ACTION - Fluor Idaho · TRA TSA TSF U.S. DOE U.S. EPA WAG WAG 1 WAG 2 WAG 3 VVACJ 4 WAG 5 WAG 6 WAG 7 WAG 8 WAG 9 WAG 10 ..I. n WRRTF Test Reactor Arm - Transuranic Storage Area -

ACTION PLAN TABLE OF CONTENTS

Acronyms

1.0 Introduction

1. I Action Plan Goal

1.2 CERCLA Philosophy/Strategy

1.3 CERCLA Integration with Other Programs

2.0 CERCLA Process

2.1

2.2

2.3

2.4

2.5

2.6

2.7

2.8

2.4

2-10

2.11

2.12

2.13

2.14

CERCLA Pmcess Overview

!nitia! OpeX&!e unit screening

Preliminary Scoping Track 1


Interim Acdon Planning

RIFFS Scoping Prucess

RIPS Implementation

Decision Process

ROD Schedule

Post-ROD Process

-.-, R n l R -.. A - -- c r ~ p i ~ g P ~ Q ~ P ~ c

Remedial Design Process

Remedial Action Process

Operation and Maintenance

3.0 WAG Concept and Descriptions

3.1 WAG 1

3.2 WAG 2

3.3 WAG3

v

1

1

1

2

3

3

5

5

8

8

8

15

15

:s 20

20

21

22

23

24

26

26

23

. . . 111

4.0

5.0

3.4 WAG4

3.5 WAG 5

3.6 WAG6

3.7 WAG 7

3.8 WAG 8

3.9 WAG 9

3.10 WAG 10

3.1 I Eiiiikiiig ‘iV~ter Actions

Project Management

4.1

4.2 Lead Agency Concept

4.3 Project Managers’ Meeting

4.4 Recommended Training and Qualifications

Data Quality Objectives and Risk Assessment

Project Manager Roles and Responsibilities

Appendix A

Enforceable Deadlines, Operable Units and CERCLA Process Tracks, and Schedule

Appendix B

No Further Action Determination

Appendix C

Preliminary Scoping Track 2 Summary Report Outline

A - - - . - . > : . . n AppcllulA u

Project Managcr Designations

27

27

28

28

28

29

29

29

31

31

31

32

32

33

A- 1

B- I

c- I

D- 1

This document has been reprinted. Page numbers do not conform to original.

iv

AEA

A N L W

ANP

ARA

ATR

BORAX

BRA

CERCLA

CFA

COCA

CSM

D&D

DOD

DQO

EBR-I

Em-!!

H&SP

HWMA

IA

ICPP

IDH W

IET

INEL

LCCDA

LEU

ACRONYMS

Atomic Energy Act

Argonne National Laboratory - West

Aircraft Nuclear Propulsion

Auxiliary Reactor Area

Advanced Test Reactor

Boiling Water Reactor Experiment

Base!ine Rlsk Assessment,

Comprehensive Environmental Response, Compensation and Liability Act

Central Facilities Area

Consent Order and Compliance Agreement

Conceptual Site Model

Decontamination and Decommissioning

Department of Defense

Data Quality Objective

Experimental Breeder Reactor-I

Exper;,r?lenta! Breeder Re2ctnr-I!

Health and Safety Plan

Hazardous Waste Management Act

Interim Action

Idaho Chemical Processing Plant

Idaho Department of Health and Welfare

Initial Engineering Test Facility

Idaho National Engineering Laboratory

Liquid Corrosive Chemical Disposal Area

Lg& L)&nnwl I Tnit r--- -----

V

LOFT

NCP

NEPA

NODA

NRF

O&M Plan

Gt'

PBF

PREPP

QAPjP

QAPP

RCRA

RD/RA

RI/FS

ROD

m-nrxrmmfl n vv NIL

SAP

SDA

SMC

sow SPERT

SRPA

SWEPP

SWMU

'PA Z I T 1 - 1 1

- Loss of Fluid Test Facility

- National Oil and Hazardous Substances Pollution Contingency Plan (National Contingency Plan)

- National Environmental Policy Act

- Naval Ordnance Disposal Area

- Naval Reactor Facility

- Operation and Maintenance Plan

- wpc'nulc u1111

- Power Burst Facility

- Process Experimental Pilot Plant

- Quality Assurance Project Plan

A-..--Ll- 11-:+

- Quality Assurance Program Plan

- Resource Conservation and Recovery Act

- Remedial Desigmemedial Action

- Remedial Investigationfieasibility Study

- Sampling and Analysis Plan

- Subsurface Disposal Area

- Specific Manufacturing Capability

- Statement of Work

- Special Power Excursion Reactor Test

- Snake River Plain Aquifer

- Stored Waste Examination Pilot Plant

- Solid Waste Management Unit

- Test Axii N G r t h

vi

TRA

TSA

TSF

U.S. DOE

U.S. EPA

WAG

WAG 1

WAG 2

WAG 3

V V A C J 4

WAG 5

WAG 6

WAG 7

WAG 8

WAG 9

WAG 10

..I . n

WRRTF

Test Reactor Arm

- Transuranic Storage Area

- Test Support Facility

- United States Department of Energy

- United States Environmental Protection Agency

- Waste Area Group

- Waste Area Group 1 - Test Area North (TAN)

- Waste Area Group 2 - Test Reactor Area (TRA)

Waste Area Group 3 - Idaho Chemical Processing Plant (ICPP) -

- IT wasit: I

-

Area G,u-up 4 - eei-,iPizl Facilities Area ( C + q

Waste Area Group 5 - Power Burst Facility (PBF)/AuxiIlary Reactor Area (ARA)

Waste Area Group 6 - Experimental Breeder Reactor No. I (EBR-I) -

- Waste Area Group 7 - Radioactive Waste Management Complex (RWMC)

Waste Area Group 8 - Naval Reactor Facility (NRF)

Waste Area Group 9 - Argonne NationaI Laboratory - West (ANGW)

-

-

- Waste Area Croup 10 - MiscelIaneous surface sites and liquid disposal areas thrntIghnut the IN’ET, that are not included within other WAGS

- Water Reactor Research Test Facility

vii

1 .O INTRODUCTION

This Action Plan implements the Idaho National Engineering Laboratory (INEL) Federal Facility Agree- ment and Consent Order (FFA/CO), hereafter referred to as “the Agreement.”

1,l Action Plan Goal

U.S. Department of Energy (U.S. DOE), U.S. Environmental Protection Agency (U.S. EPA), and Idaho Department of Health and Welfare (IDHW) have a common goal to ensure that releases or threatened releases of hazardous substances at the INEL are thoroughly investigated in accordance with the National Contingency Plan (NCP) and that appropriate response actions are undertaken and completed as necessary to protect human health and the environmenl.

The purposes of the Agreement are to:

0 Esrabiish a procedurai lrarriework arid bciiedcile for developing, piioiitizifig, i ~ p l c - meriting, and monitoring appropriate response actions at the INEL in accordance with the Comprehensive Environmental Response, Compensation and Liability Act

(CERCLA), Resource Conservation and Recovery Act (RCRA), and Idaho Hazardous Waste Management Act (HWMA)

Facilitate cooperation, exchange of information, and participation of the Parties in such i lCi iu i lS

Minimize duplication of analyses and documentation

Supersede the existing RCRA 3008(h) Consent Order and Compliance Agreement (COCA] executed on Juiy io, i987

I .2 CERCLA PhilosophylStrategy

CjZR(“i&s impieIiie,,tj,ig regulation, ;he p=cp, has 2 &*t..: -- CA+ fi,+:fi- ” A h m n A n m a n t ~ l rrnol nf rnnnerat;iiP via3 IVL ac.uvii. r x I U I I U U I I W L I ~ ~ ~ ”. y~,yyu.uLL..-.

efforts by U.S. DOE, U.S. EPA, and IDHW in implementing this Agreement is that remedial action be emphasized. This goal recognizes that no reasonable amount of investigation can resolve all uncertainty and that once remedial actions are initiated they must be able to accommodate deviations from original hypotheses. This approach encourages timely remedy selection, flexibility for remedial action, and con- tingencies to respond to new information discovered during investigations.

a Interim actions under the NCP will be used to proceed quickly with cleanup.

Site characterization will be planned on the basis of optimizing field sampling and

maximizing use of available data.

Treatability studies will proceed promptly to establish technologies that are appropriate for restoration of complex units.

I .3 CERCLA Integration with Other Programs

I .3.1 Transition From RCRA to CERCLA

The Agreement to which this Action Plan is attached supersedes the INEL COCA. This effectively moves the investigation and cleanup of reieases at the IN'Ei from a RCRA to a CERCi,A process. Ai- though data gathered and planning accomplished to date are of future value in the CERCLA process, requirements pursuant to the COCA cease al thc time of the Agreement's execution.

All waste management units identified for consideration under the COCA are accounted for in the transition to the Agreement. In some instances, this is accomplished by simply identifying those COCA units that will receive no further consideration under the new Agreement. Evaluation of existing data does not indicate a basis ror potentiai risk for these units. Consensus was rcaciicd by iiiz Parties io the kgi-eeiiieni

regarding the No Action designation. Many 0 1 these units were already approved under terms of the COCA for deletion from further consideration. Descriptions of units in this category, including the rationale for the No Action determinations, will be in the INEL Administrative Record and wil1 support the

appropriate Record of Decision (ROD) for each Waste Area Group (WAG). All units not in this category were assigned to operable units (OUs) within the CERCLA process described in this Action Plan.

r n l . I niny Larid Dispowi Uiiitb <iDUsj weie ibeiiiifid under the CGCA. AI1 30 iifthcx LEU$ will !X evz- luated under this Agreement, Units retaining the RCRA LDU designation will be remediated under the

CERCLA process in accordance with the appiicable substantive requirements of RCRAmWMA, if an unacceptable risk to human hcalth or the environment is demonstrated.

1.3.2 Integration with Other Programs

Re teases or threatened releases of hazardous substances under regulatory programs that require investigation and study for cleanup are addressed under this Action Plan.

2

2.0 CKRCLA PROCESS

This section describes the process that will be followed in implementing this Action Plan and applying the CERCLA process, as defined in the NCP, to the remedial effort at the INEL. The process is presented in -1 I . P P ; P L . ,\f f l ~ ~ s r r-harti x x , ; * h e u c n r i a t d nnnpvip time linpc. /F;immnrec 3 I thmiinh 7 '2) qnrl thp hripf nrrrrrrti\ip u L 7 G L l G . 7 "1 11\11" W - l l U I L L , " " 1 b 1 1 Y .,., " C . Y L U U B""""" L....U L . L . Y . , ,A 'b"'"' l.I """"b" b.d, U L L W C.." "I.". . * U . . U C . . I

descriptions below. Each flow chart identifies the primary and secondary documents associated with the process or "track" shown in the llow chart. Schedules, including enforceable deadlines, based on applica- tion of this process are shown in Appendix A as Figure A. Deadlines for primary documents derived from those schedules arc in Table A. 1 , Appendix A. Specific target dates for the completion of secondary documents will be established during the deveIopment of Scopes of Work, Schedules and deadlines may bc extended for good cause pursuant to Part XI11 of the Agreement.

2.1 CERCLA Process Overview

Figure 2.1 presents a general overview of the process that will be used to achieve appropriate remedial action decisions for tine various operabie units at the WEi. Consistent wiih h e "bias fur action" phiioso- phy, the Action Plan encourages and provides the necessary flexibility to reach an early determination on

an OU when there is sufficient information. The determination may be that no further action is necessary, that an interim action is appropriate: or that the OU should proceed through the Remedial Investigation/

Feasibility Study (RI/FS) process to a final action. This flexibility is supported by establishing generic "tracks" allowing consistency between the scope and duration of investigations and complexity of associated documentation, and between the scope and complexity of the problems being addressed. The process to reach expeditious decisions is depicted in Figure 2.1 by showing that an interim action OU can be broken off from any track and proceed directly to the Interim Action track and then to the Decision or ROD process at any time during the process when there is adequate information to support such a decision. T i e process aiso provides Project ivianagers with the fiexibiiity io prioriiizt: work arid ciIgiiriiae o i i s

in a manner which will achieve the most benefit with available funds.

Under this process, each potential source area at the INEL is categorized into an Operable Unit group and for investigation or remedial activities. Actions are performed as necessary to abate heaIth or environ-

mental concerns in accordance with the NCP. Those Operable Units which are determined to pose a significant but acceptable risk and have the potential to contribute to the overall cumulative risk are (jeslgriaied fur; fUi:[iier evai.uailoii* Tiie conai&raiiorr a soiirce zrea'j: c o i i ~ T ~ ~ u ~ ; o n to cumiip&tivz ii3k will be evaluated under an appropriate RIPS risk assessment.

The following subsections describe the individual generic tracks.

3

UNIVERSr' OF SWMUs & P O r n 7 7 A L L Y HAZARDOUS

(FIG. 2.2) 1 /NIDAL ou SCREENING 1

(FIG. 2.6) t

,/ INFO \ REMEDY

ADEQUATE ro SELECT -

(FlG. 2.3)

EXIST BUT NEED REWEW

I / N

BEEN S H O W TO

P REUM. SCOPING fKACK 2

[ RI/FS SCOPING k _I WORK PLAN

DEVELOPMENT I (RG. Z B ) I I 7- I

Figure 2.1 CERCLA Process Overview.

4

2.2 Initial Operable Unit Screening

The initial OU screening activity was conducted bcfore the Agreement approval and, therefore, does not

include a time line. The screening process is depicted in Figure 2.2. During this activity, individual Solid Waste Management Units (S WMUs) or potentially hazardous sites were identified for each WAG.

The extent of existing information and information gaps was identified sufficiently to assign the unit to the appropriate track. A No Further Action Determination was made only if there was no justification to further address the unit. Justification was based on the determination that no hazardous substances were released, or that an approved summary assessment existed under the COCA and there was no evidence of radiological contamination. If a clear No Further Action Determination could not be made, the unit was assigned to an interim action track or designated for further investigalion. Ail No Further Action Deter- minations are subject to review at the time of issuance of the next appropriate ROD.

lntcrim action OUs were established only on the basis that the action would prevent exposure, would control risk, would be consistent with the expected final remedy, and was of sufficient priority to justify an immediate commitment of resources.

Following assignment to the appropriate track, potentially hazardous sites were combined on a WAG basis into OUs in keeping with the NCP definition of an OW as a discrete action that constitutes an incre- mental step toward comprehensively addressing site problems. Table A.2, Appendix A, identifies the OUs and presents the tracks on which each OU will be managed. Table A.2 also shows the units that received a No Further Action Determination during initial OU screening. On the basis of new information developed during the CERCLA process, the Project Managers may move potentially hazardous sites between OUs and may add or reorganize OUs to create new ones.

2.3 Preliminarv Scouine. Track 1

The Preliminary Scoping Track 1 process is appropriate for OUs that probably will not require further c'.arperizati..fi as '1 !yWiS fer 2 +Cif=iQfl fer "" fsdlllr &-n* T-wk 1 plliPf= zre by +fi:ixi"n

sioned to be evaluations of existing data. If the data evaluation requires more than minimal field charac terization, the OU site should be in a Track 2 study (see Section 2.4).

As shown in Figure 2.3, the potentiai outcomes of a Track i study are proceeding to a iu'o Further Action Determination, a Track 2 study, an interim action, or the RIPS scoping process. These latter three tracks would be recommended if the data and qualitative risk evaluations identify unanticipated contamination cy flwcceptgb!e risk pgtpntia!.

Track 1 investigations supporting No Further Action Determinations are presented to the Project Manag- ers on a quarterly basis during Project Managers' meetings. The Project Managers sign the No Further Action Determination and it is piaced in the o'u' Administrative Record. An exampie of a ii'o Further Ac-

5

UNIERSE OF SWUs & PO E N 77AU Y HAZARDOUS

I

\ / I PO E N 77A L 1

lNITlAL ASSESSMENT SCURE IS *Oa

V EXf OSURE I EVALUA77ON

c I Y

D E E L O P

UST OF O U s FOR REMEDY POENTlAL FOR PREFIM. ~~ ~

N I N

Figure 2.2 Initial OU Screening.

!

. ACTION >

DETERMlNATlON ,/

6

COLLECT/COMP/LE PUi 77NENT

EVALUATE DATAANFO. I

EVALUATE RlSK POTENPAL I 1

i lNFO

REMEDY SELECTION

i i DEVELOP SUMMARY DEVELOP SUMMARY DNELOP SUMMARY DEMLOP SUMMAR) INFORMAnON W M lNFORMAnON WTH lNFORMA7lON WK4 lNFORMA77ON WTH

RECOMMEND. TO RECOMMEND. TO RECOMMEND. TO NO FURTHER PROCEED TO R l / . PROCEED TO PROCEED TO LA. ACnON

SCOPING TRACK 2 PROCESS RECOMMENDA n O N i

L 7 - L PROJECT MANAGER

NU FURTHER ACTON

DETERMINATION

Flgure 2.3 Preliminary Scoping Track 1.

7

lion Determination is shown in Appendix B. The Project Managcrs evaluate the recommendaticns to pro-

ceed to Track 2, interim action, or RI/FS scoping and the Agreement is modified as appropriate under Part XXX to reflect thc recommendations.

2.4 Preliminary Scoping Track 2

Preliminary Scoping Track 2, shown in Figure 2.4, is appropriate for OUs that require field data collec-

tion before a decision can be made for No Further Action or interim action of the unit. Because the Track 2 is designed for field data collection, sufficient time (1 8 months) is allowed to develop the needed planning documentation and to conduct the field investigation and laboratory analyses (Figure 2.5). Track 2

begins with the development of a Scope of Work (SOW) that summarizes scope, schedule, and deliverables. Track 2 studies end with the development of a Scoping Summary Report. A generic outiine of this report is included as Appendix C.

Track 2 investigations could result in the OU proceeding to RIPS scoping if a No Further Action or interim action decision is not justified by the data collected during Track 2 investigations.

Track 2 may also consist of the integrated demonstration of innovative technologies that represent poten- ria! !NE!. remediation processes. In this case, a Work Plan in lieu of a Sampling and Analysis Plan (SAP) would be developed. A summary report on the evaluation of the demonstration will be prepared. Both the Work Plan and the summary report would have secondary document status. The information generated in this type of Track 2 would support future interim action decisions or the evaluation of the technol-

ogy during RIPS implementation.

2.5 Interim Action Planning

An interim action is undertaken to eliminate, reduce, or control hazards posed by a site or to expedite completion of total site cleanup. The interim action plannjng process may be initiated any time the data wi II provide sufficient justification and when the Project Managers agree that immediate action is appro- y1 IdLC. - -_ .. . -

An SOW initiates the interim action process (see Figure 2.6). Data are compiled, qualitative risk findings are established, and appropriate technologies arc reviewed during a 5-month period (see Figure 2.7). This information is used to develop a proposed plan that initiates the decision process.

2.6 RIPS Scoping Process

'I'he KI/FS scoping process, as described in the K'CP ana in ihe CEkCLA RiiFS Guiduricr (OCioliei 1488, Interim Final), is basically the planning process for the RI/FS, beginning with development and approval of an SOW and culminating in the preparation and approval of the RI/FS Work Plan and other associated p!anning drrcun!en!s (see Figure 2 8 ) : A 10-month time period is provided for this effort. Figure 2.9 pro-

vides a general time line for the tasks involved.

8

SCHEDULE

-

- COKECT DATAANFO. - EVALUAE DATA/NFO. - EVALUATE EXPOSURE POTENTIAL I

PROJECT MANAGER MEETING

NO FURTHER

- 7 l - l DEVEL & SUBMlT DEVEL & SUBM/T

i DEVEL k SUBMfT SUMMARY REPORT wm NO mRmm

. ACT7ON RECOMMENDA TON

!

REVIEW k COMMENT

1

BY END OF I TMONW

I I

B r END OF ~ E M O N T H

BY €NU O f ' m 6- MONTH

BY EN5 OF 16B MONTH

p q T E r ) ACTION PROCESS

* SECONDARY DOCUMENT

Flgure 2.4 Preliminary Scoping Track 2.

9

r F i r

P

B -. 9 a c

* a a 2 W 3

a.

x

10

SCHEDULE

t.

*I DEVELOP k SUBMIT DRAFT SCOPE O f WORK (212 PAGES)

I

I- R E W W k COMMENT

DELELOP k SUBMIT PROPOSED PLAN I '

R E W M DA TAANFO. W / C H JusnnEs

I O E E L O P QUAU TA TILE

REWEW AVAILABLE PROKN

PROPOSED PLAN

BY END OF 2 9 MONTH

3RD MONJ" i

BY €NO OF

BY END OF 5 9THMONT-i

I

i DEClSlO N PROCESS

** SECONDARY DOCUMENT

Figure 2.6 Interim Action Planning Process.

11

I

i

1 7

12

SCHEDULE

DEVELOP dr SVBMlT

* I DEMtOP & SUBMIT RIFS WORK PLAN - HEALTH dr S A E M PLAN** (NOTE 7) - COMMUNITY RELATIONS PLAN (NOTE 2) - RATA MANAGEMENT PLAN - SAMPUNG & ANALYSIS PLAN - CONCEPTUAL S I E MODEL

I REVIEW & REWSION I

BY END OF' 7 X M O N T H

BY E N D OF 6 z M O N T H

1 1

BY END OF 9 2 M O N W

I DOCUMENT BECOMES RNAL

NO7E 1: THE HEALTN & S A W PLAN IS A SECONDARY DOCUMENT.

NOTE 2: THE WORK PLAN WItl fNCLURE A SUPPLEMENT TO THE l N a WE-WIDE COMMUNITY RELAnONS PLAN (CRP)

Figure 2.8 RIPS Scoping Process.

13

h- n e Y

a" 0 -L w > w

Y P a : : o

L 0

Y 0.

U Ln a

a i e. , , , . . L Y

The SOW referenced in Figure 2.8 contains a general description of the activities that wiIl occur during

the implementation of the RIPS. I t also provides adequate information about the scope of the investigation to allow Project Managers to estimatc costs and amend established deadlines as neccssary.

Figures 2.10 and 2. I 1 show a generic flow chart and time line for R I P S implementation. The process l'ollows the standard CERCLA RIPS process and is estimated to take 20 months for completion. Treat- abiiity studies shouid be inciudeci in the RIFS process as needed.

2.8 Decision Process

The decision process, shown in Figure 2.12 with a generic time line in Figure 2.13, is initiated when there is adequate information to select an interim or final remedy for an OU. The decision process is initiated with the submittal by U.S. DOE of the draft proposed plan for review. The OU Administrative Record is

updated as necessary throughout the process to ensure that it includes all documentation pertinent to the remedial action decision. All public review and comment periods, responsiveness summaries, and other mechanics of the decision process follow the NCP, U.S. EPA guidance, and the INEL Community Rela- tions Plan. Within 6 months of submittal of the proposed plan for lead and support agency review, the u .a. uuc shouid submit the draft ROD fur iead and support agency review. I ne drafi ROD iiicn pro-

ceeds through the normal review and comment incorporation cycle of a primary document. When the ROD is signed, the decision process is complete. If the ROD requires remedial action, the Remedial De- sign and Remedial Action Work Plan are developed after ROD completion to define the schedules for

completion of remedial design and remedial action.

I, cl n - r - m.

Interim actions are preliminary by nature. All interim actions must be followed by a final decision and cllnnnrtfd ""YY"' .-- by a risk .ssP,ssment to eva!uate the residua! risks ta hnm2n he.!th and the envirnnrr?ent. IE

most cases, the comprehensive RI/FS for each WAG will provide the vehicle for the decision.

2.9 ROD Schedule

Figurc A and Table A. 1 (Appendix A) provide the schedules for all INEL OU RODS. These schedules will be refined through prioritization occurring during Project Manager meetings (see Section 4.0, Project Management) and will be based on new technical information and budget availability. Enforceable dead- iines are inciuded in the scheduies. Tie criticai-path scheduie is based on the foiiowing conditions:

Submittal of the last RIPS report for all facility-specific WAGs (WAGs 1-9) will be prior to submittal of the draft RIFS Work Plan for the last "blanketing" RI/FS for WAG 10.

Submittal of the last Track 2 Summary Report for each WAG will be prior to submittal of the last RIPS SOW for that WAG.

All Track 1 reviews for each WAG will be completed prior to the submittal of the last Track 2 SAP for that WAG.

15

RI/?3 WORK PLAN IS READY FOR IMPLEMEN TA TlDN

I

DEVELOP & SUBMIT DRAFT RI REPORT wlm BASEUNE

SVBMlT RIFS REPORT

I REMEW k REWSION I

DOCUMENT BECOMES FlNAL

D E M l O P k SUBMIT DRAFT PROPOSED P U N

TO DEClSlON PROCESS

N O E I: IF ME N E D FOR ADDITIONAL 7R€ATABIUT( STUDES OR INKSl7CAnONS ARE DlSCOVERED DURING lMPLEMwTATION, ADDlTlONAL SCOPE MAY BE KELT TG A SLWiQt’Eiv’T n”i/FS FGR ir O:rFEREh‘T GU. A PMSE :I iNvEsncAnoN MAY BE ~ N ~ ~ A T E D , OR uus MAY BE REDEYELOPED.

Figure 2.1 0 RI/FS Implementation.

16

i

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v1 w l - I t m u

Y mu. H L

.- r n

m LL -. H a t

1 I

17

REGULATORY REWfW OF

8

INCORPORAE COMMENTS & SUBMIT DRAFT FINAL ROD

I

* PRIMARY DOCUMENT

** SECONDARY DOCUMENT

Flgure 2.1 2 Decision Process,

BY END OF 2 MONTHS

BY END OF 6 MONTHS

BY 7-1/2 MONTHS

1

BY END OF 9 MONTHS

BY END OF 70 MONMS

18

n e e w L)

0

n - o P

n a " H

W 0

E w I 1 0 0

z 2 J m

2.10 Post-ROD Process

A general process and documentation are necessary to implement RODS at the INEL. Post-ROD activities include the Remedial Design (RD) and Remedial Action (RA) phases. The RD/RA process will be sireamiined, to the extent possible, EO meet the CERCLA requirement to commence substantial continu- ous physical on-site remedial action within 15 months of issuance of a ROD.

2.1 I RD/RA Scoping Process

Part 12.2 of the Agreement states that U.S. DOE will, within 21 days of issuance of the ROD, propose target dates and deadlines for completion of post-ROD documents. This requirement will be met for the RD phase through the submittal of an RD/RA SOW. The R D F A SOW will establish deadlines for sub-

mitta1 of two primary documents required by Part VI11 of the Agreement, the Remedial Design and the RA Work Plan. The RD/RA SOW establishes the overall strategy for managing the RD/RA and, therefore, applies to all phases and remedial work elements. The RD/RA SOW will include, at a minimum, the foiiowing:

Strategy for RD/RA and rationale for remedial work element breakout

- critical path schedule for the RD/RA process through RA work element com- mencement

funding needs and funding availability for RD/RA

brief description of the scope of each remedial work element

- I

I plans to expedite RDmA

e Description of issues that remain to be resolved or that require further analysis

Identification of elements of the Community Relations Plan that will be implemented during RD/RA

Because it is not possible to define a single set of secondary documents that will be useful in all cases, the R D B A SOW will establish the secondary documents associated with the RD phase and the target submit- ,al uuLcil 1 u 1

following primary remedial design document, recognizing that RD secondary documents represent incre- mental steps toward completing the Remedial Design.

, . t I ,lr.tnr. Fnr A,b,.h D n n #----*-e.. ~ - - ~ ...- -- ,.-,.--A n n ~ : X I 1.. ... .. . l x v u . L - U M M W L ~ ~G;C.L;V& UII X L W I I U ~ I ~ nu uocuiiiciiih wiii UG ~ir~orporaieu tnio ihc

For complex remedies, the Project Managers may determine that RD/RA will be best accomplished by

dividing the KD and the RA processes into smaller, more manageable remedial work elements. A remedial work eleincnt is a portion of a project that has becn broken out through phasing. The crtteria lor nhnuinp r--- '*--ci m:ly he [he ~\j~j!&j!i:y of existing Infsrrr,skion, type =f wa:,te, type :>f rr,ed:a ir,v=!~ed, !c&n;;logy

requircmenth, and/or funding availability. Although the Agreement identifies the Remedial Design and

thc RA Work Plan as separate primary documents, the Project Managers may choose to comhinc these

20

documents into ii single primary document. In this instance, elements of the RA Work Plan will be incorporated into the Remedial Design.

To streamline the RD/RA process, the RD/RA SOW is not defined as a primary or secondary document in [he Agreement. I ne iead ana support agencies wiiI have 30 days after submittai to invoke dispute resolution regarding its content. However, all three Project Managers intend to participate in the development of the RD/RA SOW. Given the 21-day timeframe for submittal of the RD/RA SOW, it will be a brief document (10 to 15 pages, mostly figure< and tshlei;)

2.12 Remedial Design Process

In most cases, the Remedial Design phase will be initiated with the development of the RD Work Plan. a secondary document. For simple remedies, a separate RD Work Plan may not be necessary and the typi- cal elements of the RD Work Plan could be incorporated into the RD/RA SOW. For complex remedies, a separate RD Work Plan may be developed for each identified work element. The RD Work Plan will include:

Scope of preliminary and/or draft design documents

0 Cost estimate for the RD phase

0 Requirements for correlations between plans and specifications

b Identification of substantive permit requirements [see Part V11 C: of the Agreement)

W Identification and schedules for the preparation of other design elements (e.g., Addi- tional Required Studies, Operation and Maintenance (O&M) Plan, Quality Assurance

Project Plan (QAPjP), Site Health and Safety (H&S) Plan)

Design approval procedures and requirements.

Given the critical nature of the RD, it will be necessary to provide the agencies with early design documents to ensure that consensus is maintained. This will be accomplished through the submittal of secondary design documents. In general, at least one secondary design document, the Preliminary Design, will UT buwl l l tLt ;u . I I I ~ rieiiiikumy u~sigri wiii iypiLdiiy icyrest.rri JWO coriipieiioii of p h i s iild spccirica- tions. If available, preliminary results of any additional required studies may be included.

L,. - . . L - ! + & - A ‘PI. l”L. l:-: n--:-- ‘ 1 % ~ - . - ‘ - - l l . ._._ . - - - . - L ?Am

The Remedial Design will include:

Plans and specifications for remedial action inchding design analysis and construction drawings and specifications

W Cost estimate for remedial action

b O&M Plan

21

QAPjP

Site H&S Plan

Resuits of additionai required studies, if any.

The Draft RD (Prefinal Design) will include all aspects of the design and be essentially complete. It will be considered representative of approximately 90% design completion. The final 10% of the design will include the resolution of comments on the Draft RD and preparation of reproducible construction drawings and specifications ready for bid advertisement. These changes and additions will be included in the Draft Final RD, which is the 100% design.

2. t 3 Remedial Action Process

The RA Work Plan will incorporate, by reference, pertinent aspects of the RD Work Plan. It will

Specify any relevant changes in the content of the RD Work Plan arising from the design effort

e Update aad expmd upm schedr;!es i:: :he RE Vibrk Plan by ificlubing bztes fiii the Sub-

mittal of primary and secondary documents for that remedial work element

Update and expand upon the cost estimate for RA in the RD and

0 Identify additional RA secondary documents

The remedial action process includes the preparation of at least one primary and one secondary document. I ne Prefinai Inspection Report wiii be a secondary document that wiii include: 7.73

I Outstanding construction requirements

Completion date and

The prefinal inspection will be conducted by the Project Managers, at a minimum, and possibly by an independent fourth party. DOE will prepare the Prefinal Inspection Report. Although DOE will respond to comments received, the Prefinal Inspection Report will not be revised but, rather, will be finalized in the

context of the primary RA Report. To the extent possible, RA Reports for individual work elements will be consolidated into a single RA Report.

The RA Report will be prepared at the completion of remedial action and will include:

A brief description o t outstanding items from the Prefinal lnspection Report

22

0 Synopsis of work defined in KA Work Plan and certificati.on that this work was

performed

a Explanation of any modifications to the RA Work Plan

e Certification that the remedy is operational and functional; and

b Documentation necessary to support deletion of the site from the NPL, as discussed in Pari XXV ut iile Agreerneni.

2.14 Operation and Maintenance

A t thrl f . ~ , m n l P t ; n m -f 1 7 . Q y h A o,.t;xr:t:-p th- rid-hc r l r ; l l nv-m.lr_ GlwA ~3mmh-:t I 3 R . h R Rnmfi..t tn th- E D A ~ I L LIIL ~ I J I I I [ I I L C I W I I VI w c T i v i u b i i v L C I L ~ , L I L L vvu v v n i i yiuyuik uiiu auui i i i i uii VCXIV'I r x b y u i L LU LIIL bin CUIU

IDHW. To the extent possible, O&M Reports for individual work elements will be consolidated into a single O&M Report. This primary document will include the following elements:

e Description of O&M activities performed

b Results of site monitoring, verifying that the remedy meets the performance criteria and

b Expianation of additionai O&M (including monitoringj to be undertaken at the site

23

3.0 WAC CONCEPT AND DESCRIPTIONS

The INEL is divided into WAGs to facilitate environmental remediation efforts. WAGs 1 through 9 gen- erally correspond to U.S. DOE-INEL operational facilities, while WAG 10 corresponds to overall con- , - o r n o a ~ , c . n n ; n * n A ,,,:th tho Cn*,La D;,.a+. Din;- A n,lifA+. fC'DD.4) ,,*A thA,.A ....&--- - -A .... L.,..,C....-. _-__" --.+ ~ L L L I . ~ U;IJVLIUL~U V V L L I I ~iic u i i u h ~ I \ L V C I i iuiii nquiic.i (onin) wiu LIIVOL isuiiub~. aiiu ~ a u u a u i ~ u ~ b aiLuIs IIUL

included in the bounds of the facility-specific WAGs.

Groundwater quality of the SRPA is a significant concern. The SRPA is a dynamic system that is common to the entire INEL and is not controlled by institutional boundaries. Therefore, treating the regional concerns of the SRPA beneath the INEL as an independent OU within WAG 10 is logical from an environmental restoration viewpoint.

Individual WAGs (1-9), in addition to including all SWMUs and other potentially hazardous units associated with the WAG and the surface area encompassed by them, address subsurface concerns including the vadose zonc, perched aquifers, and the SRPA to the extent those concerns are specific to the WAG and its sources of contamination. -W-AG i U addresses alj regionai SRPA concerns reiated to the iNEL that cannot bc adequately addressed on a WAG-specific basis. In addition, WAG 1 0 includes those surface and subsurface areas not included in the bounds of the facility-specific WAGs. Only under certain circumstanccts, as zgmd hy the Pmject Managers, are regions! aqllifer cancerns zddrPsscd in z specific WAG (1-9).

In addressing WAG-specific aquifer concerns, the individual WAG investigations are not intended to characterize rhe aquifer or exten1 of aquifer conraminarion to grear distances beyond the 'WAG boundary but are intended to obtain adequate information to make WAG-specific remedial action decisions.

As a general rule, WAG (1-9) investigations are intended to be conducted within approximately 1,000 feet of WAG facility fence lines or other recognized administrative boundaries.

Validated data compiled from all WAGs are routinely evaluated by U.S. DOE to determine if potential regional (non- or multiple- WAG-specific) problems have become evident. This activity involves more

than one WAG and is considered to be part of the general administrative management function of the INEL Environmental Restoration Program. As such, it does not have a lead/support agency awxiated with it. Status of this activity is, however, a subject of Project Managers' meetings. If a problem or potential problem is identified, the situation could be considered ab a candidate for interim action, remedial

action under a facility-specific WAG, or remedial action under WAG 10, as determined by the Project Managers.

Ten WAGs are located at the INEL. A separate section describes each WAG; the WAG locations at the INEL are presented in Figure 3.1. The facility-specific WAGs are separated from one another and do not present boundary overlap problems.

24

Figure 3.1 WAG locations at the INEL.

25

3.1 WAG Z

WAG 1 is Tcst Area North (TAN) of the INEL. TAN compasses several subareas:

Technical Support Facility (TSF)

Initial Engine Test (IET) Facility

Loss of Fluid Test (LOFT) Facility

Specific Manufacturing Capabilities (SMC) Facility and

Water Reactor Research Test Facility (WRRTF)

In general, TSF consists of facilities for handIing, storage, examination, and research and development of spent nuclear fuel. The Process Experimental Pilot Plant (PREPP), a facility originally built to determine the capabilities of processing transuranic waste destined for WIPP, is also located here. Potential release

sites addressed under this Agreement include tanks, spills, disposal sites, and wastewater disposal systems (e.g., sumps, tanks, injection well, ponds, and lagoons).

The IET is an abandoned facility north of TSF that has numerous historical uses. IET was designed as a testing location for the nuclear jet engines developed under the Aircraft Nuclear Propulsion (ANP) Pro- gram in the 1950s and early 1960s. The few IET sites being investigated under this Agreement are tanks

still in place, an old injection well, and rubble disposal sites.

LOFT and SMC are contiguous facilities west of TSF that consist of structures built for those two operations and old buildings from the ANP Program. LOFT is a facility constructed for nuclear reactor tests that has been decommissioned. SMC is an active facility manufacturing components for a U.S. Depart- ment of Defense (DOD) non-nuclear weapons system. The sites being investigated include pits, tanks, a wastewater disposal pond, and two small historic spill sites.

WRRTF primarily consists of two buildings southeast of TSF that have housed several non-nuclear tests, mostly for simulating and testing water systems used in reactors. The WRRTF sites being investigated include tanks, wastewater ponds, an injection well, a burn pit, and a sewage lagoon.

The boundary of the TAN WAG includes the TSF, IET, LOFT, SMC, and WRRTF fenced areas. I t also includes the immediate areas outside of the fences where operations associated with these areas may have

taken place. The WAG includes all surface and subsurface areas.

1.2 WAC. 2

WAG 2 is the Test Reactor Area (TRA) that houses extcnsive facilities for studying the effects of radiation on materials, fuels, and equipment, The Advanced Test Reactor (ATR) is currently the only large opeidt;oiiai .wli;iiii TEA i s desigiied io pi.o&uce a iieuii.oii p1.uji if,at aiiows sim.uiation of long- duration radiation effects on materials and fuels. I t produces isotopes used in medicine, research, and industry.

26

TRA sites being investigated under the Agrecmenl include pits, tanks, rubble piles, ponds, cooling towers,

wells, french drains, arid spills, One of the higher priority sites within TRA is a percolation pond that has hcen used for the disposal of radioactively contaminated wastewater.

_. 'I 'he boundary of -W-AG 2 inciudes the area within the TrCA fence and the areas immediately outsiac the

fence where waste operations have taken place. The WAG includes all surface and subsurface areas.

3.3 WAG3

WAG 3 is the Idaho Chemical Processing Plant (ICPP) that houses reprocessing facilities for Government defense and research spent fuel. Facilities at lCPP include spent fuel storage and reprocessing areas, a waste solidification facility and related waste storage bins, remote analytical laboratories, and a coal-fired steam generating plant.

The boundary of WAG 3 includes the area within the ICPP fence and those immediately adjacent areas where waste activities have taken place; i t includes all surface and subsurface areas.

3.4 WAG4

WAG 4 is the Central Facilities Area (CFA) where services for the entire site are headquartered. These services inciude environmentai iaboratories, securi[y, fire prorecrion, medicai faciiiries, cornmunicaiioris

systems, warehouses, a cafeteria, vehicle and equipment pools, bus system, and laundry. The U.S. DOE Radiological and Environmental Sciences Laboratory and U.S. Geological Survey offices are also located here.

CFA sites investigated under the Agreement include historical spills, tanks, landfills, ponds, leach fields, and leach pits.

The boundary of WAG 4 is loosely defined as CFA does not have an enclosing fence. However, many

CFA sites investigated under the Agreement are adjacent to buildings (e .g . , tanks and dry wells). Others, including landfills and a gravel pit adjacent to one of the landfills, are located on the outskirts of CFA. The WAG includes all surface and subsurface areas.

3.5 WAG 5

WAG 5 consists of the Power Burst Facility (PBfi) and Auxiliary Keactor Area (ARA). PBF is iocated in an arca originally constructed for the Special Power Excursion Reactor Tests (SPERT). Four SPERT reactors were built beginning in the late 1950s in a radial array around what is now the PBF control/per-

gone partial or complete decontamination and decommissioning (D&D). The PBF reactor is still operational but is in a standby mode. The ARA consists of four separate groupings of buildings in which

serine! hui!di!?g cm?p!ex. '411 d the SPERT reactors were rcrnnved and the SPER-T fadities hawe ?!ndi-r-

27

various activities have occurred, including the operation of test reactors. All of the ARA reactors werc

removed from the facility and have undergone partial or complete D&D.

PBF/ARA sites investigated under the Agreement include tanks and components of wastewater disposal systems (e.g., evaporation ponds, percolation ponds, leach fieids, pits, and dry weiisj.

The boundary of WAG 5 encompasses the facility locations presently or historically used within the PBF and ARA areas and those immcdiatcly adjacent areas where waste activities may have taken place. The WAG includes all surface and subsurface areas.

3.5 WAG6

WAG 6 consists of the Experimental Breeder Reactor No, I (EBR-I) and Boiling Water Reactor Expcri- ment (BORAX) areas. Both the EBR-I and BORAX areas were originally constructed to house test reactors and were decommissioned. EBR-I is now a National Historic Landmark, open to the public. r J : , d . . L - , . l l . , +I.- Df2D A V ,.--,. L - . . O R -I t:.,- -I:fC ---- t -- , ,r .+, ,+z h,.t fifthn fn,-;1;+;Dt7 ,,,_ A;c.-qmilDA i i i a i v r i c a r i y , LILL IJWIXAA aiLa IIUUJQU I IYL U I I I ~ L ~ - I I C ILUCLU~O, v u c I L L U ~ I J V L u n b I U C . I I I I I - O W - J - Y ~ ~ T L L ~ U I I I I V Y VI

moved and no operations (other than monitoring) take place in the area.

EBR-]/BORAX sites investigated under the Agreement are primarily old tanks, but also include a small spill arca and several liquid and solid waste disposal locations.

The boundary of WAG 6 is directly related to the EBR-I/BORAX facility locations and areas immediate-

ly adjacent to them; it includes all surface and subsurface areas.

3.7 WAG 7

WAG 7 is the Radioactive Waste Management Complex (RWMC) that was established in 1952 and is a controlled arca for disposal of solid radioactive wastes generated in INEL operations. The Stored Wacte

Examination Pilot Plant (SWEPP) is also located at the RWMC and is used for certifying waste destined for shipment to WIPP.

The primary RWMC site being investigated under the Agreement is the Subsurface Disposal Area (SDA) within the RWMC. I t includes numerous pits, trenches, and vaults where radioactive and organic wastes were placed as well as a large pad where waste was placed above grade and covered.

The Transuranic Storage Area (TSA) within the RWMC has been used since the early 1970s for rctriev- able storagc of transuranic waste on carthen-covered pads and in facilities.

_. I hc boundary or -w-AG 7 is cieariy defined as the KWhGC fence, wirh tie SDA as a fenced poriion wiihiri the RWMC. I t includes all surface and subsurface areas.

3.8 WAG 8

WAG 8 is the Naval Reactors Facility (NRF) where prototype reactors are operated for reactor plant de- vclopment and in training of naval officers and enlisted personnel. NRF also supports research and devel-

28

oprnent efforts on reactor materials by preparation and examination of irradiation test specimens and by

examination of expended fuel from naval reactors.

NRF sites investigated under the Agreement include landfills, old spills, wastewatcr disposal systems (e,g., p ~ n d ~ , ditchi-s, hasinsj drainsj and drain fields) and stnr;ige ;ireas.

WAG 8 is primarily the developed area of the NRF site. However, it also includes waste operations that extended or extend outside the NRF developed area, such as the wastewater ditch. All of WAG 8 is with-

tiie uveriiit 7-quare iiiile I"u'Rr' irrc:Udes surfzce aiid su"vui-fzce aieas.

3.9 WAG 9

WAG 9 i s t hc Argnnne National 1-ahoratory - West (ANL-W) that is primarily devoted to the testing of breeder-reactor technology. I t houses the Experimental Breeder Reactor I1 (EBR-II), the first pool-type liquid-metal reactor. In addition to EBR-11, the ANL-W complex has four other reactors and two fuel examination Ihcili ties.

ANL-W sites being investigated under the Agreement include tanks and wastewater handling/disposal

systems such as ditches, ponds, pits, drains, etc.

The boundary of WAG 9 is basically the ANL-W lence; however, operations that extended or extend outside of the fence, such as the wastewater ditch, are included. WAG 9 includes all surface and subsurface areas described above.

3.10 WAG 10

WAG 1 0 includes miscellaneous surface sites and liquid disposal areas throughout the INEL that are not included within other WAGs. WAG I O also includes regional Snake River Plain Aquifer concerns related to INEL that cannot be addressed on a WAG-specific basis. Specific sites currently recognized as part of WAG 10 include:

Organic Moderated Reactor Experiment located between WAGs 4 and 5

Former ordnance areas, including the Naval Ordnance Disposal Area (NODA) located at numerous sites within the INEL

The boundary of WAG 10 is the INEL boundary, or beyond as necessary to encompass real or potential

i!??pzct h!?? !NEL 2ctiuities, and rrny arras within ? h P INEL nnt rnvered hy other WAGS

3.11 Drinking Water Actions

U.S. DOE presently monitors drinking-water wells in and around the INEL in accordance with applicable Federal and State regulations. U.S. DOE will routinely make available the resulting data to Project Man- agers.

29

In addition, within 90 days of the effective date of the Agreement, U.S. DOE will provide to the Project Managers historical monitoring data for lNEL drinking-water systems for which there are potential im- pacw 10 drinking-water quality from hazardous substances released at the INEL. The Project Managers

wil l review ik data and, ai iheii- eiii-iiesi opporiiiiiiiy-, ideiiiify arid agree upon addiiionai moniioring requirements for these systems.

..,.

In cases where drinking water monitoring results exceed promulgated standards, the Project Managers will determine if an alternate source of water is needed and U.S. DOE wiIl provide an alternate source of

water for the affected system(s) as agreed upon under this activity. Any additional actions agreed upon (i.e., interim actions) would bc carried out under other applicable provisions of the Agreement and Action ?!an.

4.0 PROJECT MANAGEMENT

The purpose of this scction is to identify and describe key project management activities and responsibilities that are important in carrying out the terms of the Agreement and Action Plan.

4.1 Project Manager Roles and Responsibilities

As provided in Part VI1 of the Agreement, each Party to the Agreement is represented by a Project Man- ager (see Appendix D). The Project Manager shall:

+ Manage INEL remedial activities for their respective agencies pursuant to the Agree- ment and Action Plan

Serve as primary contacts and coordinators for their respective agencies for purposes of implementing the Agreement and Action Plan

Prioritize work

Coordinate activities of WAG Managers (WMs), who are identified by the Project Managers, as necessary

Approve and sign No Further Action Determinations

+ Evaluate and approve changes to OUs based on investigation findings, and

Prepare monthly progress reports

The roles and responsibilities of the WMs are:

Serve as agency contact for the Project Manager for assigned WAE(s)

Participate in project management meetings as requested by respective Project Managers

4.2 Lead Agency Concept

Although U.S. DOE is the lead agency with respect to implementation of the Agreement, the Parties have agreed to a lead agency approach to minimize duplication of effort and maximize oversight productivity. The lead agency for a specific WAG is responsible for overseeing and coordinating the activities conducted under this Agreement.

The agency that is not the lead agency is designated as the support agency. The support agency will also provide comments to U.S. DOE and will lend support to the lead agency as resources permit.

Designation of lead agency is a joint determination by U.S. EPA and IDHW. The decision on lead designation is based primarily on the resources available to undertake lead responsibilities at that WAG. At the

31

time of exccution of this Agreement, lDHW L, the lead agency at WAG 7 (RWMC) and U.S. EPA is the

lead agency at all other WAGS.

4.3 Project Managers’ Meeting

Project Managers’ meetings are held as described in Part 8.9 of the Agreement or more frequently as needed. These meetings are used to conduct the business necessary to implement the Action Plan. Any agreements or commitments resulting from Project Managers’ meetings are to be signed by all Project Managers as soon as possible after the meeting.

4.4 Recommended Training and Oualifications

To effectively and efficiently implement this Action Plan, appropriate training and qualifications for all Parties’ Project Managers and WMs are necessary. While the following list of training and qualifications is not required or subject to review and approval by any Party, i t is recommended that all Project Manag- ers and WMs have expertise or obtain training on a timely basis in the following Subject areas:

a Agreement and Action Plan

m Project rriariagernent

CERCLA, NCP, RCRA, NEP, I, H ’MA, and the Atomic Energy Act (AEA) as they pertain to this Agreement and Action Plan

Remedial action process

Available remedial action technologies

OSHA Hazardous Waste Operations, per 29 CFR 1910.120

e Basic radiation protection

e Risk assessment

Public participation

32

5.0 DATA QUALITY OBJECTIVES AND RISK ASSESSMENT

The collection and use of appropriate quantities and quality of data to make remedial action decisions are a major consideration in conducting CERCLA investigations. Existing data are used whenever they meet

tional supporting data of higher quality. DQOs are defined as qualitative and quantitative statements that specify the quality of data required to support decisions during the remedial response process. Because decisions under CERCLA are risk- or health-based, DQOs should be developed under the framework of a conceptual site model relating contaminant release to potential exposure routes, contarninant toxicity, and receptors.

n,,+,, n,,,,i;f., nh;an+;l,np /nnn-\ c,,++L- ,I,.,-:~.:-- I--:..- ,,A, -.. -,.- L- ..,. I : A - + - A -..:&L - : - : - - I ..AA: UJV uuiu y u u i i r y W L ~ J ~ ~ L I V L ~ > \ u v w a 1 iw i C ~ I L U ~ L I ~ I I I L I ubiiig iaiauc, VI L ~ I I UG YLIIIUULGU WICII l l l l l i l l l t i l l ~ ~ U U I -

The devP!opmPnt nf DQOs ar?d risk assescment prnced11.a fer the R!,FS precess at INEL wi!! fG!!GW the

guidance found in CERCLA and the NCP, as well as in U.S. EPA guidance documents. Reasonable future-use scenarios will be developed for evaluation purposes in accordance with the latest CERCLA risk assessment guidance. DQOs and risk assessment for the Preliminary Scoping Track 2 defined in this Ac- tion Plan require more detailed discussion because they are not specifically covered in the U.S. EPA guidance documents.

For a Track 2, the following DQO./risk assessment process is applied:

Develop a statement of the problem at the OU.

Identify the possible outcomes of the Track 2 (No Further Action, interim action, RIPS scoping).

Determine the level of acceptable risk for the OU. This is defined in the NCP as in the rmge nf lQ-4 to !k6 fer Individlla! !ifedme cncer risk. Per ~ 0 ~ ~ 2 T c i R O g P , ~ s , a hazard

index of less than I represents acceptable risk.

0

Develop a conceptual model of the OU that identifies probable exposure pathways.

Evaluate attenuation/dilution effects expected between the source and postulated

receptor.

Determine the approximate concentration of the major contaminanif that, it' present, would pose unacceptable risk for a pathway. This requires assumptions regarding the population at risk and their activities, leading to an assumed exposure scenario. Based an the !eve! of acceptab!e risk, the expnsure scen2riq attenuatinnldi!utjnn effects, and

the toxicity of the contaminant, a concentration of the contaminant at the source is calculated for carcinogens and separately for non-carcinogens.

33

i

If risk (R) for a given pathway is R = 1 C,,T, I1

where Ci, = concentration at the receptor, and Ci, = CiAi,

where A; reflects the multiple factors that affect the change in concentration from the source to the receptor,

n A then Ci(ca~c) = - TiAi

e Design the sampling program to include special emphasis on the calculated concentrations of contaminants (Ci!caic!).

e Based on the concentrations of the contaminants determined as a result of the sampling

This is cl!cu!ltei! s e p m t d y fer CarCinGgens a:d nGr,<a:cinGger,s. program, estimate the total risk for major contaminants over the significant pathway(s).

where Po to P, are the pathways and

R, = total risk posed by the OU

If the risk estimate of the assumed exposure scenario is less than the level of acceptable risk for the OU, no further action is required.

This discussion of DQOs for the Track 2 process will be expanded and presented in a supplemental document that, with the approval of the Project Managers, wiIl be applied as site-wide generic guidance. This supplemental document, “Guidance for Assessing Low Probability Hazard Sites at the INEL,” should be

issued by September 1991.

The development of DQOs is different for the Preliminary Scoping Track 1 or the Interim Action Plan- ning Process because neither of these tracks requires data collection. For these two tracks, DQOs should address the criteria for the acceptance of existing data for the decision to be made, which may include val- idation through additional supporting data of higher quality. The risk assessment process for Track 1 will

be informal and will qualitatively assess potential exposure routes, pathways for contaminant migration, toxicity of known or suspected contaminants, and receptor populations. The risk assessment for an interim aciion or a Track 2 wiii aiso be quaiirarive.

At the conclusion of an interim action for which No Further Response action is anticipated, data of sufficient quality will be collected to support a quantitative risk assessment. DQOs will be established for this activity according to the U.S. EPA guidance. The risk assewnent will be completed prior to entering the final decision process for the WAG. The purpose of the risk assessment is to show that the interim action resulted in acceptable risk levels at the site.

34

As with DQOs, risk assessment guidance for the INEL will be expanded and presented in ;i supplemental

document.

35

Appendix A

Enforceable Deadlines,

Operable Units and CERCLA Process Tracks,

and Schedule

A- 1

TABLE A.1. iNEL ENFORCEABLE DEADLINES

vlrc ltTlVITY

VAG 01 Injection U c l t l TAM Drinking Water

Interim Action

Injection Veil/ Drinking Water RI/FS

OPERABLE UNIT

1 -07A

1-078

YAG 02 Perched Water 2-12 TRA R I f FS

Y a m Waste P w d ' 2-10 l n r e r i a Action

WAC 02 Conprehensive 2- 13 R I f F S

WAC 03 WAG 03 Conprchensivs 3- 13 R1/FS

YAG 04 Motor Pooi Pond RI/FS 4-11

teAf i ! !s I!!/F9 &* ?;z CFA

WAC 04 Conprehcrrsive 4- 13 RiiFS

VAG 05 Chmicat Pond Rl/fS 5-10 PW/ARA

PBF Evuporatiar Pond 5- t3 In te r im Action

WAC OS Conprchmsive 5-12 R I / F S

ENFORCEABLE DEADLINE.

D r a f t ROO S w b i t t c d f o r Review

Dra f t Sou S u t n i t t t d for Review Dra f t Uork Plan Subnitred fo r Review Dra f t R I / F S Subnitred f o r Revicv Dra f t ROO Sutinitttd f o r Review

Oreft SX $&it:& f o r k v i = Draf t Uork P i a n Subnitted f o r R e v i t u Draf t RI/FS $ b i t t e d f o r Review Dra f t RQ) Submitted fo r Review

Dra f t SOV Submitted for Review Dra f t R I / F S S u b n i t t e d f o r Rev iw Dra f t ROD Submitted for Review

Dra f t ROD Submitted f o r Review

Dra f t SOU Suhnitted f o r Review Dra f t Uork P lan Subnittcd fo r Rcvicv Dra f t Rl /FS S u b n i t t e d f o r Rev iw Dra f t ROO S u b n r i t t e d for Revieu

Dra f t Sou Submitted fo r Review Dra f t Uork Plan Sutrnitted fo r Review Dra f t R l / f S Sutmitted fo r Revicw Dra f t ROD S u b n i t t e d fo r Review

Dra f t RI/FS Submitted fo r Review D r a f t ROD S u t r n i t t e d f o r Review

5r:ft enu S * i t + d for DPUiPY Draf t Work P l a n Subnitted fo r Review

Dra f t R I f F S S u h n i t t e d f o r Review D r B f t ROO Submitted for Review

Dra f t SOU Subnitted fo r Review

Draft RI/FS Subnitred for Revitv Draft Rm Sutrnitted f o r Review

.iork Pian far %*vim

Draf t R I / F S Submitted f o r Review Dra f t ROD Sutmitted f o r Review

Draf t ROD S u t m i t t e d f o r Review

Draft SCU S h i t t e d for Rcvicw Draft Uork Plan Subnittcd f o r Rev iw Oraft RI/fS Submitted for Review Dra f t ROO S u b n i t t e d f o r Review

,

Juri- 1992

AUS- 1 W1 Jan- tWZ sep- 1993 Jut-1994

11.1 -1-5

Occ-1995 Aug- 1W7 J v t - t998

"I. I,,.

Apr - 1991 Nov- 1Wr Sep- 1993'

wov- 1991

hug- 1995 Jan- 1996 Sep- 1497 Jut -1998

C ~ C - I991 Ocr - 1992 A, 1"- 1 w7 _._i. . ~ _- Jan-1993

Scp- 199c Jut-1995

Aug- 1996 4.n- 1;;; sep-1998 JUl - 1999

Pec- Wi OCt.1992

J m - tW2

Stp- 1996 F+b-1997 Oct-1998 Aug- 1999

A- 3

W C - ACT IVl TY OPERABLE UYIT ENFORCEABLE D E A D t l l E '

U M 06/10 EBR ]/BORAX

! Ye Draf t 5 s Slrbnittecj f o r Review Draf t Work Plan S u b n r i t t e d for Review D r a f t I I f F S Submitted fo r Review Draf t R M Subnitred for Rev iw

m a 5 (inc. 4-01> Draft R O D Subrnit td fo r R e v i e w

!o-ni. ~ n c \ v- \"'ct u-v>, JW- 7998

WOW m a fu l -2000 nay-2001

Apr- 1 W2

AnD nisc. SITES

Ordnencc In ter im A c t i m

UAG 07 R W C

Pit 9 Inter im Action

Pad A R I / W

7- 1U Draf t Rm S u h i t t e d f o r Review Am- 1992

May- 1991 O u - I 9 9 2 = Oct-1993=

Aw-1991 Jan-1992 Sep- 1993 Jul-1994

Aug-1995 Jan-1996 Sep- 1997 Jut-1998

Jut - 1996 ; F 6

Aw- 1948 Jm-1999

7-12 Draf t XIU Subnitred f o r Reviw D r a f t R I / F S S u b a i e t e d for RcviFw O r a f t ROD Subaittcd for Review

Draf t SOU Sutmitted fo r Revieu Draf t Uork P l a n Submitted f a r Review Draft R i / F S Suhnitted f o r Review Draf t ROD S u b n i t t e d f o r Review

D r a f t Sou S u h i t t e d for Review Draf t York Plan Subnritted f o r Rwiev Draf t RI/FS S u b n i t r e d f o r Review D r a f t RQ) Subnitted fo r Review

Draf t Sou submitted f o r Review

Draft R I / F S Subnittad f o r R e v i w D r a f t R M ) SuOmitted fo r Revicw

nr*4c "....L. -I,.- C . L i r c - 2 x - - o-..:-.. _.I.. -I. I r .e,, ~ - 4 , . L L N my, *=.-IC1

Vadose zw Organics R I / F S

7- 08

7- 13 TRU P i t s and Trench- R l f F S

UAG 07 C q r e h m i v c 7-16 RI/FS

Draf t SW Subnitred for Revieu Draf t York Plan Suhnitted f a r Rcvieu Drsft R I f F S Sutnirred fo r Rwiw D r a f t R M sutrnitted f o r Review

Oreft SOU Sutmitted for Review Draf t Work Ptan Submitted f o r Review Draf t RI/FS Submitted fo r Review Draf t ROO S u b n i t t t d f o r Review

NOV- 1 W 1 hpr- 1992 Dec-1993 oct-1994

scp- 1995 Feb-1996 Oct- 1997 Aug-lP98

YAG 08 Ccnprehensivt 8-08 R I / F S

YAG 09 WAG 09 Carprehmsive 9-04 AWL-U R I / F S

Dra f t SOU subnitred f o r Review Draf t Uork P l a n S u h i t t e d f o r Reviw Draf t R I / F S Submitted f o r Review Draf t ROO Subrrrittcd f o r Revien

Jut * 1996 D@c-1996 rug- t#a Jrn- I999

Post-RM deadlines u i t l k identified as required by P a r t 12.2 o f the Agreement. Tabta A.1 w i l l k updated as appropriate throughcut the l i f e o f the Action P lan t o reflect MY post-RUl deadlines.

cvatudtion o f ex is t i ng data.

Based on SWs subrnitted, these dates my be rcducad by up t o one year.

' These o c h a l e s may be s ign i f i can t l y reduced w i n g dcvetopnnt o f the S W and

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Appendix 8

No Further Action Determination

Appendix B

10 FURTHER ACTION DETERMINATION

The U. S. Department of Energy, U.S. Environmental Protec t ion Agency-Region 10 and the S t a t e o f Idaho have completed a review o f the referenced information for (Name 1 hazardous site, as it pertains t o the IIVEL Federal Facility Agreement o f ( D a t e J . Based on this review, the Parties have determined that nu further action for purposes o f investigation o r study i s justified. This decision i s subject to review a t the time o f issuance of the Record o f Decision.

Brief Summary o f the basis for no fur ther action:

DOE Project Manager d a t e

€PA Project Manager d a t e

Idaho Project Manager date

Appendix C


Summary Report Outline

C-I

1.0

2.0

. 3 . 0

4 . 0

5.0

6.0

7.0

8.0

9.0

10.0

PRELIMINARY SCOPING TRACK 2

RECOMMENDED SUMMARY REPORT OUTLINE

INTRODUCTION

SITE BACKGROUND

DESCRIPTION OF HAZARDOUS SUBSTANCES

GROUNDWATER CONCERNS (i f appl i cab1 e )

n i i n t - m ~ r I i n - r r n r n r i r r n r i r J U K T A t C W n r CR c.uI’ILLruiJ [if appl i c a b l e )

A I R CONCERNS ( i f appl i cab le )

HEALTH AND ENVIRONMENTAL CONCERNS

QUALITY ASSURANCE/QUAtITY CONTROL

RECOMMENDATIONS FOR REMEDIAL ACTION

REFERENCES

APPENDICES

c - 3

APPENDIX D

PROJECT MANAGER DESIGNATIONS

n- 1

PROJECT MANAGER DESIGNATIONS

Mr. Jerry Lyle, Act ing Deputy Director Environmental Restoration and Waste Management U . S . Department o f Energy Field O f f i c e , Idaho 785 DOE Place, MS 1115 Idah= Fal l 5, I D 8340!=!55?

Mr. Wayne Pierre, C h i e f Federal F a c i l i t y Section i i . 5 . Environmental P r o t e c t i o n Agency Region 10 1200 S i x t h Avenue S e a t t l e , WA 98101

Mr. Dean Nygard, Superfund Project Supervisor Hazardous M a t e r i a l s Bureau Idaho Department o f H e a l t h and Welfare 1410 H . Hilton

' B o i s e , ID 83706

Documents

ACTION - Fluor Idaho · TRA TSA TSF U.S. DOE U.S. EPA WAG WAG 1 WAG 2 WAG 3 VVACJ 4 WAG 5 WAG 6 WAG 7 WAG 8 WAG 9 WAG 10 ..I. n WRRTF Test Reactor Arm - Transuranic Storage Area -