100 Area and 300 Area Component of the RCBRA
Workshop Notes – October 30, 2007
Jill Thomson (WCH)
; Welcome to workshop
; Safety discussion
; Comment disposition workshop planned for November 28.
John Sands (DOE) – Discussed alignment of RODs and integration with groundwater.
Joe Franco (DOE): Stated that the comments on the Draft A Risk Assessment are being taken seriously and that is why the comment response workshop has been delayed a month. A formal response will be out after the workshop for participant review
Goals for Record of Decision (ROD) alignment include:
; Tri-Party signatures are required for Final RODs
; Final RODs will be prepared based on geographical areas – by source and operable units
; Decisions still need to be made as to what data are needed to finish the Remedial
Investigation (RI) report to describe the nature and extent of the contamination
; Groundwater (GW) and source will have separate RIs and be done in parallel and cross-
referenced to each other. The proposed plan bridges the RIs.
; Feasibility Study (FS) is to evaluate CERCLA criteria for each area.
Paul Shaffer (Oregon Dept of Energy [ODOE])
; Does the GW risk assessment work include GW from 200 Area sources?
; Will the GW program accelerate the work? How do all the assessments work together?
; How will this work lead to a final closure plan?
John Sands (DOE) – The current risk assessment needs to address the GW from the 200 Area.
Dennis Faulk (EPA) - The 200-BP-5 risk assessment characterization is currently being done, and will integrate with this work.
Mike Thompson (DOE) - The DH&K Operable Unit (OU) systematic planning meeting was 2 weeks ago, for internal parties only. The meeting notes are in internal review. This was a kick-off meeting and the process is not complete in any way.
Barb Harper (Confederated Tribes of the Umatilla Indian Reservation [CTUIR]) – The DQO
process does not work the way it should. They will be sending a letter with comments
addressing the data and results. The DQO process is being shortened and the issues do not get addressed. Is the risk assessment for individual waste site or reactor site? The ARARs section is not a complete evaluation as does not meet requirements for protecting human health. More attention needs to be paid to the DQO process – be very clear on the decision made and what
data are needed.
John Sands (DOE) – The CERLCA Threshold criteria need to meet ARARs and human health
Larry Gadbois (EPA) – The clean ups are for individual waste sites – all the data for that waste
site goes through a mini risk assessment, then it is compared against ARARs. Feels that they are beat up by the public as they do not do a “whole” area risk assessment rather than doing an
individual waste site. However, all info is combined into a big picture risk assessment, including human risk protectiveness and ARARs; it is a multi tiered process.
Dennis Faulk (EPA) – GW will be cleaned up to MCLs and ARARs to protect river and meet
drinking water requirements.
Damon Delistraty (Ecology) – Ecological risk assessment has a more fragmented approach than
human health assessment, which is a more direct approach.
Larry Gadbois (EPA) – Eco is a little harder to look at the geographic scale as there aren‟t many
critters that are affected on a large-scale, but the approach is conservative, using small habitats for larger-scale roaming species.
Jay McConnaughey (Yakama Nation) – Wants to see the cumulative risk from contamination
addressed. Feels this risk assessment should be revised as it does not address the human effect from everything has been released from entire the Hanford Site.
Larry Gadbois (EPA) – DOE has discussed putting together a big picture summary to be
included in each separate document (i.e., D Area RI report). This should help a lot.
Barb Harper (CTUIR) – With a RI/FS report for source and one for GW/VZ there is a need to pull all the information together
Mike Thompson (DOE) - They come together in the proposed plan. There will be Feasibility Studies (FS) for each area but the proposed plans will pull it all together.
Stacy Charboneau (DOE) – The Systematic Planning Process is being done to integrate GW and River Corridor source units.
Paul Shaffer (Oregon) – What will the DHK report show? He has an issue because the kick-off meeting did not include others in the planning process. Where are the Tri-Parties in the process?
Dennis Faulk and Larry Gadbois (EPA) – The notes from the initial discussion will be
distributed for people‟s input. Then DOE will do a work plan to gather the data. Todd Martin
has been hired to contact other entities.
John Price (Ecology) – CERCLA deals with releases and those releases need to be cleaned up. The sites need to protect humans, protect groundwater from soil contaminants, and protect the environment. The following are constraints:
; Consider T&E species special
; Consider sensitive populations
; Coordinate sampling with the NRTC
; Consider cumulative impacts
(Slides Jill Thomson (Washington Closure Hanford [WCH]) – Opened discussion of Message #1
7 -10 of presentation)
Barb Harper (CTUIR) – Has the inflammatory language about tribal scenarios been revised yet?
Jill Thomson (WCH) – Comments are being addressed at this time. DOE needs to resolve the language internally and they are working on it.
Stacy Charboneau (DOE) – The risk assessment will include 200 Area groundwater as it impacts the river corridor but not the entire 200 Area. This discussion was missing from this risk assessment and will be included in the future risk assessment.
Larry Gadbois (EPA) – The entire 200 Area will be addressed by other documents (200-BP-5, 200-PO-1, etc). Not doing a cumulative risk assessment for future plumes from the 200 Area.
Mike Thompson (DOE) – Contaminants from plumes from the 200 Area are tritium, iodine-129, and nitrate. The information is gathered from 50 years of data
Barb Harper (CTUIR) – Feels that there are contaminants that are not being addressed.
Dib Goswami (Ecology) – All the 200 Area groundwater contaminants will be addressed with the 200 Area risk assessments but not in this risk assessment. This is in process.
Jill Thomson (WCH) opened the discussion of slide 10.
Barb Harper (CTUIR) – Is the grouping of OUs just for the RODs or also for the RI/FS process?
Larry Gadbois EPA – The grouping will also be used for the RI/FS reports.
Jill Thomson (WCH) – Opened discussion of Message #2 slides (Slides 11 – 13)
Scott Van Verst (WDOH) – will there be separate discussion about risks from GW vs sources?
Jill Thomson (WCH) – both discussions will be available in the document
Jill Thomson (WCH) – Opened discussion of Message #3 and the risk report (Slides 14-21)
Barb Harper (CTUIR) – Feels the biggest problem was data quality. She suggested that there be a third document that discusses the data as it impacts the human and ecological rather than repeat it in both documents. Still has issues with data quality and stated some examples. Wants an explanation of how the sampling process is determined.
Jill Thomson (WCH) – a further discussion will be added about the sampling (i.e., additional porewater samples were taken, etc.)
Scott Van Verst (WDOH) – What about the radiological dose from sculpin? The report shows very large risk from americium in fish, which is probably not real. Would it be worthwhile to analyze the new data for americium? Will this be redone?
There were split samples for WDOH taken but they were Jackie Queen & Jill Thomson (WCH) –
not sampled for americium because it‟s not technically justified. This will be explained more in
Barb Harper (CTUIR) – Didn‟t all of the workshops resolve the methodology issues and what is
Randy Ryti (Neptune) – The decision makers couldn‟t use this report to make risk decisions –
the report got hard to follow because so many COPCs were left in the assessment. The DOE has proposed a process to include all the COCs and COPCs, pertinent to Hanford Site cleanup to provide useful information to make decisions based on risk.
Larry Gadbois (EPA) – We need a short list of the COCs to show just Hanford contaminants.
Duane/Jill (WCH) – A table will be prepared to show what was omitted and why.
Barb Harper (CTUIR) – If the contaminant is retained for a waste site where it does show up?
Larry Gadbois (EPA) – If there is a waste site that has an oddball contaminant we don‟t want to carry this throughout the document to be evaluated for other waste sites but it would be addressed for that waste site.
Randy Ryti (Neptune) – All the calculations will be rerun, starting from scratch, also because the new inter-areas data will be added.
Charlene Andrade (WDFW) – Will there be a meeting to discuss the new data and how it is presented before we see the next risk assessment?
John Sands DOE – In November, a white paper will be shared on where the Tri-Parties stand on the COCs. This will provide an opportunity to provide comments.
Damon Delistraty (Ecology) / Paul Shaffer (Oregon) – It would be good to see the method used
for dropping data. What is left on and or left off the list and why? Who will make the call?
Randy Ryti (Neptune) – There will be a white paper to discuss how to handle non-detected contaminants per John Sands. The document will also include the „dropped‟ constituents and why they were dropped.
Barb Harper (CTUIR) – Is there one COC list for all waste sites in a reactor area?
Larry Gabois (EPA) – No as there are different COCs for each waste site in a reactor area.
Barb Harper (CTUIR) – Are the Exposure Point Concentrations (EPC) only for soils, or will they also apply to biota? Does it include the home range size for animals?
Randy Ryti (Neptune) – EPCs are meant to apply across many different scales.
Mark Stifelman (EPA) – We need to understand the underlying biology and apply this knowledge to the data.
Scott Van Verst (WDOH) – Will the EPC information be presented at the Nov 28 meeting? Will it spell out how the EPC calculations are to be revised?
Jill Thomson (WCH)– Yes, and it will be shown in the white papers
Scott Van Verst (WDOH) – The americium issue in fish also applies to soils – remediated sites
frequently showed radiation doses calculated from americium that was never detected.
Randy Ryti (Neptune) – Discussed WAC 173-340 (Cleanup Standards; Slides 22-23)
Beth Rochette (Ecology) –We are still working on the issue of incorporating WAC into the risk assessment.
Duane Jacques (WCH) The approach being taken is to provide a crosswalk to show the steps taken under the EPA guidance vs. the WAC guidance.
Jill gave closing statements.
Sign in Sheet
Overview of the RCBRA Public Workshop
October 30, 2007
Duane Jacques WCH Barbara Harper CTUIR Dana Ward DOE/RL John Gear Oregon DOE Charlene Andrade WDFW Jay McConnaughey Yakama Nation Shanna Muns WCH Jill Thomson WCH Jackie Queen WCH Scott Van Verst WA Dept of Health Randy Ryti Neptune Steve Weiss SELF John Sands DOE/RL Stacy Charboneau DOE/RL Wayne Johnson WCH Ella Feist WCH K. Michael Thompson DOE/RL Chuck Powers CRESP Chuck Hedel WCH Peter Bengtson WCH Dib Goswami Ecology John Price Ecology Beth Rochette Ecology John Sands DOE/RL Rico O Cruz CTUIR-DOSE Francis A SiJohn DOE/RL Larry Gadbois EPA Mark Stifelman EPA Roy Bauer FH Damon Delistraty Ecology Dan Landeen NPT Pam Shaffer Oregon Jeff Lerch WCH Laura Buelow EPA