003837

United States Department of Energy

Savannah River Site

Record of DecisionRemedial Alternative Selection for theD-Area Burning/Rubble Pits (431-D and 431-lD)(U)

WSRC-RP-96-867Revision 1February 1997

V%qo-tipp

Westinghouse Savannah River Company £ £2 ~ ~ - “% \Savannah River Site s ^ f i /*? H=Aiken, SC 29808

Prepared for the U.S. Department of Energy under Contract NO.DE-AC09-96SR18500

S A V A N N A H R I V E R S I T E

Record of Decision fw the D - b Bumix@Rubble Pita (431 -D and431 -lD) WSRGRP-96-867Savannah River Site Rcvish 1February 1997

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RECORD OF DECISIONREMEDIAL ALTERNATIVE SELECTION (U)

D-Area Burning/Rubble Pits (431-D and 431-lD)

WSRC-RP-96-867Revision 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 Ofke

Aiken, South Carolina

Record of Decision for the D Area Burning/Rubble Pits (431 D and431-lD) WSRC!-RP-96-S67Savannah River Site Revision 1Febnuuy 1997 Declaration

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Record of De&ion fm the D Area Burning/Rubble Pita (431 D and431 -lD) ^ "WsRC-RP-96-867Savannah River Site Revision 1February 1997 Declaration

DECLA&VI’ION FOR THE RECORD OF DECISION

Unit Nme and Loc&”on

D-Area BurninglRubble Pits (431-D and 431-ID)Savannah River SiteAike& South Carolina

The D-Area Burning/Rubble Pits (DBRP) (431-D and 431-lD) Waste Unit is listed as a ResourceConservation and Recovery Act (RCRA) 3004(u) Solid Waste Miinagement Unit/ComprehensiveEnvironmental Response, Compensation and Liability Act (CERCLA) unit in Appendix C of the FederalFacility Agreement (FFA) for the Savannah River Site (SRS).

Statement o fBasis and l+qvose

This decision document presents the selected remedial alternative for the DBRP located at the SRS inAikeU South Carolina. The selected alternative was developd in accordance with CERCL~ asarnende& and to the extent practicable, the National Oil and Hazardous Substances Pollution ContingencyPlan (NCP). This decision is based on the Administrative Record File for this specific RCIUVCERCLAunit.

Description of the Selected Remedy

The preferred alternative for the DBRP source operable unit soils is Institutional Controls which will restrictthis land to Mum industrial use. Additional groundwater monitoring as discussed in Section H of theROD, will also be conducted. Based on the groundwater monitoring history, the probable condition isthat no signijikant groundwater contamination has ori&ated from the DBRP. Thq no remedial &nand a perwd of continued monitoringfor conJirmdion is the only appropriate action for tke groundwaterat the DBRP. In the event that the probable condtion of the local groundwater is no longer appropriate,DOE will evaikte the need for remediul action. Implementation of the Institutional Controls alternativewill require both near- and long-term actions which will be protective of human health and the environment.For the near-terrq signs will be posted at the waste unit which indicate that this area was used for thedisposal of waste material and contains buried waste. In additio~ existing SRS access controls will be usedto maintain the use of this site for industrial use only.

In the long-te~ if the property is ever transfkxred to non-federal ownership, the U.S. Government willcreate a deed for the new property owner which would contain information in compliance with Section120(h) of CERCLA. The deed would include notification disclosing former waste management and dispmalactivities as well as remedial actions taken on the site, and any continuing groundwater monitoringcommitments. The deed notification wou.1~ in perpetuity, notify any potential purchaser that the p r o p e r t yh a s been used for the management and disposal of construction debris and other materials, includinghazardous substances.

The deed would also include deed restrictions precluding residential use of the property. However, the needfor these restrictions may be reevaluated in the event that contamination no longer poses an unacceptablerisk under residential use. In additio~ if the site is ever transferred to non-federal ownership, a survey platof the area will be prepar~ certified by a prof=ional land sumeyor, and recorded with the appropriateBarnwel.f County recording agency.

The poti-ROD dbcumen$ the Corrective Measures Iinplementatioflemed&d Action Repoti(CMW, will be submdled to the Regulators four months a@r the issuance of the ROD. TheCMWUAR w“ll contain a det~”led monitoring drategy which will outline the submittal schedkkk andconte~ of the periodic monitoring reports to inclkde: an analysis of the dat~ a concluswn, and a

Record of Decision fmh D-ArI= ~ u b b l e Pita (431 D and 431-lD) WSRC-RP-%-S67Savannah River Site Revi&m 1Februag 1997 Declaration

recommendhtiom The regulatory review perwt$ SRS revision perio4 and jkd regulatory review andapproval perwd will be 90 d@q 60 d@q and 30 dkyq r-”vely.

The South Carolina Department of Ha and Ewironmentd Control has nwdifwd the SRS RCIL4permit to incorporate the selected remedy.

Sta tutory Determina tion

Based on the DBRP RCRA Facility Investigation.kmedial Investigation @FI/RI) Report and the B ~the DBRP source operable unit poses no significant risk to the environment and minimal risk to humanhealth. Therefore, a determimtion has been made that Institutional Controls are sufficiently protective ofhuman health and the environment for the remaining contamination in the DBRP soils and groundwater.The selected remedy is protective of human health and the environment complies with Federal and Stateof South Carolina requirements that are legally applicable or relevant and appropriate to the remedialactio~ and is cost-effkct.ive. The random distribution and low levels of contamination preclude a remedyin which treatment is a practical alternative. Because treatntent of the principal threats of the site wasfound to be impracti’caldej this rentedy dims not sati$~ the statutory preference fortreatntent as aprincipal element

Institutional Controls will result in hazardous substances, pollutants, or contaminants remaining in thewaste unit. Section 300.430 (f)(4)(ii) of the NCP requires that a Five Year Review of the Record ofDecision be performed if hazardous substances; pollutan@ or contaminantts remain in the waste unit. Thethree Parties have determined that a Five Year Review of the Record of Decision for the DBRP will beperformed to ensure continued protection of human health and the environment.

•hohiDate Thomas F. Heenan

Assistant Manager for Environmental QualilyU. S. Department of Energy, Savannah River Operations OfEice

Date John H. Hankinsorq Jr.Regional AdministratorU. S. Environmental Protection Agency

Date R kWiS ShawDeputy CommissionerEnvironmental Quality ControlSouth Carolina Department of Health and Environmental Control

DECISION SUMMARYREMEDIAL ALTERNATIVE SELECTION (U)

D-Area Burning/Rubble Pits (431-D and 431-lD)

WSRC-RP-96-867Revision 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 Oflke

Aikeu South Carolina

Record oflkckkmfmthe D Area Burning/Rubble Pits (431 D and 431 ID) WSRGRP-96-867Savaanah River Site R e v k k 1F e l m u q 1997 Page ii of iv

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Record of Deciaion fw the Ikkea Burnin@ubble Pits (431 D and431-lD)Savannah River SiteFebrwuy 1997

WSRC!-RP-%-867Revision 1

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DECISION SUMMARYTABLE OF CONTENTS

Section Page

I. Site Operable Unit Name, hxatio~ and Description.....................................................1

II. Operable Unit History and Compliance History ..

m Highlights of Community Participation . .

Iv. Scope and Role of Operable Unit Within the Site Strategy ..6

v. Sumrnaxy of Operable Unit Characteristics ..

VI. SumxnaIY of Operable Unit Risks ..

VII. Description of the Considered Alternatives ..16

v m . Summary of Comparative Analysis of the Alternatives.................................................18

Ix. The Selected Remedy.................................................................................................. 20

x. Statutory Determinations.............................................................................................26

XI. Explanation of Significant Changes.............................................................................26

m . Responsiveness Summary 2.7

XIn. Post-ROD Document Schedule.....................................................................................27

Xtv. References . . .

List of Figures

Figure 1. Location of the D-Area Burning/Rubble Pits in relation to major facilities

at the Savannah River Site ...

Figure 2. Topography of the D-Area Burning/Rubble Pits and surrounding area.......................................3

Figure 3. Topography and Water Table PotentiometricA&p of the D-Area Burning/Rubble Pits 4

Figure 4. Schedule for the Corrective Measures Implementation/Remedial Action Report 28

List of Tables

Table 1. Summary of Carcinogenic Risk and Noncarcinogenic Hazards for CurrentOn-Site Visitors at the D-Area Bumi@RuMle Pits

Table 2. Sumnuuy of Carcinogenic Risk and Noncarcinogenic Hazards for FutureOn-Site Workers at the D-Area Burning/Rubble Pits

Table 3. Summary of Carcinogenic Risk and Noncarcinogenic H2zards for FutureOn-Site Resident Adults and Children at the D-Area Burning/Rubble Pits.

Table 4. Summary of the Evaluation of Alternative 1 No Action under the NineCERCLA Criteria

11

12

13

21

Record of De&km fmthe D-Area BumiI@RuMIc Pita (431 D and431 -lD) WSRGRP-96-867Savannah River Site Reviakm 1Febnuuy 1997 Page iv of iv

DECISION NJMMAIWTABLE OF CONTENTS (cent'd)

Table 5. Summary of the Evaluation of Alternative 2 Institutional Controls under theNine CERCLA Criteria 22

Table 6. Summary of the Evaluation of Alternative 3 Native Soil Cover (4') under theNine CERCLA Criteria 23

Table 7. Summary of the Evaluation of Alternative 4 Thermal Resorption/Incinerat.ionunder the Nine CERCLA Criteria 24

Table 8. Sumrruuy of the Evaluation of Alternative 5 OfRite Soil Disposal under theNine CERCLA Criteria 25

Ap~endix

A. Responsiveness Summary A-1

Record o f + i o n fw the D-Area BuminghMle Pita (431 D and 431-lD)Savannah River SiteFebruay 1997

WSRC-RP-96-867Revision 1

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L Site and Operable Unit NamqLocation, and Description

The Savannah River Site (SRS) occupiesapproximately 310 square miles of land adjacent tothe Savannah River, principally in Aiken andBamwell counties of western South Carolina. SRSis a secured U.S. Government facility with nopermanent residents. SRS is locatedapproximately 25 miles southeast of Augus@Georgia and 20 miles south of llike~ SouthCarolina.

SRS is owned by the U.S. Department of Energy(DOE). Mimagement and operating seMces areprovided by Westinghouse Savannah RiverCompany (WSRC). SRS has historically producedtritiu.q plutonkq and other special nuclearmaterials for mtional defense and the spaceprogram. Chemical and radioactive wastes are by-products of nuclear material production processes.

The Federal Facility Agreement (FFA) lists the D-Area Burning/Rubble Pits (DBRP), 431-D and431-lD, as a Resource Conservation andRecovery Act/Comprehensive EnvironmentalResponse, Compensation and Liability Act(RCRMCERCLA) u n i t r e q u i r i n g Iirtherevaluation using an investigationhssessmentprocess that integrates and combines the RCRAFacility Investigation (RFI) process with theCERCLA Remedial Investigation (RI) todetermine the actual or “@tential impact to humanhealth and the environment.

The DBRP are located in the western part of theSRS in Bamwell County, approximately 2600feet W(2St of D Area and 1.6 miles West of StateHighway 125 (Figure 1). The topography of thearea is flat and the surf’ of the DBRP is at anelevation of 130 f=t above mean sea level and45 feet above the Savannah River (Figure 2).The water table is approximately 10 feet belowground surface in the area of the DBRP (Figure3). Surface drainage is to the west-southwesttoward a nearby ephemeral tributary of theSavannah River.

The two contiguous waste pits are designated as431-D and 431-lD and cover a total area of 0.54acre. Approximate dimensions of 43 1-D are 257feet by 46 feet by 10 feeg and the dimensions of431-lD are 229 feet by 36 feet by 10 feet. The twopits are separated by a 15-foot wide berm of

undisturbed soil. The total planar area of theDBRP is assumed to be 257 feet by 97 feet (24,929ft2). The pits have been backfilled with soil andvegetation has been established on the resultingsurface. The pit cover is raised above thesurrounding terra.@ which is essentially level, toenhance drainage.

IL Operable Unit History and ComplianceHistory

Operable Unit History

Between 1951 and 1973, burning pits were usedat SRS to burn a variety of hazardous and non-t i d o u s waste. The chemical composition andvolumes of the disposed waste are unknown.Combustible materials, which were burnedmonthly, included paper, plastics, wo@ rubber,rags, cardboar~ oil, degreasers, and spentorganic solvents. No known or sqxxtedradioactive materials were allowed in theburning pits.

Burning of waste in the SRS pits wasdiscontinued by October 1973. A layer of soilwas then placed over the residue in the pits andthey were subsequently used as rubble pits.Materials allowed in the rubble pits generallyincludai concrete, bric~ tile, asphal~ plastic,metal, empty drums, wood products, and rubber.When the pits were filled to capacity in 1983 orwere no longer need~ a 1 to 3 foot layer ofclayey soil was placed over the contents and thesurface was compacted and mounded above thesurrounding terraiq which is essentially level,to enhance drainage. Vegetation wasestablished to reduce erosion.

Compliance History

At SRS, waste materials are managed which areregulated under R C ~ a comprehensive lawrequiring responsible management of hazardouswaste. Certain SRS activities have requiredFederal operating or post-closure permits underRCRA. SRS received a hazardous waste permitfrom the South Carolina Department of Health andEnvironmental Control (SCDHEC) on September5, 1995.

Recordof Decision for the D-AreBuming/Rubble piti(431-D,uid431-lD)Savannah River siteFetnuaw 1997

WSRGRP-96-S67Revision 1

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F@ure L Lwation of the IMrea Burning/Rubble Pits in relation to major facilities at the SavannahRiver Site

SOUTHCAROLINA

D-AREAB/R PITS

SOUTHCAROLINA

GEORGIA

SCALE IN MILES

Record of Decision for the D-Area Burning/Rubble Pits (431 D and431 ID)Savannah River SiteFebmary 1997

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Figure 2. Topography of the D-Area Burning/Rubble Pits and surrounding area.

SCALE 1:24000o HIU

1°CXI 2 a x ) 3000 4003 Scoo 6alo 7mo F [ a

1 KILOMCTIR

CONTOUR INTERVAL 10 FEET

Modified from DPST-87-667, El. du Pent de Nemours and Company, 1987.5

R e e o r d o f D e c i s i o n f m the D - A - ~ u b b l e P i t s ( 4 3 1 D a n d 4 3 1 I D )

S a v a n n a h R i v e r S i t e

Febrwq 1997

WSRGRP-%-S67Revklkm 1

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Figure 3. Topography and Water Table Potentiometric Map of the D-Area Burning/Rubble Pit&

DBP2C12<.2) A MONITORING WELL LOCATION. NULU3ER0I U . S 9 " [ SURFACE ELEVATION) .WA.TER LEVEL

TOPOGRAPH1C

~ T E S T P I T LOCATION. UNI1 SCREENING

APPROX

Q COOL INC WATER SURCE TANK

123 ^ POTENUOKTRIC SURFACE CONTOUR (FT . MSL

FL OK OIRECIION

C O N T O U R I N T E R V A L = 2 ' < ' » ° rut WELOCAr l ONS Of fWfN3L[Plr o07 SOL E)OFWG LC)CATN3NBOUNOAR[f S AREAPCROXIMATE

120 120I(VORAI)L lC Cf?Aol[Nl -

v t n l ICAL CNANC[ IN 14EA0(dhl 4 f l .

•f I I—I}IORIZONIA1 OISIANCC (6 192 f l .

SCAI_T IN r c n

Record of Decision for the D Area Burning/Rubble Pits (431 D and431 -lD)Savannah River SiteFebruary 1997

WSRGRP-96-867Revision 1

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Part V of the permit mandates that SRS establishand implement an RFI program to fidfill therequirements specified in Section 3004(u) of theFederal permit.

On December 21, 1989, SRS was included on theNational Priorities List (NPL). This inclusioncreated a need to integrate the established RFIProgram with CERCLA requirements to providefor a fwused environmental program. Inaccordance with Section 120 of CERCL~ DOEhas negotiated a Federal Facility Agreement @F&1993) with U. S. Environmental ProtectionAgency (EPA) and SCDHEC to coordinateremedial activities at SRS into one comprehensivestrategy which - S these dual regulatoryrequirements.

IEL Highlights of Community Participation

Both RCRA and CERCLA require that the publicbe given an opportunity to review and comment onthe draft permit modification and proposedremedial alternative. Public participationrequirements are listed in South CarolinaHkza.rdous Waste Management Regulation(SCHWMR)R61-79.124 and fkdOIM 113 and117 of CERCLA. These requirements includeestablishment of an Administrative Record Filethat documents the investigation and selection ofthe remedial alternatives for addressing the DBRPsoils and groundwater. The AdministrativeRecord File must be established at or near theficility 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 R C ~ CERCL&and the National Environmental Policy A@ 1969(NEPA). SCHWMR R61-79.124 and Sec t ionl17(a) of CERCL~ as amend~ require theadvertisement of the draft permit modification andnotice of any proposed remedial action and providethe public an opportunity to participate in theselection of the remedial action. The Statement ofBasisYProposed Plan for the BAreaBumingZRubble Pits (WSRC, 1996c), which ispart of the Administrative Record File, highlightskey aspects of the investigation and identifies thepreferred action for addressing the DBRP.

The FFA Administrative Record File, whichcontains the information pertaining to the

selection of the response actioz is available at theEPA office and at the following locations:

U. S. Department of EnergyPublic Reading RoomGregg-Graniteville LibrmyUniversity of South Carolina+liken171 University ParkwayAikeq South Carolim 29801(803) 641-3465

Thomas Cooper LibraryGovernment Documents DepartmentUniversity of South CarolinaColumbi& South Carolina 29208(803) 777-4866

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

Asa H. Gordon LibraxySavannah State UniversityTompkins RoadSavanna& Georgia 31404(912) 356-2183

The public was notified of the public commentperiod through mailings of the SRS EnvironmentalBulletin, a newsletter sent to approximately 3500citizens in South Carolim and Georgi~ throughnotices in the Aiken Standard, the AllendaleCitizen Leader, the Augusta Chronicle, theBarnwell People-tkntinel, and The Statenewspapers. The public comment period was alsoannounced on local radio stations.

The 45day public comment period began onSeptember 17, 1996 and ended on October 31,19%. A public comment meeting was held onOctober 15, 1996. A Responsiveness Sunmuuywas prepared to address comments received duringthe public comment period. The ResponsivenessSummary is available with the final RClU4 permitand is also provided in Appendix A of this Recordof Decision (ROD).

Record of Deciaion fm the D Area Burning/Rubble pita (431-D and 431-lD)Savannah River SiteFebruary 1997

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I v . Scope and Role of Operable UnitWithin the Site Strategy

The overall strategy for addressing the DBRP was

to:1) characterize the waste unit delineating the

nature and extent of e o n ~ “ o n andident.iijing the media of eoneern (WSRC,1994 and WSRC, 1995b);

2) perform a baseline risk assessment to evaluatemedia of eoneeq constituents of eoncem(COCS), exposure pathways, and characterizepotential risks (WSRC, 1995a);

3) evaluate applicable technologies and isolate apreferred technology to remediate the wastesite as needed (WSRC, 1996b and WSRC,1996c); and

4) perform a final action to remediate theidentified media of eoncem to the remedialaction objectives.

The DBRP is an operable unit heated wit.hixr theSavannah River Floodplain Swamp Watershed.Several wmree control and groundwater operableunits within this watershed will be evaluated todetermine impacts, if any, to msdated streamsand wetlands. SRS will manage all source controland groundwater operable units to minimizimpact to the watershed. Based oncharaeterizat.ion and risk assessment informatiorL

the DBRP does not signikmtly. impact thewatershed. Upon disposition of all source controland groundwater operable units within thiswatersh~ a final, comprehensive evaluation ofthe watershed will be eondueted to determinewhether any additional actions are neeessmy. Thegroundwater at the DBRP was investigated d “the RFI/RI conducted in 1993. The Baseline %RiAssessment (BIUk) (WSRC, 1995a) found no risbexceeding 1.0 x 104 for ingestion of the DBRP soilby future industrial workers, but calculated a riskof 3.0x 10< for ingestion of groundwater by futureindustrial workers. Additional groundwatermonitoring of the groundwater for modeled riskand hazard drivers at the DBRP will be conductedand reported in the five-year ROD reviews.

v. Summary of Operable UnitCharacteristics

The SRS burning/rubble pits were excavated in1951, during the emstruction of most of themajor fxilities at the Savannah River Plant.The DBRP received waste materials produced

during constmction of D-Area facilities. Thechemieal composition and volumes of thedisposed waste are unknown. During theoperation of the burning/rubble pits, emnbustiilematerials (including paper, plastics, wo@rubber, rags, cardboar~ oil, degreasem, andspent organic solvents) were burned monthly, aswas the praetiee at that time, for volumereduetion. This praetiee would have eliminatedmany of the combustible organic materials whileereat.ing combustion by-products. No known orsuspected radioactive materials were disposedin the burning pits.

Open burning of waste material wasdiscontinued at SRS in 1973. At that time, thewaste residue was covered with soil and the pitswere used as rubble pits. Materials allowed inthe rubble pits included eonerete, bricks, tile,asphal~ plastic, me@ empty drums, woodprodue@ and rubber. When the pits were filledto eapaeity about 1983, a 1 to 3 fdot layer ofclayey soil was placed over the contents and thesurhee was e o m x m o u n ~ and seeded.

Media Assessment

The Data Summary Reprt (WSRC, 1994), BRA(WSRC, 1995 a), RFI’ Reprt (WSRC, 1995b),and Corrective Measures StudyL%yusedFeasibility Study (WSRC, 1996b) contain deta.hedanalytical data for all of the environmental mediasamples taken in the characterization ,of theDBRP. These documents are available in theAdminMrative Reeord (See Section III).

SoikkXXi’’eal data indicate that little or noq o n ~ “ o n of the soil outside of the DBRP hasoecurrd Figure 3 shows the sample locations forthe Phase I characterization in 1989 and the PhaseII{ characterization in 1993. The 1989 programincluded two locations in eaeh pi~ one in the bermbetween the pits, and one directly down gradient ofthe pita. The 1993 program consisted of four soilborings in each pit and four boMgs around thepits.

In the B ~ the analytical data horn the 1993 soilsamples were divided into two groups:

• surikee soils, 0.0 to 2.0 feet (@narydirect contact exposure interval forsoils) and

Record of Decisionfbr the D Area Burnin@ubbie Pits (431 D and431-lD)Savannah River SiteFebruary 1997

WSRC!-RP-96-S67Revision 1

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• subsurface soils, 0.0 to 4.0 feet (potentialexposure intend for future scenarioswhere excavation may occur).

The B W identified the following constituents ofconcern:

arsenic,benzo(a)pyrene,Chromiurq

manganese,octachlorodibenzo-p-diox@PCB-1260, andtotal alpha emitting radium.

Dieldrin was identified as a modeled-DBRP-soils-to-groundwater ingestion risk driver tofiture residents, 81% of 8X104 in Revision O ofthe BRA. Dieldrin was only detected two timesout of 45 soil samples collected in the DBRP.The maximum value reported was JO.0165mg/Kg in the 4 to 6 foot interval of boring 11,the "J" qualifier indicates that the analyte wiisrecognized below detection limits and the valuewas estimated. The risk contribution of dieldrinwas reevaluated in the B ~ Revision 1 anddieldrin was eliminated as a risk driver based onits high uncertainty of detection and low numberof occurrences.

Two times the mean background value for aconstituent was used in screening thatconstituent for consideration as a constituent ofpotential concern. The mean background valuefor arsenic at the DBRP is 2.3 mgkg. In the O-2foot interval of the DBRP, arsenic only exceeds2 times mean background (4.6 mgkg, parts permillion) at one locatio~ boring 7 (7.6 mg/kg).The levels of arsenic detected are consistent withthe levels found throughout SRS. Arsenic maybe naturally omurring, added to the soils as apesticide, or a constituent of waste materialsdisposed in the DBRP. Arsenic in the soil atSRS is believed to be primarily the residue ofpre-SRS agricultural pesticide application. Theoccurrence of arsenic will be evaluated on a site-wide scale in the forthcoming SRS backgroundsoils study report.

In the near-surfhce soil at the DBRP, chromiumonly exceeded 2 times mean background (80.8mg/kg) in bor ing 12 (339 mg/kg). Thechromium present in the DBRP is believed to bepredominantly CrIII (chromium in the +3valence state) which is much less mobile and

toxic t h a n the CM (chromium+6) assumed inthe BRA evaluation. CrVI isthermodynamically unstable in soils in theregion including SRS and is rapidly reduced toCrIII. Mangamx only exceeded 2 times meanbackgro~ (242 m@g) in the near-surkeinternal in boring11 (260 mg/kg).

- a ) ~ = (RIP) did not exceed detectionlimits in the O-2 foot intend at the DBRP.Octachlorodibenzo-pdioxin (OCDD), w h i c hcomprised only 9% of the risk via soil ingestionfor Mum on-site workers, was detected at lowconcentrations in all of the shallow soil samples.Dioxins are common products of incompletecombustion. Polychlorinated Biphenyl-1260(PCB-1260) was identified in only one locatiorL

soil boring 12; the maximum concentration ofPCB-1260,3.39 mgkg was found in the 0.5-2.0foot inkxval. Total alpha emitting radium wasonly detected in the O-2 foot interval (1.2 pCi/g)in boring 7; 2 times mean background was 2.49pcilg.

Based on the f t i that a.ll the soil analytes passedeither the simple site-specific or detailed site-specific method of screening there is little or nochance for the residual waste at tie D B ~ to be asource of fitu.re c o n ~ “ o n . The remainingsoil contaminantts pose little, if any threat forfhture contamination.

GroundwaterGroundwater monitoring data indicate that nosignificant release of hazardous substances togroundwater from the DBRP has omurredHowever, risk evaluation indicates agroundwater ingestion risk of 3.OX 10* forfiture workers and 1.0x 103for future residentsdue to arsenic (dimssed later in this section).There are 5 monitoring wells in the DBP (D-Area Burning Pit) well series: DBP-1, -2, -3(installed in September 1983), DBP- 4 (installedin June 1984), and DBP-5 (installed in June1993). Figure 3 shows the locations of themonitoring wells comprising the DBP networkand the potentiometric water table map.Comparison of constituent concentrations, from1984 through 1992 in the four downgradient

DBP wells with concentrations in the upgradientweu DBP-3, indicates little or no constituentconcentration increae in gmundwa~r afterflowing beneath the DBRP. The onlyconstituents which show any apparent increase

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are iro~ manganese, l x sulfate, and possiblygross il@M and total radium. hO~ manfy.ne.se,and sulfate are c covered by the SecondaryDrinking Water Standards which deal with theaesthetic properties of public drinking water.The RCRA groundwater protection stadard forlead is 0.05 @ L . The highest value of leadreported for the period of interest was 0.013mg/L.

The measured groundwater risk drivers underthe Mum resident scenario are: arsenic(dern@ 3 x 10A and ingestio~ 1 x 10-3);dichloromethane (inhalation 2 x 10*); Ra-226and Ra-228 (ingestio~ 2 X 10-5); and tritium(inhdatio~ 3 x 10-~. The modeled-DBRP-soilsto groundwater risk drivers areoctachlorodibenzo-pdioxin ( O C D D ) a n dheptachlorodibenzq-pdioxin (HpCDD) (derrnal,1 X 10~; po@mmatic hydrocarbons ( p m )and 1,1,2-trichloroethane (1,1,2-TCA)(ingestio~ 2 x 10+); l,2dichloroethane (1,2-DCA), 1,1,2-TC& and chloroform (inhalatio&3 X 10-~; and tritium (ingestio~ 2 X 1 0-5 andinhalation 3x 10-5). The measuredgroundwater hazard drivers are: (manganese(derrnal, 1.0); arsenic and manganese(ingestio~ 50.0); and toluene (inhalatio~0.005). The modeled-DBRP-soil-to-groundwater hazard drivers are: OCDD andHpCDD (dermal, 5.0); acetone and naphthalene(ingestio~ 20.0); and carbon disulfide(inhalatio~ 0.3). Many of these exposurescenarios are well below the 1 x 10~ risk and1.0 hazard .levels.

Arsenic was the sole nonradioactive contributorto risk under the measured groundwateringestion pathway in the BIU4. The risk to thefbture on-unit worker was 3.0 x 104; to theMum on-unit resident the risk was 1.0 x 10-3.The maximum contaminant level for arsenic indrinking water is 0.05 mglL. Arsenic was onlydetected twice in the DBP monitoring networlGthe higher value in the December 1993 samplefrom well DBP-5 was reported as 0.044 rng/L.The following quarter when the well wasresarnpl~ arsenic was reported below detectionlimits of 0.002 mg/L. Therefore the risksattributed to this single arsenic value arebelieved to be exaggerated.

Manganese is covered by the secondarymaximum contaminant level of 0.05 mg/L. This

contaminantt level addresses the aestheticproperties of public drinking water rather thandealing with h@th-based concerns. Themaximum value of manganese reported in theDBP well series was 1.44 mg/L from well DBP2 in the fourth quarter of 1993.

Dichlorometbane (methylene chloride), acommon laboratory artifi@ was only reported inthree soil samples in a total of 55 samplescollected horn the DBRP with a maximum ofVO.06 mg/Kg (boring 7 at a depth of 4.04.0fet). The"V" qualifier indicates that theaualyte was also detected in the associatedmethod bla.nlq indicating laboratmycontamimW“on. Therisk at t r ibutedtodichlorometbane via the groundwater inhalationpathway by fiture residents was 2 x 10', wellbelow 1 x 104. Dichloromethane was detectedin the groundwater in excess of the 0.005 mg/Lmaximum contaminantt level four times sinceJanuary 1993, two of these exceedances were inupgradient well DBP 3. Dichlorometbane wasevaluated and determined to be a laboratoryartifact. Likewise, acetone has been detected inup- and downgradient wells and is a c o ~ o nlaboratory artifhct.

Gross alpha and total radhun were the onlyradioactive constituents in the Unit Assessmentsamples (cover@g three quarters in 1993) forwhich p - r n aximum contaminantt levelsmay have been exceeded. The maximumcontaminantt level @CL) for gross alpha is 15pCi/L, this level may have been exceeded in theDecember 1993 sample from well DBP-2 (15pci/L ~ 0.21 pci/L).' This gross alpha anomalyoccurred only once in a single well that hadpreviously contained no detectable gross alphaand may be due to field or laboratorycontamination.

The MCL (regulatory standard) for total radiumis 5 pCi/L; an increase to 20 pCi/L is beingconsidered under proposed regulations(56FR33050). Total radium in the groundwalerhas only exceeded 5 pCi/L once sincemonitoring began at the DBRP. Thisexceedance occurred in the sample collectedfrom well DBP-2 in December 1993 (the samesample which yielded the gross alpha anomaly);Ra-226 was 4.8 p c f i and Ra-228 W= 3.5pCi/L. The relationship of the gross alpha andRa-226/228 anomalies in the same sample

Record of Decision fw the D Area BWL@/RUWC pits (431 D and 431-lD)Savannah River SiteFebruary 1997

WSRGRP-96-S6700383 gwisionl

Page 9 of 29

sugfyxts that t h e s e a.UOIWdkS could be due toproblems with laboratory or field samplingtechniqu&.

During evaluation performed for the BR& theassumption was made that all the radiumpresent was Ra-226, the only radium species forwhich slope fhctors have been determined andthe most toxic radium species. This assumptioncontributed to an exaggeration of the riskattributed to radium. The ingestion of radiumin the groundwater pathway risks was evaluatedat 6.0 x 10~ for fbture workers and 2.0 x 10-5forfitum residents.

Tritium was recognized & a risk driver in themodeled-DBRP-soil-to-groundwater exposurepathway as discussed in the precedingPr%WPhs. Tritium only exceeded the twotimes mean background screening level (5.26pCi/g) in the DBRP soils seven times in 49 soilsampl* the maximum value reported was 13.'5pCi/g from the 2 to 4 foot intend in boring 8.The maximum contaminantt level for tritium is20,000 pCi/L, the highest value of tritiumreported from the groundwater was only 3400pCi/L, 17% of the MCL. The maximummodeled-soil-to-groundwater concentration was11,500 pcilL.

The PAHs, HpCDD, OCDD, 1,1,2-TC~1,2-D C ~ caibon disulfide, and chloroform have notbeen detected in groundwater . Theseconst i tuents have ve~ low solubilities inaqueous systems and tend to be stronglyadsorbed to clays and humates in the SOL theyare not readily transferred from soil togroundwater. The modeling in the BRA isconservative in that it assumes that thecontaminantt is present at its maximum detectedconcentration throughout the waste body andthat the contaminantt does not suffer degradationor depletio~ thus the modeled-DBRP-soil-to-groundwater risks are exaggerated.

Under current land use (and recommendedinstitutional controls)' the on-site visitor issupplied with drinking water from the SRSdrinking water supply system. Under SRSinstitutional control, the local groundwater atthe DBRP is not used for drinking or hygienicpurposes.

VL Summary of Operable Unit Risks

Human HeaM Rikk Assessment

As part of the investigationhssessment processfor the DBRP waste unit a BRA was performedusing data g e n e - during the assessmentphase. Detailed information regarding thedevelopment of constituents of potential concern(coPCs), the fate and transport ofcontaminantts, and the risk assessment can befound in the BRA (WSRC, 1995 a) and theREIAU Report for the D-Area Burnin@lubblePits (43 1-D and 431-ID) ~), (WSRC, 1995b).

COPCS are site- and media-specific, man-madeand I l a t i y mcurrin~ inorganic and organicchemical% pesticides, and radionuclides detectedat a unit under investigation. These constituentsare potentially site-related and data tnatingtheir distribution and concentration are ofsufficient quality for use in the risk assessment.The process of designating the COPCs wasbased on consideration of backgroundconcentrations, fi-equen~ of detectio~ therelative toxic potential of the chemicals, andchemical nutrient status.

Constituents of concern (COCs) are isolatediiom the list of COPCS by c a l c u l a t i n gcarcinogenic (cancer-causing) risks andnoncarcinogenic hazard indices. A COCcontributes significantly to a pathway thatcontributes to either a cumulative sitecarcinogenic risk greater than 1.0 x 10~ or ahazard index greater than 1.0.

An exposure assessment was performed toprovide an indication of the potential exposureswhich could occur based on the chemicalconcentrations detected during Sa.mp@activities. The only current exposure scenarioidentified for the DBRP was for on-site worker&who may perform environmental research ormaintenance activities (such as mowing andinspt.iom) on the DBRP on a limited andintermittent basis. Conservative Mum exposurescenarios identified for the DBRP includedfuture environmental researchers andmaintenance workers and fiture resident adultsand children. The reasonable maximumexposure concentration value was used as theexposure point concentration.

Read of Decisicm fm the D - h &dn@Mble Pits (431 D and 431-lD)Savamaah River s i teFebnuuy 1997

WSRGRP-96-S67Revision 1

Page 1 0 of29

Per EPA guidance, the carcinogenic risks andnoncarcinogenic hazards must be calculated todetermine the appropriate remedial action for awaste unit. Carcinogenic risks are estimated asthe incremental probability of an individualdeveloping cancer over a lifetime as a result ofPathway-spedic exposure to cancer-cawingcontaminant ts. These risks are expressed as theincreased likelihood that an exposed individualwill develop cancer during his lifetime (70 years)because of a 30-year (chronic) exposure to thecontaminant ts at a given waste site.

Cancer risks are related to the EPA target riskrange of one in ten thousand (1.0 x 1 0 ~ to one inone million (1.0 x 104) for incremental cancer riskat National Priorities List sites.

Remedy selectio~ addressing significant risksand/or principal threat source material, wasCmpleted in a c o m p r e h e n s i v e CorrectiveMeasures Study/Feasibility Study (CMWFS).Alternatives that are permanent and/or employtreatment as a principal element of the remedy arenemssary for inclusion in the CMS/FS.

Non-carcinogenic &3kcts are also evaluated toidenti& a level at which there may be concernfor potential health effects other than cancer.The hazard quotient which is the ratio of theexposure dose to the reference dose, is calculatedfor each coqtaminant. Hazard quotients aresummed for each exposure pathway to determinethe spaiiic hazard index @I.) for each exposurescenario. If the hazard index exceeds unity(1.0), there is concern that adverse health effectsmight occur.

Exposure r@s and hazards for the three landuse scenarios are presented in Tables 1 through3. The fidu.re residential scenario includeshomegrown produce as an exposure poingwhich is not considered under the current on-unit visitor or future industrial worker scenarios.

Current Land Use -Noncarcinogenic H~ds

Under the current land use scenario, humanhealth risks and noncarcinogenic hazards werecharacterized for the current on-unit visitor. Anon-unit visitor is described as an employee ofSRS who works at the DBRP for short periodson an infrequent basis, (i.e., a few hours permonth performing environmental sampling or

maintenance activities). " Current on-unitvisitors are supplied with drinking water fromthe SRS &inking water supply system, the localgroundwater is not used for drinking or hygiene.

The BRA (WSRC, 1995a) shows that potentialadverse noncarcinogenic health eftkcts are notlikely to occur, because none of the haza.rdindices exceeds a value of one. Table 1 containsa sumnuuy of noncarcinogenic hazards underthe current land use scenario.

Current Land Use - Carcinogenic R&

Under the current land use scenario, humanhealth risks were characterized for the currenton-unit visitor. Table 1 contains a summary ofcarcinogenic risks. All of the estimatednonradiological cancer risks were less than 1.0 x104, indicating that carcinogenic risk fium theunit is not significant. Media evaluated includesoil inside the DBRP, soil outside the DBRP,associated airborne sbil particulate, and surfacewater and sediment in the Stream/wetland.

All of the @imated radiological risks were lessthan 1.0 x 104. Radiological risks wereestimated for three exposure pathways:ingestion of soil inside the DBRP, inhalation ofparticulate from soil inside the DBRP, andingestion of sediment. ‘

Future Land U&- - Noncarcinogenic Hazards

The HIs were less than one, indicating adversenoncarcinogenic effects are unlikely for thefollowing pathways:• direct exposure of on-unit workers to soils

inside and outside the DBRP (Table 2)• direct exposure of adult and child residents to

soils inside and outside the DBRP (Table 3)• direct exposure of child+mly residents to soils

inside and outside the DBRP• exposure of a child to surfhce water and

sediment

NonnuL _.gica_ iwiuouiuiutjitoi 'Exposure Point Current On-Unit Current On-Unit

Exposure Route Visitor Risk Nonra/«nWe«l V,*V TViv™, v:..:*-. U a ^ XT -•--<-riCfli "» 7 B r HTViv« ,

„ - „ , . . loot ins.de W L - ,dermalingestion

sou (V-z loot outside UUK.P)dennalingestion

sunace waterdermal

_ imentdermalingestion

Air (V-J. foot inside utsa?)soil particulate inhalationsoil vapor inhalation

Air (v-2 loot outside DilRP)soil particulate inhalationsoil vapor inhalation

Exposure PointExposure Route

loot insiae uuiQ^^^dermalingestion

-4 foot inside UBRPdennalingesti

foot outside DBKPdermalin estion

edimentingest

Air v . _ foot ins.de UBKP,soil particulate inhalation

2E-095E-09

7E-114E-11

1E-09

4E-094E-08

9E-102E-10

5E-W3EJ9

PCB-1260 52%, OCDD 43%PCB-1260 78%,BaP10%

OCDD 100%OCDD97%

As 100%

As61%,BaP22%As96%,BaP3%

Cr 99%1,2-DCA77%, 1,1,2-TCA23%

OCDD 97%1 I .IV 1 ! »?«/i 1 1 1.TT1 ISO/.

3E-036E-04

6E-064E^)6

3E-041E-03

NCNC

NC

CrCr, PCR-mn

OCDDornn

A s T7

CrAs

NANA

NA

Kad gica_Current On-Unit

Visitor Risk Radiological Ri«W T>iv»«

NC3E-13

NANA

NRNR

E

1E-18

NATritium 100%

NANA

NANA

Radium 100%

Tritium 100%Air (0-2 foot ..de DBRP, j ,

so articu ate inh on NR N

»

NA - Not applicable for this receptor.

NC - No data was available for the toxicity of the COPCs in this medium, for this exposure route. Therefore, a quantitative risk value could not be calcu atedNR - No radiological COPCs in soils outside the pits.Air exposures are modeled values based on soil contaminant data.

H

n"

I3

3B'

P 5

nI.o

sn'50

n

£8CD p h

Exposure PointExposure Route

Soil (0-2 foot inside DBRP)ingestion

Soil (0-4 foot inside DBRP)ingestion

Soil (0-2 foot outside DBRP)ingestion

Groundwater (measured)ingestion

Groundwater (modeled)ingestion

Air (0-2 foot inside DBRPsoil particulate inhalation

Air (0-4 foot inside DBRP)soil particulate inhalationsoil vapor inhalation

Air (0-2 foot outside DBRP)soil particulate inhalationsoil vaoor inhalation

Nonradi^^caiFuture On-Unit

Worker Risk

1E-06

1E-O6

8E-09

3E-04

4E-0J

4E-07

6E-074E-09

1E-121R-07

Nonradiological Risk Drivers

PCB-1260 78%, BaP 10%, OCDD 9%

PCB-1260 78%, BaP 10%, OCDD 9%

OCDD97%

As 100%

PAH 53%, 1,2-DCA 10%, As 9%

Cr 100%

Cr 100%1,2-DCA 77%, 1,1,2-TCA23%

OCDD 97%l 7.T\T.A «?•/» i i o.rr A I »•/.

i> w u auiiuugiuuFuture On-UnitWorker Hazard

3E-02

3E-02

1E-04

6E+00

2E+00

NC

NCNC

NC

Nonradiological Hazard Drivers

Cr

Cr

OCDD

As,Mn

Acetone

NA

NAN A

N AX I *

1Exposure Point

Fvrwnifft "Rmitft

1 w i i yv-4. fOOt uraide A^JUUVI f

direct radiationingestion

" iJUll \V~t fOOt U131UC UDRX)

direct radiationingestion

1 kVYUJ. \V-*. fOOt VUlOlde JUMJ41J. f

direct radiationinpestion

Grouiidw&id ^uicosured^ingestion and inhalation

• Oroundwater (modeled,,ingestion and inhalation

1 Air ^ - toot ins.de JJBRP,soil particulate inhalation

mi \y-* iooi msioe vaiur)soil particulate inhalation

Radiw^^calFuture On-Unit

NC7E-11

NC7E-11

NRNR

6E-06

JE-06

• 3E-17

3E-17

NATritium 100%

NATritium 100%

NA•MA

Ra-226 5 5 % Ra-228 32%

Tritium 100%

Tritium 100%

Tritium 100%

1

1

1

•

NA - Not applicable for this receptor.

NC - No data was available for the toxichy of the COPCs in this medium, for this exposure route. Therefore, <>• quantitative risk value could not be calculated.NR - N o radiological COPCs in soils outside the pits.Air exposures are modeled values based on soil contaminant data.

£3n

Exposure Point

dermalingestion

Soil (0-4 foot inside DBRP)dermalingestion

Soil (0-2 foot outside DBRP)dermalingestion

Groundwater (measured)dermalingestioninhalation

Oroundwater (modeled)dermalingestioninhalation

L7UIIOI*« Waici ^measured,;dermalingestion

Surface Water (modeled)dermal

ingestionSediment

dermalingestion

Air (0-2 foot inside DBRP

Ail1 v , foot ins.de u u * u ,soil particulate inhalationsoil vapor inhalation

Air v - - - foot w ^ d e ^ * v i ,soil particulate inhalationsoil vapor inhalation

gica RiFuture On-Unit Resident

Adult and Child

1E-061E-05

1E-061E-05

4E-087E-08

3E-061E-032E-08

1E-O42E-043E-05

NANA

NA

NA

NANA

1E-06

1E-069E-09

2E-123E-07

Child Oniv

NANA

NA>JA

NANA

NANANA

NANANA

1E-072E-07

1E-08

7E-09

1E-077E-06

NA

NANA

NANA

PCB-1260 52%, OCDD 43%PCB-1260 79%

PCB-1260 52%, OCDD 43%PCB-1260 79%

OCDD 100%OCDD 97%

As 100%As 100%Methylene chloride 100%

OCDD 53%, HpCDD 34%PAHs 61%, 1,1,2-TCA 22%1,2-DCA 48%, 1,1,2-TCA""*' ""oro'orm^

As 100%As 100%

1,1,2-TCA 47%,1,2-DCA 34%As 54%, 1,2DCA28%

As61%,BaP22%As 96%

rv 1 nn«/.

Cr 100%1,2-DCA 77%, 1,1,2-TCA23%

OCDD 97%1,2-DCA 82%, 1,1,2-TCA

Future On-Unit Resident

9E-027E-0

1E-019E-01

2E-O34E-03

1E+005E+015E-O3

5E+002E+013E-01

NANA

NA

NA

NANA

ury

NCNC

NCNC

> — J Onlv

6E-027E-0

7E-02RRJ11

1E-034E-O3

8E-014E+013F-O3

3E+O01E+012E-01

3E-033E-03

1E-02

4E-04

5E-O31E-01

NCNC

NCNC

Cr, OCDD 1Cr, PCB-1260 ^ ^ ^ ^ ^ ^ J

^ •Cr, OCDD 1Cr.PCB-1260 •

OCDDnrnn

MnAs,Mn

OCDD, HpCDDAcetone, NaphthaleneCarbon disulfide

AsAs

2-Methylnaphthalene

2-Methylnaphthalene, Acetone

CrAs

IT *

NANA

NANA

a.o

Si

wf9

GTJ

O.n

1Exposure Point

Exnosure T?mitA

_. _ , . _ loot ins.de DBRP,direct radiationingestion

, loot insde DBRP,direct radiationingestion

_... „. _ loot de DBRP,direct radiationin esti

Uroundwater (meas /

ingestioninhalation

uroundwater (mode ed,ingestioninhfllfltinn

Rad gica. RiFuture Qn-Unh Resident

NC NA3E-10 NA

NC NA3E-10 NA

NR NRNR NR

2E-O3 NA3F.-0Q NA

2E-05 NA^T?_A ^ XT A

_ _rtace Water (meas , .ineestion 1 NA ?P.in

ounaee water (modeled;incestion 1 NA IITJIO

NATritium 100%

NATritium 1 fino/.

NAN

Ra-226 35%, Ra-228 32%

Tritium 100%

edimentingestion NA 5E-O8 Radium, total atoha emitting 100%

Air,. _footins.deUJBW,soil particulate inhalation 4E-17 NA P,Hi,,m fM,l . 1 ^ . —;«,•-„ inn./.

hGr7_ foot ins.de DBRP,soil particulate inhalation 4E-17 NA Tritium 100%

Homegrown ttwJuce v . _ toot ins.de DBRP,ingestion of leafy vegetablesingestion of tuberous vegetablesingestion of fruits

Homegrown lYoduce v . . loot inside DBRP,ingestion of leafy vegetablesingestion of tuberous vegetablesingestion of fruits

NA NANA NANA NA

NC NANC NANC NA

NANAMA

NANAMA

</) H ?

NA - Not applicable for this receptor.NC - No data was available for the toxicity of the COPCs in this medium, for this exposure route. Therefore, a quantitative risk value could not be calculated.NR • No radiological COPCs in soils outside the pits.Air and homegrown pixxluce exposures are modeled values based on soil contaminant data.

l-'n

ll

9.B

3 S

:

liI?- g

a

O5

5*

ii3os

3 SH a< a0, S.

a>

I

Record of Decision fm the D - h = Burnin@ubble Pits (431 D and431 -lD)Savannah River SiteFebruary 1997

. : ~ ~ 9-&-S 6'Revkion 1

Page 15 of29

The groundwater ingestion and inhalationpathway yielded a m of 50 from arsenic andmanganek to kture resident adults andchildren. This hazard is reduced to 6 for fitureon-unit workers.

Future Land Use - Carcinogenic Risks

Several exposure pathways for the fiture on-unitresident had estimated nonradiologicalcarcinogenic risks exceeding the lower bound ofthe target risk range, 1.0 x 10X (Tables 2 and 3).No contamination was found in concentrationsthat yielded risks greater than the upper boundof the risk range of 1.0 x 104 except for arsenicby groundwater ingestion. Under thegroundwater ingestion pathway, the risk due toarsenic to the future on-unit worker was 3.0 x10+; to the fiture on-unit resident the risk was1.0 x 10-3. These risks were based on a singlemeasured arsenic value in the groundwa~rwhich was less than the MCL for drinkingwater.

For the fiture on-unit worker, cancer rislm foringestion of soil from inside the DBRPs wereequal to the EPA point of departure of 1.0x 104

for the 0-2.0 foot and 0-4.0 foot depth intexvals.Estimated risks for dermal contact with soil andinhalation of soil particulate at both depthsinside the DBRP were equal to 1.0 x 10%.

Ecological Rikk Assessment

Based on characterization of the environmentalsetting and identification of potential receptororganisms, a conceptual site model wasdeveloped to determine the complete exposurepathways through which receptors could beexposed to COPCs.

Interpretation of the ecological significance ofthe unit-related contamination at the DBRPindicated that there was essentially no likelihoodof unit-related chemicals causing significantimpacts to the community of species in thevicinity of the unit.

Site+eczjik Considerations

Site-speciiic considerations, based on theconclusions of the BRA and RFI/RI, which

suggest limited or no potential for significantrisk include:

1) The DBRP contain a large volume of buriednon-hazardous waste material and cover soil.

2) The levels of contamination recognizedduring Phase II characterization are generallyvery low, there is a preponderance of non-detects. The contaminants are very stablechemically and exhibit limited mobility in thesoil.

3) The groundwater monitoring programindicates that there has not been significantimpact from the waste materials in the pits.

4) The DBRP are in a remote area which hasbeen recommended as a fiture industrial zoneby the Citizens Advisory Board (CAB) and inthe Slzvannah River Site Future Use ProjectReport (DOE, 1996).

Remedial Action Obje&”ves

Remedial action objectives speci.& unit-specificcontaminantts, media of conce~ potentialexposure pathways, and remediation goals. Theremedial action objectives are based on thenature and extent of c o n ~ “ o ~ threatenedresources, and the potential for human andenvironmental exposure. Initially, pdimimuyremediation goals are developed based uponApplicable or Relevant and Appro@ateRequirements (NUIRs), or other informationfrom the RFI/RI Report and the BIU%. Thesegoals should be modifi@ as necasary, as moreinformation concerning the unit and potentialremedial technologies becomes available. Finalremediation goals will be determined when theremedy is selected and shall establish acceptableexposure levels that are protective of humanhealth and the environment.

Risk levels at or above the upper-bound of thetarget risk range 1.0 x 104 are consideredsignificant and are expected to undergoremediation.

Location-specific ARARs must consider Federal,State, and local requirements that reflect thephysiographical and environmentalcharacteristics of the unit or the immediate area.Remedial actions may be restricted or precludeddepending on the location or characteristics ofthe unit and the resulting requirements.

Record of Decision fm the D Area B - u b b l e pi~ (431-D and 43 1 ID)Savannah River SiteFebruary 1997

WSRC-RP-96-867Revision 1

Page 16 of29

None o f the risks associated with the soil in theDBRP was found to be greater than 1.0 x 10A.PCB-126Q horn the 0-2 foot soil interval in Pit431-D was the predominant risk driver forfiture residen~ contributing 79?! of the 1.0 x10-5risk.

The hazard index for this exposure scenario was0.7. The only guidance that was exceeded forsoil concentrations was for PCB-1260 which hada maximum value of 3.39 mg/kg in the O-2 footinterval of boring 12 in Pit 431-D. The to-be-considered guidance for PCBS is recommendedsoil action levels of 1.0 m@lcg for residential useand 10-25 @kg for industrial use (EPA 1990).The PCB-1260 concentration in Pit 431-D iswell below the range for industrial land use.

VBL Description of the ConsideredAlternatives for the DBRP SourceControl Operable Unit

The RFI/RI and BRA indicate the DBRP poseminimal risk to the environment. The risk tofuture on-unit workers is only 1.0 x 10+.Ingestion of soil in the top two f t i layer byfuture residents poses a risk of 1.0 x 10-s,primarily from PCB-1260. The CorrectiveMemurea Study/Focused Feasibility Study(CMS/FFS) was developed to consider possibleactions which could reduce the risks to 1.0x 104

or less.

A broad suite of treatment alternatives hasalready been considered in the F-AreaBurningA?ubble Pits (231-E 231-IF and 231-2F) Corrective Measures Study@’easibilityStudy (U) (WSRC, 1996a). Both sets ofburning/rubble pits received similar wasteswhich were managed under similar conditionsand practices; similar constituents of concernhave been recognized for both ft it ies. OnJuly 20, 1995, SRS, SCDHEC, and EPA held ascoping me@.ing for the DBRP CMS/FS. Theagenda of this meeting included discussion ofthe site specific considerations anduncertainties, the limited risks associated withthe DBRP, and the CAB proposed industrialland use zones. The conclusion of the scopingmeeting was that focusing on a limited suite ofalternatives in the faibility study for the DBRPwould be appropriate. Therefore, SRSconducted the CMS/FFS (WSRC, 1996b) for the

DBRP, reducing the number of treatmentoptions to be considered to the five alternatives&cussed. in the following paragraphs.

Five alternatives were evaluated for remedialaction at the DBRP source control operable unit.Each alternative is kcribed below:

A&rn&”ve 1 No A&n

Under this alternative, no action would be takenat the DBRP. EPA policy and re@tiOIISrequire consideration of a no action alternativeto serve as a basis against which otheralternatives can be compared. Because nofiulher action would be taken and the DBRPwould remain in their present conditio~ thereare no costs associated with this alternative andthere would be no reduction of risk. Potentialrisks of 1.0 x 10-s due to soil ingestion and 1.0x 10-3 from ingestion and inhalation ofgroundwater would remain for possible fi@reresidents. However, the groundwater risk isbelieved to be overestimated based on thegroundwater monitoring history andcontaminant t concentrations in the DBRP soil as&scuwed. in Section V.

A&erndve 2 Indtutional Controls '

Under this alternative, institutional controlswould be implemented at the DBRP.Implementation of this alternative will requireboth near- and long-term actions. For the near-tern@ gns will be posted indicatingt hat thisarea was used to manage hazardous materials.In additio~ existing SRS access controls will beused to rnaintain the use of this site forindustrial use Oil@.

In the long-te~ if the property is evertransferred to non-federal ownership, the U.S.Government would create a deed for the newproperty owner in compliance with Section120(h) of CERCLA. The deed would includenotification disclosing former DBRP wastemanagement and disposal activities, results fromgroundwater monitoring and remedial actionstaken on the site. The deed notification wouldin perpetuity, not.i& any potential purchaser thatthe property has been used for the managementand disposal of non-hazardous, inertconstruction debris, and that wastes containinghazardous substances, such as degreasers and

Record of Decision fm the D-AI= JMmiII@ubblc Pita (431 D and 43 1-ID)Savannah River SiteFebruary 1997

WSRGRP-96-S67Revision 1

Page 17 of29

solven@ were also mmaged ~ d burned on thesite.

The deed would also include deed restrictionsprecluding residential use of the property.However, the need for these deed restrictionscould be reevaluated at the time of transfer inthe event that c o n ~ “ o n no longer poses anunacceptable risk under residential use.

In additio~ if the site is ever transferred to non-ftieral ownership, a survey plat of the area willbe p r e - certified by a professional landsumyor, and recorded with the appropriatecounty recording agency.

There are no construction costs associated withthis alternative. The cost for surveying the landand filing with the Barnwell County Records isestimated to be $2,000. If five year reviews ofremedy are requir~ the estimated present valuefor these reviews over the next 30 years ii$8,000. The total present value costs forAlternative 2 are $10,000. Additionalgroundwater monitoring and reporting costswould total about $12,000 annually, these costsmay not continue indefhitely and are notincluded in the total cost ustyi for comparison.

With essentially no further action except for themodest cost of deed notifications and restrictionsupon transfer of the lan~ and five ye& reviews,under Alternative 2 Ixist.itutional Controls, risksattributable to future workers at the DBRPwould be 1. 0X 10~.

Atiern&”ve j " N&gve Soil Cover (47 .

A four foot thick cover of native soil would beinstalled over the present surfkce of the IIBRP toreduce the likelihood that Mum excavation forconstruction of a typical basement would exposewaste or contaminated soil. If the property isever transferred to private ownership, incompliance with CERCLA 120(h), the U. S.Government would create a deed withnotifications and restrictions similar to thoseidentified in Alternative 2. Future deedrestrictions on excavation below four f=t wouldbe necessary to prevent potential exposure offiture workers or residents to buried wastewhich may contain low concentrations ofhazardous constituents.

The preparation of a Remedial Design/RemedialAction Work Plan wotid cost $50,000. Theconstruction costs associated with thisalternative are estimated at $160,000 for theinstallation of a four foot thick native soil coder.The cost for sumeying the land and filing withthe Barnwell Counly Records is @imated to be$2,000. Maintewce costs for 30 years areestimated at $15,000. If five year reviews wouldbe requir@ the e@ima&d present value forthese reviews over the next 30 years is $8,000.Total present value costs for this alternative aestimated at $235,000.

With deed restrictions upon the transfer of theland to non-f~ral ownership per Section120(h) of CERCL& the risk to Mum workersand possible fiture residents would be reducedto less than 1.0 x 10X. The need for the deedrestrictions would be reevaluated prior totransfer.

Atiern&”ve 4 Thermal DesorptiotiIncineration

Under this alternative, the upper two fmt ofcontaminated soil would be excavated fortreatment to eliminate the PCB-1260, BaP, andOCDD. The soil would be fed through a high~mperature rotaxy kiln to ext.qct the volatiledrganic contaminantts horn the soil. Theextmcted gases would then be destroyed in theincinerator. The treated soil would be &urnedto the site and vegetation would be established tdprevent erosion. If the property is &ertransferred to p~vate ownership, in compliancewith CERCLA 120(h), the U. S. Gove~entwould create a deed with notifications andrestrictions similar to those identified inAlternative 2. Future deed restrictions (upon- e r of the land to non-federal ownership) onexcavation below two feet would be neceswuy toprevent potential exposure of fiture workers orresidents to buried waste which may contain lowlevels of hazardous constituents. The need forthese deed restrictions could be reevaluated atthe time of transfer in the event thatcontamination no longer poses an unacceptablerisk under residential use.

Preparation of the Remedial Design/RemedialAction Work Plan to implement this alternativewould cost $150,000. A National Emission

Record of Decision fm tbe D Area Bumkg/Rubble Pits (431 D and 431-lD)Savannah River s i t eFebruary 1997

WSRGRP-96-867Revisioa 1

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Standards for Hamdous Air Pollutants permitwould be required at a cost of $150,000 becauseof the potential fm atmospheric releases duringremediation. The treatment cost for thisalternative would be $1,500,000 and the deedrestriction on excavation below two fmt wouldcost $2,000 for a total cost of $1,502,000.

This alternative is protective of human health andwould permanently reduce risk to less than 1.0 xlO"* for ingestion of soil from PCB-1260 for Mumon-site workers and fiture residents.

Aklern&”ve 5 Off iite Soil Disposal

Under this alternative, the upper two feet ofcontaminated soil would be excavated andtransported to a licensed &site disposal fkility.The excavation would be tilled to grade withclean native soil and cover vegetation would beestablished. If the property is ever transferred tbprivate ownership, the U. S. Government wouldcreate a deed with notifications and restrictionssimilar to those identified in Alternative 2 incompliance with CERCLA 120(h). Thepotential risk for exposure of fbture workers andpossible residents to low concentrations ofhazardous constituents in the remaining wastewould necessitate the filing of a deed restrictionon excavation below two f~t upon the transferof the land to non-federal ownership. The needfor these deed restrictions could be reevaluatedat the time of transfer in the event thatcontamination no longer poses an unacceptablerisk under residential use.

The preparation of a Remedial Desi@RemedialAction Work Plan would cost $150,000. Thecost for excavatio~ pansportatio~ disposal f =and bacldlling would be $932,000. The totalcost for this would be $1,084,000, including$2,000 for recording the deed notifications andrestrictions.

The risk to fiture workers and possible Mu.reresidents would be reduced to less than 1.0 x104 from ingestion of PCB-1260 contaminatedsoil.

VIIL Summmy of Comp-ative Analysis ofthe Alternatives

Description of Nike Evaluation Criteria

Each of the remedial i3.kXIMtiVt3S was evaluatedusing the nine criteria established by the NationalOil and Hazardous Substances Contingency Plan@cP). The criteria were derived from thestatutq 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 andthe environment

• compliance with ARM!@• long-term effiztiveness and permanence,.reduction of toxicity, mobility, or volume

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

In selecting the prefernxi alternative, the abovementioned criteria were used to evaluate thealternatives developed in the D-AreaBumin@ubble Pits (43X-D and 431-ID)Corrective Measures Stu@lRocused FeasibilityStudy ~) (WSRC, 1996b). Seven of the criteriaare used to evaluate all the alternatives, based onhuman health and environmental protectio~ co~and f-ibility issues. The preferred alternative isfhrther evaluated based on the final two criteria:state acceptance and canrmmity acceptance. Briefdescriptions of all nine criteria are given below.

Overall Protection of Human H&lth and theEnvironment - The remedial alternatives areassessd to determine the degree to which eachalternative elirnina~ reduces, or controls threatsto human health and the environment throughtreatmen~ engineering methods, or institutionalcontrols.

Compliance with Atmkable or Relevant andAtmromiate Requirements - ARARs are Federaland state environmental regulations that establishstandards which remedial actions must meet.There are three types of ARM& (1) chemical-

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WSRGRP-96-S67Revision 1

Page 19 of 29

specific, (2) hcation-specific, and (3) action-specific.

Chemical-specific ARARs are usually health- orrisk-based levels or methodologies which whenapplied to unit-spxific ccmditio~ result in theestablishment of, numerical values. Often thesenumerical values are promulgated in Federal orstate regulations.

Location-spedc ARARs 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 hazmdoussubstances or unit-specific conditions. ~ e s erequirements are triggered by the particularremedial activities that are selected to accomplisha remedy.

The remedial activhies are msessed to determinewhether they attain AILIRs or provide grounds forinvoking one of the five waivers for AW4Rs.These waivers are:

• the remedial action is an interim measureand will become apart of a total remedialaction that will attain the u

• compliance will result in greater risk tohhman health and the enviro~ent thanother alternatives,

• complianu is technically impracticablefrom an engineering perspective,

.the alternative remedial action will attainan equivalent standard of performancethrough use of another method orapproac~

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

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

Lon~-Term Eff’veness and Permanence - Theremedial alternatives are msessed based on theirabilily to maintain reliable protection of humanhealth and the environment after implementation.

Reduction of Toxicitv. Mobility. or VolumeThnmh Treatment - The remedial akematives areassessd based on the degree to which they employtreatment that reduces toxicity (the harmfid natureof the contaminantts), mobility (ability of thecontaminantts to move through the environment),or volume of contaminantts associated with theunit.

S h o r t - T e r m Eff&tiveness - The remedialalternatives are assessed considering fhctorsrelevant to implementation of the remedial actio~including risks to the community duringimplementatio~ impacts on worke~ potentialenvironmental impacts (e.g., air emissions), andthe time until protection is achieved

Inmlementability - The remedial alternatives areawessed by c o n s i d e r i n g the d.ifticulty ofimplementing the alternative including technicalf~ibility, Constructability, reliability oftechnology, ease of undertaking additionalremedial actions (if required), mbnitoiingconsiderations, administrative fdibility(regulatory requirements), and availability ofsetices and materials.

C o s t - The evaluation of remedial alternativesm u s t i n c l u d e ;capital and pper@ona.1 andmaintenance costs. Present value costS areestimated within +50/-30 percent per EPAguidanm. The co& estimates given with eachalternative are p~pared 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 fromthe mtimatm presented herein.

State AcceDtance - In accordance with the FF&the State is required to cmnrnent ordapprove theRFI/RI RepoK the Baseline Risk Assessment theCorrective Measures Studyllkhsibility Study, andthe Statement of Basis/Proposed Plan.

community AUDWNX - The communityacceptance of the preferred alternative is msessed

Record of Decision fm &e D Area Bumin@ubble Pits (431 D and 431-lD)Savannah Riva SiteFebruary 1997

WSRC-RP-96-S67Revkktl 1

Page 20 of 29

by giving the public an opportunity to comment onthe remedy selection process. A public commentperiod was held and public comments concerningthe proposed remedy are addressed in theResponsiveness Summary of this Record ofDecision.

De&ailed Evaluation

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

DC The Selected Remedy

Based on the B ~ the DBRP unit soil poses arisk of 1.0 x 104 for fbture workerx in anindustrial land use scenario via ingestion of thesoil in the top 2 fwt layer. Analysis of the riskevaluation indicated that calculated risks tofhture workem and r e s iden t s unde r theinhalation and ingestion of groundwaterpathway were exaggerated because ofconsavative assumptions in the modeling. Theprobable condition is that the DBRP source unitis not contributing to groundwatercontamination. As a resul~ no remedial actionfor the groundwater with a period of continuedmoni tor ing for conthmation is the onlyappropriate action.

Institutional Controls (Alternative 2) for theDBRP Source Unit and no remedial action forthe groundwater with a period of cdhmatoxygroundwater monitoring is the preferred actionat the DBRP because:1) the groundwater history at the DBRP

( ~ in Section V) indicates lowfrequency of occurrences at lowconcentrations of gross alpha and totalr a d i ~

2) the DBRP soils do not represent a crediblethreat to the quality of groundwater in thefiture.

A plan for continued annual groundwatermonitoring, during the second quarter of eachcalendar year, for the five wells at the DBRPwill be included in the post-ROD documen~ theCorrective Measures Implementation/ RemedialAction Report (CMI/RAR). The groundwatersamples will be analyzed for following proposedlist of constituents many of which have not been

detected in the groundwater at the DBRP sincemonitoring began in 1983.

arsenicbenzenebenzo(a)anthracenebenzo(a)pyrenebenzo(b)fluoranthenebenzo(k)fluoranthenechromiumChrysenel,2dichloroethanedichloromethaneendrinmanganeseOctachlorodibenzo-pdioxinPCB-1260total radium1,1,2-trichloroethanetritium

The CMI/RAR will contain a detai ledmonitoring strategy which will outline thesubmittal schedule and contents of themonitoring reports, which will include ananalysis of the dam a conclusio~ and arecommendation. The recommendation sectionof the CMI/RAR will provide for appropriatechanges to the monitoring program withSCDHEC and EPA concurrence.

Alternative 1 No ction

iin

I3s

TJ W M

i l l\ Uvcral Frdccu Comp

Human Health and ARARsthe Environment

No actions taken.Will not reduce rulesfrom those reportedin the BRA

Comp

PCB-1260 exceedsthe TBB guidancel.Omg/igforresidential use.• Compliance withaction-jptcificARARs

No «ctjon taken. Notapplicable.

• Complianct withlocationsptcijicARARi

The site u inconq)liaoce with alllocation-specificTBCi.• Complianct withothtr criteria.athriaorits, andgvldanctNo action taken. Notapplicable.

Long-tcim RcUuutiouurffectivenesi Tojdcity, Mobility, or

MagTii jrtsidual risk

Riika within EPArisk range 1 X 10"* to1 x 10*. HK1.

• Adtquacyandreliability ofcontrols

Not applicable.

- ..—tm.... l,roct33ystd and mattriaUtrtattd

No treatment used.

• Amount ofhatardous materialsdestroyed or treated

None destroyed orIj-cated.

• Dtgrte ofexpected reductionin toxidty, mobility,and volumeNo reduction intoxicity, mobility, orvolume.

• Degree to whichtreatment isnrvtrsible

Not applicable.

• Type and quantityofruidualsrvmatning aftertreatmentNot applicable.Nothing i i changed

on Required N is ase

Short*termEffectiveness

- Protection MJcommunity duringremedial actions

Not applicable. Noremediationperformed.

• Protection ofworkers duringremedial action

Not applicable Noremediationperformed.• Environmentalimpacts

None.

• Time untilremedial actionobjectives areachievedNot applicable.

• Contaminants

PCB-lKOnotreduced

compan (IB

Imp ementab

* /lowly toconstruct andoperate thetechnologyNot applicable. Noaction taken.

• Reliability of thetechnology

Not applicable. Notechnology applied

• Ease ofundertakingadditional remedialaction, If necessaryVery easy.

• Ability to monitoreffectiveness of theremedy

Easy to monitor.

• Coordination withand ability Inobtaining approvalsfrom other agenciesNot applicable. Noaction taken.• Availability ofnecessary equipmentand specialists andoff-iit* servicesNot applicable. Noaction taken. '• Availability ofprospectivetechnologiesNot applicable. Noacti— taken.

Coat

• capital costs

None.

• Operating andmaintenance costs

None.

be cons dered gu dance

tate Acceptance

• Features ofth*alternative the stalesupports

None.

• Features of thealternative aboutwhich the state hasreservationsNot applicable.

• Elements of thealternative the statestrongly opposes

Not applicable. Thestate has concurredwith InstitutionalControls.

Acceptance

• Features of thealternative the 'community supports

None.

• Features of thealternative aboutwhich the communityhas reservationsNot applicable.

* Elements of thealternative thecommunity stronglyopposesNot applicable. Theijininimtty «ii] A" •**

Institutional Controls.

(D

—

I.©'

5Si5'n

©'sea.n

ow8nI5'

if

a

Institutional-Canted"

Chuall Pmtcction ofHutmn Health mdthe EnVimomcnt

• P?vtidfunes.s

Exceeds TBCs forfdture m3idcnIs cnly.Precludes residentialUsC of this prupaly.

Gm7pliana withARARs

. Complim

DBRP mmpliu withidxtrid TBcguidanct 10-2smgfcg..Compliance withaction-specificARARs

No ~ c n takcm N&qplicablc.

• Compliarm w“t.hlocalion-qwclj$cARARs

The sit4 is inmmplinna with dlocasion-spdcguidmce.

• Complkvm w“thother cn”t8n”4

advisories andg’midam

No actkn tdcrn Notapplioabla

sdascd (Ycsn+o): Yes

Long-termEffectiveness

.Magnitude ofrrsidual rid

Ovudl risk is l x104, HI is 0.03.

.Adequacy andreliability ofmntrols

Dud restrictionswill p w r l t fiullrcruidcntid use.

Rdwtion ofToxic i ty , Mobility,orvolume

• Trvatnwnt pmccssused andmaturiahtreated

No trcdmcnt Usd

»Amount ofhazardous materiakdestroyed or treated

Nonc dcstqcd ortrcdcd.

.Degree ofccptcted rmhctionIn &axJ”@, mobility,and volumeNo reduction intoxicity, mobili~, orvolume,

. D*P* to whichtiatnwntisrtversibU

Not applicable.

.3>jxand quantityof residual.?r8mafnlng qlertr8atmcntAll Cdmin8ntsremain.

Short-termBffdvenus

. Pratmtion ofcommunity duringrunwdial action$

Not rqplicabk. Noremediationperformed.

• PnX8ction ofwoken &ringrumedial action

Not applicable. NoRmdiatimperformed• &witvnmentalimpacts

Nooe.

• TYme untilrcmdial actionobjectives artachkwdNot @kable.

• Conhnninants

PcB-1260notreduced.

Implcmcntability

. Abfli~ toCvrutrmct andoperate tnetcchnobgyNot appkdbk Noacticn hkca

.Reliability of thetechnology

Not q@icablo. Notechnology rqplicd

• Bare ofundwtakhgadditional remedialactio~ (f mms.raryvery easy.

. Abfffy (o monitoreffectiveness qfthtrtme~

toy to mdor.

• (kwdhation withand ablliy inobtaining approvalsj%om other agcnckN o t cpplicabla. Noactial taken

.Availability ofnOWaty qdpmentand specialists andoff-site servicesN o t qplicabla Norlctirm tllkcn..Availability ofprospectivet8chnolo@Not q@icablo, Noactkn tdccn.

c n t

, Cupital &xtr

I#w.

.Operating andmaintenam cwts

Low.

State A a x p k x

. Featnrus of tinalternative the statesupports

R & below 1 x 1 0 4 .

.Features of t.kalttmaOve aboutwhich h stab hasr8.T*WatfonsState supportsImti lut iod CQIltmls

. BUments of thealternative t?n Sw#strongly opposes

Sme SuppatsImtittuiontll CQntxols.

CommunityAcceptance

.Features of thealtirnatiw tk6Vmmnrdp Xupports

Risks b c h 1 x104 ,

.Features of thealtm!attw aboutwhich tk cvmmnniyhat rm8rvadonsCommunity supportsImtitutionfll CQKmd.$.

, Eknwnts of tialternative thecommnnip stronglyOppo!m$Community supportsIostitllliond CQntmls.

Rationale: 14w ccd alternative. Complies with CAB rcccnnmcndation fm future industrialuse of the land MARs arc met(TIM - To bc comi

CO

i5

a,

I1"

Alternative 3 Native Soil Cover f4*1

Human Health and ARAR5the Envircnrnent

^WULIJW JJi

Risl; below lxlO"1.

—e«cd w es^M,. .v

Will meet PCBTBCguidance formiilcntial 1 mgfcg.

» Compliance withaction-specificARARs

Must meet CAArequirements for dustcontrol.

• Compliance withlocation-specificARARs

None applicable.

• Compliance withother criteria.advisories, andguidanceMust comply withOSHA.

Ton^tcnnEffectiveness

Mag . ,residual risk

Risk remainhowever 4' layerwould allow shallowexcavation.* Adequacy andreliability ofcontrols

Reliable unlessdeed restrictions ondeep excavation «renot enforced.

Reduction ofToodcity, Mobility, orV-lUtM

used and materialstreated

No treatment used

• Amount ofhazardous materialsdestroyed or treated

None destroyed ortreated

• Degree ofexpected reductionin toxtdty, mobility,and volumeNo reduction intoxicity or volume.dust and leaching togroundwitet reduced• Degree to whichtreatment itreversiblm

Cover is completelyreversible.• Typt and quantityof residualsremaining aftertreatmentAll contaminantsisniftini

horMennEffectiveness

- PrOimwut/n ojcommunity duringremedial actions

No risk to communitywhile cover isinstalled

• Protection ofworken duringremedial action

Minor risk to workersduring installationdue to heavyequipment snd dust• EnvironmentalImpacts

Potential impacti toenvironment fiomheavy equipment anddust• Tim* untilremedial actionobjectives areachievedCover can beinstalled in < 1 year.• Contaminants

PCB-1260 remains,but cover provides tbarrier to exposure.

• — t o d ""to" "»'•<•

lmp-ementabiliv

• jioiaiymconstruct andoperate thetechnologyEasy to install cover.

• Reliability of thetechnology

Cover can bebreached Maybedifficult to preventdeep excavation.• East ofundertakingadditional remedialaction, if necessaryEasy, additional "remediation mayrequire removal ofcover..• Ability to monitoreffectiveness of theremedy

Easy to monitoreziecttYcness.• Coordination withend ability inobtaining approvalsfrom other agenciesRelatively easy toobtain approval forinstalling cover.• Availability ofnecessary equipmentand specialists andoff-tit* servicesEasily available.• Availability ofprospectivetechnologiesReadily av»i1»h

tate Acceptance

* Capital costs

Low.

• Operating andmaintenance costs

Low. Inspection andmaintenance will berequired

• Features of thealternative the statesupports

Low cost, toil coverprovides barrier.

• Features cf thealternative aboutwhich the state hasreservations

* Elements of thealternative the statestrongly opposes

None.

Acceptance

• Features of thealternative the 'community supports

Low cost, soil coverprovides barrier. CABjecuiiiuf udffd futureindustrial use.• Ftatures of thealternative aboutwhich the communityhas reservations

future industrial use.

• Elements of thealternative thecommunity stronglyopposesNone.

in

iBSi

n

e

o

*n

ino

no

ea.n

jo8

ff(0

p

S»tiv

n

23"

a&a.

Mtemaii w-A . I h a s ? «J-De«sasSio»iflcc< wraivnr

2vu!lll FnX4Xtion of-iuman Health mdis EkVimnmalt

, Prote&V6 n6ss

OfTen completepraaxion of humenhc.Akh and theenvironment.

CcmplilLmX withARARa

• Compliana

Wti meet FCB TBCfcx ruidential we 1mg/kg.

• Comphanm rn”thadon-speaj?cARARs

Must meet CAArequirements for dust

d ofr-gas anmol.

• Compli~ w hloca tlon-spe dficARARs

None applicable.

• Comphkncu withather cnlerf4a&krie.$ andgnidanuMust cuq.dy withOSHA

Sclccd (YdNo): Y a

LQng-tumEffectiveness

• Magnitude ofresidual rUk

Remaining risk * ^bc bclow 1 x 104.

•Adequacy andrziiabilify ofmntrols

Reliable u n kdeed rutrictions ondeep C’xcavation alnot enforad

Reduction ofToxioity, Mobility, orvolume

. Truatnwnt pnxussKMI and matdahtreated

PcBs will bedcstmyd

. Amount ofhaxardans materiahdu.ttrqwd or truatud

PcBswillbedestroyed.

• Degree ofexpected reductionin toxic7”@ mobilip,and wlumeVirtuauy complete.

^Degree to whichtreatmunt isreverjible

kVcrsiile.

• Type and quantityof rusiduakrwnaining aflertreatmentNone.

Ibtionale: AMFU are met Would allow

Short-termEffectiveness

. protection ofmmmnnip dutingrumudial actions

CUmmunity will bcprotected rrumoff-gu and dust byengineering contxols.. Pmtuction ofworkers duringremedial action

Mamgcable lisk toWolkcrs duc tacquipmc@ Off-gEs,

and dust• Bwkonmdntalimpoctf

Potcotid implwtS toenvironment uomequipment, gas, anddust. ZYme unfilmmudial actionobj6ctiv6s areachievedCan be ccunplated in<lyollr.• Contaminants

FCB-1260 deStro@

Implementability

. Ability locvnstnIct andop6mt8 th8technologyImplementable.

^Reliability of thetechnology

VUy fcliable.

• Ease ofundertakingadditional remedialactiofi f nucuearyEasy, no additionalremediation shouldbc quired.

. Abiliy fo monitor~ectivunuss # theremedy

Buy to monitaerrectrveness.• Combination withand &lip inobtaining apprwahJ?om othur agendusAir pcrmits rqukcd.•Availability ofn6C8.tSary equipmentand apuciakts andoffdte s6micussomewhat limited.• Availability ofprospectivetechnologiesSOmcwhrlt limited,

Cost

• Capital crxtx

High.

• Operating andmaintenanm carts

H @ Sukqucntmaintenance will notb equired.

State Acceptance

. Featnrat of thealtmnattw the Stat6support?

CompleteKancdiation

• F6atnres of theakrnativu abmltwhich the stats harusurvatioruNone

• Elemunti of the(altumadVe the SW6stmng~ opposes

Nom.

Acceptance

. Featnrus of thedtmmath the 'mnnnlniy Jnpport.r

CUnplctcremcdxaQon. *

• Fuatnms of thealternative aboutwhich the ammnniyhas rusuwa$om

future inftntrial use.High cost fcr slightrisk reduction.• Elements of thealternative thecomnnmify StrongyopposesNone,

f.hture residential usc of pmpcrty with restrictions on excavation below 2 f - (l”X - To b coomidcred

arnp3. So 5

Akernativc 5 Of&ilsoil

Ovcmll Prot&xion ofHuman Health andthe EaVimnmCn.t

• Proiec&vtntss

Offers completeprotectiCQ of hunvtotxMh. md theenvironment.

soil Disposal

Cou!pliana withARAFU

• Compiiatxx

Will meet PCBTBCgllidmcc fmresidential use, 1mgfcg.• Compiiamu rn’thaction-spedfi cARARt

Must mat C.AARquiruncnts fca dustccatroL

9 V Compliance rn”thiocution-qwa~cARARt

None applicable.

• Compliance rn”thother critedaadvisories, andgnidanrNMix! Comlply withOSHA

Sdcckd (YCdNo): Y

Lung-turnEffectiveness

• Magm”tnde ofm.ridual risk

Rcmhi.ng risk willbe below 1x 104,

• Adequ~ andnliabilip ofCvntrol!r

Reliable tmlcss&Xd Kutaictims ondeep excavation «renot cnflolud.

Rahlction ofToxicity, Mobility, orvolume

• Treatment pressused and matdaktreated

Pm contaminatedSOil will bc mmovcd.

. Amonntqfhazardaw matetiakdesbvyed or treated

PCB contaminatedSoil will be removcd8nd r@nced withclean m• Degree ofexpected reductionjn tadcity, mobility.and wlumeViltlldly c o m p l *PCB u rernowd

«£VjnM t o whichtreatment hrtvtmbU

Irrewsibla

• Z)ge and qnanti~oftwidna,brtmcArdng aftertreatmentNone.

Ra!bnak: ARAIU arc met Would tdlof

Short-tamKfTecUve&ess

• Proktion 4camnnfni~ dxtingrvme&21 actions

Cannnmity will bcprotected from dustby engineeringcootrola., Pmtecdon ofwrkent dudngremedial action

Manageable risk t owaters due toequipment and dust

. Environmentalmpocts

Potential impacts toenvironment fromCquipmult and dust. 7Ym4 untilrvmedial aciionobftcttvuanachiewdCan. be completed mSix months., Contwninants

PCB-1260 removed

Implcmcntability

. Abiliy taconstruct andoperate ihetOchnokqyImplcmcntabla

.R€tiabitityofthttechnology

v a y rcliablc.

• SVu* ofundertakingadditional mnedialactioh fneces.raryEasy, no bdditkalrcmcdiatian shouldbe quired,»Abilip M monitorflktberwm of the

rtmtdy

E4uy to monitorenecttvcDCSs,• Coordination Wthand abili~ {nobtaining approwzl.rfrom other agencie.sDOT ItguhAions..Availability ofnOce.uaty % quipmentand rpecialiatx andoffsitt ttrvtctsReadily lvailable,. Awfiab{li@ ofprosptcttvttechnotogitiRcaddy “wailablc.

CQst

• Capital costs

Kgh.

• Operating andmaintenanm costs

High. fhlbqwltmain-cc will notbc requkd.

ixture residential uso of prqxrty with rutrictions on Cxcdvation t*

Ute Acceptance

. Featnrw #thealternatiw the statssupports

completeremediation.

, Features of theOzternative aboutwhich tk xtate &xreserwltiomNone.

, Elements of thealtmultive h Xtat4strongfy opposes

None.

iw2feet (TBC-1

Acceptance

• Feahwws @ thealkmattve theComnnlniiy Suppm

completeremediation.

• Featnw # thealternative aboutwhich b comnwniyh rusenution.tC A B pM*j**i'irii^iyvri

future industrial me.High @utfar alightnsx reduction• Z7@ments # theal&marlVe thecommunity stronglyoppoSe.SNone

x considerMf)

n55

Record of Decision for the D Area Burning/Rubble Pita (431 D and431 -lD)Savannah River SiteFebruary 1997

WSRC RP96 867Revision 1

Page 26 of29

Implementation of this alternative will requireboth near- and long-term actions. For the near-terq signs will be posted indicating that thisarea was used to manage hazardous materials.In additio~ existing SRS access controls will beused to maintain the use of this site forindustrial use OIlly.

In the long-terrq if the property is evertransferred to non-federal ownership, the U.S.Government will create a deed for the newproperty owner in compliance with Section120(h) of CERCLA. The deed will includenotification disclosing former wastemanagement and disposal activiti~ results fromgroundwater monitoring, and remedial actionstaken on the site. The deed notification will, inperpetuity, notify any potential purchaser thatthe property has been used for the managementand disposal of non-hazardous, inertconstruction debris, and that wastes containinghazardous substances, such as degreasers an’dsolven@ were also managed and burned on thesite.

The deed will also include deed restrictionsprecluding residential use of the property.However, the need for these deed restrictionscould be reevaluated at the time of transfer inthe event that contamination no longer poses anunacceptable risk under residential use.

In additio~ if the site is ever transferred to non-fderal ownership, a suwey plat of the area willbe prepar~ certified by a professional landsumeyor, and recorded with the appropriateCQunty recording agency.

The Institutional Controls Alternative isintend&1 to be the final action for the DBRPSource Unit. The solution is intended to bepermanent and effective in both the long andnear terms. This alternative is considered to bethe least cost option which is still protective ofhuman health and the environment.

The SCDHEC has modifkd the SRS RCRA&mnit to incorporate the selected remedy.

This proposal is consistent with EPA guidanceand is an efkct.ive use of risk managementprinciples.

X. Statutory Determinations

Based on the DBRP RFI/RI Report and theB Q the DBRP source operable unit poses nosignificant risk to the environment and minimalrisk to human health. Therefore, adetermination has been made that InstitutionalControls are sufficiently protective of humanhealth and the environment for the remainingcontamination in the DBRP soils andgroundwater.

The selected remedy is protective of humanhealth and the environment complies withFederal and State of South Carolinarequirements that are legally applicable orrelevant and appropriate to the remedial actio~and is cost-effective. The random distributionand low levels of contamination preclude aremedy in which treatment is a practicalalternative. Institutional Controls will result inhazardous substances, pollutants, orcontaminants remaining in the waste 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 (i)(4)(ii) of the NCP requiresthat a five-year review of the ROD be petiormedif hazardous substances, pollutants, orcontaminant ts remain in t.he waste unit. Thethree Parties, DOE, SCDHEC, and EPA havedetermined that a Five Year Review of the RODfor the DBRP will be pefiormed to ensurecontinued protection of human health and theenvironment.

XL Explanation of Significant Changes

The Statement of Basis/Proposed Plan and thedraft RCRA permit modification provided forinvolvement with the community through adocument review process and a public commentperiod. A public meeting was advertised and heldon October 15. Comments that were receivedduring the 45day public comment period(September 17 through October 31, 19%) areaddressed in Appendix A of this Record ofDecision and are available with the final RCRApermit.

Record of Decision fix the D Area Burning/Rubble Pits (431 D and431 -lD) WSRC-RP-96-867Savannah River Site Revision 1February 1997 Page 27 of 29

The only changes to the remedy proposed for theDBRP in the Statement of Basi@roposed Plan(WSRC, ‘1996c) "are: (1) that the probablecondition is that no significant groundwatercontamination is originating in the DBRP and noremedial action for the groundwater with a periodof continued monitoring for confirmation of noleaching to groundwater is the only appropriateactio~ and (2) it was determined that it was notappropriate to append the continued groundwatermonitoring plan to the ROD as proposed in theStatement of Basis/Proposed Plan. The plan forcontinued groundwater monitoring will beincluded in the CMX/RAR In the event that theprobable condition is no longer appropriate, DOEwill evaluate the need for remedial action.

XBL Responsiveness Summary

There were three comments received during thepublic comment period. The ResponsiveriessSummary (see Appendix A) of this Record ofDecision addresses these comments.

XIIL Post-ROD Document Schedule

The post-ROD document schedule is listedbelow and is illustrated in Figure 4:

1. Corrective Measures Implementation/Remedial Action Report (CMI/MR)Revision O for the DBRP will be submittedfor EPA and SCDHEC review four monthsafter issuance of the ROD.

2. EPA and SCDHEC review of the DBRPCMURAR Revision O will last 90 days.

3. SRS revision of the DBRP CMI/RARRevision O will be completed in 60 daysafter receipt of all regulatory comments.

4. EPA and SCDHEC final review andapproval of the DBRP CMURAR Revision 1will last 30 days.

ACTIVITYDESCRIPTION

ORIGDUR -1 1 2 | 3 4 5

MONTHS( 7 1 <1 9 10

—11 | 12

EPA/SCDHEC ROD ISSUANCE

CORRECTIVE MEASURES IMP./REMEDIAL ACTION REPORTO

DEVELOP CMI/RAR

SRS SUBMITTAL OF REV.O CMI/RAR

EPA/SCDHEC REVIEW 90

SRS INCORPORATE EPA/SCHDEC COMMENTS 60

SRS SUBMITTAL OF REV.l CMI/RAR

EPS/SCHDEC FINAL REVIEW S APPROVAL

EPA/SCDHEC APPROVAL

J

o

CO

or

Oo

3o

a>

Plot Date 4FE397Data Date 1OCT96Project Start 1OCT96Project Finish 27JUL97

c) Prinavera Systems, Inc.

ENVIRONMENTAL RESTORATIOND-AREA BRP

POST ROD IMPLEMENTATION SCHEDULE

Date Revision Checked Approved

Record ofDeciaionfmthe D Area Bum&/Rubble Pita (431 D and 431 ID)Savannah River SiteFebruary 1997

WSRGRP-96-867Revision 1

Page 29 of 29

xxv. REFERENCES

DOE (U: S. De@rtment of Energy), 1994.Pub[ic Involvement A Plan for SavannahRiver Site. Savannah River OperationsOflice, Aikcq south Carolina (1994).

DOE, 1996. Savannah River Site Future UseProject Report, StakeholderRecommendations for MS Land andFacilities W). Savannah River OperationsOffice, lli.lce~ South Carolina (January1996).

EPA 1990. (U. S. Environmental ProtectionAgency). A Guide on Remedial Actions atSuperfund Sites with PCB Contamination.OEiee of Emergency and RemedialResponse. Directive 9355.4-01 FS (August1990).

EPA 1995. Supplemental Guidance to RAGS:Region 4 Bulletins; Development of Risk-Based Remedial Optionq 13uman EkalthRisk Assessment Bulletin No. 5 (November1995).

Federal Facility Agreement 1993. FederalFacility Agreement for the Shvannah RiverSite, Administrative Do&et No. 8945-IT,(E&et&e Date: August 16, 1993).

WSRC (Westinghouse Savannah RiverCompany), 1994. Data Summary Report forthe D-Area Burninglltubble Pits. WSRC-RP-94-709, Rev. O, Westinghouse Savannah

River Company, Aike~ South Carolina(1994).

WSRC, 1995a. Baseline Risk Assessment forthe D-Area Burnin#?ublde Pi@ (TJ).WSRC-TR-94-708, REV. 1, WestinghouseSavannah River Company, Aikeu SouthCarolina (1995).

WSRC, 1995b. REM?? Report for D-AreaBurnin@?ubble Pits (431-D and 431-lD)(tJ. WSRC-RP-94-707, Rev. 1,Westinghouse Savannah River Company,Aike~ South Carolina (1995).

WSRC, 1996a. F-Area Burnin@ubb!e Pits(231-E 231-1~ and 231-2F) CorrectiveMeasures Stu@ZFeasibility Stu@ ~).WSRC-RP-95-660, Rev. 1, WestinghouseSavannah River Company, lli.lce~ South@OliIla (March 1996).

WSRC, 1996b. D-Area Burnin@lubble Pits(431-D and431-lD) Corrective MeasuresStudy@ocused Feasibility Stu+ V).WSRC-RP-95-904, Rev. 1, WestinghouseSavannah River Company, Aike% SouthtiOliXla (March 1996).

W S R C , 1996c. Slatement of BasisZi+oposedPlan for the ~Area BumingA?ubble Pits(43 1-D and 431-ID) ~). WSRC-RP-95-905, Rev. 1.3, Westinghouse SavannahRiver Company, Aike~ South Carolina(August 1996).

Record of DecisionRemedial Alternative Selection for the

D-Area Burning/Rubble Pits (431-D and 431-lD)(U)

WSRC-RP-96-867Revision 1

February 1997

Appendix AResponsiveness Summary

The 45day public comment period for the Statement of Basis/Proposed Plan for the D-AreaBurning/Rubble Pits (43 1-D and 431-lD) (U) began on September 17, 1996 and ended on October 31,1996. A public meeting was held on October 15, 1996. Specific comments and responses are found

below. The comments are italicized and the responses are bolded

Public Meetinfl Comments

The following comments were received during the Limited Action Proposed Plans/Permit Modificationspresentations. These comments were taken from the October 15, 1996 Public Meeting as recorded in theSavannah River Site Information Exchange transcript.

Comment 1: Public Citizen: "JJ%at risk is there for animals or I guess future environmental, lib ifyou were going to turn this into a park?"

Response to Comment 1: As a part of the baseline risk assessment process for the DBRP, anecological risk assessment was conducted to assess the potential impacts to biotacaused by exposure to chemical and radiological constituents at the DBRP. A siteecological reconnaissance survey was conducted in April 1994. No stressedvegetation was observed on or around the DBRP. No threatened and endangeredspecies were observed in the vicinity of the DBRP or the adjacent ephemeralstream.

Based on the ecological risk assessmen~ there is little or no risk of adverseecological effects from the DBRP. Therefore, if the unit is turned into a park in thefuture, the animal and plant species would not be affected.

Record of Deciaion fbr the D Area Bum&/Rubble MS (431 D and431-lD) WSRGRP-96-867Responaivenesa Summary = 2 ASavannah River Site Revision 1Februaiy 1997 Page A 2 of 3

Comment 2: Public Citizen: "Are you using like private land~lls and private - or I guess what otherc%mrnunities have developed? I mean it looti Iikz a hnd]ll to me. And it looks likethere are landfills all over the country and there's a whole lot of landfills that havebeen turned into like parks and stufi Is that an opportunity here to turn it into a parkor to use private models and maybe look at who has done this a lot? I guess the EPAguy was talking about streamlining. Are you guys using private streamlining ideas?"

Response to Comment 2: There is a proposal for the entire Savannah River Site (SRS) tobecome a national research park at some time in the future Even now, the SRS is anational environmental research park and as such, the site is/will be used forenvironmental research For the institutional control uni~ the only thing that ourremedial decision has done is to state that on this waste unit there will not be anyresidential use

Due to its location, approximately 0.7 mile from the Savannah River and theabsence of remarkable scenery, the DBRP would be unlikely to become arecreational sik The risk levels for the soils alone barely exceed the threshold forresidential use; the presence of buried waste should not interfere with the use of theDBRP as a park. However, there is groundwater contamination at the DBRP thatcould preclude use of the lo@ shallow groundwater as a source of drinking water.Groundwater risk modeling indicates that there are constituents present whichcould exceed primary drinking water standards in the future

It should also be noted that the use of the DBRP as an environmental research orrecreational park would be evaluated at the time of property transfer if ownershipof the land is ever transferred from the Federal government DBRP is one of thefirst buminghubble pits at SRS to be evaluated and will contribute to a streamlinedprocess for characterization, technology evaluation, and determining likelyresponse actions at subsequent burninghbble pits.

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

Comment 3: Mil& Rourak: My name is Mike Rourak and my question is directed to Mr. BrianHennesseyk earlier discussion (unintelligible) Silverton Roadproperty, for example. Inthe Future Usc Manual that was sent out to some of us about the disposal of close to amillion acres of property for DOE, in your deed restrictions there's things that wecannot do. And we Ye going to need a litt!e bit before we can respond back toWashington. l%ose of us who received the manual, we almost are going to need to knowwhat those deed restrictions are because if we cannot have a subdivision then there's noneed to bid the price accordingly or say that's what we want to use it for. If we cannotgraze cattle here like we do in Tennessee at (unintelligible) or something or grow cropsbecause we cannot put a well in for contamination, then we are Iefi with only looking atit for the pine trees.

So being federal, you own this property, Even with deed restrictions you 've got to giveus either a Phase I, IL or III audit. In this case, it's the seller who has to provide thisliability, not necessarily the buyer's neglect of liability to due diligence. & it wouldreally help af we knew what deed restrictions would be there to a more extent and alsowhat we can use the land for. If I want to use it for applying 50- under the Code ofFederal Regulations 503, lf’ I want to use it for bio solid disposal, can I do so? Becauseit's adjacent to your other property. So the deed restrictions that you brought up wereof immense concern about responding back to the future use and the disposal of roughly

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Record of Decision fm the Ik4rea Bumin@uMIe pits (431 D and 431 ID) WSRGRP-96-S67Responsiveness Sununmy = : ; ASavannah River Site Revision 1February 1997 Page A 3 of 3

849,000 acres nationwide for - to be put back into -I understand #om Wmhington,they would like to put it back mainly into public use to get the taxes o~ of it. Maybe notso for the government, but for the local entities who lose the tax base. Xhank you.

Response to Comment 3: The SRS Future Uke hojed Report was distributed to informcitizens of the planned future uses of the S W The recommendations that werepresented in the report may change over time and will be discussed with thestakeholders. Deed restrictions for federal property are not determined until theland is transferred to non-federal controL At the time of property transfer, theneed for deed restrictions will be evaluated. Due to natural attenuation, decay, etc.,the conditions at spe&c areas may not warrant any deed restrictions. All legalrequirements will be met at the time of property transfer.