCONI: Yes, accepting that it's a federal land and you are bringing in
federal waste; is that not true?
LAYTON O'NEILL: Yes, sir.
BILL VASCONI: So the benefits to be derived for Nevada would be negotiating
for the waste in tonnage and/or condition of; right?
LAYTON O'NEILL: I believe so, and we think that the waste is not going to get
into the ground water table, so we think they are not going to be harmed any.
JOHN WALKER: Just on the question of money and benefits, it seems to me
that DOE receives the disposal funds from its off-site generators. Isn't that the case
that derives some of the waste management budget?
JOE FIORE: Yes. DOE takes out of the one pocket and puts it into another.
We provide a budget for the generator site and as we receive it, they pay us so much
per cubic foot. So overall, the DOE, the disposal of it. is funded by the Department.
LAYTON O'NEILL: Last year we had excess money and Reynolds Electrical
and Engineering Company was forced to return two million dollars; I think it was, to
Headquarters, because we had more money than we were suppose to spend. So it
was returned to the Treasury.
JOE FIORE: And to the extent that those funds support workers at the Test Site
and their jobs, that's the extent of the benefit to the economy of the state.
JOHN WALKER: It's a federal activity, clearly not a state activity.
JOE FIORE: Correct.
JOANNE STOCKILL: Many years ago there were discussions about the state
charging a fee for use of Nevada roads and transportation. Has there been any
recent discussions on that, for Nevada to gain some money from shipments that are
going to the Test Site?
C-IV-2-19
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FEMP-OU4ROD-8 FINAL
December 1994
PAUL LIEBENDORFER: I can speak to recently. I believe it is Nye County that
has looked into some of those situations. I would believe a separate tax to use the
roads, within a road use, would be Department of Transportation, typical to any
trucking activity that went over it. I do know a couple of counties that are actually
looking at determining whether or not they could assess waste shipments that come
back in to support county emergency response activities. And I do know one of the
counties is actually looking at that to support their emergency response if something
would happen on a road, but just a separate assessment that is specific to low-level
waste or hazardous waste or something else, I don't think. Any interstate transport
would have to be equal no matter what the material was.
LAYTON O'NEILL: I was involved, in my early days before I got into the waste
management field, in the training. My bosses went to the speak to the Governor, and
it was at the time we had been asked by Headquarters to start to receive off-site
waste from the other locations in the United States. We made some concessions to
the state of Nevada, and we promised to train every patrolman in response to
radiological accidents and to provide them a radiation kit that was calibrated on a
regular basis so they could depend on it. We never did provide them with
instruments, but we made a deal with the state emergency management group to use
civil defense instruments, and we calibrated them for about seven or ten years until
the state asked us to cease that program of calibrating.
We still are training highway patrolmen at this time. We still are training fire
fighters in the state of Nevada. We provided monitoring gear for the stop-stations for
registering trucks coming in and out of the state of Nevada, and we set them up with
a monitoring device and an alarm that would detect radiation if the truck had any that
they weren't admitting or didn't know about. They were able to check and make sure
they were within limits.
We were providing training for emergency medical people, and we are still doing
that today underneath the waste management program. I'm paying REECo a yearly
amount to go out and do this training. And we have trained most all of the fire
fighters in the city of Las Vegas and all the cities that have fire departments; we train
a few of the volunteer fire departments.
We are doing these programs today underneath the waste management money.
JOE FIORE: I would just like to make a comment and maybe get an answer to
a question to put this transportation thing in perspective. We did some back-of-the-
envelope calculations that said 15,000 shipments over 30 years. That's 500
shipments a year. How does that relate to what we receive now? Don't we receive
about 800 or a 1,000 a year today?
LAYTON O'NEILL: We are getting about three or four a week now. This isn't
our heavy time now, because they are just getting out of the snow up there. So I
guess, a couple hundred a year.
C-IV-2-20
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FEMP-OU4ROD-8 FINAL
December 1994
KATHERINE YURACKO: I have three concerns on this. One, is that, from what
I can tell, this appears to be inconsistent with the Departments' own policy on 11e(2)
material: two. I haven't been convinced that this is the only place that this material
can go; and three, I'm concerned that Nevada gets nothing for this.
PROPOSAL NO. 1
At this point Katherine Yuracko proposed that the Board request a 30-day extension
(for comments on the Draft EIS) in order to prepare an appropriate response, and in
the meantime be provided with the Draft EIS and the four volumes of supporting
documentation.
1. Dennis Bechtel concurred and requested that the Board ask for an extension.
2. Joe Fiore stated that this being the first procedural request that has been made
by the Board, that he would abide by the consensus of the Board.
3. Jim Henderson also felt there was not enough information at the present time to
make comments.
4. Bill Vasconi inquired if the Board's request for an extension would be adhered to
by Fernald. In response, Jack Craig (a Fernald representative) said yes, they would.
5. DECISION: The Board voted on the proposal, and the proposal carried
unanimously.
6. ACTION: Dennis Bechtel agreed to write a letter of request for a 30-day
extension. The Board agreed that each Board member would need a copy of the
summary DEIS, and the Board as a whole would request one copy of the four
volumes of the supporting documentation therefrom.
7. The suggestion was made that the Feasibility Study and the EIS could be made
available through Joe Fiore. There were four copies of the proposed plan, or
summary document made available at the meeting through Fernald representatives.
A request for any additional copies would need to go through Joe Fiore in order for
Fernald to send them.
PROPOSAL NO. 2
Katherine Yuracko proposed that at future briefings, the Board needs to receive the
summary documents in advance in order to review them before the presentation.
C-IV-2-21
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FEMP-OU4ROD-8 FINAL
December 1994
1. Bill Vasconi concurred with Kathy that the Board needed the summary
information in advance.
2. ACTION: Joe Fiore recognized the need for the Board to be better informed in
advance of any briefing or presentation and agreed to get information to the Board in
advance at future briefings.
DISCUSSION ON THE CLASSIFICATION OF 11ef2>
1. Richard Nicolla asked for direction from DOE on why the proposed Fernald
waste is classed as 11 e(2) waste.
2. It was determined that Fernald asked DOE/NV to identify the proposed waste as
11E2. In turn DOE/NV requested Headquarters to give them policy and call back on
it, because it wasn't clear to DOE/NV what it was.
3. Dennis Nixon made the point that in the DOE Orders, it refers to 11e(2) material
being received at NTS in small quantities. The concern and question being can
6,000 cubic yards of the treated waste form be considered a small quantity? Thus
leaving the question: What was the intent when "small quantities" was written in the
DOE Orders?
4. The question was raised that there are other disposal facilities in the United
States that can receive 11e(2) material. Why can't this waste go to these facilities?
5. ACTION: Joe Fiore agreed to pursue the intent of the words "small quantities"
as written in the DOE Orders, but wanted to make sure everyone knew that it would
take DOE longer than 30 days to get that answered.
6. ACTION: Fernald representatives agreed to respond and answer the question
on why the other disposal facilities were not receiving this waste.
ANNOUNCEMENTS
1. Bill Vasconi announced that there was another CAB north of Las Vegas
(SNFCAB). The SNFCAB is a cooperative agreement between Nye County and
Lincoln County and Esmeralda County. They have elected a representative to attend
and monitor this CAB's meetings for their benefit, and when appropriate this tri-
county CAB would be prepared to give a presentation to this CAB on the group's
activities.
C-IV-2-22
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FEMP-OU4ROD-8 FINAL
December 1994
2. Joe Fiore expressed his appreciation to the DOE and contractors representatives
from Fernald for responding promptly to this Board's request for a presentation.
3. „oe Fiore also brought to everyone's attention that the Fernald representatives
supplied copies of a public-information package which has their charter and fact
sheets for each member of the Nevada CAB to review.
4. Dave Rast expressed the importance of follow-up in the formal documentation
process in the comment resolution. The written portion of the process is very
important.
Meeting adjourned at 9:50 p.m.
C-IV-2-23
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December 1994
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FEMP-OU4ROD-8 FINAL
December 1994
APPENDIX D
ADMINISTRATIVE RECORD FILE INDEX
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December 1994
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FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number Document Number
Document Title
U-006-101.27 DOE-750-92
2705
THE ORIGIN OF K-65 MATERIAL
U-006-101.28 KLX-1222
4412
SUMMATION REPORT RECOVERY OF RADIUM FROM K-65 RESIDUE
U-006.101.29
4443
PRELIMINARY ASSESSMENT OF ALTERNATIVES FOR PROCESSING
AND DISPOSAL OF THE AFRIMENT RESIDUES
U-006-101.30
5884
RESPONSE TO SPECIFIC REQUEST DURING HEARING BEFORE
SUBCOMMITTEE ON ENERGY RESEARCH AND DEVELOPMENT
U-006-104.1
1776
UMCO:EC:90-0204
PRMIT TO INSTALL/PERMIT TO OPERATE DETERMINATION ON
GLOVE BOX
U-006-104.2 DOE-1372-90
1777
PERMIT REQUIREMENTS FOR GLOVE BOX USE IN TREATABILITY
TESTING FOR K-65 SILO RESIDUES
U-006-104.4 DOE-23-91
2428
RESPONSE TO OEPA STIPULATIONS FOR INSTALLATION AND
OPERATION OF THE GLOVE BOX FOR TREATABILITY TESTING
U-006-104.10
2450
OEPA MAKES THE FOLLOWING STIPULATION REGARDING THE
INSTALLATION AND OPERATION OF THE GLOVE BOX
U-006-105.1
695
CALCULATION OF RADON EMISSION, DISPERSION AND DOSIMETRY
FROM K-65 STORAGE TANKS AT THE FEED MATERIALS
PRODUCTION CENTER
U-006-105.2
786
K-65 SILOS STUDY & EVALUATION REPORT
U-006-105.3
3666
K-65 SILOS STUDY & EVALUATION CAMARGO REPORT APPENDIX A
& B FEBRUARY 1986
U-006-105.4
3667
K-65 SILOS STUDY & EVALUATION CAMARGO REPORT APPENDIX
C, D & E FEBRUARY 1986
Page No. 1
10/14/94
Document
Date
From
To
01/27/1992 DOE
BLEEKER PUBLISHING
# of Type of
Pages Docunents
3 Letter
02/12/1952 VITROCORP
USAEC (DOE)
05/15/1981 BATTELLE
DOE
50 Report
59 Report
07/22/1987 DOE
METZENBAUM
3 LETTER
06/14/1990 UMCO
DOE-FMPC
2 Letter
07/06/1990 DOE-FMPC
UMCO
2 Letter
11/06/1991 DOE
OEPA
2 Letter
09/27/1990 OEPA
DOE
2 Letter
10/01/1985 COLORADO STATE UNIV
UMCO
14 Letter
02/25/1986 CAMARGO
DOE
02/01/1986 CAMARGO
DOE
45 Report
500 Report
02/01/1986
CAMARGO
DOE
500
Report
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FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No. 2
10/14/94
Index Number Document Number
U-006-105.5
3703
U-006-105.6
3704
Document Title
K-65 SILOS STUDY & EVALUATION CAMARGO REPORT APPENDIX F
1 OF 2 FEBRUARY 1986
K-65 SILOS STUDY & EVALUATION CAMARGO REPORT APPENDIX F
2 OF 2 FEBRUARY 1986
Document
Date
02/01/1986
From
To
CAMARGO
DOE
02/01/1986 CAMARGO
DOE
# of Type of
Pages Documents
500 Report
500 Report
U-006-105.7 DE-AC05-810R20722
167
U-006-105.8 DE-AC05-810R20722
168
STUDY AND EVALUATION OF K-65 SILOS FOR THE FEED
MATERIALS PRODUCTION FACILITY AT FERNALD, OHIO
APPENDICES A THROUGH H: STUDY AND EVALUATION OF K-65
SILOS FOR THE FMPC
01/01/1990 BNI
DOE-FMPC
01/01/1990 BNI
DOE
50 Report
90 Report
U-006-105.9 DE-AC05-810R20722
169
U-006-105.10 FMPC/SUB-20A UC
555
APPENDIX I: STUDY AND EVALUATION OF K-65 SILOS FOR THE
FEED MATERIALS PRODUCTION CENTER AT FERNALD, OH
A PROBABLISTIC RISK ASSESSMENT FOR THE K-65 SILOS AT
THE FMPC, REVISION 1
01/01/1990 BNI
DOE
10/01/1990 UC
DOE-FMPC
482 Report
194 Report
U-006-105.11
2007
A PROBALISTIC RISK ASSESSMENT FOR THE K-65 SILOS AT THE
FMPC NOVEMBER 1990
11/01/1990 UC
DOE-FMPC
100 Report
U-006-105.13 DOE-827-89
5619
K-65 SILOS STRUCTURAL ANALYSIS REPORT
03/28/1989
DOE-FMPC
USEPA
2 LETTER
U-006-105.14
5620
STUDY AND EVALUATION EFFECT OF INTERNAL ATTENUATION
LAYER ON K-65 SILOS VOLUME 1 DECEMBER 1988 (A CAMARGO
REPORT)
03/28/1989
DOE-FMPC
USEPA
482 REPORT
U-006-105.15
5621
STUDY AND EVALUTATION EFFECT OF INTERNAL ATTENUATION
LAYER ON K-65 SILOS VOLUME II DECEMBER 1988 (A
CAMARGO REPORT)
03/28/1989
DOE-FMPC
USEPA
83 REPORT
U-006-105.16
5622
STUDY AND EVALUATION EFFECT OF INTERNAL ATTENUATION
LAYER ON K-65 SILOS VOLUME III DECEMBER 1988 (A
CAMARGO REPORT)
03/28/1989
DOE-FMPC
USEPA
752 REPORT
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FEHP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No. 3
10/14/94
Index Number Document Ntwber
U-006-108.1 NEPA DOC. 19
4476
U-006-108.2 NEPA DOC. 38
4477
U-006-108.3 NEPA DOC. 118
4478
U-006-108.4 NEPA DOC 373
4480
U-006-108.5 NEPA DOC 412
4482
Document Title
K-65 SILO CLOSED CIRCUIT TELEVISION (CCTV) MONITORING
SYSTEM NEPA DOC. 19
K-65 SILO RADON MITIGATION AND DOME REINFORCEMENT NEPA
DOC NO. 38
K-65 AND METAL OXIDE RESIDUE SAMPLING DOC NO. 118
CATEGORICAL EXCLUSION DETERMINATION K-65 EMERGENCY
POWER SUPPLY NEPA DOC NO 373
CATEGORICAL EXCLUSION DETERMINATION OPERABLE UNIT 4
PILOT PLANT PHASE I NEPA DOC NO 412
Document
Date
From
To
05/19/1987 DOE
DOE
09/14/1987 DOE
DOE
08/10/1988 DOE
DOE
03/03/1992 DOE
DOE
04/02/1993 DOE
DOE
# of Type of
Pages Documents
9 Report
18 Report
17 Report
3 Report
5 Report
U-006-108.6 NEPA DOC. 451
5843
OPERABLE UNIT 4 PILOT PLANT PHASE II NATIONAL
ENVIRONMENTAL POLICY ACT (NEPA) DOCUMENT NO. 451
06/23/1994 DOE-FN
FERMCO
5 LETTER/CATX
U-006-201.1 DOE-697-92
2821
ACTION MEMORANDUM: K-65 SILOS RADON TREATMENT SYSTEM
02/18/1992 DOE
WEMCO
2 Letter
U-006-202.1
2822
REMOVAL SITE EVALUATION K-65 SILOS RADON TREATMENT
SYSTEM
01/01/1992 DOE
WEMCO
25 RSE
U-006-209.3
4180
ORNL/TM-12185
U-006-301.1 PRE1256COV
91
WASTE-SURFACE MAPPING OF THE FERNALD K-65 SILOS USING A
STRUCTURED LIGHT MEASUREMENT SYSTEM
SAMPLING AND ANALYSIS PLAN FOR STORAGE SILOS 1,2 AND 3
AT THE U.S. DEPARTMENT OF ENVERGY'S FMPC
10/01/1992 ORNL
DOE-FN
04/01/1988 AS I
WEMCO
85 Report
215 Report
U-006-301.2
394
U-006-301.3
1693
IMPLEMENTATION PLAN FOR THE K-65 AND METAL OXIDE
RESIDUE SAMPLING PROJECT AT THE FMPC REV. 5
RI/FS WORK PLAN ADDENDUM: OPERABLE UNIT 4 K-65 AND
METAL OXIDES SILOS AND SUBSOILS SAMPLING AND ANALYSIS
PLAN (WITH TREATABILITY PLAN) JANUARY 1990
12/01/1988 WMCO
DOE
01/17/1990
532 Report
29 Addendum
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Nunber
U-006-301.4
270
U-006-301.5
829
U-006-301.6
276
U-006-301.7
1276
U-006-301.8
1831
U-006-301.9
1995
9 U-006-301.10
1996
U-006-301.11
2430
U-006-301.12
1374
U-006-301.13
1300
U-006-301.14
1865
Doc intent Nunber Document Title
DOE-745-90 TASK 9.33 K 65 SILO SAMPLING
SITE SPECIFIC HAZARD ASSESSMENT FOR BORINGS 2028 AND
2033 LOCATED IN THE K-65 CONTROL AREA MARCH 27, 1990
90L02298.HLW K-65 SILO RE-SAMPLING OPERATING PROCEDURES
DOE-1758-90 K-65 SAMPLING PROJECT
DOE-277-91 K-65 SILOS SAMPLING AND ANALYSIS
DOE-285-91 REVISED K-65 SILO SUBSOILS SAMPLING ANO ANALYSIS PLAN
RI/FS WORK PLAN ADDENDUM: K-65 SILO SUBSOILS SAMPLING
AND ANALYSIS PLAN NOVEMBER 13, 1990
RI/FS WORK PLAN ADDENDUM: K-65 SILO BERM VERTICAL
BORING SAMPLING AND ANALYSIS PLAN WITH SITE SPECIFIC
HEALTH AND SAFETY PLAN DECEMBER 1990
DOE-1511-91 ADDITIONAL REVISIONS TO THE K-65 RESIDUE SAMPLING AND
ANALYSIS PLAN
RESIDUE SAMPLING FOR K-65 SILOS SAMPLING AND ANALYSIS
PLAN U.S. DEPARTMENT OF ENERGY FEED MATERIALS
PRODUCTION CENTER FERNALD, OHIO MAY 28, 1991
DOE-1802-91 REVISIONS TO K-65 SILOS SUBSOILS SAMPLING AND ANALYSIS
PLAN
Page No. 4
10/14/94
Document From
Date To
05/08/1990 DOE
ASI
# of Type of
Pages Documents
1 Letter
03/27/1990 ASI
DOE-FMPC
03/29/1990 ASI
DOE-FMPC
40 Report
52 Work Plan
08/24/1990 DOE-FMPC
ASI
1 Letter
11/15/1990 DOE-FSO
USEPA
2 Letter
11/16/1990 DOE-FSO
USEPA
2 Letter
11/13/1990 DOE-FSO
EPAs
12/01/1990 DOE
EPAs
14 Report
50 Addendum
06/13/1991 DOE
EPAs
12 Letter
05/28/1991 DOE
EPAs
180 Report
07/10/1991
DOE 2 Letter
EPAs
-------
FEHP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number Document Number
Document Title
U-006-301.15
1866
RI/FS WORK PLAN ADDENDUM K-65 SILO SUBSOILS AND PERCHED
GROUNDWATER SAMPLING AND ANALYSIS PLAN JUNE 27, 1991
U-006-301.16 DOE-1882-91
1744
REVISED SAMPLING AND ANALYSIS PLAN FOR THE K-65 SILOS
RESIDUE SAMPLING PROJECT
U-006-301.17
1745
RESIDUE SAMPLING FOR K-65 SILOS SAMPLING AND ANALYSIS
PLAN JULY 15, 1991
U-006-301.18 WEMCO:ER:92-191
3016
K-65 SILOS DATA VALIDATION AND CHARACTERIZATION
U-006-301.19 DOE-244-91
5196
REVISED K-65 RESIDUE SAMPLING PROCEDURES
O
U-006-301.20
5197
K-65 SILOS SAMPLING AND ANALYSIS PLAN ADDENDUM TO
THE FMPC RI/FS WORK PLAN
U-006-301.21 UMCO:R:AEC:90-0032 OPERATIONAL SAFETY REQUIREMENTS FOR THE SAMPLING AND
5345
U-006-301.22 DOE-1519-90
5816
ANALYSIS OF THE MATERIALS IN K-65 SILOS 1 AND 2
K-65 SAMPLING PROCEDURES
U-006-302.1 DOE-1315-90
1008
OPERABLE UNIT 4 SAMPLING RESULTS
U-006-302.2
344
TRANSMITTAL OF ANALYTICAL DATA
U-006-302.3
246
CERTIFICATE OF ANALYSIS - PROJECT NUMBER 482331 JOB
NUMBER 303317.24.05.20 - SILO MATERIAL
U-006-302.4
3101
WEMCO:ER:92-191
CHARACTERIZATION OF K-65 SILO CONTENTS
Page No. 5
10/14/94
Document
Date
06/27/1991
From
Ifi
DOE
EPAs
# of Type of
Pages Documents
30 ADDENDUM
07/25/1991 DOE
EPAs
2 Letter
07/15/1991 DOE
EPAs
400 Report
03/17/1992 UEMCO
DOE
2 Letter
11/09/1990 DOE-FSO
USEPA
2 LETTER
11/09/1990 DOE-FSO
USEPA
204 ADDENDUM
09/05/1990 DOE-FMPC
35 REPORT
07/25/1990 DOE-FN
EPAs
179 PROCEDURES
06/29/1990 DOE
OEPA
17 Letter
05/18/1990 ASI
DOE
173 Data
03/22/1990 IT
UMCO
33 Certificate
03/31/1992 UEMCO
DOE
2 Letter
-------
FEHP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number
U-006-303.1
1717
U-006-303.2
1718
U-006-303.3
2246
U-006-303.4
2247
U-006-303.5
2311
U-006-303.6
2506
O
U-006-303.7
2470
U-006-303.8
2471
U-006-303.9
2711
U-006-303.10
2713
Docunent Number Document Title
DOE-1892-91 OPERABLE UNIT (OU) 4 TREATABILITY STUDY WORK PLAN
TREATABILITY STUDY WORK PLAN FOR OPERABLE UNIT 4 TASK 5
WORK PLAN JULY 1991
DOE-017-92 OPERABLE UNIT 4 TREATABILITY WORK PLAN
TREATABILITY STUDY WORK PLAN FOR OPERABLE UNIT 4
OCTOBER 1991
ADDENDUM TO OPERABLE UNIT 4 TREATABILITY STUDY WORK
PLAN OCTOBER 1991
OPERABLE UNIT 4 TREATABILITY STUDY WORK PLAN FOR THE
VITRIFICATION OF RESIDUES FORM SILOS 1, 2, AND 3 DRAFT
NOVEMBER 1991
DOE-605-92 REVISED OPERABLE UNIT 4 TREATABILITY STUDY WORK PLAN
FOR STABILIZATION AND CHEMICAL SEPARATION
TREATABILITY STUDY WORK PLAN FOR OPERABLE UNIT 4
JANUARY 1992
DOE-753-92 REVISED OPERABLE UNIT 4 TREATABILITY WORK PLAN FOR
VITRIFICATION
OPERABLE UNIT 4 TREATABILITY STUDY WORK PLAN FOR THE
VITRIFICATION OF RESIDUES FROM SILOS 1, 2, AND 3
JANUARY 1992
U-006-303.11
2920
DOE-1017-92
PROCEDURES FOR VITRIFICATION OF OPERABLE UNIT (OU) 4
WASTE
Page No. 6
10/14/94
Docunent
Date
07/23/1991
From
To
DOE
EPAs
# of Type of
Pages Documents
2 Letter
07/01/1991
10/03/1991
10/01/1991
DOE
EPAs
DOE
EPAs
DOE
EPAs
167 Work Plan
2 Letter
251 Report
11/01/1991 DOE
EPAs
4 Addendum
11/01/1991 DOE
EPAs
70 Work Plan
01/02/1992 DOE
EPAs
2 Letter
01/01/1992 DOE
EPAs
250 Report
01/28/1992 DOE
EPAs
2 Letter
01/01/1992 DOE
EPAs
75 Work Plan
03/05/1992
DOE
EPAs
2
Letter
-------
FEHP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No.
10/14/94
Index Number Document Number
U-006-303.12
2921
Docunent Title
PROCEDURES FOR THE OPERABLE UNIT 4 TREATABILITY STUDY
WORK PLAN FOR THE VITRIFICATION OF RESIDUES FROM SILOS
1, 2, AND 3
Document From
Date To
03/05/1992 DOE
EPAs
# of Type of
Pages Documents
50 Work Plan
U-006-303.13 DOE-1174-92
3003
REVISED OPERABLE UNIT 4 VITRIFICATION TREATABILITY
STUDY WORK PLAN
03/24/1992 DOE
EPAs
2 Letter
U-006-303.14
3006
OPERABLE UNIT 4 TREATABILITY STUDY WORK PLAN FOR THE
VITRIFICATION OF RESIDUES FROM SILOS 1, 2, AND 3 MARCH
1992
03/01/1992 DOE
EPAs
145 Work Plan
U-006-303.15 DOE-1352-92
3088
DOCUMENT CHANGE REQUESTS (DCRS) FOR OPERABLE UNIT 4
TREATABILITY WORK PLAN FOR STABILIZATION AND CHEMICAL
EXTRACTION
04/13/1992 DOE
EPAs
2 Letter
U-006-303.16
3161
OPERALBE UNIT 4 TREATABILITY STUDY WORK PLAN FOR THE
VITRIFICATION OF RESIDUES FROM SILOS 1, 2, AND 3
APPENDIX D PROCEDURES AND METHODS REVISED APRIL 1992
04/24/1992 DOE
EPAs
40 Work Plan
U-006-303.17 DOE-0069-93
3804
DOCUMENT CHANGE REQUEST (DCR) FOR OPERALBE UNTI 4
TREATABILITY WORK PLAN FOR STABILIZATION AND CHEMICAL
EXTRACTION
10/08/1992 DOE
EPAs
6 Letter
U-006-303.18 DOE-0156-93
4098
DOCUMENT CHANGE REQUEST (DCR) FOR OPERABLE UNIT 1 AND
OPERABLE UNIT 4 TREATABILITY STUDY WORK PLANS FOR
CEMENTATION (OU4)
10/20/1992 DOE-FN
EPAs
7 Letter
U-006-303.19 DOE-118-91
2026
REVISED PLAN FOR THE TREATABILITY SCREENING ACTIVITIES
FOR OPERABLE UNIT 4
10/22/1990 DOE-FSO
EPAs
2 Letter
U-006-303.20
2027
U-006-303.21
1433
TREATABILITY WORK PLAN (LABORATORY SCREENING) FOR SILOS
1 AND 2 SEPTEMBER 1990
SITE SPECIFIC SAFETY PLAN FOR THE K-65 VERTICAL BORING
OPERATIONS
09/01/1990
03/01/1991
66 Report
67 Report
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number Docunent Number
U-006-303.22
5233
Document Title
OPERABLE UNIT 4 REMEDIAL ACTION SAFETY ASSESSMENT
REVISION 0 FEBRUARY 1993
Docunent
Date
From
To
02/01/1993 DOE-FN
# of
Pages
65
U-006-303.23 DOE-1009-94
5212
OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY
WORK PLAN
02/25/1994 DOE-FN
EPAs
U-006-303.24 UP-18-0007
5213
OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY
WORK PLAN REVISION 0 FEBRUARY 1994
02/25/1994 DOE-FN
EPAs
123
U-006-303.25 DOE-400-89
5564
K-65 SILOS NEAR-TERM ACTIVITIES AND FINAL REMEDIATION
PLAN
01/10/1989 DOE-ORO
OEPA
U-006-303.26 DOE-712-89
5618
K-65 SILOS INTERIM STABILIZATION - SAND FILL (K-65 SILO
PROJECT OUTLINE LAYER INSTALLATION) (WORK PLAN FOR THE
K-65 STORAGE SILOS INTERIM STABILIZATION PROJECT -
INSTALLATION OF SAND LAYER)
03/10/1989 DOE-FMPC
USEPA
68
U-006-303.27 DOE-1009-94
5850
OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY
WORK PLAN
02/25/1994 DOE-FN
EPAs
U-006-303.28 UP-18-0007
5845
OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY
WORK PLAN REVISION 0 FEBRUARY 1994
02/01/1994 USEPA
DOE-FN
100
U-006-303.29 DOE-1675-94
5836
OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY STUDY
WORK PLAN
05/11/1994 DOE-FN
EPAs
U-006-303.30
5838
OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY STUDY
WORK PLAN FEMP **DRAFT** MAY 1994
05/11/1994 DOE-FN
EPAs
156
U-006-303.31
5832
OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY STUDY
WORK PLAN **DRAFT FINAL** AUGUST 1994
08/04/1994
DOE-FN
EPAs
162
U-006-304.1
1274
D0E-1763-90
TRANSMITTAL OF THE REMEDIAL INVESTIGATION REPORT FOR
OPERABLE UNIT 4 - FMPC
08/20/1990
DOE-FN
DOE-HQ
Page No. 8
10/14/94
Type of
Docunents
REPORT
LETTER
WORK PLAN
WORK PLAN
REPORT
LETTER
TS WORK PLAN
LETTER
WORK PLAN
TS WORK PLAN
Memorandum
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Nimber Document Number
Document Title
U-006-304.2 DOE-1774-90
1024
REMEDIAL INVESTIGATION REPORT FOR OEPRABLE UNIT 4
U-006-304.3 FMPC-0406-4
510
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4 TASK
6 REPORT AUGUST 1990
U-006-304.4 DOE-215-91
583
OPERABLE UNIT 4 - REMEDIAL INVESTIGATION (RI) REPORT
U-006-304.5 FMPC-0406-5
584
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4 TASK
6 REPORT OCTOBER 1990
U-006-304.6 DOE-1261-93
4258
EXPOSURE FACTORS USED IN THE REMEDIAL INVESTIGATION AND
BASELINE RISK ASSESSMENT FOR OPERABLE UNIT 4
O
vo
U-006-304.7 DOE-1688-93
4301
U-006-304.8
4290
OPERABLE UNIT 4 DRAFT REMEDIAL INVESTIGATION REPORT
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 1 OF 3 APRIL 1993 DRAFT
U-006-304.9
4291
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 2 OF 3 APRIL 1993 DRAFT
U-006-304.10
4292
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 3 OF 3 APRIL 1993 DRAFT
U-006-304.11
4698
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 1 OF 3 AUGUST 1993
U-006-304.12
4699
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 2 OF 3 AUGUST 1993
U-006-304.13
4700
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
VOLUME 3 OF 3 AUGUST 1993
Page No. 9
10/14/94
Document
Date
From
To
08/24/1990 DOE
EPAs
# of Type of
Pages Documents
Letter
08/20/1990 DOE
EPAs
535 Report
11/06/1990 DOE
USEPA
3 Letter
10/29/1990 DOE
EPAs
567 Report
03/05/1993 DOE
EPAs
10 Letter
04/16/1993 DOE
EPAs
2 Letter
04/16/1993 DOE
EPAs
04/16/1993 DOE
EPAs
04/16/1993 DOE
EPAs
08/20/1993 DOE-FN
EPAs
08/20/1993 DOE-FN
EPAs
08/20/1993 DOE-FN
EPAs
450 Report
500 Report
450 Report
600 Report
600 Report
600 Report
•A
ra
2
15
6
c
O £
8 o
g 9
O- 0°
" a
2
ft
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Nutriber Document Nuifcer Document Title
U-006-304.14 DOE-0238-94 OPERABLE UNIT 4 FINAL REMEDIAL INVESTIGATION
4946 REPORT/BASELINE RISK ASSESSMENT
U-006-304.15 REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
4947 FINAL VOLUME 1 OF 3 NOVEMBER 1993
U-006-304.16 REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
4948 FINAL VOLUME 2 OF 3 NOVEMBER 1993
U-006-304.17 REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
4949 FINAL VOLUME 3 OF 3 NOVEMBER 1993
U-006-304.18 DOE-1282-94 REVISIONS TO THE OPERABLE UNIT 4 REMEDIAL INVESTIGATION
5357 FINAL REPORT
U-006-304.19 DOE-1724-94 OPERABLE UNIT 4 FINAL REMEDIAL INVESTIGATION REPORT
5625
U U-006-305.1 RI/FS WORK PLAN ADDENDUM TREATABILITY STUDY OPERABLE
~L 2137 UNIT 4 U.S. DOE FERNALD OH6 890 008 976
O
U-006-305.2 RI/FS WORK PLAN ADDENDUM TREATABILITY STUDY OPERABLE
2146 UNTI 4 U.S. DOE FERNALD
U-006-305.3 OU#4 RI DISAPPROVAL U.S. DOE - FERNALD OH6 890 008 976
1925
U-006-305.4 RI - OU #4 SAMPLING U.S. DOE - FERNALD OH6 890 008 976
2457
U-006-305.5 RI/RISK ASSESSMENT O.U. 4
1767
U-006-305.6
2147
OU#4 - TREATABILITY STUDY U.S. DOE - FERNALD 0H6 890
008 976
Page No. 10
10/14/94
Document From
Date To
11/02/1993 DOE-FN
EPAs
# of Type of
Pages Documents
1 LETTER
11/02/1993 DOE-FN
EPAs
550 REPORT
11/02/1993 DOE-FN
EPAs
550 REPORT
11/02/1993 DOE-FN
EPAs
550 REPORT
03/18/1994 DOE-FN
EPAs
22 LETTER
05/20/1994 DOE-FN
FERMCO
19 RESPONSES
09/06/1990 USEPA
DOE-FN
6 Letter
09/07/1990 USEPA
DOE
3 Letter
09/27/1990 USEPA
DOE-FSO
9 Letter
10/18/1990 USEPA
DOE
2 Letter
10/02/1990 OEPA
DOE
1 Letter
11/21/1990 USEPA
DOE-FSO
4 Letter
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No. 11
10/14/94
Index Number Document Number Document Title
U-006-305.7
1172
NOTICE OF VIOLATION 0U#4 RI/RISK ASSESSMENT U.S. DOE -
FERNALD 0H6 890 008 976
Document F rom
Date To
12/07/1990 USEPA
DOE-ORO
# of Type of
Pages Documents
4 Letter
U-006-305.8
2459
OU#4 RI DISAPPROVAL U.S. DOE - FERNALD 0H6 890 008 976
12/07/1990 USEPA
DOE
30 Letter
U-006-305.9
1817
REVISED RI-RISK ASSESSMENT O.U. 4
12/07/1990 OEPA
DOE
1 Letter
U-006-305.10
1175
0U#4 RI DISPUTE U.S. DOE • FERNALD 0H6 890 008 976
01/04/1991 USEPA
DOE
1 Letter
U-006-305.11
1176
0U#4 RI DISPUTE U.S. DOE - FERNALD OH6 890 008 976
01/04/1991
USEPA
DOE
2 Letter
U-006-305.12
1179
DISPUTE OU #4 RI U.S. DOE - FERNALD 0H6 890 008 976
01/10/1991
USEPA
DOE
2 Letter
U-006-305.13
1204
OU#4 EPA RI DISPUTE U.S. DOE - FERNALD OH6 890 008 976 01/25/1991
USEPA
DOE
2 Letter
U-006-305.14
1205
OU#4 EPA RI DISPUTE U.S. DOE - FERNALD 0H6 890 006 976 01/30/1991
USEPA
DOE
2 Letter
U-006-305.15
2390
0U#4 EPA RI DISPUTE U.S. DOE - FERNALD 0H6 890 008 976 02/22/1991
USEPA
DOE
2 Letter
U-006-305.16
2159
OHIO EPA COMMENTS CONCERNING: THE TREATABILITY STUDY 08/22/1991
WORK PLAN FOR OERPABLE UNIT 4
OEPA
DOE
7 Comnent
U-006-305.17
2154
DISAPPROVAL OF TREATABILITY STUDY WORK PLAN FOR 0U#4
09/03/1991 USEPA
DOE-FSO
2 Letter
U-006-305.18
2340
U.S. EPA COMMENTS ON TREATABILITY STUDY WORK PLAN FOR
0U4
10/01/1991 DOE-FSO
EPAs
36 Response
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No. 12
10/14/94
Index Number Document Number Document Title
U-006-305.19
2421
CONDITIONAL APPROVAL O.U. 4 TREATABILITY STUDY W.P.
Document
Date
11/01/1991
From
To
OEPA
DOE
# of Type of
Pages Documents
1 Letter
U-006-305.20
2844
ADDENDUM AND REVISED TREATABILITY STUDY WORK PLAN FOR
OU #4
12/02/1991 USEPA
DOE
1 Letter
U-006-305.21
2612
DISAPPROVAL OF THE OU #4 VITRIFICATION TREATABILITY
STUDY WORK PLAN
12/24/1991
USEPA
DOE
1 Letter
U-006-305.22
2589
OHIO EPA COMMENTS ON 0U4 VITRIFICATION TREATABILITY
STUDY WORK PLAN
OEPA
DOE
1 Letter
U-006-305.23
2738
APPROVAL O.U. 4 TREATABILITY WORK PLAN
01/27/1992
OEPA
DOE
1 Letter
U-006-305.24
2923
OHIO EPA COMMENTS 0U4 VITRIFICATION TREATABILITY STUDY
WORK PLAN
OEPA
DOE
2 Enclosure
U-006-305.25
2966
DISAPPROVAL OF THE REVISED OU #4 VITRIFICATION
TREATABILITY STUDY WORK PLAN
03/05/1992 USEPA
DOE
1 Letter
U-006-305.26
3097
CONDITIONAL APPROVAL OF THE SECOND REVISION OU #4
VITRIFICATION TREATABILITY STUDY WORK PLAN
04/01/1992
USEPA
DOE
1 Letter
U-006-305.27
3264
0U4 VITRIFICATION STUDY CONDITIONAL APPROVAL
05/14/1992 OEPA
DOE
1 Letter
U-006-305.28
3545
REVISED PROCEDURES FOR OU #4 VITRIFICATION TREATABILITY 06/22/1992 USEPA
STUDY DOE
2 Letter
U-006-305.29
4211
DOCUMENT CHANGE REQUEST FOR 0U4 VITRIFICATION
TREATABILITY STUDY
03/05/1993 USEPA
DOE-FN
1 Letter
U-006-305.30
4533
OHIO EPA COMMENTS ON THE 0U4 RI REPORT
06/17/1993 OEPA
DOE
26 Comment
-------
FEHP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No. 13
10/14/94
Index Number Document Number Document Title
U-006-305.31
4718
U.S DOE EXTENSION REQUEST FOR SUBMITTAL OF 0U4 DRAFT
FINAL RI REPORT
Document
Date
From
12
08/24/1993 USEPA
DOE-FN
# of Type of
Pages Documents
1 Letter
U-006-305.32
4752
DISAPPROVAL OF THE OU 4 REMEDIAL INVESTIGATION REPORT
06/23/1993 USEPA
DOE-FN
72 COMMENTS
U-006-305.33
4766
CONDITIONAL APPROVAL OF REVISED OPERABLE UNIT 4
REMEDIAL INVESTIGATION REPORT
09/22/1993 OEPA
DOE-FN
3 COMMENTS
U-006-305.34
4808
CONDITIONAL APPROVAL OF THE OU 4 REMEDIAL INVESTIGATION
REPORT
10/06/1993 USEPA
DOE-FN
13 COMMENTS
U-006-305.35
4938
OHIO EPA APPROVAL OF THE FINAL OU 4 RI REPORT
OEPA
DOE-FN
1 LETTER
U-006-305.36
469
SILO SAMPLING U.S. DOE-FERNALD OH6 890 008 976
05/25/1989 OEPA
DOE
1 Letter
U-006-305.37
1049
SILO SAMPLING U.S. DOE-FERNALD 0H6 890 008 976
05/25/1989 OEPA
DOE
1 Letter
U-006-305.38
1755
K-65 SAMPLING
07/26/1990 OEPA
DOE
1 Letter
U-006-305.39
1277
K-65 SAMPLING 0U#4 U.S. DOE-FERNALD 0H6 890 008 08/15/1990 USEPA
976
DOE
8 Letter
U-006-305.40
2460
OU#4 EXTERNAL SAMPLING U.S. DOE FERNALD OH6 890 008 12/13/1990 USEPA
976 DOE
2 Letter
U-006-305.41
3345
FURTHER CLARIFICATION RELATIVE TO DISPOSAL OF THE K-65
RESIDUES AT THE FMPC
01/10/1991 USEPA
USEPA
5 Memorandum
U-006-305.42
1816
CONDITIONAL APPROVAL K-65 SILO VERTICAL BORING SAMPLING 02/07/1991 OEPA
PLAN DOE
2 Letter
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Nimber
U-006-305.43
1743
U-006-305.44
2121
U-006-305.45
5051
U-006-305.46
5566
U-006-305.47
5568
U-006-305.48
5567
U-006-305.49
5632
U-006-305.50
5833
U-006-305.51
5834
U-006-305.52
5844
U-006-305.53
5804
U-006-306.1
1924
Document Nimber Document Title
OU #4: K-65 SILO RESIDUE SAMPLING AND ANALYSIS PLAN
APPROVAL OF K-65 SILO CONTENT SAMPLING PLAN
CONDITIONAL APPROVAL OF THE OU 4 REMEDIAL INVESTIGATION
FINAL REPORT
WASTE ANALYSIS FOR SILOS U.S. DOE-FERNALD 0H6 890 008
976
COMMENTS ON THE K-65 SILO SAND FILL PROJECT
K-65 SAND PROJECT U.S. DOE-FERNALD OH6 890 008 976
RISK ASSESSMENT COMMENTS ON CONDITIONALLY APPROVED OU 4
REMEDIAL INVESTIGATION FINAL REPORT
OPERABLE UNIT 4 PILOT PLANT PHASE I TREATABILITY STUDY
WORK PLAN U.S. EPA COMMENTS
OPERABLE UNIT 4 PILOT PLANT TREATABILITY WP - COMMENTS
DOE FEMP MSL #531-0297
MSL#531-0297 OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY
WORKPLAN OHIO EPA COMMENTS
FINAL COMMENTS ON THE OU 4 REMEDIAL INVESTIGATION AND
FEASIBILITY STUDY REPORTS
DOE-40-91 OPERABLE UNIT 4 - REMEDIAL INVESTIGATION (RI) REPORT
Page No. 14
10/14/94
Document
Date
07/01/1991
From
To
USEPA
DOE
# of Type of
Pages Documents
3 Letter
09/10/1991 USEPA
DOE
2 Letter
01/06/1994 USEPA
DOE-FN
6 COMMENTS
02/01/1989 USEPA
DOE-FMPC
2 COMMENTS
05/19/1989 OEPA
DOE-FMPC
12 COMMENTS
05/22/1989 USEPA
DOE-FMPC
2 COMMENTS
04/25/1994 USEPA
DOE-FN
3 COMMENTS
04/04/1919 USEPA
DOE-FN
13 COMMENTS/LET
05/06/1919 OEPA
DOE-FN
9 COMMENTS
06/27/1994 OEPA
DOE-FN
08/02/1994 USEPA
DOE-FN
10/26/1990 DOE
USEPA
5 COMMENTS/LET
5 COMMENTS
2 Letter
3
2
S
c
l-l *
8 o
J2
VO
VO
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No. 15
10/14/94
Index Number Dociment Number
U-006-306.2
585
Document Title
RESPONSE TO U.S. EPA & OEPA COMMENTS ON THE REMEDIAL
INVESTIGATION REPORT FOR OPERABLE UNIT 4
Dociment
Date
From
l£_
10/29/1990 DOE
EPAs
# of Type of
Pages Documents
50 Report
U-006-306.3 DOE-336-91
1843
OPERABLE UNIT 4 - RI/FS SCHEDULE
11/30/1990 DOE
EPAs
2 Letter
U-006-306.4 DOE-429-91
1835
OPERABLE UNIT 4 - FEASIBILITY STUDY (FS) REPORT
12/13/1990 DOE-FSO
USEPA
2 Letter
U-006-306.5 DOE-452-91
948
NOTICE OF DISPUTE - U.S. EPA DISAPPROVAL - OEPRABLE
UNIT 4 REMEDIAL INVESTIGATION (RI) REPORT AND U.S. EPA
NOTICE OF VIOLATION (NOV)
12/20/1990 DOE
USEPA
3 Enclosure
U-006-306.6 DOE-463-91
984
PHASE I TREATABILITY STUDY FOR OPERABLE UNIT 4
12/20/1990 DOE
USEPA
2 Letter
U-006-306.7 DOE-499-91
1174
SUPPLEMENT TO NOTICE OF DISPUTE - OPERABLE UNIT 4
REMEDIAL INVESTIGATION (RI) REPORT
12/26/1990 DOE
USEPA
3 Letter
U-006-306.8 DOE-663-91
998
OPERABLE UNIT 4 - DISPUTE RESOLUTION
01/28/1991 DOE
USEPA
3 Letter
U-006-306.9 DOE-748-91
1206
DISPUTE RESOLUTION • OEPRABLE UNTI 4 REMEDIAL
INVESTIGATION REPORT
02/13/1991 DOE
USEPA
2 Letter
U-006-306.10 DOE-537-91
947
DISPUTE RESOLUTION - OPERABLE UNIT 4 REMEDIAL
INVESTIGATION (RI) REPORT
01/07/1991 DOE
USEPA
2 Letter
U-006-306.11
2252
RESPONSE TO COMMENTS TREATABILITY STUDY WORK PLAN FOR
OPERABLE UNIT 4 JULY 1991 OCTOBER 1991
10/01/1991 DOE
EPAs
50 Response
U-006-306.12
2472
RESPONSE TO COMMENTS RECEIVED ON THE OPERABLE UNIT 4
DRAFT TREATABILITY STUDY WORK PLAN DOCUMENT DATE -
OCTOBER 1991 JANUARY 1992
01/01/1992 DOE
EPAs
25 Response
-------
FEHP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number Document Number
Document Title
U-006-306.13
2712
RESPONSE TO THE U.S. EPA COMMENTS OPERABLE UNIT 4
TREATABILITY STUDY WORK PLAN FOR THE VITRIFICATION OF
THE RESIDUES FROM SILOS 1, 2, AND 3
U-006-306.14
2883
RESPONSE TO THE OEPA COMMENTS OPERABLE UNIT 4
TREATABILITY STUDY WORK PLAN FOR THE VITRIFICATION OF
THE RESIDUES FROM SILOS 1, 2, AND 3
U-006-306.15
3004
RESPONSE TO THE OHIO EPA COMMENTS OPERABLE UNIT 4
TREATABILITY STUDY WORK PLAN FOR THE VITRIFICATION OF
THE RESIDUES FROM SILOS 1, 2, AND 3
U-006-306.16
3005
RESPONSE TO THE U.S. EPA COMMENTS OPERABLE UNIT 4
TREATABILITY STUDY WORK PLAN FOR THE VITRIFICATION OF
THE RESIDUES FROM SILOS 1,2, AND 3
U-006-306.17 DOE-1434-92
3159
REVISED PROCEDURES FOR OPERABLE UNIT 4 (OU 4)
VITRIFICATION TREATABILITY STUDY
0
1
ON
U-006-306.18 DOE-1773-92
3475
RESPONSES TO THE OPERABLE UNIT (OU) 4 VITIRIFICATION
STUDY CONDITIONAL APPROVAL
U-006-306.19 DOE-2561-92
3693
REVISED PROCEDURES FOR OPERABLE UNIT 4 VITRIFICATION
TREATABILITY STUDY
U-006-306.20 DOE-2245-92
4097
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS) - USE
OF BLAST FURNACE SLAG IN OPERABLE UNITS 1 AND 4
FORMULATIONS
U-006-306.21 DOE-2416-93
4592
REQUEST FOR EXTENSION FOR RESUBMITTAL OF THE OPERABLE
UNIT 4 REMEDIAL INVESTIGATION REPORT
U-006-306.22 DOE-2594-93
4658
OPERABLE UNIT 4 REMEDIAL INVESTIGATION REPORT - DRAFT
COMMENT RESPONSE DOCUMENT
U-006-306.23 DOE-2789-93
4697
OPERABLE UNIT 4 DRAFT FINAL REMEDIAL
INVESTIGATION/BASELINE RISK ASSESSMENT REPORT
Page No. 16
10/14/94
Document
Date
From
To
DOE
EPAs
# of Type of
Pages Documents
16 Response
DOE
EPAs
9 Response
03/24/1992 DOE
EPAs
3 Response
03/24/1992 DOE
EPAs
3 Response
04/24/1992 DOE
EPAs
2 Letter
05/27/1992 DOE
OEPA
6 Letter
08/31/1992 DOE
USEPA
3 Letter
07/29/1992 DOE-FN
EPAs
2 Letter
07/13/1993 DOE-FN
EPAs
07/29/1993 DOE-FN
EPAs
08/20/1993 DOE-FN
EPAs
2 Letter
142 Response
52 Response
a
2
s
c
D 50
8 o
is
" a
•- z
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number Document Number
Docunent Title
U-006-306.24 DOE-0182-94
4835
RESPONSES TO OPERABLE UNIT 4 REMEDIAL INVESTIGATION
REPORT ORIGINAL COMMENTS #12, #13 AND #19
U-006-306.25
4945
RESPONSES TO USEPA AND OHIO EPA COMMENTS ON THE
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4,
AUGUST 1993
U-006-306.26 DOE-873-89
3358
NOTIFICATION OF SAMPLING OF K-65 SILOS AT THE U.S. DOE
FMPC
U-006-306.27
1997
COMMENT RESPONSE TO U.S. EPA COMMENTS ON: THE RI/FS
WORK PLAN ADDEDNDUM: K-65 SILO EMBANKMENT AND SUBSOILS
SAMPLING AND ANALYSIS PLAN JULY 1990
U-006-306.28 DOE-1711-90
1275
K-65 SAMPLING PROCEDURES
0
1
K—»
U-006-306.29 DOE-1722-90
1805
U-006-306.30
2028
INFORMATION SUBMITTAL UNDER PARAGRAPH XIII (B) OF THE
1990 CERCLA CONSENT AGREEMENT - GLOVE BOX TREATABILITY
TESTING
FMPC RI/FS REPORT OPERABLE UNIT 4 LABORATORY SCREENING
WORK PLAN
U-006-306.31 DOE-1937-90
1921
K-65 RESIDUE SAMPLING - RESPONSE TO U.S. EPA COMMENTS
ON SAMPLING PROCEDURES
U-006-306.32
2426
FMPC RI/FS PROJECT K-65 SILOS SAMPLING AND ANALYSIS
PLAN RESPONSE TO OEPA COMMENTS
U-006-306.33 DOE-60-91
1842
K-65 SAMPLING
U-006-306.34 DOE-413-91
911
INFORMATION SUBMITTAL UNDER PARAGRAPH XIII (B) OF THE
1990 CONSENT AGREEMENT - ORGANIC EXTRACTION - K-65 SILO
RESIDUE SAMPLE ANALYSES
Page No. 17
10/14/94
Docunent
Date
From
To
10/28/1993 DOE-FN
EPAs
# of Type of
Pages Documents
4 RESPONSES
11/02/1993 DOE-FN
EPAs
23 RESPONSES
04/06/1989 DOE
SOAPCA
2 Letter
07/01/1990 DOE
EPAs
8 Response
08/10/1990 DOE
USEPA
4 Letter
08/14/1990 DOE
EPAs
4 Letter
09/01/1990 DOE
EPAs
11 Comment
09/19/1990 DOE
USEPA
2 Letter
10/02/1990 DOE
OEPA
2 Response
10/11/1990 DOE
USEPA
12/11/1990 DOE
EPAs
2 Letter
3 Letter
a
2
*0
6
c
i-i
o 70
§
a- oo
" 2
z
¦¦o s,
2 r
-------
FEHP ADMINISTRATIVE RECORD Page No. 18
OPERABLE UNIT # 4 - - SILOS 1 - 4 10/14/94
Index Nimber Document Number Doc intent Title
U-006-306.35 DOE-579-91
1836
K-65 SILOS BERN SAMPLING WORK PLAN
Document
Date
01/14/1991
From
To
DOE
USEPA
# of Type of
Pages Documents
1 Letter
U-006-306.36
1157
RESPONSES TO OEPA COMMENTS ON THE K-65 SILO BERM
VERTICAL BORING SAMPLING PLAN
01/01/1991
DOE
OEPA
2 Response
U-006-306.37 DOE-1803-91
1874
K-65 CONTENTS RESAMPLING
07/10/1991
DOE
EPAs
2 Letter
U-006-306.38 DOE-1886-91
1871
K-65 SLANT BORING #2
07/24/1991 DOE
EPAs
2 Letter
U-006-306.39 DOE-2195-91
2069
COMPLETION OF OPERABLE UNIT 4 SAMPLING ACTIVITIES
09/10/1991 DOE
EPAs
2 Letter
U-006-306.40
3344
REQUESTING A MEETING CONCERNING THE APPLICATION OF EPA
STANDARDS FOR THE MANAGEMENT AND DISPOSAL OF HIGH-LEVEL
AND TRANSURANIC NUCLEAR WASTE
03/23/1992 DOE-HQ
USEPA
3 Letter
0
1
oo
U-006-306.41 DOE-82-89
5338
K-65 AND METAL OXIDE SILO SAMPLING SCHEDULE
11/10/1988 DOE-FMPC
USEPA
1 LETTER
U-006-306.42 DOE-1364-89
5469
STORAGE OF K-65 AND METAL OXIDE SAMPLE MATERIAL
08/30/1989 DOE-FMPC
USEPA
1 LETTER
U-006-306.43 DOE-1806-91
5442
CONFIRMATION OF VERBAL APPROVAL TO PROCEED ON CONTENT
RESAMPLING
07/12/1991 DOE-FSO
EPAs
2 LETTER
U-006-306.44 DOE-067-92
5350
U-006-306.45 DOE-291-89
5563
U-006-306.46 DOE-1308-89
5565
OPERABLE UNIT 4 TREATABILITY WORK PLAN ADDENDUM
RESPONSES TO USEPA COMMENTS ON K-65 AND METAL OXIDE
SILO SAMPLING PLAN
RESPONSE TO U.S. AND OHIO EPA QUESTIONS ON K-65 SILO
INTERIM REMEDIATION
10/08/1991 DOE-FN
EPAs
12/23/1988 DOE-ORO
USEPA
07/14/1989 DOE-FMPC
USEPA
2 LETTER
11 RESPONSES
33 RESPONSES
3
£
6
c
D $
§ 8
2 D
i <»
3 3
>- 2
¦o C
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number
U-006-306.47
5734
U-006-306.48
5837
U-006-306.49
5842
U-006-306.50
5851
U-006-307.1
4635
U-006-307.2
4612
U-006-307.3
4637
U-006-307.4
4702
U-006-307.5
4703
U-006-307.6
4704
U-006-307.7
4705
Document Number Document Title
REMEDIAL INVESTIGATION REPORT FOR OPERABLE UNIT 4
RESPONSE TO COMMENTS AUGUST 12, 1993
TECHNICAL REVIEW COMMENTS ON OPERABLE UNIT 4 (0U4)
PILOT PLANT PHASE I TREATABILITY STUOY WORK PLAN,
REVISION 0 GENERAL COMMENTS
DOE-1837-94 RESPONSES TO COMMENTS FROM THE OHIO EPA ON THE PHASE I
WORK PLAN FOR THE OPERABLE UNIT 4 PILOT PLANT
DOE-2187-94 OPERABLE UNIT 4 PILOT PLANT PHASE II TREATABILITY STUDY
WORK PLAN
GEOLOGY OF CINCINNATI AND VICINITY 1916
RAINFALL AND RUNOFF IN THE MIAMI VALLEY STATE OF
OHIO MIAMI CONSERVANCY DISTRICT 1921
PROCESS ENGINEERING REPORT OPERATING MANUAL FOR K-65
STORAGE AREA FEED MATERIAL PRODUCTION CENTER,
FERNALD, OHIO
K-65 STORAGE TANK NO. 1
K-65 STORAGE TANKS
LEASE OF FACILITIES TO AFRICAN METALS
LEASE OF K-65 TANK AREA
Page No. 19
10/14/94
Document From
Date To
08/12/1993 DOE-FN
EPAs
# of Type of
Pages Documents
150 RESPONSES
05/11/1994 DOE-FN
EPAs
12 COMMENTS
06/01/1994 DOE-FN
EPAs
10 RESPONSES
08/04/1994 DOE-FN
EPAs
18 COMMENTS/LET
01/01/1921
CCC, INC.
USAEC
217 Report
235 Report
50 Report
11/25/1953 NLO
1 Memorandum
12/01/1953 USAEC
NLO
1 Letter
07/15/1958 USAEC
NLO
1 Letter
08/28/1958 USAEC 1 Letter
NLO
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number
U-006-307.8
4611
U-006-307.9
4636
U-006-307.10
4613
U-006-307.11
4681
U-006-307.12
4614
U-006-307.13
4610
U-006-307.14
4440
U-006-307.15
4441
U-006-307.16
4603
U-006-307.17
4445
Document Number Document Title
RAINFALL FREQUENCY ATLAS OF THE UNITED STATES FOR
DURATIONS FROM 30 MINUTES TO 24 HOURS AND RETURN
PERIODS FROM 1 TO 100 YEARS TECHNICAL PAPER NO.40
SCOPING INVESTIGATION OF SHORT-TERM STORAGE COSTS FOR
AFRIMET RESIDUES - NFSS AND FMPC SEPTEMBER 29, 1980
SOIL SURVEY OF BUTLER COUNTY, OHIO
BMI-2083 UC-11 PRELIMINARY ASSESSMENT OF ALTERNATIVES FOR PROCESSING
AND DISPOSAL OF THE AFRIMET RESIDUES FINAL REPORT
1981
SOIL SURVEY OF HAMILTON COUNTY, OHIO
FIRM FLOOO INSURANCE RATE MAP COUNTY OF HAMILTON
OHIO
FEASIBILITY INVESTIGATION FOR CONTROL OF RADON EMISSION
FROM THE K-65 SILOS
CONCEPTUAL DESIGN REPORT K-65 STORAGE SILO RADON
MITIGATION AND DOME REINFORCEMENT STUDY
FMPC-2142 THE K-65 WASTE STORAGE SILOS AT THE FEED MATERIALS
PRODUCTION CENTER SEPTEMBER 1988
SAMPLING AND RADIOLOGICAL ANALYSES OF SEDIMENT FROM
PADDY'S RUN AND THE STORM SEWER OUTFALL DITCH
U-006-307.18
4770
TOPOGRAPHIC SURVEY AND GEOTECHNICAL INVESTIGATION
FMPC WATER POLLUTION CONTROL FERNALD, OHIO
Page No. 20
10/14/94
Document
Date
From
To
05/01/1961 US COMMERCE
# of Type of
Pages Documents
65 Report
09/29/1980 NLO
DOE-FN
01/01/1980 USAG
05/15/1981 BATELLE
DOE
49 Report
259 Report
64 Report
08/01/1982 USAG
06/01/1982 FEMA
07/30/1987 WEMCO
DOE
05/13/1987 WEMCO
DOE
09/01/1988 WEMCO
DOE-ORO
09/07/1989 IT
AS I
10/05/1982 ATEC ASSOC.
NLO
286 Report
1 Map
100 Report
51 Report
12 Report
3 Memorandum
75 REPORT
-------
FEHP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No. 21
10/14/94
Index Nuwber Document Number
U-006-307.19
4942
Document Title
EFFECT OF INCREASED PUMPING OF GROUND WATER IN THE
FAIRFIELD-NEU BALTIMORE AREA, OHIO - A PREDICTION BY
ANALOG-MOOEL STUDY GEOLOGICAL SURVEY PROFESSIONAL
PAPER 605-C (ANDREW M. SPEIKER)
Document
Date
From
To
USGS
# of Type of
Pages Documents
50 REPORT
U-006-307.20
4943
TREATMENT OF PITCHBLENDE RESIDUES FOR RECOVERY OF METAL
VALUES (JOHN E. LITZ)
05/30/1974 HAZEN RESEARCH
COTTER CORP
30 REPORT
U-006-307.21
4944
WASTE WATER QUALITY REPORTS, NPDES PERMIT PARAMETERS
AND DATA SUMMARIES 1979 TO 1983
NLO
250 REPORTS
U-006-307.22
5030
ECOREGIONS OF THE UNITED STATES
U.S. FOREST SERVICE 1976
BY ROBERT G. BAILEY
01/01/1976
1 MAP
U-006-307.23
5031
GLACIAL GEOLOGIC MAPPING IN HAMILTON COUNTY, OHIO
(REPORT OF PROGRESS ON THE FIRST PHASE) BY C. SCOTT
BROCKMAN SEPTEMBER 1986 OHIO DEPT. NATURAL
RESOURCES, DIV. GEOLOGICAL SURVEY
09/01/1986
17 REPORT
U-006-307.24
5032
RADIOLOGICAL AND CHEMICAL BASELINE RISK ASSESSMENT
OPERABLE UNIT 4 APRIL 2, 1990 PELIMINARY
DRAFT
04/02/1990 IT CORP
DOE-ORO
150 REPORT
U-006-307.25
5033
BEDROCK TOPOGRAPHY OF BUTLER COUNTY, OHIO BY JACK A.
LEOW JULY 1985 OHIO DEPT. NATURAL RESOURCES, DIV.
GEOLOGICAL SURVEY
07/01/1985
1 MAP
U-006-307.26
5034
GROUND-WATER HYDROLOGY AND GEOLOGY OF THE LOWER GREAT
MIAMI RIVER VALLEY, OHIO BY ANDREW M. SPIEKER
1968 U.S. GEOLOGICAL SURVEY PROFESSIONL PAPER
605-A
01/01/1968
40 REPORT
U-006-307.27 FUTURE DEVELOPMENT OF THE GROUND-WATER RESOURCE IN THE 01/01/1968 50 REPORT
5035 LOWER GREAT MIAMI RIVER VALLEY, OHIO - PROBLEMS AND
SOLUTIONS BY ANDREW M. SPIEKER 1968 U.S.
GEOLOGICAL SURVEY PROFESSIONAL PAPER 605-D
-------
FEHP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number
U-006-307.28
5036
U-006-307.29
5450
U-006-307.30
5451
U-006-307.31
5747
U-006-401.1
576
U-006-401.2
337
U-006-401.3
417
U-006-401.4
1746
U-006-401.5
1747
U-006-401.6
1670
U-006-401.8
5578
Document Number Document Title
BEDROCK TOPOGRAPHY OF HAMILTON COUNTY, OHIO BY JOEL
VORMELKER JULY 1985 OHIO DEPT. NATURAL
RESOURCES, DIV. GEOLOGICAL SURVEY
BEDROCK GEOLOGY OF THE CINCINNATI WEST QUADRANGLE AND
PART OF THE COVINGTON QUADRANGLE, HAMILTON COUNTY, OHIO
BY JOHN P. FORD 1974 OHIO DIV GEOLOGICAL
BEDROCK GEOLOGY OF HAMILTON COUNTY, OHIO BY M.
SWINFORD OHIO DIV GEOLOGICAL SURVEY (IN PREPARATION)
CHRONIC AND SUBCHRONIC, SYSTEMIC AND CARCINOGENIC, ORAL
AND INHALATION TOXICITY INFORMATION FOR 2-HEXANONE,
MAGNESIUM, TRIBUTYL PHOSPHATE, AND MIXED XYLENES. ORAL
AND DERMAL ABSORPTION FACTORS FOR MULTIPLE CHEMICALS.
(OU4, OU1 & OU2 RI REFERENCE)
ARAR IDENTIFICATION FOR OU4 FMPC RI/FS
DOE-1265-90 POTENTIAL STATE ARARS FOR OPERABLE UNIT 4
DOE-1317-90 APPLICABLE RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARS) FOR OPERABLE UNIT 4
ASSESSMENT OF IMPACTS OF ADDITIONAL ARAR.40CFR191
AUGUST 14, 1990
ASSESSMENT OF IMPACTS OF ADDITIONAL ARAR, 40CFR191
AUGUST 24, 1990
DOE-02-91 POTENTIAL ARARS FOR OPERABLE UNIT 4 - REVISION 1
APPLICATION OF 40 CFR 191 TO OU #4
Page No. 22
10/14/94
Docunent From
Date To
07/01/1985
# of Type of
Pages Documents
1 MAP
01/01/1974
2 REPORT
11/10/1992
22 REPORT
07/21/1993 DOLLARHIDE
VANLEEUUEN/EPA
106 REPORT
04/30/1990 ASI
DOE
25 Letter
06/11/1990 DOE
OEPA
1 Letter
06/27/1990 DOE
USEPA
64 Letter
08/14/1990
08/24/1990
70 Report
25 Report
10/22/1990 DOE
EPAs
83 Letter
04/25/1994 USEPA
DOE-FN
1 LETTER
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Member
U-006-401.9
5570
U-006-401.10
5885
U-006-402.1
336
U-006-402.2
299
U-006-402.3
1804
U-006-402.4
1846
U-006-402.5
560
U-006-403.1
416
U-006-403.2
1586
U-006-404.1
4737
U-006-404.2
4738
Document Nunber Document Title
DOE-1630-94 APPLICATION OF 40 CFR 191 TO OPERABLE UNIT 4
APPLICABILITY OF 40 CFR PART 191 TO THE FEED MATERIALS
PRODUCTION CENTER (FHPC)
DOE-1166-90 INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4
FMPC-0412-4 INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 12 REPORT MAY 1990
FMPC-0412-5 INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 12 REPORT AUGUST 1990
DOE-137-91 INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4 -
FINAL REPORT
FMPC-0412-6 INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 12 REPORT OCTOBER 1990
FMPC-0413-2 DETAILED ANALYSIS OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 13 PRESENTATION JUNE 1990
DETAILED ANALYSIS OF ALTERNATIVES FOR OPERABLE UNIT 4
TASK 13 PRESENTATION JULY 1990
DOE-2954-93 OPERABLE UNIT 4 DRAFT FEASIBILITY STUDY REPORT/PROPOSED
PLAN
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4
REMEDIAL INVESTIGATION AND FEASIBILITY STUDY VOLUME
1 OF 4 DRAFT SEPTEMBER 1993
U-006-404.3
4739
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4
REMEDIAL INVESTIGATION AND FEASIBILITY STUDY
2 OF 4 DRAFT SEPTEMBER 1993
VOLUME
Page No. 23
10/14/94
Docunent
Date
From
To
05/05/1994 DOE-FN
EPAs
# of Type of
Pages Docunents
16 LETTER
07/10/1987 DOE
USEPA
2 LETTER
06/01/1990 DOE
EPAs
2 Letter
05/01/1990 DOE
EPAs
08/03/1990 DOE
EPAs
132 Report
200 Report
10/29/1990 DOE
USEPA
2 Letter
10/01/1990 DOE
EPAs
235 Report
06/01/1990 ASI
DOE
53 Handout
07/01/1990
106 Handoul
09/08/1993 DOE-FN
EPAs
3 Letter
09/08/1993 DOE-FN
EPAs
600 Report
09/08/1993
DOE-FN
EPAs
600
Report
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number Docunent Number Document Title
U-006-404.4
4740
FEASIBILITY STUDY REPORT FOR OPRABLE UNIT 4
REMEDIAL INVESTIGATION AND FEASIBILITY STUDY
3 OF 4 DRAFT SEPTEMBER 1993
VOLUME
U-006-404.5
4741
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 REMEDIAL
INVESTIGATION AND FEASIBILITY STUDY VOLUME 4 OF 4 DRAFT
SEPTEMBER 1993
U-006-404.6 DOE-0383-94
4924
REQUEST FOR EXTENSION ON SUBMITTAL OF THE OPERABLE UNIT
4 DRAFT FINAL FEASIBILITY STUDY REPORT AND PROPOSED
PLAN
U-006-404.7 DOE-0636-94
5037
OPERABLE UNIT 4 DRAFT FINAL FEASIBILITY STUDY
REPORT/PROPOSED PLAN
U-006-404.8 DOE/EIS-0195D
5038
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4
1 OF 4 DECEMBER 1993 DRAFT FINAL
VOLUME
to
4*>
U-006-404.9 DOE/EIS-0195D
5039
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4
2 OF 4 DECEMBER 1993 DRAFT FINAL
VOLUME
U-006-404.10 DOE/EIS-0195D
5040
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4
3 OF 4 DECEMBER 1993 DRAFT FINAL
VOLUME
U-006-404.11 D0E/EIS-0195D
5041
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4
4 OF 4 DECEMBER 1993 DRAFT FINAL
VOLUME
U-006-404.12 DOE-1008-94
5204
OPERABLE UNIT 4 FINAL FEASIBILITY STUDY REPORT/PROPOSED
PLAN
U-006-404.13 DOE/EIS-0195D
5205
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
1 OF 4 FINAL FEBRUARY 1994
U-006-404.14 DOE/EIS-0195D
5206
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
2 OF 4 FINAL FEBRUARY 1994
Page No. 24
10/14/94
Docunent From
Date Jo
# of Type of
Pages Documents
09/08/1993 DOE-FN
EPAs
631 Report
09/08/1993 DOE-FN
EPAs
600 Report
11/22/1993 DOE-FN
EPAs
2 LETTER
12/21/1993 DOE
EPAs
2 LETTER
12/21/1993 DOE
EPAs
700 REPORT
12/21/1993 DOE
EPAs
700 REPORT
12/21/1993 DOE
OEPA
700 REPORT
12/21/1993 DOE
OEPA
700 REPORT
02/22/1994 DOE-FN
EPAs
2 LETTER
02/22/1994 DOE-FN
EPAs
683 REPORT
02/22/1994 DOE-FN
EPAs
773 REPORT
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number Document Number Document Title
U-006-404.15 DOE/EIS-0195D
5207
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
3 OF 4 FINAL FEBRUARY 1994
U-006-404.16 DOE/EIS-0195D
5208
FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 4 VOLUME
4 OF 4 FINAL FEBRUARY 1994
U-006-405.1 DOE/EIS-0195D
4742
PROPOSED PLAN FOR OPERABLE UNIT 4 DRAFT AUGUST 1993
U-006-405.2 DOE/EIS-0195D
5042
PROPOSED PLAN FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4
DECEMBER 1993 DRAFT FINAL
U-006-405.3 DOE/EIS-0195D
5209
PROPOSED PLAN FOR REMEDIAL ACTIONS AT OPERABLE UNIT 4
FINAL FEBRUARY 1994
U-006-407.1
893
OU#4 ALTERNATIVES U.S. DOE FERNALD 0H6 890 008 976
N>
l/l
U-006-407.2
894
OHIO EPA COMMENTS - OPERABLE UNIT 4 INITIAL SCREENING
OF ALTERNATIVES REPORT
U-006-407.3
1928
OU#4 - ALTERNATIVES U.S. DOE - FERNALD OH6 890 008 976
U-006-407.4
2135
OU#4 DISPUTE RESOLUTION U.S. DOE FERNALD 0H6 890 008
976
U-006-407.5
2136
OU#4 ALT SCREENING DISPUTE RESOLUTION U.S. DOE
FERNALD 0H6 890 008 976
U-006-407.6
1813
OU#4 ALT SCREENING DISPUTE RESOLUTION U.S. DOE FERNALD
0H6 890 008 976
U-006-407.7
1173
EXTENSION REQUEST OU #4 FS REPORT U.S. DOE FERNALD
OH6 890 008 976
Page No. 25
10/14/94
Document From
Date To
02/22/1994 DOE-FN
EPAs
# of Type of
Pages Documents
690 REPORT
02/22/1994 DOE-FN
EPAs
815 REPORT
09/08/1993 DOE-FN
EPAs
100 Work Plan
12/21/1993 DOE
OEPA
100 REPORT
02/22/1994 DOE-FN
EPAs
105 REPORT
07/05/1990 USEPA
DOE
15 Letter
07/06/1990 OEPA
DOE
6 Letter
09/04/1990 USEPA
DOE
5 Letter
10/03/1990 USEPA
DOE
2 Letter
10/18/1990 USEPA
DOE
2 Letter
10/31/1990 USEPA
DOE
1 Letter
12/19/1990 USEPA
DOE
2 Letter
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number
U-006-407.8
1800
U-006-407.9
2962
U-006-407.10
4907
U-006-407.11
4909
U-006-407.12
4930
U-006-407.13
5121
U-006-407.14
5145
U-006-407.15
5532
U-006-408.1
1946
U-006-408.2
1927
U-006-408.3
1681
U-006-408.4
1672
Document Number Document Title
OU #4 ARARS U.S. DOE - FERNALD OH6 890 008 976
OPERABLE UNIT #4 ARARS
OHIO EPA COMMENTS ON THE OU 4 FEASIBILITY STUDY REPORT
AND PROPOSED PLAN
DISAPPROVAL OF THE O.U. 4 FEASIBILITY STUDY AND
PROPOSED PLAN
APPROVAL OF THE CLARIFICATION TO THE OU 4 FEASIBILITY
STUDY DOCUMENT CHANGE REQUEST
OHIO EPA COMMENTS ON THE REVISED O.U. 4 FS/PP
CONDITIONAL APPROVAL OF THE DRAFT FINAL OU 4
FEASIBILITY STUDY REPORT AND PROPOSED PLAN
APPROVAL OF THE FINAL OU 4 FEASIBILITY STUDY REPORT AND
PROPOSED PLAN (CONDITIONAL APPROVAL)
OEPRABLE UNT1 4 INITIAL SCREENING OF ALTERNATIVES
COMMENT-RESPONSE DOCUMENT
DOE-1853-90 INFORMAL DISPUTE RESOLUTION MEETING
DOE-1772-90 OPERABLE UNIT 4
DOE-46-91 OEPRABLE UNIT 4 - DISPUTE RESOLUTION
Page No. 26
10/14/94
Docunent
Date
01/21/1991
From
To
USE PA
DOE
# of Type of
Pages Documents
4 Letter
03/04/1992 USEPA
DOE
2 Letter
11/09/1993 OEPA
DOE-FN
18 COMMENTS
11/09/1993 USEPA
DOE-FN
66 COMMENTS
11/24/1993 USEPA
DOE-FN
1 LETTER
01/24/1994 OEPA
DOE-FN
18 COMMENTS
02/09/1994 USEPA
DOE-FN
18 COMMENTS
05/09/1994 USEPA
DOE-FN
6 COMMENTS
DOE
EPAs
60 Report
09/07/1990 DOE
USEPA
2 Letter
09/24/1990 DOE
AS I
1 Letter
10/11/1990
DOE
USEPA
3
Letter
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Nimber Docunent Niwber Docunent Title
U-006-408.5 OPERABLE UNIT 4 INITIAL SCREENING OF ALTERNATIVES
2339 COMMENT - RESPONSE DOCUMENT
U-006-408.6 DOE-208-91 OPERABLE UNIT 4 - FEASIBILITY STUDY (FS) REPORT
1847
U-006-408.7 DOE-401-91 OPERABLE UNIT 4 - FEASIBILITY STUDY (FS) REPORT
913
U-006-408.8 DOE-551-91 OPERABLE UNIT 4 - PROPOSED PLAN
960
U-006-408.9 DOE-333-92 OPERABLE UNIT 4 • APPLICABLE OR RELEVANT AND
2507 APPROPRIATE REQUIREMENTS (ARARS)
U-006-408.10 FEASIBILITY STUDY REPORT AND PROPOSED PLAN FOR OPERABLE
5043 UNIT 4 RESPONSES TO COMMENTS DECEMBER 1993
O
NJ
-J U-006-408.11 DOE-1944-92 OPERABLE UNIT
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number
U-006-409.1
4796
U-006-409.2
5448
U-006-409.3
5498
U-006-409.4
5449
U-006-409.5
5309
U-006-409.6
5453
U-006-409.7
5497
U-006-501.1
5812
U-006-504.1
5902
U-006-707.1
4855
U-006-707.2
5073
Document Number Doc intent Title
OPERABLE UNIT 4 TREATABILITY STUDY REPORT FOR THE
VITRIFICATION OF RESIDUES FROM SILOS 1, 2, AND 3
HAY 1993
TREATABILITY STUDY REPORT FOR OPERABLE UNIT 4 DRAFT
MARCH 31, 1993
TECH REPORT Y-87-1 CORPS OF ENGINEERS WETLANDS DELINEATION MANUAL WETLANDS
RESEARCH PROGRAM TECHNICAL REPORT Y-87-1 FINAL REPORT
JANUARY 1987 BY ENVIRONMENTAL
FEED MATERIALS PROOCUTION CENTER, NEAR FERNALD, OHIO
DEPARTMENT OF ENERGY INTENT TO PREPARE A REMEDIAL
INVESTIGATION/FEASIBILITY STUDY - ENVIRONMENTAL IMPACT
STATEMENT FOR THE FIRST OF FIVE REMEDIAL ACTIONS AT THE
DOE/NV/10630-20 U.S. DEPARTMENT OF ENERGY NEVADA OPERATIONS OFFICE
ANNUAL SITE ENVIRONMENTAL REPORT - 1990 VOLUME I
SEPTEMBER 1991
A PHASE I CULTURAL RESOURCES RECONNAISSANCE OF THE FEED
MATERIALS PROOUCTION CENTER ALTERNATE WATER SUPPLY
SYSTEM, FERNALD, HAMILTON COUNTY. OHIO BY US ARMY
DOE-2185-94 OPERABLE UNIT 4 DRAFT RECORD OF DECISION/RESPONSIVENESS
SUMMARY
APPROVAL OF THE DRAFT OU 4 RECORD OF DECISION
DOE-0245-94 OPERABLE UNIT 4 REMEDIAL INVESTIGATION/FEASIBILITY
STUDY SCHEDULE
U.S. EPA/OHIO EPA MAJOR COMMENT RESOLUTION MEETING ON
THE FEASIBILITY STUDY REPORT AND PROPOSED PLAN FOR
REMEDIAL ACTION AT OPERABLE UNIT 4
Page No. 28
10/14/94
Document From
Date To
05/01/1993 FERMCO
DOE-FN
# of Type of
Pages Documents
150 REPORT
03/31/1994 DOE-FN
500 REPORT
01/02/1987 US ARMY
100 REPORT
05/05/1987 OHIO HIS SOC
DOE-FMPC
1 LETTER
05/15/1990 DOE
8 NOTICE
09/01/1991 DOE-NEVADA
200 REPORT
09/01/1992 US ARMY
DOE-FN
65 REPORT
08/05/1994 DOE-FN
EPAs
569 REPORT
09/01/1994 USEPA
DOE-FN
5 LETTER
11/03/1993 DOE-FN
EPAs
8 LETTER
11/22/1993
DOE-FN/FERMCO 4 MINUTES
EPAs
-------
FEHP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Index Number
U-006-708.1
5139
U-006-710.1
5531
U-006-710.2
5515
U-006-710.3
5572
U-006-710.4
5633
U-006-710.5
5646
U-006-710.6
5791
U-006-1003.1
308
U-006-1003.2
326
U-006-1003.8
4293
Document Nunber Document Title
DOE-0854-94 COMMENCEMENT OF OPERABLE UNIT 4 REMEDIAL ACTIONS WITHIN
15 MONTHS AFTER RECEIPT OF UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY APPROVED RECORD OF DECISION
U.S. DOE REQUEST FOR EXTENSION ON THE OU #4 DRAFT
RECORD OF DECISION
DOE-1640-94 OPERABLE UNIT 4 RECORD OF DECISION EXTENSION - FORMAL
AMENDED CONSENT AGREEMENT AMENDMENT
DOE-1734-94 OPERABLE UNIT 4 CONSENT AGREEMENT SCHEDULE • REQUEST
FOR EXTENSION OF THE FEASIBILITY STUDY/PROPOSED
PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT PUBLIC REVIEW
PERIOO AND THE SUBMITTAL OF THE DRAFT RECORD OF
DECISION TO THE USEPA
U.S. DOE REQUEST FOR SECOND EXTENSION OF THE OU #4
DRAFT RECORD OF DECISION
DOE-1860-94 OPERABLE UNIT 4 RECORD OF DECISION EXTENSION - FORMAL
AMENDED CONSENT AGREEMENT AMENDMENT
U.S. DOE OU #4 DRAFT RECORD OF DECISION EXTENSION
AMENDMENT
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW
OF THE INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE
UNIT 4 (SILOS 1,2,3,4 4) AT THE DOE'S FMPC AT FERNALD,
OHIO
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW
OF THE INITIAL SCREENING OF ALTERNATIVES FOR OPERABLE
UNIT 4 (SILOS 1,2,3,4) AT THE DOE FMPC AT FERNALD, OHIO
C:OP:93-484 APPROVAL OF NOTICE OF AVAILABILITY (NOA) FOR OPERABLE
UNIT 4 REMEDIAL INVESTIGATION REPORT
Page No. 29
10/14/94
Document
Date
From
To
# of Type of
Pages Documents
02/09/1994 DOE-FN
EPAs
2 LETTER
04/29/1994 USEPA
DOE-FN
6 LETTER
05/05/1994 DOE-FN
EPAs
6 LETTER
05/19/1994 DOE-FN
EPAs
2 LETTER
05/26/1994 USEPA
DOE-FN
6 NOTICE
06/13/1994 DOE-FN
EPAs
7 LETTER
07/25/1994 USEPA
DOE-FN
5 LETTER
06/04/1990 DOE
PUBLIC
1 NOA
05/30/1990 DOE
PUBLIC
1 NOA
04/06/1993 FERMCO 1 Letter
DOE
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No. 30
10/14/94
Index Number Document Number
U-006-1003.9
4294
Document Title
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEU
AND COMMENT OF THE ADMINISTRATIVE RECORD FILE FOR THE
OPERABLE UNTI 4 REMEDIAL INVESTIGATION REPORT AT THE
DOE FEMP AT FERNALD, OHIO
Document
Date
From
To
04/19/1993 DOE
PUBLIC
# of Type of
Pages Documents
1 NOA
U-006-1003.10 C:OP:93-484
4959
APPROVAL OF NOTICE OF AVAILABILITY (NOA) FOR OPERABLE
UNIT 4 REMEDIAL INVESTIGATION REPORT
04/06/1993 FERMCO
DOE
1 LETTER
U-006-1003.11
4960
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEU
AND COMMENT OF THE ADMINISTRATIVE RECORD FILE FOR THE
OPERABLE UNIT 4 REMEDIAL INVESTIGATION REPORT AT THE
DOE FEMP, FERNALD, OHIO
04/06/1993 DOE
PUBLIC
1 NOA
U-006-1003.12 C:P:93-1343
4963
APPROVAL FOR NOTICE OF AVAILABILITY (NOA) FOR THE
OPERABLE UNIT 4 DRAFT FEASIBILITY STUDY REPORT AND
DRAFT PROPOSED PLAN
09/13/1993 FERMCO
DOE
1 LETTER
U-006-1003.13
4964
u>
o
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC
INSPECTION OF THE DRAFT FEASIBILITY STUDY REPORT AND
DRAFT PROPOSED PLAN FOR OPERABLE UNIT 4 AT THE DOE
FEMP, FERNALD, OHIO
09/13/1993 DOE
PUBLIC
2 NOA
U-006-1003.14 C:ENV:94-0006
5183
APPROVAL FOR NOTICE OF AVAILABILITY (NOA) OF THE
OPERABLE UNIT 4 FEASIBILITY STUDY REPORT/PROPOSED PLAN
- DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR FORMAL
PUBLIC COMMNET
02/23/1994 FERMCO
DOE-FN
3 LETTER
U-006-1003.15 THE USDOE AT THE FEMP, FERNALD, OHIO, ANNOUNCES THE 03/02/1994 DOE-FN 2 NOA
5184 AVAILABILITY OF THE OPERABLE UNIT 4 FEASIBILITY STUDY PUBLIC
REPORT/PROPOSED PLAN - DRAFT ENVIRONMENTAL IMPACT
STATEMENT FOR FORMAL PUBLIC COMMENT
U-006-1003.16
5483
U-006-1003.17
5484
C:ENV:94-0016
APPROVAL FOR NOTICE OF AVAILABILITY (NOA) FOR EXTENDING
THE PUBLIC COMMENT PERIOO FOR THE OPERABLE UNIT 4
FEASIBILITY STUDY/PROPOSED PLAN - DRAFT ENVIRONMENTAL
THE USDOE FEMP ANNOUNCES THE EXTENSION OF THE PUBLIC
REVIEW AND COMMENT PERIOD ON THE OPERABLE UNIT 4
FEASIBILITY STUDY REPORT/PROPOSED PLAN-DRAFT
04/19/1994
04/19/1994
FERMCO
DOE-FN
DOE-FN
PUBLIC
LETTER
NOA
¦n
ro
sj
s
C
4>>
PO
O
D
-------
FEMP ADMINISTRATIVE RECORD
OPERABLE UNIT # 4 - - SILOS 1 - 4
Page No. 31
10/14/94
Index Number
U-006-1003.18
5581
Document Number
C:ENV:94-0020
Document Title
APPROVAL FOR NOTICE OF AVAILABILITY (NOA) FOR EXTENDING
THE PUBLIC COMMENT PERIOD FOR THE OPERABLE UNIT 4
FEASIBILITY STUDY/PROPOSED PLAN - DRAFT ENVIRONMENTAL
IMPACT STATEMENT
Document
Date
05/18/1994
From
To
FERMCO
DOE-FN
* of
Page9
Type of
Documents
LETTER
U-006-1003.19
5582
THE USDOE FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
ANNOUNCES THE EXTENSION OF THE PUBLIC REVIEU AND
COMMENT PERIOD ON THE OPERABLE UNIT 4 FEASIBILITY STUDY
PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT
05/18/1994
DOE-FN
PUBLIC
NOA
U-006-1003.20
5828
C:ENV:94-0032
APPROVAL FOR NOTICE OF AVAILABILITY (NOA) FOR DRAFT
RECORD OF DECISION FOR REMEDIAL ACTIONS AT OPERABLE
UNIT 4
06/27/1994
FERMCO
DOE-FN
LETTER
U-006-1003.21
5829
THE UNITED STATES DEPARTMENT OF ENERGY ANNOUNCES THE
AVAILABILITY FOR PUBLIC INSPECTION THE PROPOSED DRAFT
RECORD OF DECISION FOR REMEDIAL ACTION AT OPERABLE UNIT
4 AT THE FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
08/17/1994 DOE-FN
PUBLIC
1 NOA
U-006-1004.2
5369
U.S. DEPARTMENT OF ENERGY PUBLIC MEETING MARCH 21,
1994
03/21/1994 DOE-FN
PUBLIC
65 TRANSCRIPT
U-006-1005.1
5417
PUBLIC HEARING AND FORMAL COMMENT SESSION ON THE
PROPOSED PLAN FOR OPERABLE UNIT 4
03/14/1994 DOE-FN
PUBLIC
1 NOTICE
U-006-1005.2
5418
AGENDA, OVERHEADS AND HANDOUTS FROM THE PUBLIC HEARING
ON THE OPERABLE UNIT 4 PROPOSED PLAN MARCH 21, 1994
03/21/1994 DOE-FN
PUBLIC
65 HANDOUTS
U-006-1005.3
5419
PUBLIC HEARING SIGN-IN SHEETS FROM THE OPERABLE UNIT 4
FEASIBILITY STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL
IMPACT STATEMENT HELD MARCH 21, 1994
03/21/1994 DOE-FN
42 ROSTER
U-006-1006.1
5189
FACT SHEET FOR THE PROPOSED PLAN FOR REMEDIAL ACTIONS 02/18/1994 DOE-FN
AT OPERABLE UNIT 4 SILOS 1-4 FEBRUARY 1994 PUBLIC
16
FACT SHEET
-------
FEHP ADMINISTRATIVE RECORD
REHOVAL ACTION # 4 - - SILOS 1 AND 2
Index Number Document Number
R-008-101.1
2226
R-008-101.2
1292
R-008-101.3
1298
R-008-101.4
1369
R-008-101.5
1564
R-008-101.6
1620
R-008-101.7 DOE-1756-91
1867
R-008-101.8
1741
R-008-101.9
1906
R-008-101.10
1896
R-008-101.11
2059
R-008-101.12
1931
Doc intent Title
K-65 AREA WEEKLY REPORT HAY 23, 1991
K-65 AREA WEEKLY REPORT NAY 30, 1991
K-65 AREA WEEKLY REPORT JUNE 6, 1991
K-65 AREA WEEKLY REPORT JUNE 14, 1991
K-65 AREA WEEKLY REPORT JUNE 21, 1991
K-65 WEEKLY REPORT JUNE 28, 1991
K-65 WEEKLY REPORT JULY 5, 1991
K-65 WEEKLY REPORT JULY 19, 1991
K-65 WEEKLY REPORT JULY 26, 1991
K-65 WEEKLY REPORT AUGUST 2, 1991
K-65 WEEKLY REPORT AUGUST 9, 1991
K-65 WEEKLY REPORT AUGUST 16, 1991
Page No. 1
10/14/94
Document
Date
05/23/1991
From
To
DOE
EPAs
05/31/1991 DOE
USEPA
06/06/1991 DOE
USEPA
06/14/1991 DOE
USEPA
06/21/1991 DOE
USEPA
06/28/1991 DOE
USEPA
07/05/1991 DOE
USEPA
07/19/1991 DOE
USEPA
07/26/1991 DOE
USEPA
08/02/1991 DOE
EPAs
08/09/1991 DOE
EPAs
08/16/1991 DOE
EPAs
# of Type of
Pages Documents
23 Report
4 Report
4 Report
4 Report
7 Report
12 Report
2 Letter
10 Report
4 Report
4 Report
4 Report
3 Report
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 4 - - SILOS 1 AMD 2
Index Mumber Document Nuifecr Document Title
R-008-101.13
1999
K-65 WEEKLY REPORT AUGUST 22, 1991
R-008-101.14
2061
K-65 WEEKLY REPORT AUGUST 30, 1991
R-008-101.15
2236
K-65 WEEKLY REPORT SEPTEMBER 13, 1991
R-008-101.16
2237
K-65 WEEKLY REPORT SEPTEMBER 20, 1991
R-008-101.17
2209
K-65 WEEKLY REPORT SEPTEMBER 27, 1991
R-008-101.18
2238
K-65 WEEKLY REPORT OCTOBER 4, 1991
u>
u>
R-008-101.19
2239
K-65 WEEKLY REPORT OCTOBER 11, 1991
R-008-101.20
2314
K-65 WEEKLY REPORT OCTOBER 18, 1991
R-008-101.21
2359
K-65 WEEKLY REPORT OCTOBER 25, 1991
R-008-101.22
2372
K-65 WEEKLY REPORT NOVEMBER 1, 1991
R-008-101.23
2402
K-65 WEEKLY REPORT NOVEMBER 8, 1991
R-008-101.24
2509
K-65 WEEKLY REPORT NOVEMBER 15, 1991
Page No. 2
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Document
Date
08/22/1991
From
To
DOE
EPAs
# of Type of
Panes Documents
3 Report
08/30/1991
DOE
EPAs
4 Report
09/13/1991
DOE
EPAs
4 Report
09/20/1991 DOE
EPAs
4 Report
09/27/1991 DOE
EPAs
10/04/1991 DOE
EPAs
10/11/1991 DOE
EPAs
10/18/1991 DOE
EPAs
10/25/1991 DOE
EPAs
11/01/1991 DOE
EPAs
11/08/1991
11/15/1991
DOE
EPAs
DOE
EPAs
7 Report
4 Report
4 Report
6 Report
4 Report
4 Report
4 Report
4 Report
*n
ra
5
s
G
8 o
g o
O- °°
s a
£ P
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 4 - - SILOS 1 AND 2
Index Number Document Number Document Title
R-008-101.25
2516
K-65 WEEKLY REPORT NOVEMBER 22, 1991
R-008-101.26
2521
K-65 WEEKLY REPORT NOVEMBER 29, 1991
R-008-101.27
5347
K-65 WEEKLY REPORT JULY 12, 1991
R-008-101.28
5348
K-65 WEEKLY REPORT SEPTEMBER 6, 1991
R-008-105.1
1432
REVIEW OF THE K-65 SILOS STUDIES FOR THE FMPC APRIL 1,
1991
R-008-106.1 DOE-745-92
2703
SILOS 1 AND 2 REMOVAL ACTION BENTON ITE EFFECTIVENESS
ENVIRONMENTAL MONITORING PLAN
£ R-008-106.2 DOE-1015-92
3030
REVISED SILO 1 AND 2 REMOVAL ACTION BENTONITE
EFFECTIVENESS ENVIRONMENTAL MONITORING PLAN
R-008-106.3 OOE-1382-92
3184
SILOS 1 & 2 REMOVAL ACTION BENTONITE EFFECTIVENESS
ENVIRONMENTAL MONITORING PLAN
R-008-106.4 DOE-1742-92
3290
BENTONITE EFFECTIVENESS MODEL RESULT FOR JANUARY
THROUGHT APRIL, 1992
R-008-106.5 OOE-2022-92
3512
BENTONITE EFFECTIVENESS MOOEL RESULT FOR MAY 1992
R-008-108.1 NEPA DOC 278
4479
EVALUATION OF STRUCTURAL STABILITY OF THE K-65 SILOS AT
FERNALD NEPA DOC 278
R-008-201.1 DOE-1060-90
3047
REMOVAL SITE EVALUATION K-65 SILOS
Page No. 3
10/14/94
Document
Date
11/22/1991
From
To
DOE
EPAs
11/29/1991 DOE
EPAs
# of Type of
Pages Documents
4 Report
4 Report
07/12/1991 DOE
EPAs
4 REPORT
09/06/1991 DOE
EPAs
4 REPORT
04/01/1991 SANDIA NL
DOE
27 Report
01/27/1992 DOE
EPAs
2 Letter
03/17/1992 DOE
EPAs
2 Letter
04/16/1992 DOE
EPAs
2 Letter
05/22/1991 DOE
EPAs
2 Letter
06/30/1992 EPA
DOE
3 Letter
10/30/1989 DOE-FMPC
DOE-HQ
2 Report
05/21/1990
DOE-FO
WMCO
1 Letter
-------
FEHP ADMINISTRATIVE RECORD
REMOVAL ACTION # 4 - - SILOS 1 AND 2
Index Number
R-008-201.2
1683
R-008-202.1
294
R-008-203.1
444
R-008-203.2
1244
R-008-203.3
443
R-008-203.4
3270
R-008-203.5
3271
R-008-204.1
266
R-008-204.2
5349
R-008-204.3
5444
R-008-204.4
2336
R-008-204.5
1875
Document Number Document Title
DOE-159-91 REMOVAL ACTION MEMORANDUM: SILOS 1 & 2 REMOVAL ACTION
REMOVAL SITE EVALUATION K-65 SILOS
A BASELINE RISK ASSESSMENT FOR THE K-65 SILOS USING EPA
METHOOOLOGY FOR APPLICABILITY TO THE EE/CA MAY 11, 1990
DOE-1537-90 TRANSMITTAL OF THE K-65 SILOS EE/CA - CONSENT AGREEMENT
DELIVERABLE
ENGINEERING EVALUATION/COST ANALYSIS (EE/CA) K-65 SILOS
REMOVAL ACTION AT THE FMPC JULY 1990
ENGINEERING EVALUATION/COST ANALYSIS - ENVIRONMENTAL
ASSESSMENT FOR THE K-65 SILOS REMOVAL ACTION, FEMP
FINDING OF NO SIGNIFICANT IMPACT ENGINEERING
EVALUATION/COST ANALYSIS - ENVIRONMENTAL ASSESSMENT
K-65 SILOS REMOVAL ACTION FERNALD ENVIRONMENTAL
DOE-566-90 REVISED K-65 WORK PLAN
PM&A-PM4-91-406 RISK MANAGEMENT PLAN FOR OPERABLE UNIT 4 SILOS 1 & 2
(K-65) REMOVAL ACTION
SILOS 1 AND 2 OPERATIONAL SAFETY REQUIREMENTS REVISION
NO. 4 NOVEMBER 1991
DOE-213-91 K-65 SILOS REMOVAL ACTION WORK PLAN
SILOS 1 AND 2 (K-65 SILOS) REMOVAL ACTION UORK PLAN
NOVEMBER 1990
Page No. >
10/14/94
Document
Date
From
To
10/29/1990 DOE-FSO
UMCO
# of Type of
Pages Documents
2 Letter
05/21/1990 DOE-FMPC
UMCO
5 RSE
05/11/1990 UC
DOE-FMPC
132 Report
07/31/1990 DOE-FMPC
EPAs
2 Letter
07/31/1990 BNI
DOE
135 Report
11/14/1991 DOE
DUFFY
2 Letter
11/14/1991 DOE
9 Report
03/13/1990 DOE-ORO
DOE-FMPC
9 Work Plan
09/11/1991 WEMCO
DOE
19 REPORT
11/01/1991 PARSONS
DOE-FN
25 REPORT
11/02/1990 DOE-FMPC
EPAs
2 Letter
11/01/1990
25
Report
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 4 - - SILOS 1 AND 2
Index Number
R-008-204.7
1561
r-008-204.8
1562
R-008-204.9
4009
R-008-204.10
4010
R-008-204.11
4777
R-008-205.10
1006
R-008-205.18
3015
R-008-205.20
4452
R-008-206.3
2830
R-008-206.5
3601
R-008-206.6
4749
R-008-207.1
3329
Document Number Document Title
DOE-1512-91 REMOTE SURFACE MAPPING TECHNOLOGY SUPPORT DEMONSTRATION
ON FERNALD SILO 4
FERNALD SILO #4 REMOTE SURFACE MAPPING TECHNOLOGY
SUPPORT DEMONSTRATION WORK PLAN MAY 1991
DOE-0650-93 BENTONITE EFFECTIVENESS EVAUATION FOR OPERABLE UNTI 4
AT THE FERNALD ENVIRONMENTAL MANAGEMENT PROJECT
K-65 SILO REMOVAL ACTION • BENTONITE EFFECTIVENESS
EVALUATION DECEMBER 17, 1992
DOE-0021-94
OPERABLE UNIT 4 SILO 2 CAMERA INSTALLATION/BENTONITE
INSPECTION WORK PLAN
UHC0:EMT:90-869
APPROVAL FOR RUST FORCE ACCOUNT TO COMPLETE THE SILOS 1
AND 2 REMOVAL ACTION
WEMCO:ER:92-158 TIGER TEAM COMMITMENT NO. TT:89:0243 (TTA#611)
INTERIM STABILIZATION (FFCA) AND COMPLETE
CHARACTERIZATION REQUIRED (K-65 SILOS)
DCR65A
K-65 SILO VERTICAL BORING SAMPLING AND ANALYSIS PLAN
RI/FS WORK PLAN ADDENDUM MARCH 1991
CHARACTERISTICS OF FERNALD>S K-65 RESIDUE BEFORE,
DURING AND AFTER VITRIFICATION FEBRUARY 1991
DOE-2349-92
RESULTS OF GRAB SAMPLES AND CONTINUOUS PYLON MONITORS
FOR SILOS 1 AND 2
C:OP:93-1284
K-65 SILOS - HEADSPACE RADON CONCENTRATION
COMMENTS ON K-65 INTERIM STABILIZATION PROJECT
Page No. !
10/14/94
Document
Date
06/21/1991
05/01/1991
12/17/1992
12/17/1992
10/05/1993
12/18/1990
03/17/1992
03/01/1991
02/01/1991
08/07/1992
09/09/1993
10/09/1987
From # of Type of
To Pages Documents
DOE-FSO 2 Letter
EPAs
DOE 49 WORK PLAN
EPAs
DOE-FN 2 Letter
EPAs
DOE-FN 200 Report
EPAs
DOE-FN 10 WORK PLAN
EPAs
WMCO 3 Letter
DOE
WEMCO 2 Letter
DOE
4 Addendum
60 Report
DOE 2 Letter
EPAs
FERMCO 4 LETTER
DOE-FN
OEPA 2 Letter
DOE
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 4 - - SILOS 1 AND 2
Index Nunfeer Document Number Document Title
R-008-207.2 USEPA REVIEW OF K-65 SILOS INTERIM STABILIZATION
3440 PROJECT
R-008-207.7 OU#4 - REMOVAL #4 K-65 BORINGS U.S. DOE FERNALD 0H6
2456 890 008 976
R-008-207.8 EE/CA K-65 REMOVAL #4 U.S. DOE-FERNALD OH6 890 008
547 976
R-008-207.9 K-65 EE/CA
1711
R-008-207.11 EE/CA K-65 REMOVAL #4 U.S. DOE-FERNALD 0K6 890 008
1879 976
R-008-207.12 REMOVAL #4 WORK PLAN U.S. DOE-FERNALD 0H6 890 008
919 976
O
w R-008-207.13 CONDITIONAL APPROVAL OF K-65 REMOVAL WORK PLAN
-1 1794
r-008-207.16 BACKGROUND INFORMATION ON HOU TARGET RADON
2804 CONCENTRATION WAS DERIVED
r-008-207.19 APPROVAL - REMOTE SURFACE MAPPING TECHNOLOGY SUPPORT
2453 DEMONSTRATION ON FERNALD SILO 4 WORK PLAN
R-008-207.21 DISAPPROVAL OF THE SILO 1 AND 2 REMOVAL ACTION
2903 BENTONITE EFFECTIVENESS ENVIRONMENTAL MONITORING PLAN
r-008-207.22 APPROVAL OF THE REVISED SILO 1 AND 2 REMOVAL ACTION
3168 BENTONITE EFFECTIVENESS ENVIRONMENTAL MONITORING PLAN
r-008-207.23
4129
DISAPPROVAL OF THE BENTONITE EFFECTIVENESS EVALUATION
FOR OU4
Page No. 6
10/14/94
Document From
Date To
10/19/1987 USEPA
DOE
# of Type of
Pages Documents
3 Letter
08/27/1990 USEPA
DOE
3 Letter
09/04/1990 USEPA
DOE
3 Letter
09/05/1990 OEPA
DOE
2 Letter
10/18/1990 USEPA
DOE
2 Letter
11/30/1990 USEPA
DOE
2 Letter
12/05/1990 OEPA
DOE
1 Letter
01/29/1992 USEPA
DOE
2 Letter
07/25/1991 OEPA
DOE
1 Letter
02/19/1992 USEPA
DOE
1 Letter
04/21/1992 USEPA
DOE
1 Letter
02/12/1993
USEPA 25 Comment
DOE-FN
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 4 - - SILOS 1 AND 2
Index Number Docunent Nunber Document Title
R-008-207.24
4931
APPROVAL OF THE CAMERA INSTALLATION/BENTONITE
INSPECTION WORK PLAN
R-008-208.5
557
K-65 SILOS REMOVAL ACTION ENGINEERING EVALUATION/COST
ANALYSIS RESPONSIVENESS SUMMARY
R-008-208.7 DOE-1904-90
1680
EXTENSION OF PUBLIC COMMENT PERIOO FOR THE K-65 EE/CA
R-008-208.9 DOE-1870-90
1732
K-65 SILOS REMOVAL ACTION
R-008-208.11 DOE-19-91
1908
K-65 SILOS REMOVAL ACTION - INFORMAL DISPUTE RESOLUTION
R-008-208.12 DOE-35-91
1933
K-65 REMOVAL ACTION • STATEMENT OF DISPUTE
.U R-008-208.14 DOE-131-91
oo 1932
K-65 REMOVAL ACTION
R-008-208.15 DOE-557-91
5346
RESPONSE TO OHIO EPA COMMENTS ON THE SILOS 1 AND 2
REMOVAL ACTION WORK PLAN
R-008-208.17
1910
RESPONSE TO U.S. EPA COMMENTS
R-008-208.18
1911
RESPONSE TO OHIO EPA COMMENTS
R-008-208.21 DOE-1023-91
2182
K-65 SILOS WORKING GROUP STATUS REPORT
R-008-208.22
2979
DOE-1186-91
MAJOR POINTS AND ISSUES RESULTING FROM THE APRIL 10,
1991 MEETING
Page No. 7
10/14/94
Document
Date
From
To
11/24/1993 USEPA
DOE-FN
# of Type of
Pages Documents
1 LETTER
10/17/1990 DOE
EPAs
14 Response
09/11/1990 DOE
EPAs
2 Letter
09/27/1990 DOE
EPAs
2 Letter
10/04/1990 DOE
USEPA
2 Letter
10/11/1990 DOE
USEPA
3 Letter
10/22/1990 DOE
USEPA
3 Letter
01/11/1991 DOE-FMPC
OEPA
31 RESPONSES
DOE
USEPA
DOE
OEPA
4 Response
12 Response
03/28/1991
DOE
K-65 SR. COMMITTEE
1
Letter
04/22/1991
DOE
EPAs
7
Letter
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 4 - - SILOS 1 AND 2
Index Number
R-008-208.23
1502
R-008-208.24
1287
R-008-208.25
1366
R-008-208.29
2515
R-008-209.1
4374
R-008-209.2
5528
R-008-1002.1
5905
R-008-1003.1
447
R-008-1003.2
305
R-008-1004.1
4068
Document Number Document Title
DOE-1344-91 K-65 REMOVAL ACTION ADVISORY COMMITTEE
D0E-1359-91 MAJOR POINTS OF DISCUSSION
DOE-1508-91 K-65 TABLETOP EXERCISE
DOE-382-92 DELAY OF THE INITIATION OF THE INSTALLATION OF THE
BENTONITE IN SILOS 1 AND 2
DOE-871-88 COMPLETION REPORT FOR THE EXTERIOR FOAM
APPLICATION/RADON TREATMENT SYSTEM OPERATION OF THE
IC-65 INTERIM STABILIZATION PROJECT - FEED MATERIALS
PRODUCTION CENTER
DRAFT FINAL REPORT FOR THE SILOS 1 & 2 (K-65) REMOVAL
ACTION MAY 1994
ADDENDUM TO THE RI/FS COMMUNITY RELATIONS PLAN FOR
REMOVAL ACTION NO. 4 SILOS 1 AND 2 AUGUST 1990
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEU
OF THE ENGINEERING EVALUATION/COST ANALYSIS FOR THE
K-65 SILOS (SILOS 1 AND 2) REMOVAL ACTION AT THE DOE
FMPC AT FERNALD, OHIO
THE USDOE ANNOUNCES THE AVAILABILITY OF THE
ADMINISTRATIVE RECORD FILE FOR THE K-65 SILOS (SILOS 1
AND 2) REMOVAL ACTION AT THE DOE'S FMPC AT FERNALD,
OHIO
K-65 SILOS REMOVAL ACTION COMMUNITY WORKSHOP AND SITE
SPECIFIC PLAN PRESENTATION AUGUST 16, 1990
Page No. 8
10/14/94
Document
Date
From
To
# of Type of
Pages Documents
05/15/1991
DOE
USE PA
2 Letter
05/17/1991
DOE
EPAs
10 Letter
06/11/1991
DOE
EPAs
4 Letter
11/20/1991 DOE
EPAs
2 Letter
05/23/1988 DOE
USEPA
50 Report
05/17/1994 DOE-FN
EPAs
146 REPORT
08/01/1990 DOE-FN
EPAs
5 ADDENDUM
08/01/1990 DOE
PUBLIC
2 NOA
05/07/1990 DOE
PUBLIC
1 NOA
08/16/1990
DOE-FN 150 Transcript
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 5 - - K-65 DECANT SUMP TANK
Index Number
R-014-108.1
4461
R-014-201.1
901
R-014-202.1
485
R-014-204.1
539
R-014-204.2
2187
R-014-204.3
546
R-014-204.4
905
R-014-204.5
5441
R-014-207.1
1994
R-014-207.2
1789
R-014-207.3
1139
R-014-207.4
1989
Document Number Document Title
NEPA DOC 312 CATEGORICAL EXCLUSION DETERMINATION K-65 DECANT SUMP
TANK REMOVAL ACTION NEPA DOC. NO. 312
DOE-1784-90 REMOVAL ACTION MEMORANDUM: K-65 DECANT SUMP TANK
UMCO:EMT:90-539 REMOVAL SITE EVALUATION K-65 DECANT SUMP TANK WATER
K-65 DECANT SUMP TANK REMOVAL ACTION WORK PLAN FMPC
DRAFT
DOE-76-91 K-65 DECANT SUMP TANK REMOVAL ACTION WORK PLAN
K-65 DECANT SUMP TANK REMOVAL ACTION WORK PLAN FMPC
SEPTEMBER 1990
K-65 DECANT SUMP TANK REMOVAL ACTION WORK PLAN FMPC
DECEMBER 1990
K-65 DECANT SUMP TANK REMOVAL ACTION RISK MANAGEMENT
PLAN MARCH 1991
REMOVAL #5 K-65 DECANT TANK U.S. DOE-FERNALD OH6
890 008 976
COMMENTS K-65 DECANT SUMP TANK REMOVAL U.P.
REMOVAL #5 - DECANT SUMP TANK U.S. DOE FERNALD
OH6 890 008 976
CONDITIONAL APPROVAL K-65 DECANT SUMP REMOVAL WORK PLAN
Page No. 1
10/14/94
Document
Date
From
To
12/21/1990 DOE
DOE
# of Type of
Pages Documents
4 Report
08/23/1990 DOE
WMCO
2 Letter
08/17/1990 WMCO
DOE
8 RSE
09/01/1990 WMCO
DOE-ORO
45 Work Plan
10/17/1990 DOE
EPAs
2 Letter
09/01/1990 DOE
EPAs
49 Work Plan
12/01/1990 DOE
EPAs
71 Work Plan
03/01/1991 WEMCO
DOE-FN
6 WORK PLAN
11/13/1990 USEPA
DOE
4 Letter
11/19/1990 OEPA
DOE
1 Letter
01/10/1991 USEPA
DOE
2 Letter
01/11/1991
OEPA
DOE
2
Letter
-------
FEHP ADMINISTRATIVE RECORD
REMOVAL ACTION # 5 - - K-65 DECANT SUMP TANK
Index Number Dociment Number
Document Title
R-014-207.5
1098
K-65 DECANT SUMP REMOVAL
R-014-207.6
3763
U.S. EPA COMMENTS ON REMOVAL ACTION 5: K-65 DECANT SUMP
TANK FINAL REPORT
R-014-207.7
3787
OHIO EPA COMMENTS ON THE OU 4 - DECANT SUMP TANK
REMOVAL ACTION FINAL REPORT
R-014-207.8
4024
APPROVAL OF THE OU4 DECANT SUMP TANK FINAL REPORT
R-014-207.9
4019
REMOVAL ACTION 5: K-65 DECANT SUMP TANK FINAL REPORT
RESPONSE TO COMMENTS
R-014-208.1
1140
UMCO TECHNICAL RECOMMENDATIONS FOR THE RESPONSE TO U.S.
EPA MODIFICATIONS OF THE K-65 DECANT SUMP TANK REMOVAL
ACTION WORK PLAN
R-014-208.2 DOE-867-91
1142
K-65 DECANT SUMP TANK REMOVAL ACTION
R-014-208.3
903
RESPONSE TO THE U.S. EPA COMMENTS K-65 DECANT SUMP TANK
REMOVAL ACTION UORK PLAN
R-014-208.4
904
RESPONSE TO OHIO EPA COMMENTS K-65 DECANT SUMP TANK
REMOVAL ACTION UORK PLAN
R-014-208.5
1990
THE RESPONSE TO OHIO EPA GENERAL COMMENTS ON THE K-65
DECANT SUMP TANK REMOVAL ACTION UORK PLAN
R-014-208.6
3895
DOE-0343-93
RESPONSES TO COMMENTS ON THE OPERABLE UNIT (OU) 4
DECANT SUMP TANK FINAL REPORT
R-014-209.1
3611
FINAL REPORT K-65 DECANT SUMP TANK REMOVAL ACTION
AUGUST 1992
Page No. 2
10/14/94
Dociment
Date
04/01/1991
From
To
OEPA
DOE
# of Type of
Pages Documents
1 Letter
09/25/1992 USEPA
DOE
1 Letter
10/01/1992 OEPA
DOE
1 Letter
12/14/1992 OEPA
DOE-FN
1 Letter
12/29/1992 USEPA
DOE-FN
1 Response
UMCO
DOE
7 Enclosure
03/01/1991
DOE
USEPA
12/11/1990 DOE
USEPA
12/11/1990 DOE
OEPA
DOE
OEPA
11/19/1992 DOE
EPAs
2 Letter
8 Response
2 Response
2 Response
30 Response
08/01/1992
DOE
EPAs
40
Report
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 5 - - K-65 DECANT SUMP TANK
Page No. 3
10/14/94
Index Number Document Number
R-014-209.2 DOE-1282-93
4148
Document Title
DECANT SUMP TANK FINAL REPORT
Document
Date
03/05/1993
From
To
DOE-FN
EPAs
# of Type of
Pages Documents
2 Letter
R-014-209.3
4149
R-014-401.1
1141
REVISED FINAL REPORT K-65 DECANT SUMP REMOVAL ACTION
FEBRUARY 1993
POTENTIAL ARARS K-65 DECANT SUMP TANK REMOVAL ACTION
02/01/1993
DOE-FN
EPAs
DOE
EPAs
30 Report
5 Report
R-014-1002.1
5906
ADDENDUM B TO THE RI/FS COMMUNITY RELATIONS PLAN FOR
REMOVAL ACTION NO. 5 K-65 DECANT SUMP TANK AUGUST
1991
08/01/1991
DOE-FN
EPAs
5 ADDENDUM
R-014-1003.1
1766
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW
OF THE ADMINISTRATIVE RECORD FILE FOR THE K-65 DECANT
SUMP TANK REMOVAL ACTION AT THE DOE FEMP, FERNALD, OHIO
DOE
PUBLIC
1 NOA
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 21 - - SILO 3 EXPEDITED
Page No. 1
10/14/94
Index Number Document Number Docunent Title
R-025-104.1 DOE-65-91
5443
PERMIT TO OPERATE FOR FMPC SILO NO. 3
Document
Date
From
To
10/19/1990 DOE-FMPC
OEPA
# of Type of
Pages Documents
8 LETTER
R-025-108.1 NEPA DOC. 369
4462
R-025-108.2 NEPA DOC 386
4481
CATEGORICAL EXCLUSION DETERMINATION SILO 3 REMOVAL
ACTION NEPA DOCUMENT 369
CATEGORICAL EXCLUSION DETERMINATION SILO 3 BEST
MANAGEMENT PRACTICES (BMP) WEATHERPROOF ING NEPA DOC 386
03/03/1992 DOE-FN
DOE-HQ
07/02/1992 DOE-FN
DOE-HQ
5 Report
4 Report
R-025-201.1 DOE-015-91
2244
ACTION MEMORANDUM: SILO 3
10/03/1991 DOE
UEMCO
2 Letter
R-025-201.2 DOE-515-91
2676
ACTION MEMORANDUM: SILO 3 REMOVAL ACTION
12/13/1991 DOE
UEMCO
2 Letter
R-025-201.3 DOE-523-92
2538
SILO 3 REMOVAL ACTION
12/19/1991 DOE
EPAs
2 Letter
R-025-202.1
2245
REMOVAL SITE EVALUATION SILO 3
09/01/1991 DOE
UEMCO
50 RSE
R-025-204.1 UEMCO:P:91-957
2677
SILO 3 REMOVAL ACTION SCOPE OF UORK
12/17/1991 UEMCO
DOE
4 Letter
R-025-204.2 UEMCO:P:92-008
2780
SILO 3 BEST MANAGEMENT PRACTICE UORK PLAN
01/06/1992 UEMCO
DOE
16 Uork Plan
R-025-206.1 DOE-016-92
2211
CHAIN-OF-CUSTODY FOR SILO 3 MATERIAL
10/04/1991 DOE
USEPA
2 Letter
R-025-209.1
2682
UEMCO:EVP:92-014 SILO 3 REMOVAL ACTION
01/23/1992 UEMCO
DOE
1 Letter
R-025-209.2
4143
DOE-1215-93
SILO 3 EXPEDITED REMOVAL ACTION FINAL REPORT
02/24/1993 DOE-FN
EPAs
2 Letter
-------
FEMP ADMINISTRATIVE RECORD
REMOVAL ACTION # 21 - - SILO 3 EXPEDITED
Index Number Document Number
R-025-209.3
4144
R-025-1003.1 UEMCO:EM(AR):91-087
2678
R-025-1003.2
2679
Document Title-
FINAL REPORT SILO 3 REMOVAL ACTION FEBRUARY 1993
APPROVAL OF NOTICE OF AVAILABILITY (NOA) FOR THE SILO 3
EXPEDITED REMOVAL ACTION
THE USDOE ANNOUNCES THE AVAILABILITY FOR PUBLIC REVIEW
OF THE ADMINISTRATIVE RECORD FILE FOR THE SILO 3
EXPEDITED REMOVAL ACTION AT THE DOE FMPC, FERNALD, OHIO
Page No. 2
10/14/94
Document
Date
02/01/1993
From
To
DOE-FN
EPAs
01/09/1992
UEMCO
DOE
DOE
PUBLIC
# of
Pages
Type of
Documents
40 Report
Letter
NOA
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FEMP ADMINISTRATIVE RECORD - DRAFT INDEX
OPERABLE UNIT * 4 --- TRANSMITTAL 52
Page No. 1
10/14/94
Docuaant Fro* 9 of Pages
Index Hffeer Docuaent Nwfeer Title Date la Document Type
•******************************************************
U-006-105 . FINAL DESIGN REPORT RADON MITIGATION I DOME REINFORCEMENT PROJECT 08/20/87 IT CORP. 337
DOE-FN REPORT
5975
U-006-105 . EVALUATION Of UNCO FOAM ALTERNATIVES 04/26/88 IT CORP. 144
DOE-FN REPORT
5976
U-006-105 . QUALITATIVE FEASIBILITY STUDY OF ALTERNATIVES FOR INTERIM REMEDIATION 06/17/88 IT CORP. 27
OF K-65 SILOS DOE-FN REPORT
5977
U-006-105 . QUANTITATIVE ANALYSIS REPORT OF ALTERNATIVES FOR INTERIM REMEDIATION 07/01/88 188
OF K-65 SILOS REPORT
5978
o
^ U-006-105 . THE ADAPTABILITY OF VITRIFICATION TECHNOLOGY TO K-65 RESIDUE MATERIAL 05/25/89 PAC. NU LABS 7
5979
DOE-FN REPORT
U-006-302
5999
INDEX OF CHEMICAL DATA PACKAGES • OPERABLE UNIT 4 - AUGUST, 1994
08/31/94 FERMCO
FERMCO
24
DATA
U-006-302
6000
INDEX OF REFERENCED CHEMICAL ANALYTICAL DATA PACKAGES - OPERABLE UNIT 08/31/94 FERMCO
4 - AUGUST 1994 FERMCO
6
DATA
U-006-302
6001
INDEX OF RADIOLOGICAL ANALYTICAL DATA PACKAGES - OPERABLE UNIT 4 •
AUGUST 1994
08/31/94 FERMCO
FERMCO
7
DATA
U-006-302
6002
U-006-302
6003
INDEX OF REFERENCED RADIOLOGICAL ANALYTICAL DATA PACKAGES - OPERABLE 08/31/94 FERMCO
UNIT 4 - AUGUST 1994 FERMCO
INDEX OF FIELD FORMS - OPERABLE UNIT 4 - AUGUST 1994
08/31/94 FERMCO
FERMCO
6
DATA
9
DATA
3
2
s
c
§ 8
3 °
Er »
n
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FEMP ADMINISTRATIVE RECORD - DRAFT INDEX Page No.
OPERABLE UNIT # 4 --- TRANSMITTAL 52 10/14/94
Index Nuwber Document Nuwtocr
Title
Document Fro*
Bsis Is
# of Pages
Docuwent Type
U-006-303
5980
SITE SPECIFIC SAFETY PLAN FOR THE K-65 LOW-ANGLE BORING OPERATIONS
MARCH 6, 1991
03/06/91 IT
DOE-FN
65
REPORT
U-006-305
5981
HAMILTON COUNTY COMMENTS - OU 4 PHASE II PILOT PLANT TRT STUDY UP
09/08/94 OEPA
DOE-FN
COMMENTS
U-006-408
5982
DOE-2378,79,80-94
TRANSMITTAL OF RESPONSIVENESS SUMMARY FOR THE OPERABLE UNIT 4 09/09/94 DOE-FN 3
FEASIBILITY STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT, STAKEHOLDER LETTER
SEPTEMBER 1994
U-006-408
5983
RESPONSIVENESS SUMMARY FOR THE OPERABLE UNIT 4 FEASIBILITY 09/09/94 DOE-FN 352
STUDY/PROPOSED PLAN - DRAFT ENVIRONMENTAL IMPACT STATEMENT - SEPTEMBER EPA/STAKEHOLDER RESPONSE
1994
U-006-504
5984
OU4 RECORD OF DECISION - COMMENTS
09/12/94 OEPA
DOE-FN
4
COMMENTS
U-006-505
5985
D0E-2389-94
EXTENSION REQUEST FOR THE SUBMITTAL OF THE FINAL OPERABLE UNIT 4 FINAL 09/14/94 DOE-FN
RECORD OF DECISION USEPA
2
LETTER
U-006-505
6056
DOE-0034-95
TRANSMITTAL OF RESPONSES TO THE UNITED STATES ENVIRONMENTAL PROTECTION 10/11/94 DOE-FN
AGENCY AND THE OHIO ENVIRONMENTAL PROTECTION AGENCY COMMENTS ON THE EPAS
CONDITIONALLY APPROVED DRAFT RECORD OF DECISION FOR OPERABLE UNIT 4
2
LETTER
U-006-505
6057
PROPOSED DRAFT RECORD OF DECISION FOR REMEDIAL ACTIONS AT OPERABLE
UNIT 4 RESPONSE TO COMMENTS • OCTOBER 1994
10/11/94 DOE-FN
EPAS
15
RESPONSES
U-006-1003.
5986
U-006-1003.
5987
C:ENV:94-0047
APPROVAL FOR NOTICE OF AVAILABILITY (HOA) OF THE RESPONSIVENESS 09/13/94 FERHCO
SUMMARY FOR THE OPERABLE UNIT 4 FEASIBILITY STUDY/PROPOSED PLAN-DRAFT DOE-FN
ENVIRONMENTAL IMPACT STATEMENT
THE UNITED STATES DEPARTMENT OF ENERGY ANNOUNCES THE AVAILABILITY FOR 09/14/94 DOE-FN
PUBLIC INSPECTION OF THE RESPONSIVENESS SUMMARY FOR THE OPERABLE UNIT PUBLIC
4 FEASIBILITY STUDY/PROPOSED PLAN-DRAFT ENVIRONMENTAL IMPACT STATEMENT
3
LETTER
1
NOA
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2
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6
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D 73
8 °
a O
§• «
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n
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FEMP ADMINISTRATIVE RECORD - DRAFT INDEX
OPERABLE UNIT # 4 TRANSMITTAL 52
Page No. 3
10/14/94
Index Nurttter Document Nuwfcer
Title
Document
P«te
Fro*
IS—
§ of Page*
Dociwent Type
U-006-1005.
5988
OVERHEADS PRESENTED AT THE MAT 11, CAB MEETING IN NEVADA - (CITIZEN'S
ADVISORY BOARD)
05/11/94 DOE-FN
CAB
48
OVERHEADS
o
A.
3
2
¦v
O
c
O *
8 2
| 9
zr <*>
O ra
s
*-
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FEMP-OU4ROD-8 FINAL
December 1994
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FEMP-OU4ROD-8 FINAL
December 1994
APPENDIX E
STATE OF OHIO CONCURRENCE
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FEMP-OU4ROD-8 FINAL
December 1994
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OhioERfV
FEMP-OU4ROD-8 FINAL
December 1994
Sutc of Ohio Environmental Protection Agtncy
Southwait District Offlca
*0 Sour Svwt
Oayior OhK3 4S4C2-20M
;5!3) 285-6357
FAX 15131 285-6404
Qoorg* V. Vomovicr
Gov«rno^
February 11. 1994
Mr. Jack R. Craig
Project Manager
U.S. DOE - FEMP
Post Office Box 398705
Cincinnati, Ohio 45239-8705
Dear Mr. Craig:
The purpose of this letter is to conditionally approve the revised O.U.4 FS/PP based on
comment responses and conference calls that have occurred during the past several weeks.
Conditional approval is given until we see the negotiated changes in the final document.
If you have any questions, please contact Tom Schneider or me.
Graham E. Mitchell
Project Manager
GEM:nys
cc: Jenifer Kwasniewski, DERR
Tom Schneider, DERR
Mike Proffitt, DDAGW
Jim Saric, U.S. EPA
Ken Alkema, FERMCO
Lisa August, GeoTrans
Jean Michael, PRC
Robert Owen, ODH
Sincerely
E-l
*¦ U.S. GOVERNMENT PRINTING OFFICE. 1995-650 252/00034
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FEMP-OU4ROD-8 FINAL
December 1994
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