EA-0877; Operable Unit 3 - Proposed Plan for Interim Remedial Action Fernald

ACM: asbestos containing materials
ALARA: as low as reasonably achievable
AMAD: activity median aerodynamic diameter
ARAR(s): applicable or relevant and appropriate requirement(s)
BRA: baseline risk assessment
CERCLA: Comprehensive Environmental Response, Compensation, and Liability Act of 1980
CFR: Code of Federal Regulations
CPID: Closure Plan Information and Data
CRU3: CERCLA/RCRA Unit 3
CSF: Central Storage Facility
DOE: United States Department of Energy
DOE-FN: United States Department of Energy ¾ Fernald Field Office
DOT: United States Department of Transportation
EA: environmental assessment
EDE: effective dose equivalent
EE/CA: engineering evaluation/cost analysis
EPA: United States Environmental Protection Agency
FEMP: Fernald Environmental Management Project
FERMCO: Fernald Environmental Restoration Management Corporation
FMPC: Feed Materials Production Center
FONSI: finding of no significant impact
FS: feasibility study
HEPA: high-efficiency particulate air filter
HVAC: heating, ventilating, and air conditioning
HWMU: hazardous waste management unit
IROD: Interim Record of Decision
ISF: interim storage facility
LLW: low-level waste
MEPA: medium efficiency particulate air filter
MSL: mean sea level
NCP: National Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300
NEPA: National Environmental Policy Act
NPL: National Priorities List
NRC: Nuclear Regulatory Commission
NTS: Nevada Test Site
O&M: Operation and Maintenance
OAC: Ohio Administrative Code
OEPA: Ohio Environmental Protection Agency
ORC: Ohio Revised Code
OSHA: Occupational Safety and Health Administration
OU1: Operable Unit 1
OU2: Operable Unit 2
OU3: Operable Unit 3
OU4: Operable Unit 4
OU5: Operable Unit 5
PCB(s): Polychlorinated biphenyl(s)
PID: photoionization detector
RCRA: Resource Conservation and Recovery Act
RI: remedial investigation
RI/FS: remedial investigation and feasibility study
ROD: record of decision
S.R.: State Route
SARA: Superfund Amendments and Reauthorization Act of 1986 SVOC(s) semivolatile organic compound(s)
SWCR: Sitewide Characterization Report
TBC: to be considered
TSI: thermal system insulation
TSS: tension support structure
VOC(s): volatile organic compounds(s)
WEMCO: Westinghouse Environmental Management Company of Ohio
WPA OU3 RI/FS: Work Plan Addendum
XRF: X-ray Fluorescence

Units of Measure

CF: cubic feet
Ci: Curies CY cubic yard(s)
ft²: square foot (feet)
m: meter(s); m² square meter(s)
m³: cubic meter(s)
mRem: millirem(s)
mCi/ml: microcuries per milliliter
yd³: cubic yard(s)

This document presents a Proposed Plan and an Environmental Assessment for an interim remedial action to be undertaken by the U.S. Department of Energy (DOE) within Operable Unit 3 (OU3) at the Fernald Environmental Management Project (FEMP).

1.1 Purpose of the Proposed Plan

The purpose of this Proposed Plan is to solicit input from the public and other interested persons and stakeholders on the proposed interim action to be implemented by the DOE to accelerate the cleanup process within OU3 at the FEMP. This interim action is being proposed as an initiative to remove contaminated buildings and other related facilities located at the FEMP.

1.2 Scope of the Proposed Plan

This Proposed Plan provides site background information, describes the remedial alternatives being considered, presents a comparative evaluation of the alternatives and a rationale for the identification of DOE's preferred alternative, evaluates the potential environmental and public health effects associated with the alternatives, and outlines the public's role in helping DOE and U.S. Environmental Protection Agency (USEPA) to make a final decision on a remedy. This Proposed Plan also provides the necessary evaluation of the environmental consequences of the action to support an informed decision under the National Environmental Policy Act (NEPA). A fact sheet, providing a summary of the proposed action, has also been prepared.

The alternatives considered within this Proposed Plan are:

Alternative 0 -- No Action
Alternative 1 -- No Interim Action
Alternative 2 -- Decontaminate Surfaces Only
Alternative 3 -- Decontaminate and Dismantle

An Interim Record of Decision (IROD) to be issued following this Proposed Plan will formally document the decisions concerning the proposed interim action. The issuance of an IROD would permit cleanup actions to proceed ahead of the current RI/FS schedule.

1.3 Regulatory Requirements and Governing Agencies

Remedial activity at the FEMP is being conducted in accordance with the requirements of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act (SARA), hereinafter jointly referred to as CERCLA. The lead agency for implementation of the requirements of CERCLA at the FEMP is the DOE, with the USEPA and Ohio EPA (OEPA) acting as support agencies. The DOE, as the lead agency, has the responsibility of drafting this Proposed Plan, soliciting comments from the support agencies and the public, and responding to comments. The responsibility of the USEPA and OEPA as support agencies is to review and to provide comments to DOE in a timely fashion on this Proposed Plan.

For DOE sites such as the FEMP undergoing investigations and cleanup under CERCLA, it is the policy of the DOE to integrate the values of NEPA into the procedural and documentation requirements of the RI/FS process, wherever practical. Consistent with this policy, this Proposed Plan has been written to incorporate NEPA values and additionally represents an Environmental Assessment. The content of this document is not intended to represent a statement on the legal applicability of NEPA to remedial actions conducted under CERCLA.

A separate RI/FS has not been prepared for the proposed interim remedial action; however this Proposed Plan fulfills the requirements of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR 300) for a detailed analysis of alternatives associated with the scope of this action. This Proposed Plan is being issued consistent with Section 117 (a) of CERCLA which requires publication of a notice and brief analysis of the proposed alternatives for site cleanup. Pursuant to CERCLA, the plan must be made available to the public to provide an opportunity for meaningful input into the decision process.

Consideration of state and community input may result in modifications to the interim remedial action selected, so the final decision may differ from the preferred alternative identified in this plan. Therefore, public comment on each alternative in this plan is an important element of the decision-making process for the interim remedial action. Community comments on the preferred alternative and other alternatives will be evaluated and documented as part of the IROD.

1.4 Overview of the FEMP and Operable Unit 3

The FEMP, formerly known as the Feed Materials Production Center(1), is a DOE facility which operated from 1952 to 1989 to provide high purity uranium metal products to support United States defense programs. The FEMP is located in southwestern Ohio about 17 miles northwest of downtown Cincinnati. Production operations were halted in 1989 to focus available resources on environmental restoration activities at the facility. One of these activities, the OU3 RI/FS process, is being conducted pursuant to the terms of an agreement with the USEPA for the purpose of identifying the most promising cleanup actions to be undertaken at the FEMP to address environmental concerns. These environmental concerns have been identified by DOE, USEPA, OEPA, and members of the community living near the facility. They include: (1) the potential impacts on human health and the environment from past releases of hazardous materials from the FEMP to the air, water, and surrounding soils; (2) the on-site accumulation of a large inventory of uranium process materials and low level radioactive and hazardous wastes; and (3) the deteriorated state of, and levels of contamination in, the former uranium processing buildings and support facilities at the site.

To promote a more structured and expeditious cleanup, the FEMP has been divided into five operable units. An operable unit is a term employed under CERCLA to identify a logical grouping of facilities or environmental issues at a cleanup site. Separate RI/FS documentation, including RI and FS Reports and Proposed Plans are being issued for each of the five operable units at the FEMP. The Amended Consent Agreement (EPA 1991) defines the five operable units at the site. The operable units are roughly defined as: Operable Unit 1, the Waste Pit Area; Operable Unit 2, Other Waste Units; Operable Unit 3, the Production Area and associated facilities and equipment; Operable Unit 4, Silos 1-4; and Operable Unit 5, Environmental Media.

Operable Unit 1 reports are currently in preparation and review phases. The Remedial Investigation (RI) Report is being reviewed by EPA and the Feasibility Study (FS) is being prepared for delivery to EPA in March of 1994. For OU2, both the RI and the FS are being prepared and are scheduled for submittal to EPA in February and April of 1994, respectively. Operable Unit 3 is currently undergoing field investigation to support an RI Report submittal to EPA in March 1996. Operable Unit 4 received conditional approval on the RI Report in September of 1993 and EPA is currently reviewing the final version. The FS Report for OU4 is currently being revised based on EPA comments. For OU5, the RI and FS Reports are being prepared for submittal to EPA in June and November of 1994, respectively.

As previously stated, this document presents a Proposed Plan for an interim remedial action to be undertaken within OU3 at the FEMP. A separate Proposed Plan for final actions will be issued for OU3 following completion of the ongoing RI/FS. Operable Unit 3 consists of the following:

Production Area and Production-associated facilities and equipment (including all above- and below-grade improvements);
All other facilities and equipment not specifically included in OUs 1, 2, 4, and 5;
Drummed Waste Inventories;
Waste Product Materials, Feedstocks and Thorium;
Wastewater Treatment Facilities and Effluent Lines;
Fire Training Facilities;
Scrap Metal, Coal, and Existing Soil Piles;
Identified Storage Ponds and Basins; and
Storage Pads, Roadways, and Railroad Tracks.

1.5 Purpose and Need for the Interim Remedial Action

The buildings, equipment and other facilities contained within OU3 exhibit elevated concentrations of radiological and other hazardous substances at levels which exceed certain standards and guidelines for protecting human health and the environment. The existence of these contaminants results in ongoing exposures to workers and represents, under certain potential circumstances involving releases, an unacceptable threat to neighboring residents.

While DOE maintains an active maintenance program, the former uranium processing support facilities contained within OU3 are, in general, at or beyond their design life and in a state of advancing deterioration. These current conditions present an increasing probability of future releases of hazardous substances to the environment due to structural collapse or other failure mechanisms. While the DOE and USEPA are proceeding toward a decision on the proposed final disposition of these structures as part of the OU3 RI/FS process, the decision resulting from this effort is not scheduled until late 1997.

DOE, as the lead agency for the FEMP, has the responsibility to reduce risks to human health and the environment as quickly as possible. Therefore, DOE is fulfilling its responsibility as the lead agency in accordance with CERCLA and the NCP by proposing to implement an interim remedial action to accelerate the cleanup process within OU3. DOE's preferred alternative is the decontamination and dismantlement of contaminated buildings, equipment, and facilities within OU3 which represent potential sources of releases to the environment. This action could potentially accelerate the clean up process by four years. This proposed action is considered reasonable due to (1) the substantial cost savings to the public from reduced maintenance costs, (2) the resulting reduced exposures to site workers, and (3) the early opportunity to implement cleanup actions to address the advanced state of facility deterioration and continued potential for contaminant release. The DOE has identified no future use for the OU3 facilities, and therefore, considers the removal of these facilities to be a prudent measure to ensure the continued protection of human health and the environment. The proposed interim action is consistent with USEPA guidance (EPA 1989 and 1991b), which allow interim remedial actions to be implemented to respond to an immediate site threat or to take advantage of an opportunity to more promptly reduce site risk.

DOE maintains active custody of the site and restricts access with fences and guards, precluding a member of the public from being exposed to the more heavily contaminated facilities on the site. Additionally, DOE continues an active maintenance program to reduce gross contamination levels within the structures and to implement the necessary corrective actions to minimize the potential for the release of significant quantities of hazardous substances to the environment. While available environmental monitoring data demonstrate that off-site populations are not currently being exposed to risk by OU3 contaminants due to access and administrative controls, the purpose of DOE's environmental restoration program is to eliminate or reduce the potential for such impacts.

1.6 Scope of the Interim Remedial Action

The proposed interim action represents a major component of the OU3 remediation effort. The combination of the interim action and the final action will result in an overall cleanup approach that is consistent with the current leading remedial alternative. The interim action represents an approach to reduce risks to human health and the environment, as well as support a potential acceleration of the OU3 remediation.

Included within the scope of this alternative is the removal of all OU3 facilities, including former uranium processing buildings and equipment, support structures, below-grade and above-grade utilities, and identified ponds and basins. These facilities would be removed and decontaminated to the extent feasible to maximize resource recycling and reduce waste generation, with debris and other waste generated incidental to these actions placed into a safe storage facility at the FEMP and a limited quantity dispositioned to approved off-site disposal facilities. Decisions regarding the location and method of permanent disposition of the removed materials are excluded from the scope of this action and will be made through the ongoing Remedial Investigation/Feasibility Study (RI/FS) process for OU3.

The construction, operation, maintenance, and monitoring of the required interim storage facilities to house the generated debris and waste is within the scope of the action. EPA guidance, Guide to Developing Superfund No Action, Interim Action, and Contingency RODs (EPA 1991b) for interim actions specifically addresses "relocating contaminated material from one area of a site to another area of the site for temporary storage until a decision on how best to manage the site wastes is made." Debris and waste would remain in this storage configuration until issuance of the final ROD on the OU3 RI/FS, which will identify a permanent disposal method. Portions of the contaminated debris and other wastes generated during the period prior to the final ROD would be transported from the site for disposal at an approved off-site disposal facility. The quantity of the material shipped from the site as a consequence of this interim action would not represent greater than 10 percent of the total OU3 waste inventory, including contaminated construction materials and process related waste residues. The shipment of this quantity of material would not bias the final disposal decision in the final ROD. These materials may be shipped off-site due to limitations on available or newly constructed interim storage capacity.

1.7 OU3 RI/FS Integration

The RI/FS process for OU3 is being conducted in accordance with an Amended Consent Agreement (EPA 1991) between USEPA and DOE. One objective of the RI/FS is to develop a detailed understanding of the nature of the contamination on or within the OU3 facilities, their impacts on the surrounding environment, and the threat that the facilities pose to human health and the environment. The OU3 RI/FS Work Plan Addendum (DOE 1993b) detailing proposed investigations to develop this detailed understanding of OU3 was approved by USEPA on August 4, 1993. Following the completion of these investigations, RI and FS Reports will be issued consistent with the milestone schedules defined in the Amended Consent Agreement. Following approval of these RI/FS documents, a draft Record of Decision (ROD) will be submitted to USEPA for approval by April 2, 1997.

The effect of the IROD and the associated proposed interim action would be to separate decontamination and dismantlement activities from the final disposition of wastes and potentially allow decontamination and dismantlement of OU3 components to begin 4 years ahead of the current schedule (see Figure 1-1) . The need to address technologies or options for facility removal in the RI/FS documentation for OU3 would be precluded by the issuance of the IROD. The OU3 RI/FS would then be focused upon the evaluation of waste treatment technologies, and methods and locations for the final disposal of the OU3 materials. Through implementation of the interim action and the final RI/FS decision, all of OU3 would be remediated.

Figure 1-1 Schedule Comparison of the Preferred Alternative and the Current RI/FS

Following the IROD, a Remedial Design/Remedial Action (RD/RA) Work Plan would be issued to provide more detailed plans and schedules of how the facilities are to be decontaminated and dismantled, consistent with the alternative selected. Remediation plans associated with current Removal No. 13 (Plant 1 Ore Silos) and Removal No. 19 (Plant 7 Dismantling), will form a basis to develop and support the RD/RA Work Plan design and scheduling. Before implementation of this interim action could begin, it is anticipated that both of these removal actions would be complete or near completion. Therefore, lessons learned from the design and implementation of these removal actions will be incorporated into the RD/RA Work Plan. The RD/RA Work Plan will include a logic flow diagram detailing the evaluation to be performed in assessing a schedule of activities. Some of the factors involved in the schedule process are: attainment of the greatest risk reduction; estimation of funding available; facility and utility requirements during remediation; and coordination of activities with other OUs including soil and groundwater remediation.

The proposed interim remedial action would be coordinated and integrated with ongoing approved removal actions or newly identified removal actions. It is anticipated that most removal actions will be completed before beginning the interim remedial action. The exceptions are Removal of Waste Inventories (Removal No. 9), Safe Shutdown (Removal No. 12), Improved Storage of Soil and Debris (Removal No. 17), and Asbestos Abatement (Removal No. 26). These removal actions are programmatic in nature and represent actions being applied to the site as a whole. Both Safe Shutdown and Improved Storage of Soil and Debris are removal actions connected to the interim remedial action that require coordination of activities. The Removal of Waste Inventories and Asbestos Abatement programs would be completed within buildings and facilities before the decontamination and dismantlement would begin. A discussion of the OU3 removal actions is presented in Section 2.3.

Upon issuance of the final ROD for OU3, the interim action would be integrated with the actions dictated by this RI/FS decision document to provide a unified remediation approach. Once the final ROD has determined the treatment and disposal options to be implemented, materials from the interim action will be controlled and managed to meet the requirements of the final ROD. Discussion of this unified remedial strategy will be provided within the RD/RA Work Plan issued subsequent to the final ROD.

Similarly, for each operable unit, a Feasibility Study is being prepared to develop remedial action alternatives. Remedial actions for each operable unit will be coordinated to achieve overall risk reduction for the FEMP. The actions proposed in this document represent one portion of the entire site remediation through removal of structures and buildings within OU3. These activities combined with the other operable unit remedial and removal actions will lead to remediation of the entire site.

It should be noted that contaminated environmental media, including soils and groundwater in the vicinity of or underlying the OU3 facilities are being addressed under a separate operable unit (Operable Unit 5) which is examining such media on a site-wide basis. Remediation interfaces between OU5 and OU3 will require the highest degree of integration during remedial actions to assure removal of above- and below-grade facilities as coordinated with remediation of environmental media. OU3 interfaces with OUs 1, 2, and 4 are physically minimal due to boundaries established around each operable unit; however, remediation activities and waste storage facilities planning for all operable units are coordinated to maximize available resources and limited space.

1.8 Organization of this Proposed Plan

This Proposed Plan has been prepared to satisfy each of the listed objectives. This Proposed Plan is organized such that:

Section 2 provides a summary of relevant site background information including a more thorough description of OU3 and its associated radiological and chemical contamination. Section 2 also presents a brief discussion of related site actions.
Section 3 describes each of the alternatives considered for implementation.
Section 4 presents a detailed evaluation of the alternatives employing the criteria identified under CERCLA for use in the RI/FS process.
Section 5 presents the results of the comparative analysis of the alternatives and provides the rationale for selection of DOE's preferred alternative.
Section 6 summarizes the role of the public in the decision process, solicits public comment on this Proposed Plan, and provides relevant information on how to provide input.
Section 7 presents a schedule for preparation of CERCLA decision documents for the interim remedial action.
Finally, a series of appendices provide additional detailed supporting information for topics covered in Sections 2 and 4.

2.0 BACKGROUND INFORMATION

This section summarizes background information concerning the FEMP and OU3 relevant to this Proposed Plan. Included in this section is a brief summary of the site location and affected environment (Section 2.1), a description of OU3 (Section 2.2), a description of ongoing removal actions in OU3 (Section 2.3), and a summary of information on the nature and extent of contamination within OU3 (Section 2.4).

The background information summarized within this section is based upon the data and information presented in the Sitewide Characterization Report (SWCR) (DOE 1993c), the OU3 RI/FS Work Plan Addendum (DOE 1993b), and other references as noted. The plate map at the back of the document shows the details of the site.

2.1 Site Location and Affected Environment

The FEMP is located on a 1,050-acre site in a rural agricultural area about 17 miles northwest of downtown Cincinnati, Ohio (Figure 2-1) . The site is near the villages of Fernald, New Baltimore, New Haven, Ross, and Shandon, Ohio. The nearest resident is located at the property boundary and no individuals reside on the site.

Figure 2-1 Location of the FEMP Facility

The FEMP is a government-owned, contractor-operated federal facility that produced high-purity uranium metal products for the DOE and its predecessor agency, the Atomic Energy Commission, during the period 1952-1989. Thorium was also processed, but on a smaller scale, and is still stored on the site. Production activities were stopped in 1989, and the production mission of the facility was formally ended in 1991. The FEMP was included on the National Priorities List in 1989. The current mission of the site is environmental restoration in accordance with the requirements of CERCLA, as amended by SARA.

Although not considered part of OU3, environmental media are part of the potential transport and exposure pathways that must be considered. This section presents a description of the environmental media and the characteristics of the FEMP that may be affected by the proposed remedial activities. A brief description of the physical, environmental, and demographic settings of the study area is provided in this section. Topics discussed include air quality, meteorology, topography and surface water hydrology, soils and seismology, geology and groundwater hydrology, socioeconomics and land use, biotic resources, and wetlands and floodplains. More extensive discussions of these topics are provided in the SWCR (DOE 1993c) and the OU3 RI/FS Work Plan Addendum (DOE 1993b).

Air Quality

Radioactive and nonradioactive airborne particles are generated by remediation and restoration activities, as well as containerization and packaging of wastes. Airborne particles eventually settle to the ground, creating a potential for resuspension, as well as a potential for introduction to the human food chain through soil, grass, produce, and milk. For these reasons, the air pathway is considered to have the greatest potential for exposure of the public. Through site monitoring programs, engineering controls, and work practices, potential off-site exposures are minimized.

Existing site conditions at the FEMP are in compliance with air quality and health protection standards of the National Ambient Air Quality Standards and the State of Ohio.

Meteorology

Information on the local climate is available from two primary sources: an on-site meteorological system installed at the FEMP in 1986 and the National Weather Service Office at the Greater Cincinnati/Northern Kentucky International Airport.

The average annual precipitation for the Cincinnati area for the period of 1960 through 1989 was 40.56 inches and ranged from 27.99 inches in 1963 to 52.76 inches in 1979. The highest precipitation occurred during the spring and early summer. The maximum 24-hour rainfall event of record occurred in March 1964 when 5.21 inches fell. Precipitation is typically lowest in late summer and fall. The average annual snowfall for the 1960 to 1989 period was 23.5 inches, with the heaviest snowfall usually occurring in January. The maximum monthly snowfall of 31.5 inches occurred in January 1978.

Data from the on-site meteorological system, averaged over 1986 to 1992, were used to obtain the atmospheric dispersion results presented in Appendices D, E, and F.

Topography and Surface Water Hydrology

The maximum elevation on the site is along the northern boundary of the FEMP property and is approximately 700 feet above mean sea level (MSL). The former Production Area and the majority of OU3 components rest on a relatively level plain at about 580 feet above MSL. The plain slopes from 600 feet above MSL along the eastern boundary of the FEMP to 570 feet above MSL at the K-65 silos, and then drops off toward Paddys Run at an elevation of 550 feet above MSL. All drainage, including surface water, on the FEMP is generally from east to west into Paddys Run, with the exception of the extreme northeast corner, which drains east toward the Great Miami River.

Surface waters on and adjacent to the FEMP are the Storm Sewer Outfall Ditch, Paddys Run, and the Great Miami River. The Storm Sewer Outfall Ditch originates within the FEMP and flows toward the southwest where it enters Paddys Run, which flows southward along the western boundary of the facility. Paddys Run, in turn, is a tributary of the Great Miami River. The Great Miami River flows generally toward the southwest; however, locally it flows to the east and south.

Soils

Mineralogy as well as certain soil geochemical parameters influence both the physical characteristics of a soil and its ability to constrain or allow movement of dissolved organic and inorganic constituents. Soil characteristics affect (1) the suitability of a site for agriculture or construction, (2) the likelihood of erosion during remedial actions, and (3) the kinds of habitat (e.g., wetlands) that can develop on a site. Soils in the region of the FEMP were formed from materials deposited during the Wisconsin and Illinoisan glacial periods. These parent materials consist mainly of till, but include sand, gravel, glacial-lake clays, and silt clays. The soil series occurring within the FEMP are Dana, Eden, Fox, Genesee, Hennepin, Henshaw, Markland, Martinsville, Miamian, Radsdale, Raub, Russell, and Uniontown (USDA 1982).

Geology and Groundwater Hydrology of the FEMP

The FEMP lies in the Till Plains section of the Central Lowland physiographic province, characterized by structural and sedimentary basins and domes. The main physiographic features in the area are gently rolling uplands, steep hillsides along the major streams, and the Great Miami River Valley. This valley is relatively broad, flat-bottomed, and flanked on either side by bluffs that rise to a maximum of 300 feet above the general level of the valley floor.

The Great Miami Aquifer is the principal aquifer within the FEMP Study Area and has been designated a sole source aquifer under the provisions of the Safe Drinking Water Act. The buried valley in which it occurs varies in width from about 0.5 mile to more than 2 miles, having a U-shaped cross section with a broad, relatively flat bottom, and steep valley walls. This valley is filled with extensive deposits of sand and gravel that range in thickness from 120 to 200 feet in the valley to only several feet in scattered silt and clay deposits along the valley walls. Large groundwater supplies occur in the sand and gravel deposits allowing the aquifer to yield a considerable amount of water.

Erratically distributed pockets of sand and gravel within the glacial overburden contain zones of perched groundwater. These zones are located throughout the Production Area and range in depth from 1 to 15 feet below the land surface.

Socioeconomics and Land Use

The FEMP is approximately 17 miles northwest of Cincinnati, Ohio, the focal point of a regional market encompassing the following thirteen counties in Ohio, Kentucky, and Indiana: Brown, Butler, Clermont, Hamilton, and Warren counties in Ohio; Boone, Campbell, Gallatin, Grant, Kenton and Pendleton counties in Kentucky; and Dearborn and Ohio counties in Indiana. These thirteen counties also define the Cincinnati Consolidated Metropolitan Statistical Area. Within a 5-mile radius of the FEMP there are an estimated 23,000 residents. Labor force in the multi-county area was more than 920,000 with unemployment at approximately 5.5 percent in December of 1991 (DOE 1993c).

The transportation network serving the FEMP region are three interstate highways (I-71, I-74 and I-75) providing inter-regional access to locations within the Cincinnati area and two interstate connectors (I-275 and I-471) providing intra-regional highway access. Primary roads providing access to the FEMP include S.R. 128, S.R. 126, New Haven Road, Willey Road and Paddys Run Road. A 1990 traffic count showed Willey Road carrying 800-1000 daily movements.

There are no areas within the FEMP boundaries considered to be prime farmland under the Farmland Policy Protection Act of 1981 (7 CFR 658). The farmland commercial activity adjacent to the FEMP is generally restricted to the village of Ross, approximately 3 miles northeast of the facility, and along State Route 128, south of Ross.

Cultural Resources

The area surrounding the FEMP has a large and diverse archaeological and historical resource base. According to records kept by the Miami Purchase Association for Historic Preservation, an unusually high percentage of the existing 19th century buildings in the area are historically important. Within the vicinity of the FEMP (a 2-mile radius from the boundary), there are three properties listed in the National Register of Historic Places and a number of additional structures that have been judged eligible for inclusion on the listing. Six major archaeological sites lie within 5 miles of the FEMP and five of these are included in the National Register.

Biotic Resources

The FEMP and surrounding areas lie in a transition zone between two distinct regions of the Eastern Deciduous Forest Province (Bailey 1978): the Oak-Hickory and the Beech-Maple forests. The region is characterized by the presence of a mosaic of these forest types. Beech-Maple forests are typically dominated by beech trees in the canopy, the uppermost layer of the forest, with sugar maples dominant in the understory, below the canopy. For the Oak-Hickory forest, the dominant species are oaks, with an abundance of hickories. The fauna vary little between the two forest sections and include white-tailed deer, gray fox, gray squirrel, white-footed mouse, and short-tailed shrew; the cardinal, woodthrush, summer tanager, red-eyed vireo, and the hooded warbler; the box turtle, and common garter snake (Bailey 1978; Shelford 1963).

Potential remedial actions at the FEMP must comply with the substantive requirements of the Endangered Species Act of 1973. To comply with Section 7 (a)(2) of this act, as amended, requiring federal agencies "...in consultation with and with the assistance of..." the Secretaries of the Interior and Commerce, to ensure that their actions are "...not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of the critical habitat of such species...", Miami University performed an Ecological Characterization Study of the FEMP in 1989. Updated surveys have been performed for the Sloan's crayfish and the cave salamander. The following discussions concern threatened and endangered species with potential habitats in the vicinity of the FEMP.

The Indiana bat (Myotis sodalis) is listed as both a federal and state endangered species. It is present in Butler and Hamilton counties. Surveys were conducted at the FEMP to determine it's distribution and presence and to identify potential habitat at the FEMP and the immediate vicinity. The Indiana bat has not been identified at the FEMP, but during the summer of 1988, a population was identified approximately 4.8 km (3.0 mi) northeast of the FEMP on Banklick Creek, a tributary of the Great Miami River (Facemire 1990). Potential habitat for the Indiana bat occurs in portions of the riparian woodland associated with Paddys Run. An updated survey will be performed to determine presence of individuals.

The cave salamander (Eurycea lucifuga), a state listed endangered species, has not been identified at the FEMP site. During the summer of 1988, a population was identified 1.6 km (1.0 mi) northeast of the FEMP at the Ross Trails Girl Scout Camp. Preliminary data from a 1993 survey has identified excellent habitat in an on-property well, but no individuals.

The Sloan's crayfish (Orconectes sloanii) is a state threatened species reported from Paddy's Run by Facemire et al. (Facemire 1990). Current preliminary data from a September 1993 survey shows populations residing in northern sections of Paddy's Run on-site and southern sections of Paddy's Run off-property near New Haven Road.

Several other threatened and endangered species also have the potential to occur in the vicinity of the FEMP. These include the following: Northern waterthrush (Seiurus noveboracensis), Northern harrier (Circus cyaneus), Red shouldered hawk (Bueto lineatus), Slender finger-grass (Digitaria filiformis), Mountain bindweed (Polygonum cilinode), Dark-eyed junco (Junco hyemalis), Running buffalo clover (Trifolium stoloniferum), and Cobblestone tiger beetle (Cicendela margipennis).

The cobblestone tiger beetle, listed as a Federal 2 (F2) species and statelisted special-interest species, was found in 1988, on a gravel bar in the Great Miami River 2 miles west/southwest of the bridge at New Baltimore, Ohio. As an F2 species, this beetle has been considered by the U.S. Fish and Wildlife Service for possible inclusion on the federal threatened or endangered species list. Special-interest species are listed by the Ohio Department of Natural Resources and are often eligible, with more information, to be listed as state threatened or endangered. This beetle remains on both lists because insufficient information on its past existence and habitat prevents it from being elevated to a threatened or endangered category.

Wetlands and Floodplains

The 100- and 500-year floodplains within the FEMP property are confined to the north-south corridor containing Paddys Run. Outside the boundaries of the FEMP, the 100- and 500-year floodplains of the Great Miami River extends west of the Big Bend area nearly to the eastern boundary of the facility. The 100-year floodplain of the river also extends northward along Paddys Run from the confluence of the two streams to a point about 600 feet from the southern boundary of the FEMP.

A site-wide wetland delineation was conducted in February 1993 in accordance with the 1987 Army Corps of Engineers Wetlands Delineation Manual. The purpose of the delineation was to determine the extent of jurisdictional wetlands and waters of the United States. A jurisdictional determination has been requested from the U.S. Army Corps of Engineers to verify the wetland boundaries and waters of the United States. Preliminary results from the site-wide delineation, subject to the U.S. Army Corps of Engineers approval, indicate a total of 35.9 acres of wetlands which included 26.58 acres of palustrine forested wetlands, 6.95 acres of drainage ditches/swales, and 2.37 acres of isolated emergent and emergent-scrub/shrub wetlands. On-site waters of the United States are confined to Paddys Run and an unnamed tributary and total approximately 8.9 acres. Some wetland areas occur on the perimeter of OU3.

2.2 Description of Operable Unit 3

Operable Unit 3 consists of the former Production Area and production-associated facilities and equipment. The Production Area occupies about 136 acres near the center of the FEMP site and contains many buildings, scrap metal and soil piles, containerized materials, storage pads, a parking lot, roads, railroad tracks, above- and underground tanks, utilities, and equipment. Several impoundments, ponds, and basins also are included. Operable Unit 3 does not specifically include the soil and groundwater under the various improvements. These media are within OU5, but are important as potential pathways between sources of contamination in OU3 and receptors.

Because of the complexity and large number of structures and other improvements included in OU3, the planning process for the OU3 RI/FS required the categorization of these components. The term component refers to the smallest physically distinct unit considered separately in the development and implementation of this Proposed Plan. The basis for identifying and categorizing OU3 components was developed in the RI/FS Work Plan Addendum for the operable unit. Table 2-1 provides a comprehensive list of the 227 OU3 components. For each component, the table lists the component name, its alpha-numeric designation, and its component category type. All components listed are within the scope of this Proposed Plan.

The Table 2-1 list includes all elements of OU3 designated as components as of the date of this Proposed Plan. This list, however, may change as the program progresses. For example, components would be taken off the list as the interim actions resulted in their demolition and storage. The list of components will be updated as new information warrants. Components are categorized on the basis of physical similarity or use into 11 separate component categories. Categories 1-4 consist of those OU3 components classified in the general category of structures, facilities, and/or buildings. The four categories are separated by basic function. Within each of these categories, individual components include such associated items as equipment, machinery, inside sumps, utilities, and piping (tank/distribution systems), provided that those items are considered integral parts of the component. Items not considered to be integral parts of the component are placed in category 9 or 10 (piping/utilities/equipment).

Table A.2.0 in Appendix A of the OU3 RI/FS Work Plan Addendum (DOE 1993b) summarizes the typical types of construction of the buildings in OU3. To support the evaluation of remedial alternatives and to estimate waste volumes, the buildings have been grouped into four main categories on the basis of their primary construction materials. Most of the structures fit within the definition of a single category; however, because of additions and annexes, several buildings are identified as hybrid designs.

Table A.2.1 in the OU3 RI/FS Work Plan Addendum provides descriptive information about the various structures and other components in OU3. Eleven major process facilities, 6 major administrative facilities, 20 major warehouse facilities, and essentially all major structures in the operable unit have been detailed. In total, more than 200 entries are described in Table A.2.1. The table summarizes structural design information and identifies each entry with its unique alphanumeric component designator as identified in Table 2-1.

Each item on the component list was reviewed for past and current uses. Many of the facilities have been used for more than one type of process during the 41-year history of the site. Table A.2.1 in the OU3 RI/FS Work Plan Addendum describes these processes and the major associated equipment and provides a subdivision of the major components by processes performed. Segregation by process provides a basis for more detailed description of activities within each facility and supports a structured approach to identification of potential contamination resulting from past and current activities.

TABLE 2-1 Operable Unit 3 Component Identification

Component	Component Designation	Category	Component	Component Designation	Category
Preparation Plant	1 A	3	Service Building	11	1
Plant 1 Storage Shelter	1 B	2	Main Maintenance Building	12 A	4
Plant 1 Ore Silos	1 C	5	Cylinder Storage Building	12 B	2
Ore Refinery Plant	2 A	3	Lumber Storage Building	12 C	2
General/Refinery Sump Control Bldg.	2 B	4	Pilot Plant Wet Side	13 A	3
Bulk Lime Handling Building	2 C	4	Pilot Plant Maintenance Bldg.	13 B	4
Metal Dissolver Building	2 D	3	Sump Pump House	13 C	3
NFS Storage & Pump House	2 E	5	Pilot Plant Thorium Tank Farm	13 D	5
Cold Side Ore Conveyor	2 F	9	Administration Building	14 A	1
Hot Side Ore Conveyor	2 G	9	Building 14 EOC Generator Set	14 B	9
Conveyor Tunnel (From Plant 1)	2 H	10	Laboratory	15	3
Maintenance Building	3 A	4	Main Electrical Station	16 A	9
Ozone Building	3 B	4	Electrical Substation	16 B	4
NAR Control House	3 C	1	Electrical Panels & Transformer	16 C	9
NAR Towers	3 D	5	Main Electrical Switch House	16 D	4
Hot Raffinate Building	3 E	3	Main Electrical Transformers	16 E	9
Harshaw Digestion Fume Recovery	3 F	5	Trailer Substation #1	16 F	9
Refrigeration Building	3 G	4	Trailer Substation #2	16 G	9
Refinery Sump	3 H	5	10-Plex North Substation	16 H	9
Combined Raffinate Tanks	3 J	5	10-Plex South Substation	16 J	9
Old Cooling Water Tower	3 K	10	BDN Surge Lagoon	18 A	11
Electrical Power Center Building	3 L	4	General Sump	18 B	5
Green Salt Plant	4 A	3	Coal Pile Runoff Basin	18 C	11
Plant 4 Warehouse	4 B	2	Biodenitrification Towers	18 D	3
Plant 4 Maintenance Building	4 c	4	Storm Water Retention Basin	18 E	11
Metals Production Plant	5 A	3	Clearwell Pump House	18 G	3
Plant 5 Ingot Pickling	5 B	4	BDN Effluent Treatment Facility	18 H	3
Plant 5 Electrical Substation	5 C	4	Methanol Tank	18 J	5
West Derby Breakout/ Slag Milling	5 D	4	Low Nitrate Tank	18 K	11
Plant 5 Filter Building	5 E	2	High Nitrate Tank	18 L	11
Plant 5 Covered Storage Pad	5 F	2	High Nitrate Storage Tank	18 M	5
Plant 5 Ingot Storage Shelter	5 G	2	Main Tank Farm	19 A	5
Metals Fabrication Plant	6 A	3	Pilot Plant Ammonia Tank Farm	19 B	5
Plant 6 Covered Storage Area	6 B	2	Tank Farm Control House	19 C	4
Plant 6 Electrostatic Precipitator (South)	6 C	3	Old North Tank Farm	19 D	5
Plant 6 Electrostatic Precipitator (Central)	6 D	9	Pump Station & Power Center	20 A	4
Plant 6 Electrostatic Precipitator (North)	6 E	3	Water Plant	20 B	4
Plant 6 Salt Oil Heat Treat Building	6 F	3	Cooling Towers	20 C	9
Plant 6 Sump Building	6 G	3	Elevated Potable Storage Tank	20 D	5
Plant 7	7 A	2	Well House #1	20 E	4
Plant 7 Overhead Crane	7 B	9	Well House #2	20 F	4
Recovery Plant	8 A	3	Well House #3	20 G	4
Plant 8 Maintenance Building	8 B	4	Process Water Storage Tank	20 H	5
Rotary Kiln/Drum Reconditioning	8 C	3	Gas Meter Building	22 A	4
Plant 8 Railroad Filter Building	8 D	4	Storm Sewer Lift Station	22 B	4
Drum Conveyor Shelter	8 E	9	Truck Scale	22 C	4
Plant 8 Old Drum Washer	8 F	9	Scale House & Weigh Scale	22 D	4
Special Products Plant	9 A	3	Utility Trench to Pit Area	22 E	10
Plant 9 Sump Treatment Facility	9 B	3	Meteorological Tower	23	9
Plant 9 Dust Collector	9 C	9	Railroad Scale House	24 A	4
Plant 9 Substation	9 D	4	Railroad Engine House	24 B	4
Plant 9 Cylinder Shed	9 E	4	Chlorination Building	25 A	4
Electrostatic Precipitator	9 F	3	M.H.#175/Eff. Line/Sampling Bldg.	25 B	4
Boiler Plant	10 A	4	Sewage Lift Station Building	25 C	4
Boiler Plant Maintenance Bldg.	10 B	4	U.V. Disinfection Building	25 D	4
Wet Salt Storage Bin	10 c	4	Digester & Control Building	25 E	4
Cont. Oil/Graphite Burn Pad	10 D	8	Sludge Drying Beds	25 F	11
Primary Settling Basins	25 G	11	Plant 2 West Pad	74 B	8
Trickling Filters	25 H	5	Plant 8 East Pad	74 C	8
10-Plex Sewage Lift Station	25 J	10	Plant 8 West Pad	74 D	8
Pump House-HP Fire Protection	26 A	4	Plant 4 Pad	74 E	8
Elevated Water Storage Tank	26 B	5	Plant 7 Pad	74 F	8
Main Electrical Strainer House	26 C	4	Plant 5 East Pad	74 G	8
Security Building	28 A	1	Plant 5 South Pad	74 H	8
Human Resources Building	28 B	1	Plant 6 Pads	74 G	8
Guard Post on South End of 'D' St.	28 C	1	Plant 9 Pad	74 K	8
Guard Post on West End of 2nd St.	28 D	4	Building 65 West Pad	74 L	8
Chemical Warehouse	30 A	2	Building 64 East Pad & R.R. Dock	74 M	8
Drum Storage Warehouse	30 B	2	Building 12 North Pad	74 N	8
Old Ten Ton Scale	30 C	8	Decontamination Pad	74 P	8
Engine House/Garage	31 A	3	Plant 8 Old Metal Dissolver Pad	74 Q	8
Old Truck Scale	31 B	8	Plant 8 North Pad	74 R	8
Magnesium Storage Building	32 A	2	Building 63 West Pad	74 S	8
Building 32 Covered Loading Dock	32 B	2	Plant 1 Storage Pad	74 T	8
Pilot Plant Annex	37	3	Pilot Plant Pad	74 U	8
Propane Storage	38 A	4	Laboratory Pad	74 V	8
Cylinder Filling Station	38 B	9	Building 39A Pad	74 W	8
Incinerator Building	39 A	3	Finished Products Warehouse(4A)	77	2
Waste Oil Decant Shelter	39 B	3	D & D Building (Under Constr.)	78	4
Incinerator Sprinkler Riser House	39 C	4	Plant 6 Warehouse	79	2
Sewage Treatment Plant Incinerator	39 D	9	Plant 8 Warehouse	80	2
Rust Engineering Building	45 A	1	Plant 9 Warehouse	81	2
Utility Shed East of Rust Trailers	45 B	4	Receiving/Incoming Mat'ls. Insp.	82	2
Heavy Equipment Building	46	4	Clearwell Line	88	10
Six to Four Reduction Facility #2	51	4	Parking Lot	89	8
Health & Safety Building	53 A	1	Skeet Range Building	90	1
In-Vivo Building	53 B	1	Railroad Tracks	G-001	8
Six to Four Reduction Facility #1	54 A	3	Roads	G-002	8
Pilot Plant Shelter	54 B	2	Storm Sewer System	G-003	10
Pilot Plant Dissociator Shelter	54 C	4	Utility Lines	G-004	10
Slag Recycling Building	55 A	3	Underground Storage Tanks	G-005	6
Slag Recycling Pit/Elevator	55 B	3	Process Trailers	G-006	1
CP Storage Warehouse	56 A	2	Non-process Trailers	G-007	1
Storage Shed (West)	56 B	2	Pipe Bridges	G-008	9
Storage Shed (East)	56 C	2	Drums (Non-RCRA)	G-009	5
Quonset Hut #1	60	2	RCRA Drums	G-010	5
Quonset Hut #2	61	2	Inventory	G-011	5
Quonset Hut #3	62	2	Mobile Containers (Sea-Land)	G-012	5
KC-2 Warehouse	63	2	Soil Piles	G-013	7
Thorium Warehouse	64	2	Rock salt pile	P-001	7
(Old) Plant 5 Warehouse	65	2	Sand piles	P-002	7
Drum Reconditioning Building	66	3	Gravel pile	P-003	7
Plant 1 Thorium Warehouse	67	2	Copper metal scrap pile	P-004	7
Pilot Plant Warehouse	68	2	Coal pile	P-005	7
Decontamination Building	69	3	Scrap metal pile	P-006	7
General In-Process Warehouse	71	2	Outside Equipment Storage Area	P-007	7
Drum Storage Building	72	2	Tension Support Structure #1	TS-001	2
Fire Brigade Training Center Bldg.	73 A	1	Tension Support Structure #2	TS-002	2
Fire Training Pond	73 B	11	Tension Support Structure #3	TS-003	2
Fire Training Tank	73 C	5	Tension Support Structure #4	TS-004	2
Fire Training Burn Trough	73 D	6	Tension Support Structure #5	TS-005	2
Confined Space Burn Tank	73 E	5	Tension Support Structure #6	TS-006	2
Plant 2 East Pad	74 A	8

The 11 categories are defined as follows:

Category 1. Administrative/Support Buildings

Category 2. Warehouse/Storage Buildings

Category 3. Process Buildings

Category 4. Process Support Buildings

Category 5. Containers/Containerized Material, Above-ground (includes all drums) — Category 5 includes all above-ground containers (whether empty or not) and containerized material; all waste and product inventories, including hold-up material; and all uranium, thorium inventories. Category 5 does not include tanking/piping/ distribution systems or bulk stored materials.

Category 6. Containers/Containerized Material, Below-ground — As for Category 5, except components are below-ground.

Category 7. Bulk Material (includes waste piles) — Category 7 includes all existing scrap piles, copper piles, soil piles, and similar items within OU3. It also is intended that this category will include any newly generated soil piles, rubble piles, and the like that result from ongoing activities both in and out of the scope of OU3.

Category 8. Storage Pads/Parking Lot/Roads/Railroads — Category 8 consists of waste storage or handling pads, railroads, roads, the parking lot, and sidewalks.

Category 9. Piping/Utilities/Equipment, Above-ground — Category 9 includes all above-ground piping and utility systems, including outside tank and distribution systems.

Category 10. Piping/Utilities/Equipment, Below-ground — Category 10 includes all underground piping and utility systems.

Category 11. Ponds and Basins — Category 11 includes surface impoundments, ponds, and basins. The largest of these are the biodenitrification surge lagoon and the storm-water retention basins.

2.3 Description of Removal Actions

Several EPA approved removal actions are currently in progress. These removal actions, as defined in the Amended Consent Agreement (EPA 1991), represent the major projects and will be coordinated and integrated with the proposed interim remedial action. The removal actions are grouped in four categories according to their relationship with the interim action. Each removal action is described in the subsections below.

2.3.1 OU3 Removal Actions Completed Before Interim Action

The following removal actions are anticipated to be complete prior to initiation of the interim action. Some of these removal actions will support the RD/RA work plan design and scheduling. Each of the removal actions detailed in this section have previously obtained NEPA approval through categorical exclusions or Environmental Assessments.

2.3.1.1 Removal No. 7 -- Plant 1 Pad Continuing Release

This interim action was initiated to mitigate the continuing release of contaminants from Plant 1 Pad until final remediation. This removal action was approved in 1991 in the Amended Consent Agreement and involves three stages of activity: (1) interim runoff control; (2) soil removal, new pad addition, and covered, controlled storage pad construction; and (3) installation of sealed concrete over existing contaminated concrete.

2.3.1.2 Removal No. 13 -- Plant 1 Ore Silos

This removal action involves the dismantling of the Plant 1 ore silos and their support structures. Deteriorated valves caused the silos to leak material onto a concrete pad in February 1992. Remaining material in the silos will be removed, containerized, and placed in safe storage pending final disposition. All 14 silos and support structures will be dismantled and demolished.

2.3.1.3 Removal No. 14 -- Contaminated Soils Adjacent to Sewage Treatment Plant Incinerator

To prevent any potential contaminant migration, this removal action involved the characterization, removal, containerization, storage, and disposal of soils with elevated uranium levels in the vicinity of an out-of-service solid waste incinerator at the sewage treatment plant.

2.3.1.4 Removal No. 15 -- Scrap Metal Piles

This removal action is intended to stabilize and disposition low-level radioactive waste scrap metal currently stockpiled outdoors at the FEMP site. The action is designed to eliminate potential for releases of contaminants to the environment from 1179 metric tons (1300 tons) of scrap copper and approximately 2722 metric tons (3000 tons) of other recoverable scrap metals.

2.3.1.5 Removal No. 19 -- Plant 7 Dismantling

The Plant 7 Dismantling removal action will address the potential for release of contaminants through decontamination and dismantlement of the Plant 7 structure and allow evaluation of decontamination and dismantling methodology for future CRU3 work. Field work is scheduled to begin in fiscal year 1994 and continue into fiscal year 1996. Any beneficial experience gained will be applied in the Remedial Design/Remedial Action Work Plan for the interim remedial action. Some material dismantled from this structure will be utilized in OU3 treatability studies.

2.3.1.6 Removal No. 20 -- Stabilization of Uranyl Nitrate Inventories

This removal action is designed to process uranyl nitrate inventories at the FEMP site to a stable form which can be drummed and stored in warehouses pending final disposition. There are approximately 871 m3 (230,00 gal.) of acidic uranyl nitrate stored in 21 tanks in or near the Plant 2/3 refinery. A 1991 inspection of the tanks revealed that small leaks had developed in the piping system associated with the tanks.

2.3.1.7 Removal No. 24 -- Pilot Plant Sump

This removal action is concerned with an out-of-service sump at the Pilot Plant. The below-grade sump is a stainless steel cylinder approximately 0.6 m (2 ft) in diameter and 3 m (10 ft) deep which was installed to remove liquids from the floor drains of the Pilot Plant during a 1969 renovation. Sludges and liquids from the sump have high concentrations of lead, copper, chromium, nickel, thorium, and volatile organic compounds. The sump will be removed and its piping disconnected. The drain piping will be checked, the drain system plugged, and adjacent soils cleaned up as required.

2.3.1.8 Removal No. 25 -- Nitric Acid Tank Car and Area

This removal action is intended to remove the residual contents of a nitric acid railroad tank car, decontaminate and dispose of the tank car itself, and address potentially contaminated soils adjacent to the tank car. The tank car, which stored nitric acid from 1952 to 1989, has a capacity of 43,359 kg (100,000 lb) and now contains approximately 0.38 m3 (100 gal.) of dilute nitric acid.

2.3.1.9 Removal No. 27 -- Management of Contaminated Structures

Removal No. 27 was initiated to minimize the risk from uncontrolled release of contaminants from 25 structures within OU3. This removal action involves the decontamination and dismantlement of 25 of the same components that are included in the scope of this Proposed Plan. Upon approval of the Proposed Plan, this removal action will be incorporated into the scope of the interim remedial action.

2.3.1.10 Removal No. 28 -- Fire Training Facility

This removal action is intended to remove contamination associated with the Fire Training Facility (Building 63) structures, equipment, surficial soils, and surface water. Prior to dismantling and removal activities, all liquids will be removed from the open top tank, the skid tank pond, the sump, and the horizontal pressure vessel end piece. These liquids will be treated prior to disposal. Each of these structures, in addition to the block building and asphalt pad, will be demolished and removed for disposal. Recycling or disposal of the structure materials (debris) will be managed in accordance with Removal No. 17 and Removal No. 9.

2.3.2 OU3 Removal Actions Ongoing and Unrelated to the Interim Action

These removal actions are programmatic in nature and represent actions being applied to OU3 as a whole. The Removal of Waste Inventories and Asbestos Abatement programs are unconnected to the interim action because they would occur and be completed within specific components before implementation of the interim action. Both of these programs have received NEPA approval.

2.3.2.1 Removal No. 9 -- Removal of Waste Inventories

Since 1986, low level wastes generated by production, maintenance, and construction activities at the FEMP have been containerized and stored for future disposition. At that time, the FEMP was also the DOE repository for thorium materials, maintaining an inventory of over 15,000 containers. Much of this thorium remains in storage at the FEMP. Removal No. 9 was initiated to establish waste management procedures and to implement packaging, shipment, and disposal of these materials at the Nevada Test Site (NTS). Activities under this removal action comply with all EPA and Department of Transportation (DOT) regulations, DOE Orders, and NTS waste-acceptance criteria. For the interim remedial action, it is assumed that all inventories addressed by this removal action would be previously removed from buildings, facilities, or structures prior to beginning decontamination and dismantlement activities.

2.3.2.2 Removal No. 26 -- Asbestos Abatement Program

The Asbestos removal action documents asbestos abatement activity at the FEMP to mitigate potential asbestos release and migration. Abatement within this program includes in-situ repairs, encasement and encapsulation, and removals. Actions under this removal action are a necessary step prior to initiation of decontamination and dismantlement activities. It is assumed that only transite and other non-friable Asbestos Containing Materials (ACM) will remain within the buildings, facilities, or structures after completion of this removal action. Air monitoring for occupational protection purposes showed no levels as high as the 0.2 fiber/cc limit for occupational exposure. ACM removal under the interim remedial action will be in accordance with this removal action.

2.3.3 OU3 Removal Actions Related to the Interim Action

Two actions are directly related to the interim action proposed; these actions are EPA-approved removal actions and impact or are significantly impacted by activities under this Proposed Plan. The two removal actions are Safe Shutdown (Removal No. 12) and Improved Storage of Soil and Debris (Removal No. 17). Safe Shutdown is a related activity because Safe Shutdown activities must occur and be completed before the interim remedial actions can be implemented on a component basis. Improved Storage of Soil and Debris is a related activity, which provides the management structure for interim storage of debris from the proposed action. These two removal actions, their NEPA compliance status, and their impacts on this Proposed Plan are described in the following sections and in Appendices E and F.

2.3.3.1 Removal No. 12 -- Safe Shutdown

This removal action was created to perform the safe shutdown of all process facilities in preparation for final remediation. Safe Shutdown entails the engineering, planning, scheduling and the actual isolation of process equipment, piping systems, and associated utilities and the removal of residual process materials (e.g. equipment hold-up) and other excess materials, supplies, and combustibles to appropriate disposition and approved storage locations. Activities associated with the interim remedial action would be coordinated with the Safe Shutdown schedule to allow scheduled Safe Shutdown activities to precede or be incorporated with activities of the interim remedial action. The NEPA review for Safe Shutdown activities was a categorical exclusion.

2.3.3.2 Removal No. 17 -- Improved Storage of Soil and Debris

Improved Storage of Soil and Debris was initiated to provide controlled storage of excess contaminated soils and debris generated during maintenance, construction, removal, and remedial actions at the FEMP. This removal action includes the implementation of a soil and debris management plan and the installation of a number of tension support structures (TSS). Removal No. 17 would provide a scrap metal pad cover (16,000 ft2), a decontamination facility pad cover (10,000 ft2), and a 40,000 ft2 CSF. Five storage facilities in addition to the CSF would be needed to support interim waste storage from activities under this Proposed Plan. The NEPA review for the scrap metal pad cover and the decontamination facility pad cover was a categorical exclusion. However, additional documentation is needed to complete the NEPA review for the CSF; this documentation is being provided as part of this Proposed Plan. Although EPA has approved Removal No. 17, construction of the CSF cannot begin until the NEPA review by DOE is completed.

To facilitate the NEPA review, construction and operation of the CSF has been included within the scope of Alternative 3 in this Proposed Plan. Appendix E contains details of the CSF and the risks involved in construction and operation.

2.3.4 Removal Actions Ongoing in Other Operable Units

Removal actions outside of OU3 requiring integration are discussed below. For each, integration with the OU3 interim action is necessary to continue to provide services for related facilities or to schedule facility dismantlment around removal action activities. The two removal actions are Contaminated Water beneath FEMP Site Buildings (Removal No. 1) and South Groundwater Contamination Plume (Removal No. 3). Both of these removal actions are within Operable Unit 5.

2.3.4.1 Removal No. 1 -- Contaminated Water Beneath FEMP Site Buildings

The purpose of this removal action is to minimize the potential for uranium-contaminated perched groundwater in zones beneath some former production buildings to infiltrate the underlying aquifer. A series of wells have been installed to extract the contaminated perched groundwater from within the Production Area. The contaminated water is pumped to a treatment system within Plant 8 to remove volatile organic compounds and is then processed through the existing wastewater treatment system and discharged to the Great Miami River.

2.3.4.2 Removal No. 3 -- South Groundwater Contamination Plume

This removal action is designed to protect public health by actively addressing the uranium-contaminated groundwater in an area south of the FEMP site. The action consists of five parts. Part 1, activated in May 1992, provides an alternate water supply to an industrial user affected by the contamination plume. Part 2, initiated in July 1992, consists of the installation of a recovery well system to remove and pump the contaminated water to the FEMP site for treatment, monitoring, and discharge. Part 3 is construction of an interim advanced wastewater treatment system to remove uranium from FEMP site wastewater streams. Part 4, implemented through the FEMP's existing groundwater monitoring program, involves monitoring and institutional controls to prevent the use of contaminated groundwater by including more frequent monitoring of private wells located near areas of known contamination. Part 5 is additional investigations to identify the location and extent of any remaining contamination attributable to the FEMP site south (downgradient) of the recovery wells being installed under Part 2.

2.4 Nature and Extent of Contamination

The processes and operations within the former Production Area at the FEMP required the use of a variety of source feed materials and other radioactive and chemical reactants for both production and secondary operations. The production operations also generated a wide variety of waste materials containing both radiological and chemical constituents. During operations at the FEMP, material handling procedures resulted in chemical and radiological contamination within some OU3 components. As a result, these components may serve as current and future sources environmental contamination.

As data becomes available through the OU3 Field Characterization Program, it will be incorporated into the action proposed in this document. Early field sampling results will be available for development of the Remedial Design/Remedial Action Work Plan. The majority of field sampling data will become available for development of bid packages for vendor procurement and final design.

The following subsections, supported by Appendix B, present an overview of existing information on chemical and radiological contamination associated with the OU3 components. This summary is based upon data presented in the OU3 RI/FS Work Plan Addendum wherein additional information is available. The risk assessments and evaluations presented in this document are based on existing data and information available at the time of the document development.

Table 2-2 presents the OU3 RI/FS analyte list as developed in the OU3 RI/FS Work Plan Addendum for the characterization program. This list represents the standard EPA analyte list used for environmental characterizations with the addition of the radionuclides associated with the site. Many of the compounds included on this list have not been identified on this site, and are not expected to be found during the characterization program. Because of the nature of the uranium processing activities at the site, the predominant concerns would normally be radionuclides, inorganics, and solvents/degreasers (volatile organics). Because production ceased nearly three years earlier, the potential presence of volatile organics in the matrices associated with the structures is unlikely.

2.4.1 Radiological Contamination

Historical information and process knowledge, as detailed for each OU3 component in Table B-1, indicate that the primary radiological contaminants in OU3 are uranium (isotopes 234, 235, 236, 238, and, to a lesser degree, 233), thorium (isotopes 228, 230, and 232), radium (isotopes 226 and 228), and the associated daughters, including isotopes of lead and polonium. Additional radionuclides within OU3 that have been identified through analysis include isotopes of neptunium, plutonium, technetium, strontium, cesium, and americium. Table 2-2 lists the RI/FS analytes, including radionuclides, as developed for the OU3 RI/FS Work Plan Addendum.

Table B-1 in Appendix B lists potential radiological contaminants for each component within OU3; Tables B-2 presents a summary of radiological smear and direct survey samples by component; and Table B-3 presents airborne alpha and beta concentrations.

Through the ongoing radiation protection program at the FEMP, radiological data on most components is available. As part of this program, the following types of radiological information are collected:

× radiological smear and direct measurements for many individual OU3 components;

× smear and direct survey information on some abandoned in-place equipment;

× radon-222 and radon-220 monitoring; and

× airborne alpha and beta-emitting concentrations.

It should however, be noted that all of these types of information are not available at the current time for every component within OU3.

TABLE 2-2 OU3 RI/FS Analyte List
Radionuclides
Isotopic uranium
Isotopic thorium
Isotopic plutonium and 241
Radium-226 and 228
Neptunium-237
Americium-241
Cesium-137
Strontium-90
Lead-210
Polonium-210
Technetium-99
Alpha/Beta Screening

TAL Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide⁽¹⁾

TCL Semi-Volatile Organics
1,2-Dichlorobenzene
1,2,4-Trichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2-Chloronaphthalene
2-Chlorophenol
2-Methylnaphthalene
2-Methylphenol
2-Nitroanilene
2-Nitrophenol
2,2-Oxybis-(1-chlororpropane)
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,6-Dinitrotoluene
3-Nitroaniline
3,3-Dichlorobenzidine
4-Bromophenyl-phenyl ether
4-Chloro-3-methylphenol
4-Chloroaniline
4-Chlorophenyl-phenyl ether
4-Methylphenol
4-Nitroaniline
4-Nitrophenol
4,6-Dinitro-2-methylphenol
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
bis(2-Chloroethyl) ether
bis(2-Chloroethoxy) methane
bis(2-Ethylhexyl)phthalate
Butylbenzylphthalate
Carbazole
Chryzene
Dibenzofuran
Dibenzo(a,h)anthracene
Diethylphthalate
Dimethylphthalate
Di-n-butylphthalate
Di-n-octylphthalate
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Ideno(1,2,3-cd)pyrene
Isophorone
Napthalene
Nitrobenzene
N-Nitroso-di-n-dipropylamine
N-Nitrosodiphenylamine Pentachlorophenol
Phenanthren
Phenol
Pyrene

TCL PCBs
Arochlor-1016
Arochlor-1221
Arochlor-1232
Arochlor-1242
Arochlor-1248
Arochlor-1254
Arochlor-1260

TCL Volatile Organics
1,1-Dichloroethane
1,1-Dichloroethene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
1,1,2,2-Tetrachloroethane
1,2-Dichloroethane
1,2-Dichloroethene (total)
1,2-Dichloropropane
2-Butanone
2-Hexanone
4-Methyl-2-pentanone
Acetone
Benzene
Bromodichloromethane
Bromoform
Bromomethane
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
cis-1,3-Dichloropropene
Dibromochloromethane
Ethylbenzene
Methylene chloride
Styrene
Tetrachloroethene
Toluene
Total Xylenes
trans-1,3-Dichloropropene
Trichloroethene
Vinyl Chloride TCLP Metals
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver

TCLP Semi-Volatile Organics
1,4-Dichlorobenzene
2,4-Dinitrotoluene
Hexachlorobenzene
Hexachloroethane
Hexachloro-1,3-butadiene
Nitrobenzene
Pentachlorophenol
Pyridine
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
o-Cresol
m-Cresol
p-Cresol

TCLP Volatile Organics
Benzene
Carbon tetrachloride
Chlorobenzene
Chloroform
2-Butanone
1,2-Dichloroethane
1,1-Dichloroethylene
Tetrachloroethylene
Trichloroethylene
Vinyl chloride

¹ Requested only in components with history of cyanide usage.

2.4.2 Chemical Contamination

Data on chemical contamination within OU3 is presented in Appendix B. This information is based on chemical analyses and process knowledge of all operations over a period of 38 years. The following subsections provide further information on chemical contamination within OU3. Additional data will be gathered as part of ongoing RI activities. As available, this data will be integrated with the remedial design activities to implement the interim action.

2.4.2.1 Hazardous Waste Management Units

The Resource Conservation Recovery Act (RCRA) program at the FEMP has identified a total of 53 Hazardous Waste Management Units (HWMUs) of which 48 HWMUs are located within OU3. After further investigation, several of the 48 units have been declared non-HWMUs (i.e., evidence does not support the original declaration as a HWMU). Five of the remaining units have already been through closure or are currently undergoing closure. Closure of interim status HWMUs is currently achieved by submitting a Closure Plan Information and Data (CPID) package to Ohio EPA for review and approval.

At the present time, 32 interim status RCRA HWMUs located in OU3 and listed in Table 2-3 require closure under requirements of Subpart G of 40 CFR 265 (OAC 3745-66-10 through 3745-66-20). Under this Proposed Plan, all substantive requirements of the Applicable or Relevant and Appropriate Requirements (ARARs) for closure of these HWMUs will be addressed under CERCLA interim remedial action. The Remedial Design/Remedial Action Work Plan(s), site procedures, and other documents will be submitted to Ohio EPA for review. Closure Plan Information and Data packages will be submitted to Ohio EPA for review and approval until such time as Ohio EPA approves integrated closure documentation.

Remedial Design/Remedial Action Work Plans, site procedures, and other documents meeting substantive requirements of RCRA ARARs will be submitted to Ohio EPA for review and comment. Closure of the HWMUs will be accomplished as part of the interim remedial action for OU3, and as part of the final remedial actions for OU3 and OU5. Discussions with representatives of OEPA are currently ongoing to successfully integrate RCRA closure activities with CERCLA removal/remediation actions.

Seven active HWMUs (listed in the FEMP 1991 RCRA Part B Permit Application) are a part of OU3. Although these active HWMUs (see Table 2-3) are within OU3, clean-up actions are being deferred from being performed under the interim ROD until closure under RCRA is complete. When these seven "permit pending" active HWMUs are no longer needed to store FEMP mixed waste, they will be closed under requirements of Subpart G of 40 CFR 264 (OAC 3745-55-10 through 3745-55-20). Upon completion of RCRA closure requirements for the seven active HWMUs, they will be remediated under the interim remedial action.

2.4.2.2 Other Chemical Contamination

The available information on potential chemical contaminants associated with individual components within OU3 is presented in Appendix B. The information presented in Appendix B is qualitative in nature and based upon information developed in the OU3 Work Plan Addendum (DOE 1993b). It should be emphasized that the information presented in Appendix B represents potential contamination which may be present in the components.

An examination of the information presented in Table B-1 of Appendix B reveals several classes of chemical or contaminant groups of potential environmental concern in OU3. Principal chemical contaminant groups of concern are trace metals, other inorganics, volatile organic compounds (VOCs), semivolatile organics compounds (SVOCs), polychlorinated biphenyls (PCBs), and other materials such as oils for lubricating and heat treating. Based on the materials used at the site during operations, it is expected that radiological contaminants are a more significant source of carcinogenic risk than chemical contaminants.

Field characterization activities are scheduled to precede the interim remedial action. The results of the field characterization will be evaluated for use during development of the Remedial Design/Remedial Action Work Plan for the interim remedial action. Data will be integrated into health and safety requirements and the design process, consisting of monitoring, decontamination, dismantlement, packaging, transportation, and storage systems. Extensive use of appropriate field monitoring equipment (PID, XRF) will be employed during field implementation of the interim action to prevent exposure of workers to concealed chemical contamination.

In addition to the chemical contaminants discussed above, many of the components have been identified as having asbestos containing material (ACM). The analyses of bulk samples (Diagnostic Engineering Inc., 1992) however, indicate wide variations in the percentages of samples displaying positive ACM analysis results. This data is presented in the OU3 RI/FS Work Plan Addendum.

TABLE 2-3 Operable Unit 3 Hazardous Waste Management Units

HWMU # ^a	HWMU Description
	INTERIM STATUS UNITS
1	Fire Training Facility
3	Waste Oil Storage in Garage
4	Drum Storage Area Near Loading Dock (LAB)
5	Drum Storage Area South of W-26 (LAB)
6	Drummed HF Residue Storage Inside Plant 4
7	Drummed HF Residue Storage NW of Plant 4
8	Drummed HF Residue Storage South of Cooling Tower
9	Nitric Acid Rail Car and Area
10	NAR System Components
11	Tank Farm Sump
12	Wheelabrator - Building 66
13	Wheelabrator Dust Collector - Building 66
14	Box Furnace
15	Oxidation Furnace #1
16	Primary Calciner
17	Plant 8 East Drum Storage Pad
18	Plant 8 West Drum Storage Pad
21	Hilco Oil Recovery
22	Abandoned Sump West of Pilot Plant
25	Plant 1 Storage Building - Building 67
26	Detrex Still
28	Trane Thermal Liquid Incinerator
38	HF Tank Car
40	Bio-Surge Lagoon
41	Sludge Drying Beds
46	UNH Tanks - NFS Storage Area
47	UNH Tanks - North of Plant 2
48	UNH Tanks - Southeast of Plant 2
49	UNH Tanks - Digestion Area (2 Locations)
50	UNH Tanks - Raffinate Building (2 Locations)
52	North and South Solvent Tanks (Pilot Plant)
53	Safe Geometry Digestion Sump (Plant 1)
PART B PERMIT (Active Units)
19	CP Storage Warehouse - Building 56 (Butler Building)
20	Plant 1 Pad
29	Plant 8 Warehouse (Building 80)
33	Pilot Plant Warehouse (Building 68)
34	KC-2 Warehouse (Building 63)
35	Plant 9 Warehouse (Building 81)
37	Plant 6 Warehouse (Building 79)

^a HWMU numbers as listed on RCRA Part A Permit Application
HWMUs closed or undergoing closure: HWMU # 27, 30, 31, 32, 36
HWMUs declared non-HWMUs. (Ohio concurrence pending on some units): HWMU # 2, 23, 24, 39, 43, 44
HWMUs contained in other operable units: HWMU # 42, 45, 51

2.4.3 Mixed Waste

Mixed wastes are hazardous (RCRA) wastes that have been contaminated with radiological wastes. Radiological contamination appears to be relatively widespread throughout many components in OU3. On the basis of the information on materials handling practices and the potential chemical contamination discussed in Section 2.4.2, it is possible that some of the materials and wastes associated with OU3 components may fall into the category of mixed waste. The volumes of material included in this category are currently uncertain.

2.5 Summary of Risks for Operable Unit 3

As discussed in Section 2.2, OU3 consists of a large number of structures, including the process and support facilities at the FEMP, a large quantity of drummed inventory and waste, and various piles of materials. The process facilities, in particular, are complex structures that contain equipment, process lines, outside dust collectors, and various tanks, sumps, and dikes. OU3 contains no environmental media except for previously excavated soil piles; the contaminated media in OU3 are generally the construction materials contained in the structures. Although DOE maintains an active maintenance program, the facilities in OU3 are generally at or beyond their design lives and in a state of advancing deterioration. For example, long-term exposure to nitric acid fumes and splashes from the uranium digestion process contained in Plant 2/3 has eroded the support structure. Additionally, areas of Plant 6 and the thorium storage buildings (64 and 65) are in a deteriorated state and provide insufficient protection of their contents from the elements. Various sumps, such as one west of the former Pilot Plant, contain contaminants that could potentially be released to soils or groundwater. Significant maintenance and renovation would be required in the future simply to maintain the integrity of various structures.

On the basis of process knowledge, the most significant potential contaminants in OU3 are expected to be uranium and thorium and their decay products, along with various trace metals, solvents, PCBs, and asbestos. These contaminants are expected to be located primarily in the former process buildings and in waste residues. Section 2.4 summarizes the nature and extent of contamination in OU3.

Under current conditions, the primary routes by which individuals could be exposed to OU3 contaminants are direct exposure to and direct contact with the contaminants present in the OU3 components. In addition, small quantities of contaminants, such as uranium dust, can be released to the air and contaminants can be discharged to surface water from sources in the operable unit. A potential also exists for releases of contaminants to groundwater from building sumps or other contaminated areas.

Exposures of on-site workers and site visitors to contaminants are occurring as well as the exposure of any trespassers in OU3. However, because DOE controls access to the site, trespassers are not expected to have access to contaminated areas in OU3. Nearby off-site residents and users of foodstuffs produced near the site are potentially exposed to the small quantities of contaminants that are released from OU3. The major current concern associated with the presence of contamination in OU3 is for the exposure of on-site workers.

Risks associated with exposures to OU3 contaminants are currently low. It is estimated that a hypothetical maximally exposed off-site individual currently receives a total annual radiological dose from the FEMP (exclusive of the dose received from radon, which originates primarily from non-OU3 sources) of about 1 millirem (DOE 1993d). This dose corresponds to a risk of about 6 x 10-7 that such a hypothetical individual will develop cancer as a result of the exposure. This dose is equivalent to that received by an individual flying in an airplane at 39,000 feet for approximately two hours due to natural radiation exposure. Because OU3 contributes only a fraction of the 1 millirem dose from the site as a whole, this estimate provides an upper bound on the carcinogenic risk to an off-site individual that results from radiological contaminants from OU3. This is a small fraction of the dose received by the individual as a result of exposure to natural background radiation. Radiological doses to individuals currently working on-site are limited by DOE's own standards and are relatively low in comparison. They are also within regulatory limits. However, doses and risks to a hypothetical trespasser could be higher if it is assumed that such an individual has frequent and/or prolonged exposure to areas of highest contamination in the operable unit. Carcinogenic risks associated with exposures to chemicals are expected to be less than the risks associated with the exposures to radiological contaminants, on the basis of the materials utilized at the site. Non-carcinogenic effects of exposures to chemical contaminants have not been quantified but are also expected to be low. In its current state, OU3 poses no significant threat to human health as long as access controls of contaminated areas are maintained and facilities and waste storage systems are maintained.

More significant releases of contaminants and resulting exposures could occur in the future if no remediation of OU3 is undertaken. The major concern for OU3 is the potential for increased future risks as components deteriorate, increasing the potential for the release of contaminants. Actual or threatened release of hazardous substances from OU3, if not addressed by the preferred alternative or one of the other active measures considered, may present a current or potential threat to public health, welfare, or the environment.

3.0 REMEDIAL ACTION ALTERNATIVES

Interim remedial action alternatives were developed in accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR 300) and EPA's Guidance for Conducting RI/FS Under CERCLA (EPA 1988). The values of NEPA were incorporated into the alternative-development process. The No Action Alternative (Alternative 0) was included in the document in accordance with the requirements of NEPA (10 CFR 1021.321 (c)). The following subsections identify the remedial action alternatives considered under this Proposed Plan.

3.1 Alternative 0 -- No Action

The "No Action" alternative describes an "as is" condition of all components in OU3 with no further action occurring. Under this alternative, none of the approved removal actions, other future remedial actions, or maintenance activities would be implemented. All components would be abandoned and allowed to further deteriorate, with increased probability for releases of radioactive and other contaminants to the environment.

Therefore, the No Action Alternative would not meet the NCP threshold criterion for overall protection of human health and the environment. Because it does not meet the threshold criterion, the No Action Alternative will receive no further evaluation or discussion in this Proposed Plan.

3.2 Alternative 1 -- No Interim Action

The "No Interim Action" Alternative involves the continuation of all currently approved programs. No acceleration of site remediation would occur under this alternative. This alternative assumes that existing and approved removal actions and site maintenance programs will continue. As required, additional removal actions may be proposed to minimize potential risks. Final remedial action for OU3 components would be determined in the final ROD, presently scheduled for submittal in draft to EPA in April 1997. Analysis of this alternative also satisfies the NEPA "No Action" Alternative analysis requirement.

3.3 Alternative 2 -- Decontaminate Surfaces Only

Alternative 2 involves in-situ gross decontamination of interior and exterior surfaces of OU3 above-grade components and disposition of generated wastes through existing waste programs. In-situ decontamination of facilities within OU3 would be pursued to minimize releases of contaminants to the environment. This alternative would reduce existing surface contamination levels, thereby reducing direct exposure potential, as well as reducing available sources for wind-born or water-born contamination. All previously approved programs, maintenance activities, and presently approved removal actions would continue under this alternative. As required, additional removal actions might be proposed to further minimize potential risks. No further containment, stabilization, or removal of contamination within components would be included in the scope of this alternative.

Decontamination activities for a component would be initiated after completion of Safe Shutdown activities in the component. Safe Shutdown would carry out necessary actions that must precede the decontamination of the former process facilities. Safe Shutdown for a given facility can, generally, be described as the removal of stored product inventories, de-energization and lock-out of process equipment, and the removal and transfer of salable equipment to off-site vendors.

The methods that would be used for removing gross surface contamination would depend on the type and level of contamination present and the matrix it is found on (for example concrete block, transite, steel, etc). Surface decontamination measures would be used to remove contamination from interior and exterior walls, floors, ceilings, and structural members. Vacuum systems and/or directed air flow would be utilized in order to reduce the potential for contaminant release and migration during the decontamination activities. Table 3-1 lists a variety of proven, potential decontamination technologies that would be effective for use with the implementation of the action. The ultimate selection of decontamination technologies would not be limited to these listed. New and/or innovative technologies developed from the OU3 RI/FS Treatability Studies would be incorporated into the process as appropriate.

Secondary liquid and/or solid waste streams generated during implementation of Alternative 2 would be treated to the extent feasible using existing site systems in a manner fully compliant with identified ARARs and TBCs in order to help facilitate the action in a manner which is timely and protective of human health and the environment. Within HWMU areas, decontamination actions would be separated from actions in non-HWMU areas to minimize generating mixed wastes.

Environmental monitoring would be conducted during all activities associated with Alternative 2. The approach used for monitoring and the contingency measures that would be used if increased concentrations of airborne contaminants were detected during implementation of the alternative would be similar to those discussed below for Alternative 3.

On the basis of projected funding levels, it is estimated that decontamination activities would take about 4 years. Decontamination activities would require approximately 108 full-time workers. It is estimated that about 900,000 person-hours would be required to implement Alternative 2.

TABLE 3-1 Potential Decontamination Technologies

Technology	Media	Secondary Waste Stream
Brushing, scraping, wiping	Any solid	Dry residue
Scrubbing (manual or mechanical)	Concrete, metal, plastic, transite	Residue
Scabbling	Concrete	Concrete residue
Vacuuming	Any	Collected residue
Pressurized steam	Concrete, metal	Wet residue
Strippable coating	Any surface	Coating and contaminants
Water jet (high or low pressure)	Concrete, metal, plastic, transite	Contaminated water
Shot blasting	Metals, concrete	Shot and residue
Grit blasting	Metals, concrete	Grit and residue
CO2 pellet blasting	Concrete, metals, plastic, painted surfaces	Residue
Chemical foams, gels, pastes	Metals	Foams, gels, pastes, and removed contaminants

3.4 Alternative 3 -- Decontaminate and Dismantle

Alternative 3 primarily involves the decontamination

Weapons of Mass Destruction (WMD)

EA-0877; Operable Unit 3 - Proposed Plan for Interim Remedial Action Fernald Environmental Management Project

TABLE OF CONTENTS

LIST OF TABLES

Abbreviations, Acronyms, and Initials

Units of Measure