Abstract

The initial Resource Conservation and Recovery Act (RCRA) groundwater quality assessment report for Waste Management Area S-SX (PNNL-11810) was issued in January 1998. The report stated a plan for conducting continued assessment would be developed after addressing Washington State Department of Ecology (Ecology) comments on initial findings in PNNL-11810. Comments from Ecology were received by US Department of Energy, Richland Operations Office (DOE-RL) on September 24, 1998. Shortly thereafter, Ecology and DOE began dispute resolution and related negotiations about tank farm vadose issues. This led to proposed new Tri-Party Agreement milestones covering a RCRA Facility Investigation-Corrective Measures Study (RFI/CMS) of the four single-shell tank farm waste management areas that were in assessment status (Waste Management Areas B-BX-BY, S-SX, T and TX-TY). The RCRA Facility Investigation includes both subsurface (vadose zone and groundwater) and surface (waste handling facilities and grounds) characterization. Many of the Ecology comments on PNNL-11810 are more appropriate for, and in many cases are superseded by, the RFI/CMS at Waste Management Area S-SX. The proposed Tri-Party Agreement milestone changes that specify the scope and schedule for the RFI/CMS work plans (Tri-Party Agreement change number M-45-98-0) were issued for public comment in February 1999. The Tri-Party Agreement narrative indicates the ongoing groundwater assessments will be integrated with the RFI/CMS work plans. This addendum documents the disposition of the Ecology comments on PNNL-11810 and identifies which comments were more appropriate for the RFI/CMS work plan.

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