Rocky Flats Environmental Technology Site Golden, Jefferson County, Colorado

Progress in Reaching Interagency Agreement

DOE, EPA Region VIII, and the State of Colorado executed an IAG for the RFETS on January 22, 1991. The IAG supersedes the RCRA/CERCLA Compliance Agreement executed on July 31, 1986 among DOE, EPA Region VIII, and the State of Colorado. The IAG establishes cleanup schedules and delineates regulatory responsibilities of EPA Region VIII and the State of Colorado. In January 1994, it was agreed among EPA Region VIII, the Colorado Department of Public Health and Environment (CDPHE), and DOE that a new Rocky Flats Cleanup Agreement will be negotiated to replace the IAG. These negotiations are expected to conclude in a final agreement in the fourth quarter of FY 96.

Specific Cost Estimates and Budgetary Proposals Involved in Each Interagency Agreement

Funds budgeted for environmental restoration under the IAG total $37.8 million of appropriated funding for FY 96 and $60.3 million for FY 97 according to the request in the President's Budget.

Public Comments Regarding Interagency Agreements

Discussions began in FY 93 between DOE and the regulatory agencies regarding negotiation of the new Rocky Flats Cleanup Agreement. The public has been kept abreast of this activity, and a preliminary draft of the agreement was provided for informal comment. The newly formed Citizen Advisory Board discussed issues related to the agreement at some of the recent meetings. The draft of the new cleanup agreement will be made available for public comment when the agencies have reached agreement.

Progress in Conducting Remedial Investigations/Feasibility Studies

Initial site characterization efforts at RFETS began in July 1986 under the RCRA/CERCLA Compliance Agreement and continue under the IAG executed on January 22, 1991. A comprehensive list of all known and suspected hazardous, radioactive, and mixed waste sources at the site has been compiled, including descriptions of all known release information for 178 individual hazardous substance sites. These sites have been categorized for further environmental investigation and remediation into 16 OUs based on cleanup priorities, waste type, geographic location, and public input. Since that time, characterization has been completed and no-action RODs have been approved by DOE, EPA, and the CDPHE for three operable units (OUs 11, 15, and 16).

Phase I RI work plans for all OUs have been approved by the regulatory agencies. The number of Phase II and Phase III work plans has been reduced by innovative planning and working with the regulatory agencies to combine phases and subsequent field work for several OUs. Phase I RI field work has been completed for ten OUs and is underway in the remaining six. Seven final and two draft RI reports have been submitted to the regulatory agencies. FSs have been started in four OUs, with one completed (OU 1). In OU 7 presumptive remedies will be used, and no RIs or FSs will be required. Accelerated removal actions conducted under a proposed action memorandum procedure, developed in conjunction with the regulatory agencies, may also reduce the risk at some OUs so that a no-action ROD may be approved, further reducing remediation costs. IM/IRA decision documents are also used to accelerate cleanup, further reducing costs (OUs 2 and 7).

Phase III RI field work for OU 1 is complete, and the 14-volume final RI report was delivered to EPA and the CDPHE on its extended milestone delivery date in June 1994. The OU 1 FS was completed in FY 95, with an evaluation of the list of remediation alternatives based on the revised interpretations of the nature and extent of contamination in the final RI. The final FS Report was submitted in February 1995. The final PP was submitted in May 1995. A ROD is expected to be signed in 1996.

The final draft and final OU 2 RI Reports were delivered to the regulatory agencies in May and September 1995, respectively. The OU 2 FS began in FY 95 but has been indefinitely deferred until funding is available. In lieu of the FS, two proposed action memorandums and one IM/IRA will be initiated in FY 96, with additional proposed action memorandums being completed in FY 97 and 98. A no-action ROD is anticipated following completion of the accelerated actions.

In OU 3, Offsite Areas, the draft RI Report was completed and submitted to the regulators in October 1995. This assessment concludes that the risk from offsite contamination is below regulatory concern, and no remedial action is necessary. Following EPA and CDPHE review and comment incorporation, the final RI report is scheduled for approval in 1996.

Approximately 80 percent of the OU 4, Solar Evaporation Ponds, Phase I Assessment was completed in FY 94. Based on the 1993 dispute resolution with CDPHE and EPA, this degree of completeness was sufficient to proceed with development of the IM/IRA Decision Document for closure of the ponds. The Phase II RFI/RI Work Plan was completed and approved by the regulatory agencies, and substantial progress was made on Phase II field work in FY 95. A draft IM/IRA decision document presenting a closure plan was submitted in February 1995.

The Phase I and Phase II RI field work for OU 5 were combined so that only one RI Report will be required, the draft of which will be delivered to the regulatory agencies in October 1995. A presumptive remedy will be used for remediation of the most contaminated sites in OU 5, eliminating the need for the FS. If the Preble's Meadow jumping mouse, which has habitat in OU 5 and other buffer zone operable units, is added to the endangered species list as expected, field work in OU 5 may be delayed.

RI field work for OU 6 has been completed, and the RI Report is expected to be submitted in November 1995. The final report will be completed in FY 1996.

A proposal has been accepted by DOE, EPA, and CDPHE to consolidate operable units. Following completion of the OU 5 and OU 6 RI reports, these OUs will be combined with OU 2 and be named the Buffer Zone OU.

The two phases of OU 7 were combined with regulatory agency approval. This, along with use of a presumptive remedy to cap the present landfill, deleted 10 IAG milestones from this subproject. Design of a passive leachate collection system for the OU 7 present landfill was completed. OU 7 field work was completed in FY 95. A draft IM/IRA decision document was submitted in lieu of a draft ROD.

The field work for OUs 11 and 15 was completed. The final RI report for OU 11 was delivered in June 1995. The final RI report for OU 15 was delivered to the regulatory agencies in December 1994. No-action RODs were approved for these two operable units in September 1995.

Non-intrusive field work for OUs 8, 9, 10, 12, 13, and 14, which are located within the RFETS industrial area, was placed under a stop-work order in March 1995. An orderly shutdown of field work was undertaken, which allowed certain seasonal sampling activities to continue. The stop-work order is still in effect, and no IAG milestones are being pursued. It is anticipated that the operable units within the industrial area will be reconfigured in the new Rocky Flats Cleanup Agreement or by a modification to the existing IAG, and current milestones will be replaced by new enforceable milestones. These OUs, OU 4, and those sections of OU 5 requiring cleanup will be consolidated into one Industrial Area OU.

Intrusive field work in the reconfigured industrial area operable units will not begin until the work is integrated with future decommissioning of facilities and other plant transition activities in this location. Coordination of all these activities will be addressed in the RFETS integrated planning process. Early cleanup or removal actions could occur for selected hot spots of concentrated contamination in these operable units if the need is identified.

A no-action ROD was proposed and has been approved for five of the original seven Individual Hazardous Substance Sites in OU 16. The other two Individual Hazardous Substance Sites were transferred to other operable units for further investigation, thereby completing all OU 16 activity.

In September 1993, the EPA and Rocky Flats Field Office presented a Superfund Innovative Technology Evaluation (SITE) demonstration. This demonstration included a general plant tour of RFETS and a viewing of the technology site, accompanied by a briefing about the SITE demonstration technology. The demonstration of the Colloid Polishing Filter Method technology conducted at RFETS showed removal efficiencies of up to 90 percent for uranium and 86.8percent for gross alpha. The demonstration and results are discussed in several EPA publications available through the Office of Research and Development in Cincinnati, Ohio.

The following public involvement activities were completed:

• Four quarterly public information meetings were held.
• The Technical Review Group continued to meet monthly to provide early public input on draft documents to the regulatory agencies.
• Monthly coordination meetings were held with EPA and CDPHE.
• All required documents were placed in RFETS public reading rooms and five other repositories.
• Tours, presentation, and briefings on various topics were presented to members of the public including the Rocky Flats Citizens Advisory Board and the Rocky Flats Local Impacts Initiative.
• There were three formal public comment periods on various documents as required by CERCLA.
• There were numerous updates on the Rocky Flats Cleanup Agreement, including a workshop which resulted in a list of community values and concerns which were used in the development of the document.
• A workshop was given for stakeholders on environmental laws and regulations. About 70 members of the public attended the day-and-a-half workshop.

Progress in Conducting Remedial Actions

After public comments and regulatory agency design approval, an IRA for OU 1 (a french drain groundwater collection system and Building 891 treatment facility) was constructed and placed into operation in May 1992. The OU 1 IRA treatment facility collected and treated over 4 million gallons of potentially contaminated groundwater through FY 95. Sampling has verified that contamination levels of the water being collected by the OU 1 IRA from the Building 881 footing drain is within acceptable limits, and authorization was granted by the regulatory agencies in 1994 to cease pumping this water to the french drain. This source accounted for 85 to 95 percent of the water treated by the OU 1 IRA. Several small radioactive hot spots were removed in September 1994. The primary source of groundwater contamination will be removed by excavation in FY 96 or FY 97, pending funding.

An IRA for OU 2 which collects, treats, and releases potentially contaminated surface water was completed and placed into operation in April 1992. The OU 2 IRA treatment facility has collected and treated over 24 million gallons of potentially contaminated surface water. Sampling has verified that the contamination level of the water being collected from two of the three surface water sources by the OU 2 IRA, which account for about 90 percent of the surface water collected, is within acceptable limits. Authorization to cease collection and treatment of water from these sources was granted by the regulatory agencies in 1994 for all but one location. The OU 1 and OU 2 water treatment plants were combined in FY 95 and will be used to treat all site groundwater in the future.

A second IRA for OU 2 was mandated by the regulatory agencies in FY 1991. The Phase I design of this IRA, which evaluated conventual vacuum-enhanced vapor extraction technology to extract volatile organics from vadose-zone soils, was approved by the regulatory agencies, and construction was completed in the first quarter of FY 94. Approximately 915 pounds of volatile organic materials have been removed from the ground, processed, and disposed of. This IRA has now been canceled with approval of the regulatory agencies.

The Ryan's Pit removal action near Individual Hazardous Substance Site 109 was completed in FY 95. Approximately 200 cubic yards of contaminated soil were excavated and are awaiting treatment.

Construction of the Option B offsite water projects funded by DOE through grants to local municipalities continued through 1995. The Standley Lake Protection Project is nearly complete, and the City of Broomfield's new water treatment facility is expected to break ground in late 1995. This new facility is expected to be fully operational in 1997.

RFETS is aggressively pursuing accelerated removal actions to reduce risks in a number of operable units. The removal of three "hot spots" (small volumes of soil with relatively high radioactive contamination) in OU 1 reduced the human health and ecological risk. Other accelerated actions, including removal of additional hot spots, storage tanks, and PCB-contaminated areas, were completed in FY 95.

During FY 94, procurement and certification of above-ground sludge storage tanks for the OU 4 solar ponds were completed. Upon certification of the tanks, sludge removal operations commenced in the unemptied solar evaporations ponds, utilizing commercially available vacuum tanker trucks. This operation proved to be extremely effective in removing sludge from the ponds, thereby minimizing further introduction of contaminants to the environment. Sludge removal operations were completed in early FY 95.

The OU 4 Interceptor Trench System was in operation throughout the year, collecting potentially contaminated near-surface groundwater and surface runoff. Nearly 2.5 million gallons were collected, stored in temporary holding tanks, and ultimately processed by two evaporative water treatment facilities located at the site. Due to high operational costs of the evaporator, a new passive water treatment plant to treat this water was proposed. Construction and use of the mobile treatment unit will begin in FY 96 or FY 97.

The OU 4 remediation methodology was modified several times during the fiscal year. The Draft Phase I Proposed IM/IRA Decision Document was delivered to regulatory agencies in May 1994 and included the proposed treatment scenario, which called for 1,000-year protection of the solar pond area below an engineered cap. The design was later modified to include disposition of specific remediation wastes that include minimally treated sludge from the ponds and failed pondcrete from earlier pond sludge remediation activities. A "path-forward" process has been established by DOE and the regulators to determine the final remedy for OU 4. A limited baseline risk assessment is being conducted to assist with the decision-making process.

Implementation of a wetlands mitigation effort in the area of the OU 1 french drain was completed in FY 94. Cattails, sedges, bulrush, three square, and willows were successfully planted on the 881 Hillside as a part of the revegetation plan after the area was lined with bentonite. Construction of the new wetlands was added to the original scope after it became evident that there would be a loss of some wetlands associated with the construction of the OU 1 IM/IRA french drain. Growth of the wetland vegetation was examined, and the regulatory agencies were pleased with the work accomplished.

The final draft of the Pond Water Management IM/IRA was completed and submitted to CDPHE and EPA on November 23, 1993. The draft was required to be developed under the IAG by the regulatory agencies in 1992, even though there is no imminent hazard to public health or the environment from water on the plant site. The document went to dispute under the IAG; the parties met on April 15, 1994 and came to a resolution on dispute issues. DOE has not agreed with the use of CERCLA in lieu of the Clean Water Act to regulate surface waters; therefore, as part of the resolution, language addressing the designation of the ponds as "waters of the U.S." and preservation of DOE's rights to appeal this issue was included. A new pond operations plan, superseding the Pond Water IM/IRA, is expected to be submitted in December 1995 to DOE, EPA, and CDPHE. Pending approval, a new flow-through operations process will be implemented, with substantial cost savings.

Enforcement Activities

On July 7, 1994, a Rocky Flats Tolling (Settlement) Agreement was signed by the DOE Manager of RFETS and officials from the CDPHE and the EPA Region VIII. This agreement includes a settlement of $2,800,000 for 14 missed or expected to be missed enforceable IAG milestones for the period of March 1993 through January 1995. This settlement payment includes cash payments of $350,000 each to the CDPHE and the EPA, and $2,100,000 in Supplemental Environmental Projects related to, at, or in the vicinity of RFETS. It is anticipated that a new Rocky Flats Cleanup Agreement will be negotiated and approved in 1996. Milestones will be limited to a total of 12per year for the entire site. The FY 96 milestones will be for excavation of two trenches in OU 2 and removal of the contents and cleaning of six tanks in the Industrial Area.