DOE/RL-2003-61
Rev. 0
100 Area and 300 Area
Component of the River
Corridor Baseline Risk
Assessment: Basis and
Assumptions on
Project Scope
United States
Department of Energy
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DOE/RL-2003-61
Rev. 0
100 Area and 300 Area
Component of the River Corridor
Baseline Risk Assessment:
Basis and Assumptions on
Project Scope
December 2003
United States Department of Energy
P.O. Box 550, Richland, Washington 99352
DOERL-2003-6 1
Rev . 0
TABLE OF CONTENTS
1.0
INTRODUCTION.............................................................................................................
1
2.0
GUIDING PRINCIPLES ..................................................................................................
2
2.1
CONSISTENCY WITH CERCLA DOCUMENTATION AND GUIDANCE...... 2
2.2
OPEN COMMUNICATIONS ................................................................................
3
3.0
SCOPING STATENZENTS AND ASSUMPTIONS .......................................................
3
4.0
DELIVEUBLES AND SCHEDULE.............................................................................
6
5.0
REFERENCES ................................................................................................................
12
FIGURES
1.
2.
3.
4.
Integrating the Assessments Across the Hanford Site......................................................... 8
Deliverable Documents and Risk Assessment Schedule for the 100 Area and 300 Area
Component of the River Corridor Baseline Risk Assessment............................................
9
River Corridor Baseline Risk Assessment Components................................................... 10
100 Area and 300 Area Component of the River Corridor Baseline Risk
Assessment Process........................................................................................................... 11
IO0 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
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ACRONYMS
CERCLA
DOE
DQO
Ecology
EPA
HAB
ISS
NPL
RCBRA
RL
ROD
SAP
Comprehensive Environmental Response, Compensation, and Liability Act of I980
U.S. Department of Energy
data quality objective
Washington State Department of Ecology
U.S. Environmental Protection Agency
Hanford Advisory Board
interim safe storage
National Priorities List
River Corridor Baseline Risk Assessment
DOE, Richland Operations Office
record of decision
sampling and analysis plan
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1.0 INTRODUCTION
The 100 and 300 Areas are two of four areas at the Hanford Site placed on the National Priorities
List (NPL) of waste sites in 1989 under authority of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA). The Hanford Federal Facility
Agreement and Consent Order (Tri-Party Agreement) (Ecology et al. 1998) was developed to
achieve compliance with CERCLA, including the SuperJfund Amendments and Reauthorization
Act of 1986 remedial action provisions, and the Resource Conservation and Recovery Act of
1976. In 1991, the Tri-Parties, which included the Washington State Department of Ecology
(Ecology), the U.S. Environmental Protection Agency (EPA), and the U S . Department of
Energy (DOE) agreed to a “bias for action” approach to the CERCLA process for all of
Hanford’s NPL sites, including the 100 Area and 300 Area. The agreement, known as the
Hanford Past-Practice Strategy (DOE-RL 199l), expedited the remedial investigation/feasibility
study process to start remediation earlier than under the traditional CERCLA process. Interim
action records of decision (RODS)were developed to define cleanup goals using qualitative risk
assessments and initiate the remediation process for the 100 Area and 300 Area waste sites.
One of the key evaluations needed to complete CERCLA actions is a baseline risk assessment to
determine what cleanup levels are protective of human health and the environment. A baseline
risk assessment characterizes the current and potential threats to human health and the
environment that may be posed by contaminants released into the environment.
To support final decision making and completion of the CERCLA process for the 100 Area and
300 Area, the DOE, Richland Operations Office (RL) is conducting a baseline risk assessment
that addresses all of the hazardous substances released from waste sites along the Columbia
River Corridor. The River Corridor Baseline Risk Assessment (RCBRA) will be a multi-step
process that will include the compilation of existing data, preparation of remedial investigation
work plans, identification of issues and data gaps through the data quality objective (DQO)
process, identification of appropriate receptors and endpoints, development of sampling and
analysis plans (SAPS), data collection and analysis, and calculation of risks
measurement endpoints specified in the DQO. Results of data collection, analysis, and risk
evaluation will be published in a final risk assessmenthemedial investigation report.
The DOE is responsible for assessing risks to human health and the environment from releases of
contaminants to the environment. Contaminants have been released at the Hanford Site for more
than 50 years, and contamination will remain onsite for thousands of years. DOE must assess the
risk from contaminants remaining onsite, as well as the offsite locations where contaminants
remain or will come to be located. The DOE fulfills this responsibility via several risk assessments
to address the various facets of this effort. One of the top priorities for risk work is the protection
of the Columbia River, including its ecological resources and the humans who use it. The scope
of the baseline risk assessment is to assess the risk to the upland, riparian, near-shore, and river
environments resulting from contaminant releases.
100 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
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The results of additional Hanford Site risk assessments and studies that will be included in the
RCBRA remedial investigation report include the following:
An evaluation of the impacts of 200 Area plumes reaching the 100 Area and 300 Area in the
future (see Figure 1).
o
A risk assessment of aquatic and riparian receptors at the 100-N Area, fulfilling an interim
action ROD requirement (EPA 1999b).
The 100-B/C Pilot Project study, which addresses the baseline risk assessment needs at the
100-B/C Area.
Data relevant to the RCBRA efforts that are gathered from the above-mentioned Hanford Site
assessment projects will be evaluated and integrated, as appropriate.
2.0 GUIDING PRINCIPLES
The following subsections outline the guiding principles for communications while conducting
the RCBRA, and identify the applicable state and federal guidance documents that are to be
followed.
2.1
CONSISTENCY WITH CERCLA DOCUMENTATION AND GUIDANCE
The RCBRA will follow and be consistent with CERCLA documentation, including the
following:
0
o
Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA
(EPA 1988).
Risk Assessment Guidance for Superfund: Volume I, Human Health Evaluation Manual
(EPA 1989).
Ecological Risk Assessment Guidancefor Superfund: Process for Design and Conducting
Ecological Risk Assessments (EPA 1997a).
0
EPA Region 10 Supplemental Ecological Risk Assessment Guidance for Superfund
(EPA 1997b).
Superfund Program Representative Sampling Guidance Volume 3: Biological (EPA 1997c).
Guidelines for Ecological Risk Assessment (EPA 1998).
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Ecological Risk Assessment and Risk Management Principles for Supel-fund Sites
(EPA 1999a).
Reuse Assessments: A Tool to Implement the Superfund Land Use Directive (EPA 2001).
To maintain consistency with state regulations, the assessment will also follow specific
provisions of the Model Toxics Control Act Cleanup RegulationsRerrestrial Ecological
Evaluation Procedures (WAC 173-340-7490 through 7494), as appropriate.
2.2
OPEN COMMUNICATIONS
Communications for this project will be conducted in accordance with the Community Relations
Plan for the Hanford Federal Facility Agreement and Consent Order (Ecology et al. 2002). The
following key principles of open communication were identified in meetings with the regulatory
agencies, the Tribes, the Hanford Advisory Board (HAB), and the Natural Resource Trustee Council.
The baseline risk assessment project will be an open process,
0
The project will actively consult with the Tribes in accordance with the provisions of the
“Structured Process,” which is being developed between RL and the Tribes.
0
The project will actively coordinate with the Natural Resources Trustee Council; a trustee
coordination plan is being developed.
0
The project will maintain an open dialogue to provide frequent updates and receive input
from interested parties, including the HAB and the public.
All the pertinent input will be considered by the risk assessment decision-makers (EPA,
Ecology, and DOE), who will make the final decision as to how the input is incorporated.
Portions of the assessment, where scientific conclusions are considered paramount, may also
be subjected to independent scientific review to resolve issues.
o
Response to input will be communicated back to the reviewers in a timely manner.
3.0 SCOPXNG STATEMENTS AND ASSUMPTIONS
The 100 Area and 300 Area component scoping process has been initiated through the
distribution and discussion of guiding principles and draft scoping statements in meetings with
the regulatory agencies, the Tribes, the HAB, and the Natural Resource Trustee Council. This
document, the 100Area and 300 Area River Corridor Baseline Risk Assessment: Basis and
Assumptions on Project Scope, presents these guiding principles and scoping statements to
facilitate development of the risk assessment. The scoping statements are designed to focus the
100 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
December 2003
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baseline risk assessment to the project area and pathways necessary to obtain final remedial
action RODs for the 100 Area and 300 Area NPL sites. Figure 2 shows a schedule for the major
tasks required to complete the assessment. The 100 Area and 300 Area component work plan
will provide a more detailed list of tasks, deliverables, and schedule that are required to complete
the project. The work plan, to be completed in 2004, will follow EPA CERCLA guidance. For
example, DOE will adhere to the following six principles for CERCLA and ecological risk
assessments per EPA (1999a).
1. Reduce ecological risks to levels that will result in the recovery and maintenance of healthy
local populations and communities of biota.
2. Coordinate with Tribes, Natural Resource Trustees, and the HAB.
3. Use site-specific ecological risk data to support cleanup decisions.
4. Characterize site risks.
5 . Communicate risks to the public.
6. Remediate unacceptable risks.
A baseline risk assessment of the Columbia River, with respect to Hanford’s contribution of
contaminants, will determine if there is a substantial endangerment to public health or the
environment resulting from Hanford Site contaminants.
The RCBRA will be integrated with the following two main components.
100 Area and 300 Area Component. The subject of this document and which addresses the
100 Area and 300 Area (including the near-shore zone of the Columbia River at the 100 Area
and 300 Area) (see Figure 3). (To be completed by the Environmental Restoration/River
Corridor Contractor.)
Columbia River Component.
Several organizations have conducted numerous ecological and contaminant studies along the
Columbia River beyond the 100 Area and 300 Area near-shore zone. However, the information
still needs to be compiled, analyzed, and peer reviewed to verify its appropriateness and
adequacy for a baseline risk assessment. Should existing data prove to be adequate, the analyses
can be used as part of the basis for the 100 Area and 300 Area final remedy RODs.
100Area and 300 Area component of the RCBRA: Basis and Assumptions on Project Scope
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The scoping statements below primarily address the 100 Area and 300 Area component.
Separate scoping statements will be developed for the Columbia River component.
1. The RCBRA will follow the CERCLA process to evaluate the protection of human health
and the environment, as required for final remedy decisions for the 100 Area and 300 Area
RODs.
2. The 100 Area and 300 Area component will extend into the Columbia River only to the
point where the contaminant releases specific to the 100 Area and 300 Area no longer pose
an unacceptable risk, as defined by CERCLA. The Columbia River component will evaluate
impacts beyond this point.
3. The 100 Area and 300 Area component will evaluate the current conditions of the
groundwater in the river corridor, including remnant plumes currently beneath the 100 Area
and 300 Area that originated in the 200 Area. Analysis of plumes originating from the
200 Area that may reach the 100 Area and 300 Area shorelines will be included in this risk
assessment as the modeling results become available.
4. Hanford Generating Plant sites, part of the 100-NR-1 Operable Unit, will be included in the
risk assessment.
5. Exposure scenarios will be based on current and reasonably anticipated future use(s) for the
river corridor. Selection of scenarios will be based on existing cleanup decisions, tribal uses,
National Monument status, and the Hanford Site Risk-Based End State Vision that is
currently under development in accordance with DOE Policy 455.1. The Hanford Site RiskBased End State Vision, based on land use decisions made through the Revised Draft
Hanford Remedial Action Environmental Impact Statement and Comprehensive Land Use
Plan (DOE 1999) and Record of Decision: Hanford Comprehensive Land-Use Plan
Environmental Impact Statement (HCP EIS) (6450-01-P), is scheduled for completion in
January 2004.
6. Outfall pipelines that extend into the Columbia River (riverlines) and D-Island will be
included in the 100 Area and 300 Area component.
7 . Most of the 100 Area and 300 Area liquid waste sites have been remediated to meet the remedial
action goals as stated in the interim action RODs. Final cleanup verification sampling results
are available for these sites, and these results can be used in the risk assessment. However,
the remedial actions at solid waste burial grounds and remaining sites are still in progress.
Because interim action RODs specifying remedial action goals have already been signed for
these waste sites, the sites will be evaluated for the risk assessment as if they have already
been remediated in accordance with the RODs. As remediation on these waste sites is
completed, the actual verification sampling results will be incorporated into the risk
assessment. Additional characterization of currently unremediated sites is not required for
this risk assessment.
IO0 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
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8. Reactor cores and waste sites in the “shadow” of the reactor core (within approximately 25 m
[82 ft] of the edge of the safe storage enclosure facility) will be considered as completed
interim safe storage (ISS) projects. No additional characterization of these sites or the ISS
enclosures will be performed for this risk assessment. (It is assumed ISS will be completed
for the 100-N Reactor, but a final decision has not been made.) Because interim action
RODs and Action Memorandums specifying remedial action goals have already been signed
for these waste sites and the reactors, the sites will be evaluated for the risk assessment as if
they have already been remediated in accordance with the RODs.
9. The ongoing 100-B/C Pilot Project Ecological Risk Assessment (100-B/C Pilot Project) will
be used to help focus this assessment, including conceptual models, computational methods,
and appropriate “lessons learned.”
10. Some of the sampling is seasonally restricted. Plants are best sampled just before full bloom,
which, depending on the species, occurs from early spring through late fall. The river is best
sampled in fall when the river flow is low. Scoping for problem formulation will include fall
sampling to ensure the low-river flow period is not missed. A preliminary SAP, based on the
100-B/C Pilot Project sampling and initial DQO discussions, will likely be used to initiate
this scoping process.
11 A gamma radiation survey of the Columbia River shorelines at the applicable reactor areas
will be started in the winter of 2003/2004 to focus the DQO process. (A similar survey was a
valuable asset to the lOO-B/C Pilot Project for locating samples at the points of highest
radiation readings.)
12. Sampling may take 2 years to complete. Two sampling phases, Phase I and Phase 11, are
identified for the baseline risk assessment effort. Scopes and schedules for these efforts will
be developed in the 100 Area and 300 Area component work plan, DQO, and SAP. It is
possible that sufficient data will be collected during Phase I, the first year of sampling, so that
Phase I1 will not be necessary and the risk assessment can be completed ahead of schedule.
4.0 DELIVERABLES AND SCHEDULE
The deliverable documents and a schedule for the 100 Area and 300 Area component are shown
in Figure 2. The documents and estimated completion dates are as follows:
0
0
0
0
A remedial investigation work plan (September 2004)
Existing data compilation (April 2004)
Phase I DQO summary report (December 2004)
Phase I SAP (December 2004)
Risk assessmenthemedial investigation report (April 2007).
IO0 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
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An overview of the process for completing the 100 Area and 300 Area component is shown in
Figure 4. The risk management evaluation and decisions will be made after the risk assessment
is completed, and will be made as part of the feasibility study and final remedial action RODS for
the 100 Area and 300 Area.
100 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
December 2003
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Figure 1. Integrating the Assessments Across the Hanford Site.
IO0 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
December 2003
DOERL-2003-61
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Figure 2. Deliverable Documents and Risk Assessment Schedule for the 100 Area
and 300 Area Component of the River Corridor Baseline Risk Assessment.
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I00 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
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Figure 3. River Corridor Baseline Risk Assessment Components.
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L
100 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
December 2003
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DOE//RL-2003-61
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Figure 4. 100 Area and 300 Area Component of the River Corridor
Baseline Risk Assessment Process.
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100Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
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5.0 RETERIENCES
6450-0 1-P, Record of Decision: Hanford Comprehensive Land- Use Plan Environmental Impact
Statement (HCP EIS) (1999), U.S. Department of Energy, Washington, D.C.
Comprehensive Environmental Response, Compensation, and Liability Act of 1980,
42 U.S.C. 9601, et seq.
DOE P 455.1, Use of Risk-Based End State, U.S. Department of Energy, Washington, D.C.
DOE, 1999, Revised Draft Hanford Remedial Action Environmental Impact Statement and
Comprehensive Land Use Plan, DOE/EIS-O222D, U.S. Department of Energy,
Washington, D.C.
DOE-RL, 1991, Hanford Past-Practice Strategy, DOERL-9 1-40, Rev. 0, U.S. Department of
Energy, Richland Operations Office, Richland, Washington.
Ecology, EPA, and DOE, 1998, Hanford Federal Facility Agreement and Consent Order,
2 vols., as amended, Washington State Department of Ecology, U.S. Environmental
Protection Agency, and U.S. Department of Energy, Olympia, Washington.
Ecology, EPA, and DOE, 2002, Community Relations Plan for the Hanford Federal Facility
Agreement and Consent Order, Washington State Department of Ecology,
U.S. Environmental Protection Agency, and U.S. Department of Energy, Olympia,
Washington.
EPA, 1988, Guidancefor Conducting Remedial Investigations and Feasibility Studies Under
CERCLA, EPA/540/G-89/004, OSWER Directive 9355.3-01, Office of Emergency and
Remedial Response, U.S. Environmental Protection Agency, Washington, D.C.
EPA, 1989, Risk Assessment Guidancefor Superfund: Volume 1, Human Health Evaluation
Manual, EPA/540/1-89/002, Interim Final, U.S. Environmental Protection Agency,
Washington, D.C.
EPA, l997a, Ecological Risk Assessment Guidancefor Superfund: Process for Design and
Conducting Ecological Risk Assessments, EPA/540/R-97/006, U.S. Environmental
Protection Agency, Washington, D.C.
EPA, 1997b, EPA Region 10 Supplemental Ecological Risk Assessment Guidance for Superfiund,
EPA/910/R-97/005, U.S. Environmental Protection Agency, Washington, D.C.
EPA, 1997c, Superfund Program Representative Sampling Guidance, Volume 3: Biological,
Interim Final, EPA 540/R-97/028, U.S Environmental Protection Agency,
Washington, D.C.
100 Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
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EPA, 1998, Guidelinesfor Ecological Risk Assessment, EPA/630/R-95/002F, Risk Assessment
Forum, U. S. Environmental Protection Agency, Washington, D.C.
EPA, 1999a, Ecological Risk Assessment and Risk Management Principlesfor Superfund Sites,
OSWER Directive No. 9285.7-28P, Office of Solid Waste and Emergency Response,
U.S. Environmental Protection Agency, Washington, D.C.
EPA, 1999b, Interim Remedial Action Record of Decision for the 100-NR-I and 100-NR-2
Operable Units, U.S. Environmental Protection Agency, Region 10, Seattle, Washington.
EPA, 2001, Reuse Assessments: A Tool to Implement the Superjimd Land Use Directive,
QSWER 9355.7-06P, U.S. Environmental Protection Agency, Washington, D.C.
Resource Conservation and Recovery Act of 1976,42 U.S.C. 6901, et seq.
Superfund Amendments and Reauthorization Act of 1986,42 U.S.C. 9601, et seq.
WAC 173-340, “Model Toxics Control Act--Cleanup,” Washington Administrative Code,
as amended.
100Area and 300 Area Component of the RCBRA: Basis and Assumptions on Project Scope
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