DATE: May 22, 1998

NUMBER: 98-2

RESPONSE REQUESTED BY (date): June 18, 1998

REGARDING: February 1998 draft "Accelerating Cleanup Paths to Closure,"Oak Ridge Offices Office

TO: Jimmie Hodges, DOE

CC: Carl Froede, Jr., EPA

Tuss Taylor, KDEP

Dr. John Volpe, Radiation Control Branch

Wayne Davis, Kentucky Department of Fish & Wildlife Resources

Regular members — Nola Courtney, Edward Duff, David Fuller, Ronald Lamb, Lynn Lane, Linda Long, Ray McClennan, Craig Rhodes, Connie Sykes, Bill Tanner, Rev. Gregory Waldrop

At a regular meeting of the Site Specific Advisory Board (SSAB) held May 21, 1998, the board identified comments on "Accelerating Cleanup: Paths to Closure." With eight regular members present, two comments were adopted by concensus, and another was adopted with one dissenting opinion, which is included.

1. This comment is in regard to Page A-11/J, which states:

"Landfills and burial grounds are capped in place with long-term monitoring based on U.S. Environmental Protection Agency’s presumptive remedy guidance for landfills and Kentucky regulations for closure of RCRA land disposal units."

Item J, which concerns landfills and capping in place, is contrary to other proposed actions as far as any migration or protecting the groundwater. Therefore, a blanket capping of all landfills is not the best alternative. Each landfill should be studied individually and if any landfill has the potential of an off-site release in the future, alternatives other than capping should be explored. Capping all landfills may not meet the goals of future land use, particularly outside the security fence.

2. This comment is in regard to the risk-based polychlorinated biphenyl cleanup levels (25 parts per million) listed in assumptions in Section G of the document.

Based on existing data, the board supports the Commonwealth’s risk-based levels for cleanup standards of Polychlorinated Biphenyls, pending future studies, when evidence shows they should either be more restrictive or less restrictive.

DISSENTING OPINION

This member supports the TSCA risk-based PCB cleanup levels currently being employed by DOE.

3. Regardless of what it is named, the document is serving in effect as a funding plan. As such, it does not take into account the needs of Paducah in the long run. That compounds the boards fears about DOE’s not being able to complete the task. The board would like a thorough explanation from DOE about why it does not consider this document a "major federal action."