record of decision remedial alternative … filerecord of decision for the f-area burning/rubble...

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United States Department of Energy

Savannah River Site

Record of DecisionRemedial Alternative Selection for theF-Area Burning/Rubble Pits(231-F, 231-lF, and 231-2F) (U)

WSRC-RP-96-868Revision 1February 1997

Westinghouse Savannah River Company oNsiwt,Savannah River Site .<** **•*Aiken, SC 29808 i

Praparad for the U. S. Dapartmant of Energy under Contract No. DE-AC09=98-SR18500SAVANNAH RIVER SITE

RECORD OF DECISIONREMEDIAL ALTERNATIVE SELECTION

FOR THE F-AREA BURNING/RUBBLE PITS (231-F, 231-lF, AND 231-2F) (U)

WSRC-RP-96-868Revision 1

February 1997

Savannah River SiteAiken, South Carolina

Prepared by:

Westinghouse Savannah River Companyfor the

U.S. Department of Energy Under Contract DE-AC09-96SR18500Savannah River Operations Office

Aiken, South Carolina

Record Of Decision for the F-Area Burning/Rubble Pits (231-F, 231- lF, and 231-2F) (U)Savannah River SiteFebruary 1997


Printed in the United States of America

Prepared forU. S. Department of Energy

andWestinghouse Savannah River Company

Aiken. South Carolina

003838

Record Of Decision for the F-Area Burning/Rubble Pits (231-F, 231-IF, and 231-2F) (U) WSRC-RP-96-868Savannah River Site Revision 1February 1997 Declaration

DECLARATION FOR THE RECORD OF DECISION

Unit Name and Location

F-Area Burning/Rubble Pits (231-F, 231-lF, and 231-2F)Savannah River SiteAiken, South Carolina

The F-Area Burning/Rubble Pits (FBRP)(23 l-F, 231- lF, and 231-2F) source unit is listed as a ResourceConservation and Recovery Act (RCRA) 3004(u) Solid Waste Management Unit/ComprehensiveEnvironmental Response, Compensation and Liability Act (CERCLA) unit in Appendix C of the FederalFacility Agreement (FFA) for the Savannah River Site.

Statement of Basis and Purpose

This decision document presents the selected remedial alternative for the FBRP located at the SRS in Aiken,South Carolina. The selected alternative was developed in accordance with CERCLA, as amended, and to theextent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Thisdecision is based on the Administrative Record File for this specific RCRA/CERCLA unit.

Description of the Selected Remedy

The preferred alternative for the FBRP source operable unit is Institutional Controls which will precluderesidential use of this land. Implementation of the Institutional Controls alternative requires both near-termand long-term actions which will be protective of human health and the environment. For the near-term, signswill be posted at the source unit which indicate that this area was used for the disposal of waste material andcontains buried waste. In addition, existing SRS access controls will be used to maintain the use of this sitefor industrial use only. Groundwater contamination at the FBRP will be addressed within the TechnicalMemorandum and Summary for the FBRP. Based upon the conclusions of this document, one of three optionsdescribed below will be selected and implemented. If options 1 or 2 are selected, the new groundwateroperable unit will be placed into Appendix C of the Federal Facility Agreement. The Technical Memorandumand Summary for the FBRP will contain the proposed implementation schedule for this groundwater operableunit.

1) If no upgradient source is indicated, the contribution of the FBRP source unit is confirmed and a ROD forthe FBRP groundwater will be pursued.

2) If a previously unrecognized upgradient source is identified, a new groundwater operable unit will becreated which will undergo Remedial Investigation/Feasibility Study assessment.

3) If an existing upgradient groundwater operable unit is determined to be the source of the contamination,the boundaries of the existing operable unit will be modified to include the groundwater contamination inthe FBRP area.

In the long-term, if the property is ever transferred to n~n-federal ownership, the U.S. Government wouldcreate a deed for the new property owner which would include information in compliance with Section 120(h)of CERCLA. The deed shall include notification disclosing former waste management and disposal activitiestaken on the site. The deed notification shall, in perpetuity, notifj any potential purchaser that the property

Record Of Decision for the F-Am Burning/Rubble Pits (23 l-F, 23 1-IF, and231-2F) (U) WSRC-RP-96-868Savannah River Site Revision 1Febmry 1997 Declaration

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00^038

Record OfDeckion for the F-Area Burning/Rubble Pits (231-F, 231-IF, and 231-2F) (U) WSRC-RP-96-868Savannah River Site Revision 1February 1997 Declaration

Date . Thomas F. HeenanAssistant Manager for Environmental QualityU.S. Department of Energy, Savannah River Operations Office

Date John H. Hankinson, Jr.Regional AdministratorU.S. Environmental Protection Agency

/yDate R. Lewis Shaw

Deputy CommissionerEnvironmental Quality ControlSouth Carolina Department of Health and Environmental Control

Record Of Decision for the F-Area Burning/Rubble Pits (231-F,231-lF, and 231-2F) WSRC-RP-96-868Savannah River Site Revision 1February 1997 Declaration

has been used for the management and disposal of construction debris and other materials, includinghazardous substances.

The deed shall also include deed restrictions precluding residential use of the property. However, the need forthese restrictions could be reevaluated at the time of ownership transfer in the event that contamination nolonger poses an unacceptable risk under residential use.

In addition, if the site is ever transferred to non-federal ownership, a survey plat of the area would be prepared,certified by a professional land surveyor, and recorded with the appropriate county recording agency.

The FBRP Corrective Measures Implementation/Remedial Action Report (CMI/RAR) post-ROD documentwill identify the actions to be taken for the institutional control remedy. The CMI/RAR will be submitted tothe regulatory agencies four months after issuance of the ROD. The regulatory review period, SRS revisionperiod, and final regulatory review and approval period for the CMI/MR will be 90 days, 60 days, and 30days respectively.

The SCDHEC has modified the SRS RCRA pen-nit to incorporate the selected remedy.

statutory Determinations

Based on the FBRP RCRA Facility Investigation/Remedial Investigation (RFI/RI) Report and the BaselineRisk Assessment (BRA), the FBRP poses no significant risk to the environment and minimal risk to humanhealth. Because risk levels exceed 1 x 10-6, a decision was made to implement the Institutional Controlsalternative in an effort to be fully protective of human health and the environment.

The selected remedy is protective of human health and the environment, complies with federal and staterequirements that are legally applicable or relevant and appropriate to the remedial action, and is cost-effective. The random distribution and low levels of contaminants in the soils make treatment impractical.Institutional controls will result in hazardous substances, pollutants, or contaminants remaining in the sourceunit. Because treatment of the principal threats of the site was found to be impracticable, this remedy does notsatisfy the statutory preference for treatment as a principal element.

Section 300.430 (f)(4)(ii) of the NCP requires that a Five Year Review of the ROD be performed if hazardoussubstances, pollutants, or contaminants remain in the source unit. The three Parties have determined that aFive Year Review of the ROD for the FBRP would be performed to ensure continued protection of humanhealth and the environment.

DECISION SUMMARYREMEDIAL ALTERNATIVE SELECTION

FOR THE F-AREA BURNING/RUBBLE PITS (231-F, 231-lF, AND 231-2F) (U)


February 1997

Savannah River SiteAiken, South Carolina

Prepared by:

Westinghouse Savannah River Companyfor the

U.S. Department of Energy Under Contract DE-AC09-96SR18500Savannah River Operations Office

Aiken, South Carolina

Record Of Deeision for the F-Area Burning/Rubble Pits (231-F,231-lF, and 231-X) WSRC-RP-96-868Savannah River Site Revision 1February 1997 DeAration

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Record Of Decision for the F-Area Burning/Rubble Pits (23 l-F,231- lF, and231-2F) (U) WSRC-RP-96-868Savannah River Site Revision 1February 1997 Pageiiiofiv

DECISION SUMMARYTABLE OF CONTENTS

Section Page

I. Site And Operable Unit Name, Location, And Description...................................................1

II. Operable Unit History And Compliance History ...OO1

III. Highlights Of Community Participation ..

Iv. Scope And Role Of Operable Unit Within The Site Strategy.................................................6

v. Summary Of Operable Unit Characteristics..............................................O. . 6

V I . ~ Summary Of Operable Unit Risks........................................... . ..OO...................... . .,..........O.OO,.7

VII. Description Of The Considered Alternatives.............................................................,..,,.... O12

VIII. Summary Of Comparative Analysis Of The Alternatives....................................................16

Ix. The Selected Remedy 1.8

x. Statutory Determinations....................................................................................................24

XI. Explanation Of Significant Changes...................................................................................24

XII. Responsiveness Summary...................................................................................................24

XIII. Post-Rod Document Schedule.............................................................................................24

m . References..........................................................................................................................26

Appendix A - Responsiveness Summary 2.7

List of Figures

Figure 1 Location Of The F-Area Burning/Rubble Pits (231 -F And 231- lF) And Rubble Pit

(231-2F) In Relation To Major Savannah River Site Facilities..............................................2

Figure 2 F-Area Burning/Rubble Pits (FBRP) In Relation To The F-Area..........................................3

Figure 3 Topographic And Water Table Potentiometric Map Of The F-Area Burning/Rubble

Pits (23 1-F And 231 -lF) And Rubble Pit (23 1-2F)...............................................................4

Figure 4 Conceptual Site Risk Model For Soil For The F-Area Burning/Rubble Pits 14

Figure 5 Post-ROD Document Schedule...........................................................................................25

Record Of Decision for the F-Am Burning/Rubble Pits (231-F,231-lF, and 231-2P) (U) WSRC-RP-96-868Savannah River Site Revision 1February 1997 Page iv of iv

List of Tables

Table 1 Summary of Carcinogenic Risk and Noncarcinogenic HI Values for Soil, CurrentVisitors; Hypothetical Future Residents and Workers, Burning Rubble Pits 231-Fand231-lF ...

Table 2 Summary of Carcinogenic Risk and Noncarcinogenic HI Values for Soil, CurrentVisitors; Hypothetical Future Residents and Workers, Rubble Pit 231-2F 10

Table 3 Remedial Goal Options for Intermediate Risk Contaminants of Concern for Soil byReceptor for the F-Area Burning/Rubble Pits (231 -F/lF) and Rubble Pit (231 -IF) 13

Table 4 Evaluation of Alternative 1 - No Remedial Action Under the Nine CERCLACriteria..............................................................................................................................19

Table 5 Evaluation of Alternative 2 - Institutional Controls Under the Nine CERCLA

Criteria ...

Table 6 Evaluation of Alternative 3- Soil Cover (4') Under the Nine CERCLA Criteria 21

Table 7 Evaluation of Alternative 4 - Thermal Resorption/Incineration Under the NineCERCLA Criteria..............................................................................................................22

Table 8 Evaluation of Alternative 5 - Offsite Soil Disposal Under the Nine CERCLAC r i t .. .. .. . ...

003838

Record Of Decision for the F-Area Burning/Rubble Pits (231-F, 231-IF, and 231-2F)(U)Savannah River SiteFebruary 1997


Page 1 of29

I. SITE AND OPERABLE UNIT NAME,LOCATION, AND DESCRIPTION

SRS occupies approximately 310 square miles ofland adjacent to the Savannah River, principally inAiken and Barnwell counties of South Carolina(Figure 1). SRS is a secured U.S. Governmentfacility with no permanent residents. SRS islocated approximately 25 miles southeast ofAugusta, Georgia and 20 miles south of ~ken,South Carolina.

SRS is owned by the U.S. DOE. Management andoperating services are provided by WestinghouseSavannah River Company (WSRC). SRS has

historically produced tritium, plutonium, and otherspecial nuclear materials for national defense.Chemical and radioactive wastes are by-productsof nuclear material production processes.Hazardous substances, as defined by CERCLA, arecurrently present in the environment at SRS.

The Federal Facility Agreement lists the FBRP, asa RCRA/CERCLA unit requir ing firtherevaluation using an investigationhwessmentprocess that integrates and combines the RFIprocess with the CERCLA RI to determine theactual or potential impact to human health and theenvironment.

Figure 1 shows the location of the FBRP inrelation to other facilities at SRS, Figure 2 showsthe location of the FBRP within the F-Area, andFigure 3 shows the layout of the FBRP withsample locations and monitoring wells.

The FBRP comprise a RCRA/CERCLA sourceunit located within the SRS, approximately 3000feet west of F-Area and 1100 f=t north of SRSRoad C. Upper Three Runs is locatedapproximately 2,300 feet northwest of the pits.The local topography of the area is flat upland andthe pits are at an elevation of 290 f~t above meansea level and 170 feet above Upper Three Runs.The water table is 70 to 100 feet below groundsurface in the area of the FBRP. Surface drainageis to the northwest toward an ephemeral tributaryof Upper Three Runs about 7.5 miles upstream ofits confluence with the Savannah River.

The two contiguous burninghubble pits, whichcover a total area of 1.05 acre, are designated as231-F and 231- lF; a twenty foot wide berm ofundisturbed soil separates these two pits. Therubble pit (23 1 -2F) covers about 0.13 acre.Approximate dimensions of the pits are:

o 231 -F: 275 feet x 62 feet x 10 feeto 231-lF: 325 feet x 89 feet x 10 feeto 231-2F: 165 feet x 33 feet x 4-9 feet.

The pits have been baclcillled with soil; the pitcover is mounded above the surrounding terrain,which is essentially level, to enhance drainage.Vegetation has been established on the pits toreduce erosion.

IIe OPERABLE UNIT HISTORY ANDCOMPLIANCE HISTORY

Operable Unit History

Between 1951 and 1973, SRS used Pits 231-F and231- lF to burn a variety of wastes which wereconsidered non-hazardous at that time. Some ofthese waste materials (degreasers and solvents) arenow considered to be hazardous based on ingestionor possible derrnal contact. Waste was usuallyburned on a monthly basis. The chemicalcomposition and volumes of the disposed waste areunknown, but waste materials burned includedpaper, plastics, wood, rubber, rags, cardboard, oil,degreasers, and spent organic solvents. No knownor suspected radioactive materials were allowed inthe burning pits. These radioactive wastes weremanaged in the Radioactive Waste Burial Groundabout 1.5 miles east. Pit 231-2F was usedexclusively as a rubble pit. Large volumes ofuncontaminated construction debris disposed inthe pits may have included relatively small,nonhomogeneously distributed amounts of lowlevel contamination by cesium- 137, strontium-90,and iodine- 129. Traces of these radionuclides mayalso have entered the burninghubble pits asfallout. Uranium-238, radium-226, and

potassium-40 are all naturally occurringradionuclides; radium is always associated withuranium. The typical soils in this region contain

Record Of De&ion for the F-Area Burning/Rubble Pits (23 l-F, 231-lF, and 231-2F) (U)Savannah River SiteFebmaty 1997

WSRC-RP-9&868Revision 1

Pwe 2 0f 29

Figure 1 Location of the F-Area Burning/Rubble Pits (231-F and 231-lF) and Rubble Pit (231-2F) in Relation to Major Savannah River Site Facilities

SOUTHCAROLINA

F-AREABURNNC/RU68(.E

PITS

SOUTHCAROLINA

GEORGIA

SCALE IN MILES

Record Of Decision for the F-Area Burning/Rubble Pits (231-F, 231-lF, and 231-2F) (U)Savannah River SiteFebtuary 1997

VNRC-RP-96.868Revision 1

Page 3 of 29

Figure 2 F-Area Burning/Rubble Pits (FBRP) in Relation to the F-Area

Bfr/f E" N T -.-(T-F - J A G - ' ¥«"-

SCALE 1:24000I HIU

1000 2000 3000 «O00 5000 6000 7000 FEET

.s 1 KILOMtTCR =

CONTOUR INTERVAL 10 FEET

Adapted from USGS 7.5 Minute Quadrangle: New Ellenton SW, Rev. 1981

Record Of Decision for the F-k Burning/Rubble Pits (23 l-F, 23 1-IF, and231-2F) (U)Savannah River SiteFebmaxy 1997


Page 4 of 29

Figure 3 Topographic and Water Table Potentiornetric Map of the F-Area Burning/Rubble Pits[231-F and 231-lF) and Rubble Pit (231-2F)

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003838

Record Of Decision for the F-Area Burning/Rubble Pits (23 l-F, 231- lF, and 231-2F) (U)Savannah River SiteFebmary 1997


Page 5 of 29

about twice as much uranium and potassium as theaverage soil in the United States.

Burning of waste in the SRS pits was discontinuedby October 1973. A layer of soil was then placedover the residue in the pits and they weresubsequently used as rubble pits. Materialsallowed in the rubble pits included concrete,bricks, tile, asphalt, plastic, metal, empty drums,wood products, and rubber. When the pits werefilled to capacity in 1978, a layer of clayey soil wasplaced over the contents and the surface wascompacted and mounded. Vegetation has beenestablished to reduce erosion.

Compliance History

At SRS, waste materials are managed which areregulated under RCRA, a comprehensive lawrequiring responsible management of hazardouswaste. Certain SRS activities have requiredFederal operating or post-closure permits underRCRA. SRS received a hazardous waste permithorn the South Carolina Department of Health andEnvironmental Control on September 5, 1995.Part V of the permit mandates that SRS establishand implement an RFI Program to fulfill therequirements specified in Section 3004(u) of theFederal permit.

Hazardous substances, as defined by CERCLA, arealso present in the environment at the SRS. OnDecember 21, 1989, SRS was included on theNational Priorities List. This inclusion created aneed to integrate the established RFI Program withCERCLA requirements to provide for a focusedenvironmental program. In accordance withSection 120 of CERCLA, DOE has negotiated aFederal Facility Agreement (FFA, 1993) withU. S. Environmental Protection Agency (EPA) andSCDHEC to coordinate remedial activities at SRSinto one comprehensive strategy which Millsthese dual regulatory requirements.

HI. HIGHLIGHTS OF COMMUNITYPARTICIPATION

Both RCIL4 and CERCLA require that the publicbe given an opportunity to review and comment on

the draft permit modification and proposedremedial alternative. Public participationrequirements are listed in South CarolinaHazardous Waste Management Regulation(SCHWMR)R.61-79. 124 and Sections 113 and117 of CERCLA. These requirements include

establishment of an Administrative Record Filethat documents the investigation and selection ofthe remedial alternatives for addressing the FBRPsoils and groundwater. The AdministrativeRecord File must be established at or near thefacility at issue. The SRS Public Involvement Plan(DOE, 1994) is designed to facilitate publicinvolvement in the decision-making process forpermitting, closure, and the selection of remedialalternatives. The SRS Public Involvement Planaddresses the requirements of RCRA, CERCLA,and the National Environmental Policy Act.SCHWMR R.61-79. 124 and Section 117(a) ofCERCLA, as amended, require the advertisementof the draft permit modification and notice of anyproposed remedial action and provide the publican opportunity to participate in the selection of theremedial action. The Statement of Basis/ProposedPlan for the F-Area Burning/Rubble Pits (231-F,231-IF., and 231-2F) (WSRC, 1996e), which ispart of the Administrative Record File, highlightskey aspects of the investigation and identifies thepreferred action for addressing the FBRP.

The FFA Administrative Record File, whichcontains the information pertaining to theselection of the response action, is available at theEPA office and at the following locations:

U.S. Department of EnergyPublic Reading RoomGregg-Graniteville LibraryUniversity of South Carolina-Aiken171 University ParkwayAiken, South Carolina 29801(803) 641-3465

Thomas Cooper LibraryGovernment Documents DepartmentUniversity of South CarolinaColumbia, South Carolina 29208(803) 777-4866

Record Of Decision for theF-Aea Burning/Rubble Pits (23 l-F, 231- lF, and231-2F) (U)Savannah River SiteFebmary 1997


Page 6 of29

Reese LibraryAugusta State University2500 Walton WayAugusta Georgia 30910(706) 737-1744

Asa H. Gordon LibrarySavannah State UniversityTompkins RoadSavannah, Georgia 31404(912) 356-2183

The public was notified of the public commentperiod through mailings of the SZ?S EnvironmentalBulletin, a newsletter sent to approximately 3500citizens in South Carolina and Georgia, throughnotices in the Aiken Stan&zr~ the AUendaleCitizen Leader, the Augusta Chronicle, theBamwell People-Sentinel, and l%e Statenewspapers. The public comment period was alsoannounced on local radio stations.

The 45-day public comment period began onSeptember 17, 1996 and ended on October 31,1996. A public comment meeting was held onOctober 15, 1996. A Responsiveness Summarywas prepared to address comments received duringthe public comment period. The ResponsivenessSummary is provided in Appendix A of thisRecord of Decision.

N . SCOPE AND ROLE OF OPERABLEUNIT WITHIN THE SITESTRATEGY

The overall strategy for addressing the FRBP wasto: (1) characterize the source unit delineating thenature and extent of contamination and identifyingthe media of concern (perform the RFI/RI); (2)perform a baseline risk assessment to evaluatemedia of concern, constituent of concern (COCS),exposure pathways, and characterize potentialrisks; and (3) evaluate and perform a final actionto remediate, as needed, the identified media ofconcern.

The FBRP operable unit consists of sourcematerials, soils, and groundwater. It is locatedwithin the Upper Three Runs Watershed. Source

control and groundwater operable units within thiswatershed will be evaluated to determine impacts,if any, to associated streams and wetlands. SRSwill manage all source control units to preventimpact to the Upper Three Runs Watershed.Groundwater contamination has been documentedduring the FBRP groundwater monitoringprogram in both upgradient and downgradientwells. The Technical Memorandum and Summaryfor the FBRP is being finalized and will determinehow groundwater contamination in this area willbe addressed. This contamination will, therefore,not be dealt with concurrently with the FBRPsource operable unit. The proposed action for theFBRP source unit is intended as a final action.Upon disposition of all source control andgroundwater operable units within this watershed,a final, comprehensive ROD for the watershed willbe pursued.

v. SUMMARY OF OPERABLE UNITCHARACTERISTICS

The Data Summary Report (WSRC, 1994), RFI/RIReport (WSRC, 1996a), BRA (WSRC, 1996b),and Corrective Measures Study/Feasibility Study(WSRC, 1996c) contain detailed analytical datafor all of the environmental media samples takenin the characterization of the FBRP. Thesedocuments are available in the AdministrativeRecord (See Section III).

soils

Analytical data indicate that little or no significantcontamination of the soil outside of the FBRP hasoccurred. During the preparation of the RFI/RIReport, it was noted that constituents of potentialconcern (including arsenic, benzo(a)pyrene,cadmium, cesium-137, chromium,heptachlorodibenzo-p-dioxin, lead, manganese,PCB-1254, and radium) were confined to thedebris interval of the soil within the pits. Thisdistribution and the contaminant transportmodeling results indicate limited mobility of thesecontaminants in the soil. Despite being agroundwater risk driver, carbon tetrachloride wasnot detected in the soil of the FBRP source unit.

Record Of Decision for the F-Area Burning/Rubble Pits (231-F, 23 1-IF, and231-2F) (U)Savannah River SiteFebruary 1997


Page 7 of 29

The approximate pit boundaries and samplelocations are shown on Figure 3.

Arsenic was found in most of the samples horn thedebris interval in Pits 231-F and 231-IF, but wasonly found in one sample in Pit 231 -2F. Thehighest value reported was 15.2 mg/kg (parts permillion) in the 2-4 foot interval of boring 16 in Pit23 l-F. Cadmium was only found in nine samplesfrom Pits 213-F and 231- lF, with a maximumvalue of 22.2 mg/kg in the 6-8 foot sample fromboring 13 in Pit 231-lF. This sample also yieldedthe highest reported values for chromium (16,000mg/kg), copper (917 mg/kg), manganese (1030mg/kg), and nickel (7140 mg/kg), suggesting aconcentration of metals from a single source.

The maximum value for benzo(a)pyrene was 2.37mg/kg, found in the 4-6 foot interval of boring 14in Pit 231- lF. Benzo(a)pyrene was only identifiedin a single sample from Pit 231-2F.Heptachlorodibenzmp-dioxin was found in twosamples in Pit 231-2F and 16 samples in Pits 231-F and231-lF. The maximum value, 0.009 mg/kg,was reported from the 6-8 foot interval in boring13, Pit 231-lF.PCB-1254 was found in foursamples in Pit 231 -2F, including the highest value,9.14 mg/kg, an estimated value, in the 6-8 footinterval in boring 17. This value is less than theindustrial cleanup goal of 10 mg/kg. The 18detects in Pits 231-F and 231-lF were all less thanthe residential cleanup goal of 1 mg/kg PCB-1254.

Cesium-137 was found in 11 samples in Pit 231-2F and 27 samples from Pits 231-F and 231- lF.The highest value was 32.4 pCi/g in the 8-10 footsample from boring 12, Pit 231- lF. Themaximum value for total alpha emitting radiumwas 4 pCi/g in the 6-8 foot interval in boring 13,Pit231-lF.

VI. SUMMARY OF OPERABLE UNITRISKS

Human Health Risk Assessment

As part of the investigationhssessment process forthe FBRP, a BRA was performed using datagenerated during the assessment phase. Detailed

information regarding the development ofconstituents of potential concern, the fate andtransport of contaminants, and the risk assessmentcan be found in the RFI/RI and BRA reports. Theprocess of designating the constituents of concernwas based on consideration of backgroundconcentrations, frequency of detection, the relativetoxic potential of the constituents, and humannutrient requirements. Constituents of potentialconcern are the constituents that are potentiallysite-related and are reported at a sufficient dataquality level for use in the risk assessment.

An exposure assessment was performed to providean indication of the potential exposures whichcould occur based on the chemical concentrationsdetected during sampling activities. The onlycurrent exposure scenario identified for the FBRPwas for on-site visitors. Conservative futureexposure scenarios identified for the FBRPincluded fiture industrial workers and futureresident adults and children. The reasonablemaximum exposure concentration value was usedas the exposure point concentration.

Carcinogenic risks are estimated as theincremental probability of an individualdeveloping cancer over a lifetime as a result ofpathway-specific exposure to cancer-causingcontaminants. The risk to an individual resultingfrom exposure to non-radioactive chemicalcarcinogens is expressed as the increasedprobability of cancer occurring over the course of a70 year lifetime. Cancer risks are related to thetarget risk range of one excess human cancer in apopulation often thousand (1 x 104) to one in onemillion (1 x 104) for incremental cancer risk atNational Priorities List sites

Non-carcinogenic effects are also evaluated toidentify a level at which there may be concern forpotential health effects other than cancer-causing.The hazard quotient, which is the ratio of theexposure dose to the reference dos~ is calculatedfor each contaminant. Hazard quotients aresummed for each exposure pathway to determinethe specific hazard index for each exposurescenario. If the hazard index exceeds unity (1.0),

Record Of Decision for t h e F - k Burning/Rubble Pits (231-F, 231- lF, and231-2F) (U)Savannah River SiteFebruary 1997


Page 8 of 29

there is concern that adverse health effects mightoccur.

The following sections discuss the carcinogenicrisks and noncarcinogenic hazards for currentvisitors, hypothetical future workers, andhypothetical future residents. These risks aresummarized in Table 1 (Burning Rubble Pits 231-

. F and 231-lF) and Table 2 (Rubble Pit 231-2F).

Current Land Use - NonCarcinogenic Hazards

The BRA shows that potential adversenoncarcinogenic health effects are not likely tooccur, because none of the hazard indices exceedsa value of one.

Current Land Use - Carcinogenic Risks

Under the current land use scenario, human healthrisks were characterized for the current on-unitvisitor. The highest estimated nonradiologicalcancer risk was 2 x 10-7 for dust inhalation frompit 231-2F. Media evaluated include soil insidethe FBRP source unit, soil outside the FBRPsource unit, associated airborne soil particulate,and surface water and sediment in an adjacentseasonal wetland.

The highest estimated radiological risk for eachpathway was: 3 x 10-7 for direct radiation in all ofthe pits; 2 x 10-10for ingestion of soil in the 231-2F pit; and 3 x 10-12for inhalation of particulatefrom soil inside the FBRF.

Future Industrial Land Use - NoncarcinogenicHazards

The hazard indices were less than one for allconstituents by all exposure pathways.

Future Industrial Land Use - CarcinogenicRisks

The risks for chemical carcinogens were all withinor below the target risk range. The maximum riskfkom soil ingestion was 5 x 1 0 4 driven by arsenic,heptachlorodibenzmp-dioxin, and benzo(a)pyrene

in Pits 231-F and 231-lF and 4 x 10-6 driven byPCB-1254inPit231-2F.

Carcinogenic risk for radiological exposure waswithin the target risk range for all pathways. Thehighest risk under this pathway was 3 x 10-6 forexposure to soil from the 231-F and 231- lF pits.This risk was driven by cesium-137 andpotassium-40. Potassium-40 is a naturallyoccurring radionuclide.

Future Residential Land Use - NoncarcinogenicHazards

The hazard indices for noncarcinogenic hazardsunder a future resident scenario were less than onefor all pathways except ingestion of soil from Pit231-2F. The hazard index for ingestion of soilwas 2.0, predominantly driven by PCB- 1254 in Pit231-2F.

Future Residential Land Use - CarcinogenicRisks

The nonradiological i n g e s t i o n and dermalexposure pathways for the fhture on-unit residenthad estimated carcinogenic risks within the targetrisk range. The highest risks were 2 x 10-5for thesoil ingestion pathway in Pits 231-F and 231-lF,driven by arsenic, benzo(a)pyrene, andheptachlorodibenz~p-dioxin; 2 x 105 for the soilingestion pathway in Pit 231-2F, driven by PCB-1254.

Carcinogenic risk for radiological exposure waswithin or below the target risk range for allpathways. The highest risk under the directradiation pathway was 3 x 10-5for ingestion offruit grown in pits 23 l-F/lF. This risk was drivenby cesium-137 and potassium-40.

Exposure Route

Incidental Ingesllonnonradionucljdesradionuclides

Dermal Contactnonradionuclidesradionuclides

Direct (External) Radiationradionuclides

Inhalation -Dust(l)nonradionuclidesradionuclides

Inhalation - Volatiles(l)nonradionuclidesradionuclides

Ingestion - Leafy Produce0'nonradionuclidesradionuclides

Ingestion - Tuberous Produce12'nonradionuclidesradionuclides

Ingestion - Fruit Products0'nonradionuclidesradionuclides

Total Risks/Hazards for Soil =

Current Visitor

SOU (0-2 II)Klsk

2E-O82E-10

5E-096E-I3

3E-07

4E-113E-12

NCNC

NANA

NANA

NANA

Hazard

5E-04NA

2E-02NA

NA

9E-06NA

NANA

NANA

NANA

NANA

2K-O2

Hypothetical Future Resident

Soil (0-2 ft)Risk

2E-O52E-07

3E-O63E-I0

1E-05

8E-O84E-10

NCNC

NA5E-07

NA2E-06

NA4E-06

Hazard

6E-01NA

2E-02NA

NA

2E-02NA

NANA

NANA

NANA

NANA

6E-01

Soil (0-4 ft)Risk

2E-O52E-O7

3E-063E-10

IE-OS

IE-074E-I0

NCNC

NA6E-06

NA4E-06

NA3E-O5

7E-0S

Hazard

6E-0INA

3E-O2NA

NA

1E-02NA

NANA

NANA

NANA

NANA

6E-01

Hypothetical Future Workers

Soil (0-2 ft)Risk

5E-O65E-O8

1E-061E-II0

3E-06

8E-O97E-10

NCNC

NANA

NANA

NANA

Hazanil

2E-02NA

7E-O3NA

NA

4E-04NA

NANA

• N ANA

NANA

NANA

Snll (ft-J ft)Risk

5E-O65E-O8

1E-061E-10

3E-O6

1E-081E-12

NCNC

NANA

NANA

NANA

Hazard

2E-O2NA

8E-O3NA

NA

3E-04NA

NANA

NANA

NANA

NANA

nri - nui np|/uwoun>

NC - Not Calculated due to lack of data(1) Values for inhalalion of dust and volatiles in air are estimated from COPC(2) Values for produce are estimated from COPC concentrations in soil.

soil.

i—i £ .

E ®?.X

•aothet

_.n&s

Ha1lei

B

31

Car

o

S"o

|1re

?reident

go.

o

S"re»«ae

05S"«

S"eraR

ub

re"hdB-"

-Sa.

2

and

?a

s3.gorea

s<-

S1

inoil,

oc

3

"n199

CTQn>1^Oo• > - *

ssvan

3

kiv

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5*

o

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IF, and

• > - *

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oo383

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115

Exposure Route

Incidental lngestionnonradionuclidesradionuclides

Dermal Contactnonradionuclidesradionuclides

Direct (External) Radiationradionuclides

Inhalation - Dust(l)nonradionuclidesradionuclides

Inhalation - VolatilesU)nonradionuclidesradionuclides

lngestion - Leafy Produce'1'nonradionuclidesradionuclides

lngestion - Tuberous Produce0'nonradionuclidesradionuclides

lngestion - Fruit Products'1'nonradionuclidesradionuclides

Total Risks/Hazards for Soil =

Current Visitor

Soil (0-2 ft)Risk

2E-O82E-I0

3E-O97E-13

3E-O7

2E-072E-12

NCNA

NANA

NANA

NANA

5E-07

Hazard

2E-O3NA

5E-O4NA

NA

3E-O6NA

NCNA

NANA

NANA

NANA

3E-03

Hypothetical Future Resident

Soil (0-2 ft)Risk

2E-O52E-07

2E-063E-10

8E-06

1E-073E-I0

NCNA

NA5E-07

NA2E-06

NA2E-06

3E-05

Hazard

2E+O0NA

8E-02NA

NA

NCNA

NANA

NANA

NANA

NANA

2E+00

Soil (0-4 ft)Risk

2E-052E-07

2E-063E-10

8E-06

3E-O87E-10

NCNA

NA5E-06

NA3E-O6

NA2E-05

4E-05

Hazard

2E+O0NA

SE-02NA

NA

2E-O7NA

NCNA

NANA

NANA

NANA

2E+00

Hypothetical Future Workers

Soil (0-2 ft)Risk

4E-063E-O8

6E-079E-1I

2E-06

1E-085E-10

NCNC

NANA

NANA

NANA

7E-O6

Hazard

9E-O2NA

2E-02NA

NA

NCNA

NCNC

NANA

NANA

NANA

1E-01

Soil (0-4 ft)Risk

4E-O65E-O8

6E-CT71E-10

2E-05

3E-O98E-13

NCNC

NANA

NANA

NANA

7E-06

Hazard

8E-O2NA

1E-02NA

NA

5E-09NA

NCNC

NANA

NANA

NANA

9E-02

NA - Not ApplicableNC - Not Calculated due to lack of data(1) Values for inhalat/b'n of dust and volatiles in air are estimated from COFC concentrations in soil(2) Values for produce are estimated from COPC concentrations in soil.

a o.

i9

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3

i

en

o S. Js

Record Of Decision for the F-Area Burning/Rubble Pits (23 l-F,231-lF, and 23I-2F) (U)Savannah River SiteFebruary 1997


Page 11 of 29

Ecological Risk Assessment

Based on characterization of the environmentalsetting and identification of potential receptororganisms, a conceptual site model was developedto determine the complete exposure pathwaysthrough which receptors could be exposed toconstituents of potential concern.

Interpretation of the ecological significance of theunit-related contamination at the FBRP source unitconcluded that there was no likelihood of unit-related constituents causing significant impacts tothe community of species in the vicinity of theunit.

Site-Specific Considerations

Site-specific considerations, based on theconclusions of the BRA and RFI/RI, which suggestlimited or no potential for significant risk include:

1) The FBRP contain a large volume of buriednonhazardous waste material and cover soil.

2) The levels of contamination recognized duringPhase II characterization are generally very low;there is a preponderance of "non-detects". Thecontaminants are very stable chemically andexhibit limited mobility in the soil.

3) The groundwater monitoring program indicatesthat there has not been significant impact horn thewaste materials in the pits.

4) The FBRP are in a remote area which has beenrecommended as an industrial zone by the CitizensAdvisory Board and the Savannah River SiteFuture Use Project Report (DOE, 1996),precluding future residential use.

Remedial Action Objectives

Remedial action objectives speci& unit-specificcontaminants, media of concern, potentialexposure pathways, and remediation goals. Theremedial action objectives are based on the natureand extent of contamination, threatened resources,and the potential for human and environmental

exposure. Initially, preliminary remediation goalsare developed based upon ARARs, or otherinformation from the RFI/RI Report and the BRA.These goals should be modified, as necessary, asmore information concerning the unit andpotential remedial technologies becomes available.Final remediation goals will be determined whenthe remedy is selected and shall establishacceptable exposure levels that are protective ofhuman health and the environment.

Constituents of potential concern are site- andmedia-specific, man-made and naturally occurringinorganic and organic chemicals, pesticides, andradionuclides detected at a unit underinvestigation. Constituents of concern are isolatedfrom the list of constituents of potential concern bycalculating carcinogenic risks andnoncarcinogenic hazard indices. A constituent ofconcern contributes significantly to a pathwayhaving a carcinogenic risk greater than 1 x 104

and a hazard index greater than 1.0. Risk levels ator above the upper-bound of the target risk range1 x 10< are considered significant and these sitesare expected to undergo remediation. Risk levelsbetween 1 x 10-6 and 1 x 104 require considerationfor remediation.

ARARs are those cleanup standards, standards ofcontrol, and other substantive requirements,criteria, or limitations promulgated under federal,state, or local environmental law that specificallyaddress a hazardous substance, pollutant,contaminant, remedial action, location, or othercircumstance at a CERCLA site. Three types ofARARs; action-, chemical-, and location-specific;have been developed to simplify identification andcompliance with environmental requirements.Action-specific requirements set controls on thedesign, performance and other aspects ofimplementation of specific remedial activities.Chemical-specific requirements are media-specific, health-based concentration limitsdeveloped for site-specific levels of contaminantsin specific media. Location-specific ARARs mustconsider federal, state, and local requirements thatreflect the physiographical and environmentalcharacteristics of the unit or the immediate area.

Record Of Decision for the F-Area Burning/Rubble Pits (231-F, 231-IF, and 231-2P) (U)Savannah River SiteFebmary 1997


Prue 12 0f 29

There were no action-specific or location-specificAR4Rs relevant to establishing remedial actionobjectives for the FBRP source unit. There alsowere no chemical-specific ARARs identified,however a t-be-considered guidance level forPCBS was identified. The Toxic SubstancesControl Act establishes an action level of 10mg/kg for PCBS in soil. The maximum level ofPCBS found in the O to 2 foot interval in any of thepits was 2.87 mg/kg in 231-2F. This value isbelow the to-be-considered guidance.

None of the risks associated with the soil in theFBRP source unit has been found to be greaterthan 1 x 10A. The only hazard index thatexceeded 1.0 was for PCB- 1254 from the O-2 footsoil interval in Pit 231 -2F for future residents.The hazard index for this exposure scenario was2.0. The only guidance that was exceeded for soilconcentrations was for PCB- 1254 which had amaximum value of 2.87 mg/kg in the O to 2 footinterval. The tdwconsidered guidance for PCBSspecifies recommended soil action levels of 1.0mg/kg for residential use and 10-25 mg/kg forindustrial use (EPA, 1990). The maximumPCB-1254 concentration in Pit 231-2F is wellbelow the range for industrial land use.

Table 3 lists the Remedial Goal Options forintermediate risk contaminants (1 x 104 to1 x 10"6) for soil by receptor for all of the pits.

Figure 4 is a graphical summary of the conceptualsite risk model for soil for all of the pits for bothfuture residents and future on-site workers.

VII. DESCRIPTION OF THECONSIDERED ALTERNATIVES

Description of the Considered Alternatives forthe FBRP Source Control Operable Unit

The RFURI and BRA indicate that the FBRPsource unit poses minimal risk to the environmentand minimal risk to human health when industrialexposure scenarios are assumed. Although therisks are generally within the target risk range,this Corrective Measures Study/Feasibility Studywas conducted to consider possible actions whichcould reduce the risks to 1 x 104 or less.

The Corrective Measures Study/Feasibility Studyincluded detailed anal yses for five alternativeswhich are described below.

Alternative I. No Remedial Action

Under this alternative, no remedial action wouldbe taken at the FBRP. EPA policy and regulationsrequire consideration of a no remedial actionalternative to serve as a basis against which otheralternatives can be compared. Because noremedial action would be taken and the FBRPwould remain in their present condition, there areno costs associated with this alternative and therewould be no reduction or mitigation of risk.

Altern&”ve 2. Institutional Control

Under this alternative, institutional controls wouldbe implemented at the FBRP. Implementation ofthis alternative will require both near- and long-term actions. For the near-term, signs will beposted indicating that this area was used tomanage hazardous materials. In addition, existingSRS access controls will be used to maintain theuse of this site for industrial use only.

In the long-term, if the property is ever transferredto non-federal ownership, the U.S. Governmentwould, in compliance with Section 120(h) ofCERCLA, create a deed for the new propertyowner. The deed would include notificationdisclosing fomer waste management and disposalactivities as well as remedial actions taken on thesite. The deed notification would, in perpetuity,notify any potential purchaser that the property hasbeen used for the management and disposal ofnon-hazardous, inert construction debris, and thatwastes containing hazardous substances, such asdegreasers and solvents, were also managed andburned on the site.

The deed would also include deed restrictionsprecluding residential use of the property.However, the need for these deed restrictions couldbe reevaluated at the time of transfer in the eventthat contamination no longer poses anunacceptable risk under residential use.

003838

Record Of Decision for the F-Area Burning/Rubble Pits (23 l-F,231-lF, and231-2F) (U)Savannah River SiteFebmaq 1997


Page 13 of 29

Table 3 Remedial Goal Options for Intermediate Risk Contaminants of Concern for Soil byReceptor for the F-Area Burning/Rubble Pits (231=F/lF) and Rubble Pit (231-2F)

Medium Chemical

Target Cancer Risk

1x10 4 1x 10s 1x10 4

Target Hazard Quotient

3 1 0.1

ReasonableMaximum

EPCBRPa 231-F/lF, Future ResidentSoil(m@lcg)

soil {pcvg)(Radionuclides)

ArsenicHPCDDB[a]P

Cs-137K40

80.1520.07916.225

27.918103.390

8.0150.00791.623

2.79210.339

0.80150.00079

0.162

0.2791.034

-

-

—

-

-

-

5.290.00411

0.649

1.774.27

BRPa 231-F/lF, Future WorkerSoil (m#kg)

soil (pci/g)(Radionuclides)

RP231-2F, FutureRSoil (m@kg)

soil (pcdg)(Radionuclidea)

ArsenicHpCDD

Cs-137K-40

ResidentPCB-1254

Cs-137K40Sr-90

370.7690.374

104.118384.685

37.0770.0374

10.41238.469

3.7080.00374

1.0413.847

1.44E+01

27.898103.26851.282

1.44E+O0

2.79010.3275.128

1.44E-01

0.2791.0330.513

-

-

-

-

-

-

4.72

-

1.57

-

0.157

-

5.290.00411

1.774.27

0.178

1.774.272.96

RP 231-2F, Future WorkerSoil (m@kg)

soil (pci/g)(Rmiionuclides)

PCB-1254

Cs-137K40

6.51E+01

104.118384.685

6.5 lE+OO

10.41238.469

6.51E-01

1.0413.847

123

-

40.9

-

4.09

-

0.178

1.774.27

Note: HpCDD is Heptachlorodibenzo-p-dioxinB[a]P is Benzo[a]pyrenePCB-1254 is a contaminant of concern for 231-2F soil only.Potential future resident/worker exposure to soil contaminants includes ingestion, dennal contact, and inhalation ofparticulate.EPC is Exposure Point Concentration.. Reasonable maximum EPC is the lower of the 95%UCL of the transformed dataor the maximum.

F-AREA BRP FUTURE ON-UNIT WORKER (RME)NONRADIOACTIVE

sourceArea

PredominantReleaseMechanism

RADIOACTIVE

[Direct |Soll(0-2ft) | 3E-6

rect Isoil (o-2 lt) I 2E4 \

Aa 28%, HPCDD 24%, B[a]P 18%Wa]P 53%Aa 30%, HpCDD 23”A, B[a]P 18%B[a]P 63%

PCS-1254 S3%PCS-1264 S4%

Cs-137 SO%, K-40 39%

CS-137 61 Y., K4038%

HsxardIndex

0.0200.0070.0200.00s

00900.080

ContsminentaDrtvtngHuerd

AT, Mn, Cr, PCB 1254Cr, Mn, HgAT. Mn, Cr, PCB 1254Cr. Mn

PCS-1254S 3%PCB-1254

Future workerFuture workerFuture workerFuture worker

Future worker

F-AREA BRP FUTURE ON-UNIT RESIDENT (RME)NONRADIOACTIVE

RADIOACTtVE

Sol ju-4 ft)

Leafy

•» IngesMonIngestionIrtfl8stion

Soil (O-4 ft)FruitLealy

«•» •6E-8

BE-«

»« . I

Aa 28%, HpCDD 24%, B[a]P 18%B(a]P 55%, HPCDD 16%Aa 30%, HpCDD 23%, ~a]P 18%~a]P 5S%, HpCDD 18%

PCS-1254 93%PCS-126493%

Ca-137 80%, K403S%K-40 SS%K-40 SS%K-40 S9%

Ca-137 82%, K-40 37%K-40 88%K-40 88%K-40 8S%

0.4000.020'0.8000.030

Cd, Mn, Aa, Carbon leiCr, Mn.HpAt. Cr. PCB-1254. MnCr, Mn, Hg

2.000 I PCB-12540.080 |Cr, PCB-1254

Adult & ChildAdult * ChildAdult & ChildAdult & Child

Mutt & ChildAdult & Child

Record Of Decision for the F-Area Burning/Rubble Pits (23 l-F,231-lF, and 231-2F) (U)Savannah River SiteFebruary 1997


Page 15 Qf 29

In addition, if the site is ever transferred to non-federal ownership, a survey plat of the area wouldbe prepared, certified by a professional landsurveyor, and recorded with the appropriate countyrecording agency.

There are no construction costs associated withthis alternative. The cost for surveying the land,installing signs, and filing with the Aiken CountyRecords is estimated to be $2,000. Five yearreviews of remedy would be required; theestimated present value for these reviews over thenext 30 years is $8,000. The total present valuecost for Alternative 2 would be $10,000.

The remaining risk via soil ingestion to fhture on-site workers would be 5 x 10-6 and the hazardindex would be 0.02 for Pits 231-F and - lF. Therisk and hazard index from Pit 231 -2F would be 4x 104 and 0.09 respectively.

Alte~”ve 3. N@wve Soil Cover (4')

Under this alternative, a four foot thick cover ofnative soil would be installed over the presentsurface of each of the pits to reduce the likelihoodthat fiture excavation for construction of a typicalbasement would expose waste or contaminatedsoil. If the property is ever transferred to privateownership, in compliance with CERCLA 120(h),the U.S. Government would create a deed withnotifications and restrictions similar to thoseidentified in Alternative 2. A deed restrictionprohibiting excavation below four feet would alsobe filed in Aiken County Records. The deedrestrictions on excavation below four feet would benecessary to prevent potential exposure of futureworkers or residents to buried waste which maycontain low concentrations of hazardousconstituents.

The cost for developing a CERCLA RemedialDesignlllemedial Action Work Plan would be$50,000. The construction costs associated withthis alternative are estimated at $347,000 for theinstallation of a four foot thick native soil cover.The cost for surveying the land, installing signs,and filing with the Aiken County Records isestimated to be $2,000. Present value costs of

maintenance over 30 years is $8000. Five yearreviews of remedy could be required; the estimatedpresent value for these reviews over the next 30years is $8,000. Total present value costs for thisalternative are estimated at $415,000.

Remaining risks from the pits would beinsignificant. The hazard indices from all pitswould be less than 1.0.

Akernative 4. Thermal Resorption/Incineration

Under this alternative, the upper four feet ofcontaminated soil and waste in the pits would beexcavated for treatment to eliminate the PCB-1254and other organic contaminants by thermalresorption/incineration. The soil would be fedthrough a high temperature rotary kiln to extractthe volatile organic contaminants from the soil.The extracted gases would then be destroyed in theincinerator. The treated soil would be returned tothe site and vegetation would be established toprevent erosion. If the property is ever transferredto private ownership, in compliance withCERCLA 120(h), the U.S. Government wouldcreate a deed with notifications and restrictionssimilar to those identified in Alternative 2. Deedrestrictions on excavation below four feet would benecessary to prevent potential exposure of fhtureworkers or residents to buried waste which maycontain low levels of hazardous constituents.

A National Emission Standards for Hazardous AirPollutan& permit would be required because of thepotential for atmospheric releases duringremediation; the cost of obtaining this permitwould be $150,000. The estimated cost fordeveloping a CERCLA Remedial Design/RemedialAction Work Plan would be $150,000. The costfor excavation and backfilling would be $412,000.The cost for thermal resorption/incineration is$6,166,000. The deed notifications andrestrictions would cost $2,000. The total cost forthis alternative would be $6,880,000.

This alternative is protective of human health and ,would permanently reduce risk to less than 1 x 104

for ingestion of soil in Pit 231-2F. The remainingrisk to future residents would be 6 x 104 (from

Record Of Decision for the F-Area Burning/Rubble Pits (23 l-F,23I-lF,and231-2F) (U)Savannah River SiteFebruary 1997


Page 16 of 29

arsenic) for nonradiological exposure and 1 x 10-5for radiological exposure for direct radiation inPits 231-F and 23 I-lF and 8 x 10-6 for pit 231-2F.The risk for ingestion of h i t is 3 x 10-6 for BRPs231-F and -lF and 2 x 10-6 for RP 231-2F. Therisks from ingestion of leafy vegetables is 6 x 10-6

for the BRPs and 5 x 10-6 for the RP. The riskfrom ingestion of tuberous vegetables is 4 x 106

for the BRPs and 3 x 10-6 for the RP.

Alternative 5. Ofl site Soil Disposal

Under this alternative, the upper four feet of soil inthe pits would be excavated and transported to alicensed offsite disposal facility. The excavationwould be filled to grade with clean native soil andcover vegetation would be established. If theproperty is ever transferred to private ownership,in compliance with CERCLA 120(h), the U.S.Government would create a deed with notificationsand restrictions similar to those identified inAlternative 2. Deed restrictions on excavationbelow four feet would also be necessary to preventpotential exposure of future workers or residents toburied waste which may contain low levels ofhazardous constituents.

The cost for developing a CERCLA RemedialDesign/Remedial Action Work Plan would be$150,000. The cost for excavation and backfillingwould be $411,000. The cost for transportation isestimated to be $761,000. The cost for disposal is$3,350,000. The deed notifications andrestrictions would cost $2,000. The total cost forthis alternative would be !&l,674,000.

This alternative is protective of. human health andwould permanently reduce risk to less than 1 x 10%

for soil related risks in all of the pits.

VIII. SUMMARY OF COMPARATIVEANALYSIS OF THEALTERNATIVES

Description of Nine Evaluation Criteria

Each of the remedial alternatives was evaluatedusing the nine criteria established by the NationalOil and Hazardous Substances Contingency Plan

(NCP). The criteria were derived ffom thestatutory requirements of CERCLA Section 121.The NCP [40 CFR $300.430 (e) (9)] sets forthnine evaluation criteria that provide the basis forevaluating alternatives and selecting a remedy.The criteria are:

• overall protection of human health and theenvironment,

• compliance with ARARs,• long-term effectiveness and permanence,• reduction of toxicity, mobility, or volume

through treatment,• short-term effectiveness,• implementability,• cost,• state acceptance, and• community acceptance.

In selecting the preferred alternative, the abovementioned criteria were used to evaluate thealternatives developed in the F-AreaBurning/Rubble Pits (231-E 231-lF, and 231-2F)Corrective Measures Study/Feasibility Study (U)(WSRC,, 1996e). The nine criteria are used toevaluate all the alternatives, based on humanhealth and environmental protection, cost, andfeasibility issues. Brief descriptions of all ninecriteria are given in the following section.

Overall Protection of Human Health and theEnvironment - The remedial alternatives areassessed to determine the degree to which eachalternative eliminates, reduces, or controls threatsto human health and the environment throughtreatment, engineering methods, or institutionalcontrols.

Compliance with Applicable or Relevant andAppropriate Requirements (ARMs) - ARARs areFederal and state environmental regulations thatestablish standards which remedial actions mustmeet. There are three types of AMRs: (1)chemical-specific, (2) location-specific, and (3)action-specific.

Chemical-specific ARARs are usually health- orrisk-based levels or methodologies which, whenapplied to unit-specific conditions, result in the

003838

Record Of Decision for the F-Area Burning/Rubble Pits (23 l-F, 231-IF, and231-2F) (U)Savannah River SiteFebruary 1997


Page17of29

establishment of numerical values. Often thesenumerical values are promulgated in Federal orstate regulations.

.Location-specific AIU4Rs are restrictions placedon the concentration of hazardous substances orthe conduct of activities solely because they are inspecific locations. Some examples of specificlocations include floodplains, wetlands, historicplaces, and sensitive ecosystems or habitats.

Action-specific ARARs are usually technology- orremedial activity-based requirements or limitationson actions taken with respect to hazardoussubstances or unit-specific conditions. Theserequirements are triggered by the particularremedial activities that are selected to accomplisha remedy.

The remedial activities are assessed to determinewhether they attain ARARs or provide grounds forinvoking one of the five waivers for AMRs.These waivers are:

• the remedial action is an interim measureand will become a part of a total remedialaction that will attain the ARAR,

• compliance will result in greater risk tohuman health and the environment thanother alternatives,

• compliance is technically impracticablefrom an engineering perspective,

• the alternative remedial action will attainan equivalent standard of performancethrough use of another method orapproach,

• the state has not consistently applied thepromulgated requirement in similarcircumstances or at other remedial actionsites in the state.

In addition to ARARs, compliance with othercriteria, guidance, and proposed standards that arenot legally binding, but may provide usefulinformation or recommended procedures should bereviewed as T~Be-Considered when settingremedial objectives.

LonE-Term Effectiveness and Permanence - Theremedial alternatives are assessed based on theirability to maintain reliable protection of humanhealth and the environment after implementation.

Reduction of Toxicity, Mobility, or VolumeThough Treatment - The remedial alternatives areassessed based on the degree to which they employtreatment that reduces toxicity (the harmful natureof the contaminants), mobility (ability of thecontaminants to move through the environment),or volume of contaminants associated with theunit.

Short-Term Effectiveness - The remedialalternatives are assessed considering factorsrelevant to implementation of the remedial action,including risks to the community duringimplementation, impacts on workers, potentialenvironmental impacts (e.g., air emissions), andthe time until protection is achieved.

Implementability - The remedial alternatives areassessed by considering the difficulty ofimplementing the alternative including technicalfeasibility, constructability, reliability oftechnology, ease of undertaking additionalremedial actions (if required), monitoringconsiderations, administrative feasibility(regulatory requirements), and availability ofservices and materials.

@&t - The evaluation of remedial alternativesmust include capital and operational andmaintenance costs. Present value costs areestimated within +50/-30 percent, per EPAguidance. The cost estimates given with eachalternative are prepared from informationavailable at the time of the estimate. The finalcosts of the project will depend on actual labor andmaterial costs, actual site conditions, productivity,competitive market conditions, final project scope,final project schedule, and other variable factors.As a result, the final project costs may vary tiomthe estimates presented herein.

State Acceptance - In accordance with the FederalFacility Agreement (FFA), the State is required tocomment/approve the RFI/RI Report, the Baseline

Record Of Decision for the F - k Burning/Rubble Pits (231-F, 231-lF, and 231-2F) (U).Savannah River SiteFebruary 1997


Page 18 of 29

Risk Assessment, the Corrective MeasuresStudy/Feasibility Study, and the Statement ofBasis/Proposed Plan

Community Acceptance - The communityacceptance of the preferred alternative is assessedby giving the public an opportunity to comment onthe remedy selection process. A public comment

' period was held and public comments concerningthe proposed remedy are addressed in theResponsiveness Summary of this Record ofDecision.

Detailed Evaluation

The remedial action alternatives discussed inSection VII have been evaluated using the ninecriteria just described. Tables 4 through 8 presentthe evaluation of the remedial alternatives.

Ix. THE SELECTED REMEDY

The preferred action at the FBRP is institutionalcontrols (Alternative 2).

Implementation of this alternative will requireboth near- and long-term actions. For the near-term, signs will be posted indicating that this areawas used to manage hazardous materials. Inaddition, existing SRS access controls will be usedto maintain use of this site for industrial use only.

In the long-term, if the property is ever transferredto non-federal ownership, the U.S. Governmentwill create a deed for the new property ownerwhich will include information in compliance withSection 120(h) of CERCLA. The deed willinclude notification disclosing former wastemanagement and disposal activities on the site.The deed notification will, in perpetuity, notify anypotential purchaser that the property has been usedfor the management and disposal of non-hazardous, inert construction debris, and thatwastes containing hazardous substances, such asdegreasers and solvents, were also managed andburned on the site.

The deed will also include restrictions precludingresidential use of the property. However, the need

for these deed restrictions could be reevaluated atthe time of transfer in the event that contaminationno longer poses an unacceptable risk underresidential use.

In addition, if the site is ever transferred to non-fderal ownership, a survey plat of the area wouldbe prepared, certified by a professional landsurveyor, and recorded with the appropriate countyrecording agency.

The Institutional Controls Alternative is intendedto be the final action for the FBRP source unit.The solution is intended to be permanent andeffective in both the long and near terms.Alternative 2 is considered to be the least costoption that is still protective of human health andthe environment. Alternatives 3, 4, and 5 offeronly an incremental reduction in risk and hazardfor a substantial increase in cost (up to 688 times).

This proposal is consistent with EPA guidance andthe National Contingency Plan for sites that haverelatively large volumes of waste with low levels ofcontamination and is an effective use of riskmanagement principles.

Since the initial groundwater assessment did notconclusively determine where the groundwatercontamination was coming from, furtherassessment of the groundwater contamination wasconducted under the groundwater assessmentprogram addendum to the Work Plan (WSRC,1996d) to determine whether the FBRP source unitis the source of the contamination. Depending onthe results of the groundwater assessment, threepossible options were recognized for addressingthe groundwater contamination:

1) If no upgradient source is indicated, thecontribution of the FBRP source unit isconfirmed and a ROD for the FBRPgroundwater will be pursued.

2) If a previously unrecognized upgradientsource is identified, a new groundwateroperable unit will be created which willundergo Remedial Investigation/FeasibilityStudy assessment.

Alternative -1Overall Protection ofHuman Health andthe Environment

No remedial actiontaken. Will notreduce risks fromthose reported in the

No Remedial ActionHm

ARARl

* Complianci withcontaminant specificARARlThe level of PCB-1254 exceeds the to-be-consideredguidance for

Action-SpecificARARs

No remedial actiontaken. Notapplicable

Location-SpecificARARs

The site Is incompliance with alllocation-specificARARs.

other criteria,advisories, andguidanceNo remedial actiontaken. Not

-nr;—m>Effectiveness

* Magnitude ofresidual risk

No risks above 1 x10" from soU, HI<1.

reliability of controls

Not applicable.

__ai ~Toxicity, Mobility, orVolume

• Treatment processused and materialstreated

Not applicable. Notreatment used.

hazardous materialsdestroyed or treated

None destroyed ortreated.

reduction in toxicity,mobility, and volume

no reduction intoiddty, mobility, orvolume.

treatment isirreversible

Not applicable.

[dualsma afte

-RoTappUcaUe.Nothing chanted.

Effect, veneu

community duringremedial actionsNot applicable. Noremediationperformed.

workers duringremedial action

Not applicable. Noremediationperformed.

impacts

None.

action objectives areachieved

Not applicable.

Lev PCB- 254not reduced.

Im me

•rwnijr to constructand operate thetechnologyNot applicable. Noremedial actiontaken.

technology

Not applicable. Notechnology applied.

undertakingadditional remedialaction, if necessaryVery eaty.

effectiveness of theremedy

Easy to monitor.

an abiliobtain

Not applicable,remedial actto

anoffsiteNo applicablremedial actk.

Notapplkabfremedial action

cost

* capital costs

None.

• Operating andmaintenance costs

None.

Ac tan

• Features of thealternative the statesupportsNot applicable. Thestate supportedInstitutionalControls.

* Features of thealternative aboutwhich the slate has

Not applicable. Thestale supportedInstitutionalControl*

alternative the statestrongly opposes

Not applicable. Theftate lupportedInstitutionalControls.

CommunityAcceptance

* Features of thealternative the

Not applicable. Thecommunity hassupported theInstitutional

• Features of thealternative aboutwhich the community

Not applicable. Thecommunity hassupported the

alternative thecommunity strongly

Not applicable. Thecommunity hassupported the[mtitntiofiftJ

re"4 -

I©so

re

S

re3

reO.

>nAosdo.re

&nZre

o

In

3 5-O

70

s

o

sit

Alternative -2overall Rotcction ofHuman Hcal(h andthe Enwonmcrw

* Prolectivtttess

Exceeds A RAR forfuture raiden~only. Will preventeesldential ssse ofthis property.

Institutional ControlsCompliance withARARs

• Compliance withcontumimmt speciji’cARARs

‘hem xre noARARs for FBRP.PCB-1254 levels areMow the IndustrixfTBC guidance of10mg/kg.* Compliance with

Action-SpeciftcAR4RS

Not xpplidle. Noaction txkess.

• Compliance withLocation-Spectj7cARARs

Tlse xite fs inCampfiassce With dkcxtkm-xpec.iflc

ARARx.

* Compliance withother criteria,advisories, andguia%nce

Not xpptkxbk. NOaction txkess.

Long-Tesm

EJfectivetKSs

*Magnitude ofresidual risk

Overxll rkk is 4 x104, HI= 0.09.

+Adequacy andreliability of controls

Oeed rds’ictlossswill # ffectivelyprevent futucereskkntixl sue ofthis IxStd.

Reduction ofToxicity, Mobifity, wVolume

• Treatment processused and materialstreated

No treatment used.

*Amount ofhazardous materialsdestroyed or treated

Not Xppllcxble.None dextroyed

*Degree of expectedreduction in toxicity,mobility, and wlume

Not xppilcmble

• Degree to whichtreatment isirreversible

Not xppkabk.

• fipe and quantityof residualsremaining aftertreatment

AU contamlnantiremxiss.

Shoct-TernsEffectiveness

*Protection ofcommunity duringremedial actions

Not xppficsbk. Noremedmonperformed.

* Protection ofworkers duringremedial action

Not x@cxbk. NOremedidonperformed.

• Environmental

impacts

Norm

* Time until remedialaction objectives areachieved

Not applicable.

• Contaminants

PCB-12S4 notreducefl.

Isnpktncntability

* Ability to constructand operate thetechnology

No action taken. Notapplicable.

*Reliability of thetechnology

Not @ k x b l e , No

xctian txken

• Ease ofundertakingadditional remedialaction, if necessary

very my.

• Abilfty to monitoreffecthwsess of theremedy

Exxy b mosdtar.

* Coordination withand ability inobtaining approvalsporn otiser agencies

Not xpp fkxbk Noaction @ken*Availability of

necessary equipmentand specialists andofiite services

Not xpplicxbk Noaction taken

9 Avaikzbility ofprospectivetechnologies

Not XPpiicxbk. No

action taken

cost

* Capital costs

Low.

* Operating and

maintenance costs

Low.

Nate Acccptatsce

• Features of thealternative the statesupports

The slate supportedInstitutionalControls.

• Features of thealternative aboutwhich the state hasreservations

Not appfidsle. llsextxte supportedIn8titutionxlConkok.

o Elements of thealternative the statestrongly opposes

Not app lkxbk m estate XupportedIss#titutiossdCaMxOk.

CommunityAcc+?ptancc

• Features of thealternative thecommunity supports

l s e cosmssusity IUS

Xupported

Itntitutiotsal

Controls.

*Features of thealternative aboutwhich the communityhas reservations

Not xpplicabIe. ‘llseSXmlSmSSltty h =supportedIlntihstionxlCOntrok.

• Efenwnts of thealternative thecommunity stronglyopposes

Not xpplicabk Thesxwnmudty hassupportedInstitutionalControls.

|dCMWU.9 CHKXACriwrit

iffj

si

CO

n

%

Alfprnativp . 1

uvcraii rroiecuon 01Human Health andthe Environment

• frotectiveness

Hie soil coverreduces all risks tobelow 1 x 10*.

NativA Knil P n v o r

compliance wiuiARARs

* Compliance withcontaminant specificARARsmere are noARARs for FBRP.Will meet lo-be-considered guidancefor PCBs.* Compliance withAction-SpecificARARs

Must meet CleanAir Actrequirements fordust

* Compliance withLocation -SpecificARARs

None applicable.

* Compliance withother criteria,advisories, andguidanceMust comply withOSHA.

Long-J ennEffectiveness

* Magnitude ofresidual risk

Risk remainsbeneath the cover.Excavation must beprevented.

'Adequacy andreliability ofcontrcls

Reliable unlessexcavition is toodeep or deedrestrictions notenforced.

Reduction ofToxicity, Mobillity, orVolume

* Treatment processused and materialstreatedNot applicable. Notreatment provided.

•Amount ofhazardous materialsdestroyed or treated

Not applicable.None destroyed

* Degree of expectedreduction in toxicity,mobility, and volume

Cover will helpreduce mobility togroundwater A:airborne dust. Noreduction In lonldtyor volume.* Degree to whichtreatment isirreversible

Covering iscompletelyreversible.* Type and quantityof residualsremaining aftertreatmentNot applicable. Allcontaminantsremain.

Short-TermEffect, veneu

* Protection ofcommunity duringremedial actionsNo risks to thecommunity while thecover is beingconstructed.

* Protection ofworkers duringremedial action

Minor risk 10workers while coverIs being built due todie use of heavymachinery * dust* Environmentalimpacts

Minor Impact to theenvironment fromheavy equipmentand dust

* Time until remedialaction objectives areachieved

Cover can becompleted In lessthan one year.* Contaminants

Cover is barrier loPCB-1254 exposure.

unpiemcnuDiiHy

• Ability to constructand operate thetechnologyEasy to install thecover.

'Reliability of thetechnology

Cover can bebreached. Maybedifficult to enforceno excavation.

•Ease ofundertakingadditional remedialaction, if necessaryEasy, however,additionalremediation mayrequire removingthe cover.

'Ability to monitoreffectiveness of theremedy

Easy lo monitoreffectiveness of thecover.'Coordination withand ability inobtaining approvalsfrom other agenciesRelatively easy toobtain approval forinstalling a cover.'Availability ofnecessary equipmentand specialists andoffsite servicesEasily available.* Availability of

prospectivetechnologiesReadily available.

COSI

* Capital costs

Low

* Operating andmaintenance costs

Low. Must beInspected, mowed,repained as needed.

State Acceptance

•Features of thealternative the statesupportsNot applicable. Thestale has approvedInstitutionalControls.

'Features of thealternative aboutwhich the state hasreservationsNot applicable. Theslate has approvedInstitutionalControls.

* Elements of thtalternative the statestrongly opposes

Not applicable. Thestate has approvedInstitutionalControls.

LommunityAcceptance

' Features of thealternative thecommunity supportsNot applicable. Thecommunity hat•freed with theInstitutionalControls remedy* Features of thealternative aboutwhich the communityhas reservationsNol applicable. Thecommunity hatagreed with IheInstitutionalControls remedy'Elements of thealternative thecommunity stronglyopposesNot applicable. Thecommunity hasagreed with theImtilulioiialControl! remedy.

re

sio

so

A lte

s

>7&sB

urr iing/1

=

!|S*Soil

ftore•«

Under

zreC

ER

CL

A. Criteria

,23

1-

1

5 1

T h r m T W n n / l

Overall Protection ofHuman Health and

*Prolectiveness

Offers completeprotection of humanhealth & theMivtrnnimnL

Compliance withARARs

Long-TermEffectiveness

Reduction ofTbxicily, Mobility, or

Shon-TennEffectiveness Acceptance

* Compliance withcontaminant specificARARs

* Magnitude ojresidual risk

* I reaimcm processused and materialstreated

community duringremedial actions

There are noARARs for FBRP.Will meet to-be-considered euidancc

EC L

Risk will be reducedto below 1« 10"4.

P C B J will be

desorbed andincineraled.

Community will becompletely protectedwhile remediation isongoing.

' Compliance withAclion-SptcificARARs

• Adequacy andreliability of controls

• Amount ofhazardous materialsdestroyed or treated

* rrotecuon ojworkers duringremedial action

and operate thetechnologyImpiementable.Somewhat limitedavailability ofequipment Not aproUentt

High.

alternative the statesupportsNot applicable. ThesUte has approvedInstitutionalControls.

alternative thecommunity supportsNot applicable. Thecommunity hasagreed with theInstitutionalControls — J —

technology maintenance costs alternative aboutwhich the state hasreservations

alternative aboutwhich the communityhas reservations

Must meet CleanAir Actrequirements fordust.

Completelyadequate andreliable. Destroyscontaminants.

All soil can oetreated to removePCBs.

Protection irom nuninhalation, contactwith contaminatedsoil ft injuries fromheavy machinery

:., . . .-Die. . . .gh.pe »costs, nomaintenance after

Thestate has approvedInstitutionalControls.

NolappllclM IB.community hasagreed with theInstttuuoulControls remedy.


reduction in toxidty.mobility, and volume

impacts undertakingadditional remedial

alternative the statestrongly opposes

None applicable. Erosion win becontrolled.

alternative thecommunity strongly

_O££O>£

Easy, But noneshould be required. stale has approved

InstitutionalControls.

"Not applicable. Th.community hasagreed wits, theInitihiUonalCnntrak ramedv.

* Compliance withother criteria,advisories, and

* Degree to whichtreatment isirreversible

' lime unm remeatataction objectives areachieved

'ntntujr w mOHituteffectiveness of theremedy

uoi.^miutbe

1

I-

enL

•Type and quantityof residualsremaining after

None.

pproodntatel one

* Contaminants

B 54des ed

• isOorainauon wimand ability inobtaining approvals

1

1i

1

11

1

1necessary equipmentand specialists and

1Somewh

prospectivechn • •

Somewh

*•

nded.

1mited.

H

re"§•g

ifivai

3

W

1a.

9i?sion

PIns

3. o8" "*3. >» Sre

•«

Hre

O

•a

5"**o

re

-©'S

dso.re

re

Sre

CO

I

55-

Offs S Dispq

Offers completeprotection of humanhealth & theenvironment

ARAR

mpcontaminant specificARARs

There are noARARj for FBRP.Will meet lo-be-consldered guidancefor PCBs.

Action-SpecificARAR!

Must meet CleanAir Actrequirement* fordust. DOT fortransportation.


None applicable.

other criteria,advisories, and

U311A miUIDC

5

Effcc

residual risk

Risk will be reducedlo below 1« 10-*.

reliability of controls

Completelyadequate andreliable.

ReductiM

used and materialstreatedPCB contaminatedsoil will be shippedto orfsite wastefacility.

hazardous materialsdestroyed or treated

None destroyed, butall removed fromRP2.M-2F.

reduction in toxicity,mobility, and volume

Reduction of PCBsby removal.

Effcc veness

community duringremedial actionsCommunity will becompletely protectedwhile remediation Uongoing.

workers durin$remedial action

Protection from duslinhaUtfon. contactwith contaminated•oil * injuries fromheavy machinery

impacts

Erosion will becontrolled.

'nuttity IO constructand operate thetechnology

ImplemenUble.Limited wastefacilities available.Not a problem.

- ncuacniiir oj metechnology

Very reliable.

* Eoi* ujundertakingadditional remedialaction, if necessary

None needed.

' capital costs

High.

• uperattng anamaintenance costs

High operatingcosts, nomaintenance alterremediation.

tan

' features of thealternative the statesupportsNot applicable. Thestate has approvedInstitutionalControls.

* features of thealternative aboutwhich the state hasreservationsNot applicable. Thestale has approvedInstitutionalControls.

'Elements of thealternative the statestrongly opposes

Not applicable. Thestate has approvedInstitutionalControls.

treatment is action objectives are effectiveness of theirreversible achieved remedy

irreversible.

maobi

_2£

chnSomewh mited.

tancc

• Features of thealternative the

Not applicable. Thecommunity hasscreed with theInstitutional

* Features of thealternative aboutwhich the communityhas reservationsNot applicable. Thecommunity hasagreed with theInstitutionalControls remedy.

'Elements of thealternative thecommunity strongly

Not applicable. Thecommunity hasagreed with theInstitutional

H

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Io

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re

Oa?arr

1?oil

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O

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Record Of Decision for the F-Area Burning/Rubble Pits (23 l-F,231-lF, and 231-2F) (U)Savannah River SiteFebmary 1997


Page 24 of 29

3) If an existing upgradient groundwateroperable unit is determined to be the source ofthe contamination, the boundaries of theexisting operable unit will be modified toinclude the groundwater contamination in theFBRP area.

The Technical Memorandum and Summary for theFBRP is being finalized. Based upon theconclusions of this document, one of the threeoptions described above will be selected andimplemented. If options 1 or 2 are selected, thenew groundwater operable unit will be placed intoAppendix C of the Federal Facility Agreement.The Technical Memorandum and Summary for theFBRP will contain the proposed implementationschedule for this groundwater operable unit.

The SCDHEC has modified the SRS RCRA permitto incorporate the selected remedy.

This proposal is consistent with EPA guidance andis an effective use of risk management principles.

x. STATUTORY DETERMINATIONS

Based on the FBRP RCRA FacilityInvestigation/Remedial Investigation (lWI/RI)Report and the Baseline Risk Assessment (BRA),the FBRP poses no significant risk to theenvironment and minimal risk to human health.Because risk levels exceed 1 x 10-6, a decision wasmade to implement the Institutional Controlsalternative in order to be filly protective of humanhealth and the environment.

The selected remedy is protective of human healthand the environment, complies with federal andstate requirements that are legally applicable orrelevant and appropriate to the remedial action,and is cost-effective. The random distribution andlow levels of contaminants in the soils maketreatment impractical. Institutional controls willresult in hazardous substances, pollutants, orcontaminants remaining in the source unit.Because treatment of the principal threats of thesite was found to be impracticable, this remedydoes not satis~ the statutory preference fortreatment as a principal element.

Section 300.430 (f)(4)(ii) of the NCP requires thata Five Year Review of the ROD be performed ifhazardous substances, pollutants, or contaminantsremain in the source unit. The three Parties havedetermined that a Five Year Review of the RODfor the FBRP would be performed to ensurecontinued protection of human health and theenvironment.

xx. EXPLANATION OF SIGNIFICANTCHANGES

There are no significant changes from thepreferred alternative stated in the Statement ofBasis/Proposed Plan.

The 45-day public comment period began onSeptember 17, 1996 and ended on October 31,1996. A public comment meeting was held onOctober 15, 1996. Comments that were receivedduring the 45-day public comment period areaddressed in Appendix A of the Record OfDecision and are available with the final RCRApermit.

XII. RESPONSIVENESS SUMMARY

A Responsiveness Summary of the commentsreceived during the public comment period isincluded in Appendix A.

XIII. POST-ROD DOCUMENTSCHEDULE

The post-ROD document schedule is listed belowand is illustrated in Figure 5:

1) Corrective Measures Implementation/RemedialAct ion Report (CMURAR) (rev. O) forInstitutional Controls will be submitted 4months after issuance of the ROD.

2) EPA and SCDHEC review of the CMUILIR(rev. O), (90 days).

3) SRS revision of CMI/RAR (rev. O) after receiptof regulatory comments, (60 days).

4) EPA and SCDHEC final review of CMI/RAR(rev. 1), (30 days).

ACTIVITYDESCRIPTION

ORIGDUB

SRS 5UBMITTAL OF REV.O CMI/RAR

EPA/SCDHEC REVIEW 90

SRS INCORPORATE EPA/SCHDEC COMMENTS

SRS SUBMITTAL OF REV.l CHI/RAR

EPS/SCHDEC FINAL REVIEW I APPROVAL

EPA/SCDHEC APPROVAL

-L. _L ,1 1?1

CORRECTIVE MEASURES IMP./REMEDIAL ACTION REPORT

OL J

plot DateData Date

Project Finish

<FE8971OCT961OCT9627JUL97

I IENVIRONMENTAL RESTORATION

F-AREA BRP

POST ROD IMPLEMENTATION SCHEDULE

Pitt Revision Clucked Approved

a1

o5

»33

sre

Sito

g3no

oooSIum

e

B_inr>reO.Sre"

re

COrning/Ri

a-

re"

(23

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-3

33

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00

TO

9

Record Of Decision for the F-Area Burning/Rubble Pits (23 l-F, 231-lF, and 231-2F) (U)Savannah River SiteFebruary 1997


Page 26 of 29

xxv. REFERENCES

DOE (U.S. Department of Energy), 1994. PublicInvolvement, A Plan for the Savannah RiverSite. Savannah River Operations OffIce,Aiken, South Carolina.

DOE (U.S. Department of Energy), 1996.Savannah River Site Future Use ProjectReport. Savannah River Operations office,Aiken, South Carolina.

EPA (Environmental Protection Agency), 1990. AGuide on Remedial Actions at Supetjhnd SitesJVithPCB Contamination. OffIce of SolidWaste and Emergency Response Directive9355.4-01 FS, August 1990.

FFA, 1993. Federal Facility Agreement for theSavannah River Site. Administrative DocketNo. 89-05-FF, (Effective Date: August 16,1993).

WSRC (Westinghouse Savannah River Company),1994. Data Summury Report for the F-Area

Burning/Rubble Pits. WSRC-TR-94-0293,Rev. O, Westinghouse Savannah RiverCompany, Aiken, South Carolina (1994).

WSRC, 1996a. RFL!RI Report for F-AreaBurning/Rubble Pits (231-F, 231-IF, and231-2F)(U). WSRC-RP-94-938, Rev. 1.1,Westinghouse Savannah River Company,Aiken, South Carolina (March 1996).

WSRC, 1996b. Baseline Risk Assessment for theF-Area BumingLRubble Pits (U). WSRC-TR-94-108, Rev. 1.2, Westinghouse SavannahRiver Company, Aiken, South Carolina(March 1996).

WSRC, 1996c. F-Area Burning/Rubble Pits (231-F, 231-IF, and 231-2F) Corrective MeasuresStudy/Feasibility Study (U). WSRC-RP-95-660, Rev. 1.1, Westinghouse Savannah RiverCompany, Aiken, South Carolina (June 1996).

WSRC, 1996d. Phase 11, RCRA FacilityInvestigatiotiRemedial Investigation Plan forthe F-Area Burning/Rubble Pits (231 -F and231-IF) and Rubble Pit (231-2F)(U).WSRC-RP-90-486, Rev. 2.1, WestinghouseSavannah River Company, Aiken, SouthCarolina (May 1996).

WSRC, 1996e. Statement ofBasis#Proposed Planfor the F-Area Burning/Rubble Pits (231-E231-lF, and 231-2F)(U). WSRC-RP-95-831,Rev. 1.2, Westinghouse Savannah RiverCompany, Aiken, South Carolina (August1996).

Record Of Decision for tbe F-Area Burning/Rubble Pits (23 l-F,231 - IF, and 23 1-2P) (U)Savannah River SiteFebruary 1997


Page 27 of 29

APPENDIX A - RESPONSIVENESS SUMMARY

Record Of Decision for the F - k Burning/Rubble Pits (23 l-F, 231- lF, and 231-2F) (U) WSRC-RP-96-868Savannah River Site Revision 1February 1997 Page 28 of 29

Responsiveness Summary

The 45-day public comment period for the Statement of Basis/Proposed Plan for the F-Area Burning/RubblePits (231-F, 231-IF,and231-2F) began on September 17, 1996 and ended on October 31, 1996. A publicmeeting was held on October 15, 1996. During the public meeting, there were two questions received duringthe Public Meeting and Comment Session on the Limited Action Proposed Plans/Permit Modificationspresentations; and there was one public comment received during the Formal Public Comment Session. All ofthe comments are listed as recorded in the Savannah River Site Information Exchange transcript based on theOctober 15, 1996 Public Meeting.

Specific comments and responses are found below. The comments are italicized and the responses are bolded

Public Comments

The following two comments were received during the Limited Action Proposed Plans/Permit Modificationspresentations.

1) PUBLIC CITIZEN: What risk is there for animals or I guess jitture environmental, like ~ you were going toturn this into a park?

Response to Comment 1):

The Baseline Risk Assessment investigated the ecological affects that any contaminants at the FBRPcould have. This document determined that there is "essentially no likelihood that ecologicallysignificant impacts to the community of species in the vicinity of the unit will occur". Therefore, theanimal and plant species found in this area should not be affected by any contaminants found at the F-Area Burning/Rubble Pits. The Savannah River Site is currently considered to be a nationalenvironmental research park and as such, the site idwill be used for environmental research.

This site is located in close proximity to the F-Area which has a number of facilities which contain highlevels of radioactive waste. It is unlikely that this particular area would be made available to thepublic as a recreational park in the near future. For this reason, it is recommended that the FBRP beretained as part of an industrial area.

2) PUBLIC CITIZEN: Are you using like private landfills and private — -or I guess other communities thathave developed? I mean it looks like a land’11 to me. And it looks like there are land’lls all over thecountry and there's a whole lot of land’lls that have turned into like parks and stuff. Is that an opportunityhere to turn it into a park or to use private models and maybe who have done this a lot? I guess the EPAguy was talking about streamlining. Are you guys using private streamlining ideas ?


The FBRP was operated very much like a small-scale landilll. Waste was deposited on a regular basisand, initially, was burned monthly. After burning ceased, the waste was deposited and finally coveredby a layer of soil when the site was closed.

The Savannah River Site is currently considered to be a national environmental research park and assuch, the site ishvill be used for environmental research. The F-Area Burning/Rubble Pits have beenshown to pose an insignifkant threat to any plants or animals in the area.

003838

Record Of Decision for the F-Area Burning/Rubble Pits (231-F,231- lF, and231-2F) (U) WSRC-RP-96-868Savannah River Site Revision 1February 1997 Page 29 of 29

This site is located in close proximity to the F-Area which has a number of facilities which contain highlevels of radioactive waste. It is unlikely that this particular area would be made available to thepublic as a recreational park in the near future. For this reason, it is recommended that the FBRP beretained as part of an industrial area.

The following comment was received during the Formal Public Comment Session.

3) Mike Rourak: My name is Mike Rourak and my question is directed directly to Mr. Brian Hennessey 'searlier discussion [unintelligible] Silver-ton Road property, for example. In the Future Use Manual thatwas sent out to some of us about the disposal of close to a million acres of propetty for DOE, in your deedrestn”ctions there 'i-e things that we cannot do. And we 're going to need a little bit before we can respondback to Washington. Those of us who received the manual, we almost are going to need to know what thosedeed restrictions are because if we cannot have a subdivision then there's no need to bid the priceaccordingly or say that's what we want to use it for. If we cannot graze cattle there like we do in Tennesseeat [unintelligible] or something or grow crops because we cannot put a well in for contamination, then weare lefi with only looking at it for the pine trees.

So being federal, you own this property. Even with deed restrictions you 've got to give us either a Phase I,II, or III audit. In this case, it's the seller who has to provide this liability, not necessarily the buyer'sneglect of liability to due diligence. So it would really help if we knew what deed restrictions would bethere to a more extent and also what we can use the land for. If I want to use it for applying 50 — underthe Code of Federal Regulations 503, if I want to use it for bio solid disposal, can 1 do so? Because it'sadjacent to your other property. So the deed restrictions that you brought up were of immense concernabout responding back to the jhture use and the disposal of roughly 849,000 acres nationm”de for - to beput back into - I understand from Washington, they would like to put it back mainly into public use to getthe taxes of of it. Maybe not so much for the government, but for the local entities who lose the tax base.Thank you.


The SRS Future Use Project Report was distributed to inform citizens of the planned future uses ofSRS. The recommendations that were presented in the report may change over time and will bediscussed with the stakeholders. Deed restrictions for federal property are not determined until theland is transferred to non-federal control. At the time of property transfer, the need for deedrestrictions will be evaluated. Due to natural attenuation, decay, etc., the conditions at specific areasmay not warrant any deed restrictions. All legal requirements will be met at the time of propertytransfer.