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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20126L9041992-07-0808 July 1992 Final Response to FOIA Request for Documents.App F Records Already Available in Pdr.Forwards App G Records Being Made Available in Pdr.Portions of App H Records & All App I Records Withheld (Ref FOIA Exemptions 5 & 6) ML20126A7441992-06-18018 June 1992 Partial Response to FOIA Request for Documents.Encl App C Documents Are Being Made Available in PDR ML20125B1471992-06-17017 June 1992 Partial Response to FOIA Request for Documents Re Matter of Us Ecology,Inc.Forwards Documents Listed in App a Which Are Already Available in Pdr.Documents Listed in App B Withheld (Ref FOIA Exemption 6) ML20125B1251992-02-11011 February 1992 FOIA Request for Documents Re Matter of Us Ecology Inc, (Sheffield,Illinois low-level Radwaste Disposal Site) 25 NRC 98 (1987) Docket 27-39-SC ML20244B1901989-04-13013 April 1989 Final Response to FOIA Request for Records.App a Records Encl & Available in PDR ML20195H4811988-06-0808 June 1988 Forwards Draft Memo Re Closure Issues Pertaining to Sheffield Low Level Waste Disposal Site & Draft Technical Position Paper on Environ Monitoring of Low Level Radwaste Disposal Facilities,Per Request.W/O Encl ML20238F3451987-09-10010 September 1987 Final Response to FOIA Request for Documents Re Maxey Flat Waste Disposal Site.Forwards App K & L Documents.Documents Also Available in Pdr.App L & M Documents Partially & Totally Withheld (Ref FOIA Exemption 5),respectively ML20236E0701987-07-28028 July 1987 Partial Response to FOIA Request.App I Documents Re Maxey Flats Low Level Nuclear Waste Burial Site,Encl & Being Made Available in PDR ML20235N7931987-07-0606 July 1987 Forwards General NRC Comments on Draft Remedial Investigation Rept for Sheffield Hazardous Waste Disposal Sites. Info About Status of Remedial Investigations & Actions at Sheffield Chemical Site Will Be Appreciated ML20214T1121987-06-0505 June 1987 Submits Citation to Footnote 19,omitted from Staff 870528 Motion to Terminate Proceeding ML20214T2331987-06-0202 June 1987 Advises That Staff 870528 Motion to Terminate Proceeding Contained Three Citation & Punctuation Errors as Stated ML20210C1361987-04-29029 April 1987 Requests That Encl Published Authority Re Mason General Hosp Vs Secretary of Dept of Health & Human Svcs Be Considered When Making Decision Concerning 870316 Brief.Published Authority Not Available When Brief Submitted ML20209E8291987-04-24024 April 1987 Forwards Corrected Version of NRC 870424 Response to Us Ecology Motion for Sanctions & Other Relief.Version Corrects Omission of Line Between Bottom of Page 2 & Top of Page 3 ML20206T3231987-04-16016 April 1987 Advises That State of Il Intends to File Response Under Provisions of 10CFR2.762 to Us Ecology,Inc 870316 Brief in Support of Appeal of Final Decision.Nrc Response to Appeal Brief Will Be Submitted by 870611 ML20206B1621987-03-26026 March 1987 Requests Comments on Encl Remedial Investigation Rept Due to Proximity of Low Level Radwaste Disposal Area to Chemical Waste Disposal Areas & Mixture of Chemical & Radioactive Plumes of Contamination in Groundwater,By 870420.W/o Encl ML20211J0621987-02-20020 February 1987 Comments on Proposed Agreement Between NRC & State of Il for Transfer of Certain Regulatory Authority,Per Section 274 of Atomic Energy Act of 1954.Exclusion of Sheffield Site from Proposed Agreement Discussed ML20210S8671987-01-29029 January 1987 Forwards Complaint Filed in Circuit Court in Bureau County Re People of Illinois Vs Teledyne,Us Ecology & American Ecology Corp to Compel Cleanup of Nuclear Disposal Site at Sheffield,Il.Issue Being Explored by American Insurers ML20212R6731987-01-28028 January 1987 Forwards 870121 Fr Notice,Revising Due Date for Comments on Assessment of Proposed Agreement Between NRC & State of Il. Agreement May Be Executed as Early as 870301 ML20211N6271987-01-27027 January 1987 Forwards Current List of Refs & Citation Re USGS Study of Low Level Radwaste Disposal Site Near Sheffield,Il,Per Request.Matls Also Sent to H Henderson of Ofc of Atty General of State of Il ML20207Q2881987-01-15015 January 1987 Requests Resolution of Proceeding Before State of Il Becomes Agreement State.Nrc Jurisdiction Over Sheffield Site Will Be Relinquished Upon Execution of Agreement Scheduled for Mar 1987 ML20207C4571986-12-16016 December 1986 Proposes 861222 as Date to Start Us Ecology Exam of State Files to Obtain Documents for Use at Trial in Event That Us Ecology Pending Motion for Summary Disposition Denied. Related Correspondence ML20206C8051986-12-0404 December 1986 Forwards Third Amended Complaint Filed in Circuit Court in Burea County to Compel Cleanup of Sheffield,Il Disposal Site.Ani Put on Notice to Pay Indemnity & Defense Costs Re Litigation ML20214J7571986-11-14014 November 1986 Forwards Proposed Settlement Agreement Between Teledyne,Inc & State of Il Re Sheffield Low Level Radwaste Disposal Site ML20214A7161986-11-12012 November 1986 Advises That 861110 Response Opposing Us Ecology Motion for Summary Disposition Filed w/out-of-date Svc List.Pleading re-served to Correct Svc List.Certificate of Svc Encl ML20211E6371986-10-0707 October 1986 Forwards Summary of Quarterly Monitoring Data of Piezometers & Wells in Vicinity of Trench 18 & Trench 18 Sumps for Jul-Sept 1986,per of Agreement ML20215H1371986-10-0202 October 1986 Requests Agreement Between NRC & State of Il Allowing State Assumption of Regulatory Authority for Radioactive Matls Under Federal Jurisdiction.Agreement Would Cover Byproduct, Source & SNM & Land Disposal of Wastes ML20215E4801986-08-18018 August 1986 Discusses 860818 Visit to Sheffield Low Level Waste Disposal Site.Appreciation Expressed for Cooperation & Assistance. Detailed Notes Encl ML20214M3381986-08-12012 August 1986 Recaps History of Trench 18,per M Bowen 860718 Notification That Water Present in South Sumps.Periodic Phenomena,Due to Melting Snow & Spring Thaw,Of No Health or Safety Significance Since Amounts of Radioactivity Extremely Low ML20203K0731986-07-30030 July 1986 Requests Change to Current Mailing List to Show TR Lash as New Director of Dept of Nuclear Safety.Related Correspondence ML20199L0601986-07-0303 July 1986 Advises That Parties Available for Prehearing Conference Re Radwaste Disposal Site on Any Day of Wk Commencing 860818, Except 860821,in Response to ASLB 860613 Order ML20206P6751986-05-21021 May 1986 Requests All Documentation Re Position of Commission on Possession Issue.Related Correspondence ML20198E0311986-05-21021 May 1986 Forwards Wj Olmstead 850918 Memo Re Legal Precedent on NRC Interpretation of Licenses Authorizing Possession of Snm,Per FOIA 86-247.US Ecology Request for Similar Documents Not Honored.Requests Documents.Related Correspondence ML20197H0341986-04-0909 April 1986 Forwards Final Results of Reconnaissance Evaluation of Hazardous Chemical Migration in Groundwater in Vicinity of Two Low Level Radwaste Disposal Facilities & Results of Sept 1985 Groundwater Sampling & Analysis,Sheffield,Il ML20197H1181986-04-0707 April 1986 Forwards ORNL Final Ltr Rept, Results of Sept 1985 Groundwater Sampling & Analysis,Sheffield,Il ML20197E1851986-04-0303 April 1986 FOIA Request for Documents Re State of Il Agreement State Status Under Section 274 of Atomic Energy Act ML20137Y9401986-01-16016 January 1986 Forwards Review of Info on Sheffield,Il Low Level Waste Site ML20137Z8671985-11-18018 November 1985 Forwards Tract Description of Property Recently Acquired Adjoining Sheffield Facility.Acquisition of Area Assures That Any Pathways to Trout Lake in Control of Company ML20133N3161985-10-0404 October 1985 Requests Monthly & Quarterly Results of Environ Monitoring for Trench Sumps,Ltr Series Wells & Chemical Waste Disposal Facility Licensed by IEPA & Any Results of Analyses Samples from Wells Adjacent to Unlicensed Chemical Facility ML20133D4451985-09-26026 September 1985 Responds to FOIA Request for Info on J Neel & D Gravely Association W/Listed Companies Re Maxey Flats Nuclear Disposal Area.Forwards App B Documents.App a & B Documents Available in PDR ML20135B0111985-08-16016 August 1985 Informs That Decommissioning Activities Not Already Authorized by Existing License or by Commission Regulations Should Not Take Place W/O Prior NRC Approval,Per State of Il,Dept of Nuclear Safety Encl 850710 Request to USGS ML20127P5381985-06-13013 June 1985 Requests Reconsideration of Restriction of Technical Info Exchange Between State of Il & NRC Re Sheffield,Il Radwaste Disposal Site.Restriction Counterproductive ML20132F9611985-04-15015 April 1985 Forwards ORNL 850206 Preliminary Results from Sampling at Sheffield Low Level Radwaste Disposal Site.Rept Covers EPA Proposed Method 8600 for Organic Constituent Screening. Schedule for Future Licensing Activities Requested ML20132F9981985-02-28028 February 1985 Forwards Results Obtained in Application of Method 8600 Organic Screening Tests to Groundwater Samples from Sheffield Low Level Waste Disposal Site.Work Will Continue to Identify Predominant Organic Compounds Present ML20132F9841985-02-0606 February 1985 Forwards Results of Groundwater Analytical Program for Sheffield,Il.Water Quality Best in Well 574 & Worst in Trench Well.Analysis of Method 8600 Matrix Will Be Forwarded by 850215 ML20027D6911982-10-0505 October 1982 Forwards Trench 18 Monitoring Record for Jul-Oct 1982 ML20062G9501982-07-0707 July 1982 Forwards Summary of 820610 Technical Update Meeting Re Site Tritium Migration Investigation.Sampling & Analysis Data & Map of Locations of Well to Be Dug in Phase 2 Encl ML20054J4421982-05-11011 May 1982 Confirms 820511 Telcon Agreement That BNL Will Obtain Soil Samples & Perform Necessary Soil Tests at Sheffield Site on 820512-13 ML20054H8461982-05-11011 May 1982 Responds to 820407 Request Re BNL Site Visit to Take Trench Sump Water Samples ML20054E5531982-05-11011 May 1982 Forwards Sampling & Analysis Data for Mar 1982 Steering Committee Rept on Tritium Investigation ML20053A9401982-05-0606 May 1982 Responds to to J Shaffner.Nrc Agrees to Indemnify Us Ecology,Inc Against All Claims,Losses & Expenses Arising Out of Activities of Bnl,Sheffield,Il,Low Level Waste Facility Unless Caused by Us Ecology,Inc 1992-07-08
[Table view] Category:NRC TO OTHER U.S. GOVERNMENT AGENCY/DEPARTMENT
MONTHYEARML20235N7931987-07-0606 July 1987 Forwards General NRC Comments on Draft Remedial Investigation Rept for Sheffield Hazardous Waste Disposal Sites. Info About Status of Remedial Investigations & Actions at Sheffield Chemical Site Will Be Appreciated ML19348A0491981-10-20020 October 1981 Discusses Two Field Proposed Studies Re Movement of Water Through Unsaturated Zone & Measure of Rate of Erosion from Site Surface,In Response to ML19248D1011979-04-0505 April 1979 Discusses Nuclear Engineering Co 790308 Notice of Intention to Close Waste Disposal Site.Suggests DOE Prepare Contingency Plans Re Acceptance of Commercial Low Level Waste ML19289C0441978-09-0101 September 1978 Refers to 780417 & s Re Trench Excavation at Sheffield Site,& Concludes That NRC Approves of Study Which May Be Valuable for NRC Waste Mgt Prog.Il Pub Health Dept Does Not Monitor,Others Must 1987-07-06
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20126L9041992-07-0808 July 1992 Final Response to FOIA Request for Documents.App F Records Already Available in Pdr.Forwards App G Records Being Made Available in Pdr.Portions of App H Records & All App I Records Withheld (Ref FOIA Exemptions 5 & 6) ML20126A7441992-06-18018 June 1992 Partial Response to FOIA Request for Documents.Encl App C Documents Are Being Made Available in PDR ML20125B1471992-06-17017 June 1992 Partial Response to FOIA Request for Documents Re Matter of Us Ecology,Inc.Forwards Documents Listed in App a Which Are Already Available in Pdr.Documents Listed in App B Withheld (Ref FOIA Exemption 6) ML20244B1901989-04-13013 April 1989 Final Response to FOIA Request for Records.App a Records Encl & Available in PDR ML20195H4811988-06-0808 June 1988 Forwards Draft Memo Re Closure Issues Pertaining to Sheffield Low Level Waste Disposal Site & Draft Technical Position Paper on Environ Monitoring of Low Level Radwaste Disposal Facilities,Per Request.W/O Encl ML20238F3451987-09-10010 September 1987 Final Response to FOIA Request for Documents Re Maxey Flat Waste Disposal Site.Forwards App K & L Documents.Documents Also Available in Pdr.App L & M Documents Partially & Totally Withheld (Ref FOIA Exemption 5),respectively ML20236E0701987-07-28028 July 1987 Partial Response to FOIA Request.App I Documents Re Maxey Flats Low Level Nuclear Waste Burial Site,Encl & Being Made Available in PDR ML20235N7931987-07-0606 July 1987 Forwards General NRC Comments on Draft Remedial Investigation Rept for Sheffield Hazardous Waste Disposal Sites. Info About Status of Remedial Investigations & Actions at Sheffield Chemical Site Will Be Appreciated ML20215E4801986-08-18018 August 1986 Discusses 860818 Visit to Sheffield Low Level Waste Disposal Site.Appreciation Expressed for Cooperation & Assistance. Detailed Notes Encl ML20197H0341986-04-0909 April 1986 Forwards Final Results of Reconnaissance Evaluation of Hazardous Chemical Migration in Groundwater in Vicinity of Two Low Level Radwaste Disposal Facilities & Results of Sept 1985 Groundwater Sampling & Analysis,Sheffield,Il ML20197H1181986-04-0707 April 1986 Forwards ORNL Final Ltr Rept, Results of Sept 1985 Groundwater Sampling & Analysis,Sheffield,Il ML20133N3161985-10-0404 October 1985 Requests Monthly & Quarterly Results of Environ Monitoring for Trench Sumps,Ltr Series Wells & Chemical Waste Disposal Facility Licensed by IEPA & Any Results of Analyses Samples from Wells Adjacent to Unlicensed Chemical Facility ML20133D4451985-09-26026 September 1985 Responds to FOIA Request for Info on J Neel & D Gravely Association W/Listed Companies Re Maxey Flats Nuclear Disposal Area.Forwards App B Documents.App a & B Documents Available in PDR ML20135B0111985-08-16016 August 1985 Informs That Decommissioning Activities Not Already Authorized by Existing License or by Commission Regulations Should Not Take Place W/O Prior NRC Approval,Per State of Il,Dept of Nuclear Safety Encl 850710 Request to USGS ML20127P5381985-06-13013 June 1985 Requests Reconsideration of Restriction of Technical Info Exchange Between State of Il & NRC Re Sheffield,Il Radwaste Disposal Site.Restriction Counterproductive ML20132F9611985-04-15015 April 1985 Forwards ORNL 850206 Preliminary Results from Sampling at Sheffield Low Level Radwaste Disposal Site.Rept Covers EPA Proposed Method 8600 for Organic Constituent Screening. Schedule for Future Licensing Activities Requested ML20054J4421982-05-11011 May 1982 Confirms 820511 Telcon Agreement That BNL Will Obtain Soil Samples & Perform Necessary Soil Tests at Sheffield Site on 820512-13 ML20054H8461982-05-11011 May 1982 Responds to 820407 Request Re BNL Site Visit to Take Trench Sump Water Samples ML20053A9401982-05-0606 May 1982 Responds to to J Shaffner.Nrc Agrees to Indemnify Us Ecology,Inc Against All Claims,Losses & Expenses Arising Out of Activities of Bnl,Sheffield,Il,Low Level Waste Facility Unless Caused by Us Ecology,Inc ML20052A1351982-03-23023 March 1982 Requests Immediate Notification by Site Personnel If Water Found in Any Sumps During Routine Sump Monitoring Activities.Sampling to Be Done Under Anaerobic Conditions W/Special Portable Equipment ML20041E6841982-02-23023 February 1982 Forwards IE Insp Rept 27-0039/82-01 on 820209 of Activities Under License 13-10014-01.No Noncompliance Noted ML20041A4951982-01-22022 January 1982 Advises of 820127 Site Visit to Observe USGS Field Activities & Drainage Improvements in Vicinity of Trench 11 ML19348A0491981-10-20020 October 1981 Discusses Two Field Proposed Studies Re Movement of Water Through Unsaturated Zone & Measure of Rate of Erosion from Site Surface,In Response to ML20010J2001981-09-24024 September 1981 Forwards IE Insp Rept 27-0039/81-01 on 810908-09 & Notice of Violation ML20005B4861981-07-0202 July 1981 Forwards Documents Requested Upon Completion of Discovery Per .Requests Payment.W/O Encls ML20004F8611981-06-24024 June 1981 Informs That Discovery Documents Will Be Forwarded within Next Few Wks in Response to ML19350E9391981-06-16016 June 1981 Informs of Pending Site Visit on 810624 to Observe Field Activities of Il Geological Survey & USGS ML20126L3651981-05-28028 May 1981 Responds to Re Adequacy of Us Ecology Trench Capping Proposal.Request for Info Necessary for Full Evaluation of Proposal Encl ML20004D6211981-05-26026 May 1981 Forwards IE Insp Rept 70-0820/80-19 & Waste Packaging Rept 15000027/80-62 on 801006-24 & 0930,respectively ML20008F4981981-04-17017 April 1981 Discusses 810416 Telcon.Nrc Will Conduct File Search at Us Ecology Louisville,Ky Ofc on 810504 & Continue Through 810507 If Necessary ML19350D0061981-04-0909 April 1981 Discusses 810408 Telcon.Nrc Will Conduct File Search of Us Ecology Louisville,Ky Ofc on 810420,continuing Through 810423 If Necessary ML20003E1241981-03-31031 March 1981 Advises 810316 List of Technical Documents Does Not Contain Documents Re Us Ecology Interrogatories 3(b), 16 & 17,in Response to .Info Sought Is in Willste Bldg & Arrangements Can Be Made to Search Documents ML20003E4851981-03-27027 March 1981 Responds to Transmitting Us Ecology Proposal for Recompacting & Recovering Trenches Above Base of Existing Cap at Facility.Proposal Lacks Technical Bases Re Minimization of Trench Settlement ML19343D0451981-03-19019 March 1981 Requests Engineering Drawings,Plans & Specs Re Earthen Berm Constructed by Us Ecology Around Perimeter of Chemical Waste Disposal Site.Nrc Evaluating Potential for Interaction Between Chemical Waste & Radwaste at Facility ML19350A8851981-03-16016 March 1981 Forwards List of Technical Documents in NRC Files in Willste Bldg in Silver Spring,Md Per 810309 Telcon.Site Files Will Be Searched on 810324 & 25.Louisville,KY Ofc File Search to Be Conducted on 810414 & 15.W/o Encl ML19347D5381981-03-11011 March 1981 Advises That Only Procedure G-004 & Section 4.0 of Geology & Geotechnical Engineering Rept on Trenches 14 & 14A Be Considered Proprietary Per 761229,30 & s.Requests Justification for Other Matl Being Proprietary ML20003C3421981-02-25025 February 1981 Confirms 810225 Telcon That NRC Exam of Nuclear Engineering Co,Inc Records Would Commence on 810324,instead of 810319 ML19297D3411980-11-14014 November 1980 Forwards IE Insp Rept 27-0039/80-02 on 801022 of Activities Under License 13-10042-01.No Noncompliance Noted ML19345B5771980-11-14014 November 1980 Ack Receipt of 801103,0509 & 0318 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Waste Packaging Insp Rept 15000039/79-08E ML19338G4351980-10-27027 October 1980 Informs That,On 801027,ALAB-606 Became Final Agency Action for Purposes of Judicial Review ML19340B4891980-10-23023 October 1980 Advises That Visit to Disposal Site Is Scheduled for 801028-29 to Review Maint of Records & Discuss Operating Experience ML19338G2191980-10-23023 October 1980 Forwards NRC 801023 Objections to Nuclear Engineering Interrogatories & Requests for Admissions & Production of Documents.Pleading Constitutes Reply to TB Conner to Wj Dircks.W/O Encl ML19345B9561980-10-15015 October 1980 Responds to FOIA Request for Documents Re Sites Used for Dumping Radwaste in Pacific Ocean.Forwards Documents Listed in Apps A,B,C & D.Info Partially Withheld:Home Addresses & Telephone Numbers (Ref FOIA Exemption 6) ML19336A6811980-10-0202 October 1980 Notification of Fl Doyle 801007 Familiarization Visit to Sheffield Low Level Waste Disposal Facility.Conveys Seifken & Shaffner Request to Visit Site on 801014-15 to Observe Site Conditions & Gather Environ Assessment Info ML17209A2851980-09-19019 September 1980 Forwards Waste Packaging Insp Rept 15000039/80-15 on 800727-0801.No Noncompliance Noted ML18139A7731980-09-19019 September 1980 Forwards Waste Packaging Insp Rept 15000039/80-15 on 800727-0801.No Noncompliance Noted ML19338G0081980-09-19019 September 1980 Forwards Waste Packaging Insp Rept 15000039/80-15 on 800727-0801.No Noncompliance Noted ML19338D3741980-09-0303 September 1980 Advises That Geo-Ctrs,Inc Will Visit Site on 800908-12 to Collect Independent Info Using Subsurface Pulsed Radar Detection Equipment ML19338D2241980-09-0303 September 1980 Advises That Geo-Ctrs,Inc Will Visit Site on 800908-12 to Collect Independent Info Using Subsurface Pulsed Radar Detection Equipment ML20126D9011980-07-31031 July 1980 Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in IE Insp of License 13-10042-01 Discussed in NRC 1992-07-08
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J JUL 0 0 B M 2/-39/MFW/87/07/02/ RCRA _
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s Mr. Kevin M. Pierard FV i
RCRA Enforcement Section XE ;[ - -
U.S. Environmental Protection. Agency Region 5
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230 South Dearborn Street Chicago, Illinois 60604
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Dear Mr. Pierard:
In response to your letter of March 26, 1987, the NRC staff has reviewed the draft Remedial Investigation (RI) Report.for the U.S. Ecology, Inc. facility r
at Sheffield, Illinois.
Enclosed please find our. general comments on the RI, l
which I d1scussed with you in May 1987. The hydrogeologic characteristics j
l described in the report are generally consistent with our understanding of the j
hydrogeology of the Low-Level Radioactive Waste (LLRW) site at Sheffield.
The report is of considerable interest to us with respect to,its generic implications for assessing releases of hazardous non-radiological constituents from low-level radioactive waste disposal sitos. An earlier NRC study of the Sheffield LLRW site (NUREG-1183) indicated that hazardous organic constituents were migrating northeast away from the site in a tritium-contaminated groundwater plume. At the time we finalized our report, we were u'icertain -
about the extent to which this organic contamination was caused by the LLRW site. The RI indicates that the predominant cause of the organic contamination observed in the tritium plume is the old chentical disposal site located north
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of the LLRW.
We would appreciate being kept informed about the status of remedial investigations and actions at the Sheffield chemical site. We also encourage you to coordinate yout investigations with the Illinois Department of Nuclear l
Safety because Illinois not NRC now has the regulatory authority over the LLRW at Sheffield under an NRC Agreement State Program. Please contact me at (301)427=4746 if you have any questior.s or comments about our review.
1 Sincerely.
Michael F. Weber, Acting Section Leader Technical Branch Division of Low-Level Waste'Mancgement and Decommissioning
Enclosure:
As Stated l
cc: Terry Lash, IDNS 8707200231 870706 PDR ADOCK O2700039 C
PDR 2
.]
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GENERAL NRC COMMENTS ON THE
" DRAFT REMEDIAL INVESTIGATION REPORT FOR THE SHEFFIELD HAZARD 0US WASTE DISPOSAL SITES" y
1.
Exposure Pathways The Remedial Investigation Report (RI) identifies the surface water transport pathway as the exposure pathway with the greatest potential for human exposure-(pg. 7-2).
Although the assessment recognizes that groundwater is the dominant transport pathway for contaminants from the Sheffield sites, it does
)
not consider human exposure to contaminants via a groundwater pathway. The RI does not conservatively assess the risks posed by existing groundwater contamination et the Sheffield sites because it does not consider human exposure to contaminants via a groundwater pathway. The RI should be revised-1 to assess potential hazards to the public and environment posed by ingestion of contaminated groundwater at Sheffield.
~
T.he purpose of the RI is to assess the extent of contamination associated with the Sheffield sites and tc characterize the hazards posed by such contamination. The RI concludes that although the public is not currently exposed to contaminants released from the facility, ingestion of contaminated I
surface water north and northeast of the site is the most probable hypothetical j
exposure pathway. The exposure assessment, however, does not consider the more significant exposure pathway of contaminated groundwater ingestion.
l i
l After site closure, individuals adjacent to the site may extract and ingest contaminated groundwater.
Contaminant concentrations in the groundwater are orders of magnitude greater than the surface water concentrations used in the exposure assessment. For example, the maximum observed concentration of l
arsenic in the north wall seep was 9 ppb compared with the maximum measured l
concentration of arsenic in groundwater of 2430 ppb (cf. pages 7-4 and 5-27).
Use of the surface water exposure pathways in-place of' groundwater pathwa}s may mislead decision makers by resulting in significantly lower calculated lifetime risks.
In addition, the groundwater exposure pathway may be more I
likely than surface water exposure because future residents in the area'may be more inclined to obtain drinking water from shallow aquifers rather than from l
surface seeps and surface water bodies efeated by strip mining, j
l The RI should be revised to assess the more-conservative-groundwater exposure pathway as the basis for assessing hazards posed by contaminated groundwater and designing remedial actions to control the contamination.at Sheffield.
[
Alternatively, the RI should demonstrate why the groundwater exposure pathway is insignificant with respect to estimating human exposure and risks associated with groundwater contamination at the Sheffield _ sites.
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27-39/MFW/87/04/ ATTACHMENT 2.
Consideration of Radionuclides The exposure assessment does not consider potential health effects associated with exposure to radionuclides (e.g., tritium 1 that are present at elevated levels in groundwater northeast of the LLRW site.
The RI should be revised to consider the potential effects of human and environmental exposure to radionuclides in addition to the non-radiological contaminants in groundwater adjacent to the site.
3.
Flume Migration and Duration The RI does not estimate the future rate of contaminated groundwater migration or the duration of any hazards posed by such contamination.
The rate and duration of contaminant migration may significantly influence conclusions about the extent of such hazards and decisions about appropriate measures to i
f mitigate or eliminate the hazards.
The RI should be revised to ertimate the rate of contaminant migration and duration of groundwater contamination.
4.
Characterization of Contaminated Seeps The exposure assessment in the RI is partially based on a scenario in which an individual consumes groundwater reieased from seeps along the North Wall of j
the Sheffield rites. The RI, howeser, does not characterize the location, extent, and the rate and variability of flow of the seeps. Without such information, the hazards posed by the contaminated seeps cannot be defensibly evaluated. Although present at Sheffield, the seeps may not be a likely source of drinking water because their yield may be too low or too
)
variable. The RI should be revised to characterize the North Wall seeps and to determine whether the seeps represent a hazard to residents near Sheffield.
5.
Erosion Protection Section 2.4 (Page 2-7) indicates that the site is relatively protected against l
surface flooding because it is more than 50 feet above the 100-year, 24-hour l
flood elevation of Kings Creek. The RI does not consider, however, the erosion potential of small streams and intermittent drainages on and adjacent to tim site. The RI should be revised to consider erosion that may be caused by streams and intermittent drainages nehrer to the site than Kings Creek.
6.
(Jse of Effective Porosity The RI appears to use the terms " effective porosity" and " porosity" interchangeably, despite the significant difference in their meanings.
For example, the text appears to substitute " effective porosity" for
" porosity" in describing the factors that influence terrain conductivity j
measurements in Section 4.3.1 (Page 4-25). The text, however, does not indicate why pore interconnectedness influences terrain conductivity measurements.
In addition, Sections 5.2.3 (Page 5-21) and 5.3.3 (Page 5-38)
s.
' 4-27-39/MFW/87/04/ ATTACHMENT'
_ 3 - -.
substitute " effective porosity" for " porosity" in determining the volume of contaminated groundwater at the sitcf. This substitution reduces the calculated volume of contaminated grour.dwater because effective porosity is always less than or equal to porosity. The text does not justify the substitution. The RI should be. revised to justify the use of " effective; i
porosity" in calculating volumes of contaminated groundwater or to use total L
porosity in the calculations.
l Further. Section 4.2.3 (Page 4,17) indicates that the " effective' porosities" of 9.acial samples were characterized using water characteristic' curves.
1 Effective porosity is usually determined by laboratory column or-field tracer tes,ts so that the effective porosities are representative of the transport characteristics of the medium being investigated. The, text does not describe how effective por'>sity (as compared with total porosity) was characterized using a water characteristic cerve technique that is not conventionally used to measure effective porosity.. The RI should be revised to describe how
" effective porosity" was determined using water characteristic curve techniques and to ensure that the terms." effective' porosity"'and " porosity" are used in a manner' consistent with their conventional definitions.
7.
Ground Water Elev6 tion Map Figure 4-27 (Page 4-67) is a map of the water table surface beneath the Sheffield sites. The map and the accompanying text, however,~do not indicate whether this map represents the potentiometric surface in the shallow glacial I
units beneath the site, the potentiometric surface in bedrock, or some composite of heads in the shallow glacial and bedrock units.
The RI should be revised to indicate whether this map represents the potentiometric surface in the glacial units or bedrock and to assess the potential for vertical migration of groundwater contaminants neath the sites.
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