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Record of Decision System (RODS)

HANFORD 200-AREA (USDOE)

Abstract

Site Name:  HANFORD 200-AREA (USDOE)
Address:  200 AREA 
City & State:  BENTON COUNTY  WA  99352
County:  BENTON
 
EPA ID:  WA1890090078
EPA Region:  10
 
NPL Status:  Currently on the Final NPL
 
ROD Type:  Amendment
ROD ID:  EPA/541/R-99/038
ROD Date:  03/25/1999
Operable Unit(s):  14
 
Media:  Leachate
 
Contaminant:  Inorganics, Metals, PAH, VOC
 
Abstract:  Please note that the text in this document summarizes the Record of Decision for the purposes of facilitating searching and retrieving key text on the ROD. It is not the officially approved abstract drafted by the EPA Regional offices. Once EPA Headquarters receives the official abstract, this text will be replaced.

The U.S. Department of Energy's (DOE) Hanford Site is a 560-square mile area located along the Columbia River in southeastern Washington, situated north and west of the cities Richland, Kennewick, and Pasco, an area commonly known as the Tri-Cities. The Tri-Cities has a combined population of approximately 100,000. The land that Hanford now occupies was ceded to the U.S. Government in treaties with the Confederated Bands and Tribes of the Yakama Indian Nation and the Confederated Tribes of the Umatilla Indian Reservation in 1855. Certain portions of the Hanford Site are known to have cultural significance and may be eligible for listing in the National Register of Historic Places. The land surrounding the Hanford Site is used primarily for agriculture and livestock grazing.

The DOE Hanford Site has been operated by the Federal Government since 1943 for plutonium production for military use and nuclear energy research and development. Past activities released hazardous and radioactive substances to the environment that contaminated soil, air, and groundwater.

The Hanford Site was divided into four National Priorities List sites: the 1100 Area, the 100 Area, the 200 Area, and the 300 Area. The 200 Area is located in the center of the Hanford Site and covers an area less than 15 square miles where spent nuclear fuel was processed. The 200 West Area is an operational area where spent nuclear fuel was processed in four main facilities. The depth to ground water ranges from approximately 63 yards to 90 yards in the 200 West Area. Groundwater recharge to the aquifer below the 200 Area has been primarily from process effluents. Groundwater generally flows from west to east. However, historic discharges of large volumes of waste water have created an artificial groundwater mound that causes groundwater contaminated with carbon tetrachloride, chloroform, and trichloroethylene (TCE) to flow towards the north and northeast.

In 1995, two Records of Decision wereissued for sites within the 200 Area, one for 200-ZP-1 and one for the Environmental Restoration Disposal Facility.

The 200-ZP-1 operable unit is one of two groundwater operable units located in the 200 West Area. Contamination in 200-ZP-1 resulted from historic discharges to three primary liquid waste disposal sites. The predominant contaminants in the waste stream were carbon tetrachloride and plutonium. Monitoring data indicate that almost all of the plutonium has bound to the soil column and little has reached the groundwater. It is estimated that 600 to 1,000 metric tons of carbon tetrachloride was discharged to the soil from 1955 to 1973.
The Environmental Restoration Disposal Facility (ERDF) site covers a maximum of 1.6 square miles approximately in the center of the Hanford Site, southeast of the 200 West Area and southwest of the 200 East Area. It is anticipated that the ERDF will receive low-level radioactive, hazardous, and mixed waste and small amounts of asbestos and polychlorinated biphenyl (PCB) wastes resulting from the remediation of operable units within the 100, 200, and 300 Area National Priority List sites of the Hanford Site. The total volume of waste is expected to be less than 28 million cubic yards and is expected to consist of the following: contaminated soil; demolition debris; burial ground waste; and wastewater pipelines, ancillary equipment, and associated soil contamination.

The water table elevation beneath the ERDF site generally ranges from 405 to 455 feet. The groundwater flow is predominately from west to east. At its nearest point, the Columbia River is located approximately 7.1 miles to the north. Other surface water bodies include West Lake, approximately 4 miles north, and Rattlesnake Springs, approximately 4 miles southwest.

An Explanation of Significant Difference (ESD) for the United States Department of Energy (USDOE) Hanford Environmental Restoration Disposal Facility (ERDF) at the Hanford Site, area200 in Benton County Washington, was issued on July 26, 1996, which authorized the conditional use of the leachate for dust suppression and waste compaction through an Applicable or Relevant and Appropriate Requirement (ARAR) waiver until the leachate is delisted. The ERDF ESD identified the intention to delist the leachate from regulation as a hazardous waste. The amendment is necessary because delisting hazardous waste leachate may be a fundamental change to the ERDF Record of Decision (ROD) regarding the implementation of the Resource Conservation and Recovery Act (RCRA). Once delisted, the leachate generated and managed under this ROD will no longer be regarded as a hazardous or dangerous waste under the RCRA and the Washington Administrative Code, (WAC) 173-303, which are ARARs for this remedy.

A ROD amendment, in March 1999, served to delist both the federal listed and state-only listed waste codes that would otherwise apply to the leachate as RCRA and Dangerous Waste ARARs under the ROD.
 
Remedy:  The selected remedy modification for the Environmental Restoration Disposal Facility (ERDF) is to delist the leachate. Delisting the ERDF leachate under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to allow more cost-effective and appropriate leachate handling techniques to be implemented is considered the best option. The Applicable or Relevant and Appropriate Requirements (ARARs) for this amended remedy are unchanged from those specified in the 1995 ERDF Record of Decision (ROD) except that ERDF leachate, that is otherwise identified as a hazardous or dangerous waste, is delisted for purposes of the ROD pursuant to the Resource Conservation and Recovery Act (RCRA) and Washington Administrative Code (WAC) 173-303-910.

The Environmental Protection Agency (EPA) evaluated the information and analytical data provided by the Department of Energy (DOE) and determined that the levels of the constituents were well below the delisting levels. In response to the October 1998 ERDF Leachate Delisting Petition, EPA granted a conditional exclusion for leachate meeting the limits established in this Amendment from management as hazardous waste.

The delisting is an up-front conditional delisting for leachate, including leachate that will be generated in the future operations of the facility. The delisting is conditional because contaminant concentration requirements specified in this amendment, and in the sampling and analysis plan attached to this amendment, must continue to be satisfied. Management of the leachate must comply with the sampling and analysis plan and the leachate management plan, as approved by the EPA.

In order to confirm that the concentration of hazardous constituents in the leachate continue to be below delisting levels, a sampling and analysis plan supporting the delisting is required. The plan provides detail regarding sampling frequency and methodology and specified analytical methods. The sampling and analysis shall include comparison of leachate sample results with delisting levels. Delisting levels, in general, are based on the original docket values and health-based limits. The complete evaluation is included within the Petition. Under the sampling and analysis plan, at a minimum, the leachate shall be sampled for all contaminants of concern (COCs), quarterly, for the first year. The results of subsequent analysis will be compared to the delisting levels provided as nonhazardous. Those COCs whose analytical results from baseline sampling indicate that their concentrations are less than 10% of the delisting level will be moved into a confirmatory sampling regiment. COCs detected at concentrations greater than 10% of the delisting level will be monitored on a routine basis. DOE shall include additional constituents in the routine sampling list after an evaluation of the data, as required by the EPA. Additionally, an evaluation of the waste streams going to the ERDF shall be done biannually, in accordance with the sampling and analysis plan, to assure that the list of COCs adequately addresses contaminants being disposed. Confirmatory sampling for all COCs will take place every two years. Routine sampling will take place every six months.

Over time, it is anticipated that waste compounds will be placed in ERDF that have not been evaluated through previous analysis of leachate. Waste profiles will be evaluated for the presence of compounds that are not on record as contained in ERDF waste biannually, in accordance with the sampling and analysis plan. These compounds will be evaluated against the initial list of COCs to determine if they should be included in future sampling and if they are identified on existing EPA docket lists.

A limited volume of leachate may be recycled, as appropriate, in the disposal cells. Appropriate uses are limited to dust suppression and waste compaction. The approved operations plan for the ERDF specifies that c
 
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