Coordination of groundwater activities in the 100 N Area

Abstract

The initiation of the N Springs Expedited Response Action (ERA) in the 100 N Area will affect the groundwater monitoring networks of two Resource Conservation and Recovery Act of 1976 (RCRA) units. The 1301-N and 325-N facilities are treatment, storage, or disposal (TSD) units that have been monitored under RCRA since 1987. In September 1994, the Washington State Department of Ecology issued an action memorandum, instructing the US Department of Energy (DOE) to take the action. The planned pump-and-treat system will preclude meeting the specific objectives of interim-status RCRA groundwater monitoring representative samples and detect adverse impacts of the TSD units on. However, under RCRA final-status requirements, which will be implemented in 1999, corrective action for groundwater contamination will probably be required. The US Environmental Protection Agency (EPA) has declared parity between RCRA corrective action and Comprehensive Environmental Response, Compensation, and Liability Act of 1980 remedial action decisions. The 1301-N and 1325-N facilities are still in interim-status and therefore are not in the category of ``RCRA corrective action.`` However, DOE`s position is that parity exists between RCRA and the ERA because RCRA corrective action will almost certainly be required in the future.