Comment

Location of Response

(if applicable)

Commentor

DOE assured the State that the NABIR Program would not interfere with CERCLA remedial actions. At least two of the nine proposed test plots depicted in Figure 3-2 appear to lie in close proximity to the S-3 Ponds Reactive Barriers….CERCLA integration issues should be fully addressed in the final EA.

Section 3.1 and

Section 5.1 Cumulative Impacts

State of Tennessee Department of Environment and Conservation - DOE Oversight Division

Some mention is needed concerning contamination from the S-3 Ponds into the Upper East Fork Poplar Creek Hydrogeologic Regime as well.

Section 3.1.3.3 - Groundwater

This section does not mention precautions taken to prevent downhole contamination from contaminated soils into deeper fracture zones in the bedrock that might take place during advancement of soil borings or drilling into bedrock.

Section 4.1.1.2 - Geology

The EA should address the fact that the USACOE and TDEC have responsibility for Wetland (sic) management and for proposed mitigation for impacted resources areas. The backfilling of soil borings and abandonment of wells should mention the use of bentonite or make reference to a procedure utilizing such material during backfilling and abandonment. Bentonite should be used to prevent downhole migration of groundwater and associated contaminants into fracture zones connected to well or boring annular space.

Section 4.1.3.2 Floodplains and Wetlands

There is no discussion of drilling operations possibly impacted contaminated groundwater and creating additional paths for migration of contaminants to other aquifers, etc.

Section 4.1.3.3 Groundwater

The Endangered Species Act should be referenced on the pertinent regulation listings

Section 9.0

Section 4.1.4.1 should be modified to more accurately define the presence of various bat species and the extent of bat surveys and research in the East Fork Poplar Creek and Bear Creek watersheds

Section 4.1.4.1 and Appendix G

United States Department of Interior - Fish and Wildlife Service, Cookeville TN.

Section 9.0 of the draft EA should also be modified to include the Endangered Species Act as a applicable environmental regulation pertaining to proposed DOE activities on the ORR

Section 9.0

As part of this DOE assessment we recommend that all potential summer roosting habitat for the Indiana bat in the East Fork Poplar Creek and Bear Creek watersheds be identified.

Appendix G

A third listed species is the bull trout (Savelinus confluentus) which can be found in the Hanford Reach and should be included in the text where appropriate.

Section 3.2.4.2 and Section 4.2.4.2

State of Washington Department of Fish and Wildlife

We have noted 2 federal environmental statues missing under Applicable Environmental Regulations….For the Hanford Site the Migratory Bird Treaty Act and Endangered Species Act would be applicable. Please add.

Section 9.0

If a FRC is located at the Hanford Site, we ask that the USDOE follow guidance established in the draft Hanford Site Biological Resource Management Plan and draft Hanford Site Biological Resources Mitigation Strategy Plan.

Section 9.0

ERDF cannot accept liquids so I am assuming ERDF should be replaced with ETF.

Section 4.2.3.1 and Section 4.2.9

State of Washington Environmental Protection Agency

Need to add a statement that any work will not have any adverse impact on current remediation.

Section 4.2.2 and Section 5.2.6

EPA is not opposed to including waste generated under science work into the IDW strategy if it appears to support overall remediation. This would mean waste control plans would need to describe the work/waste.

Section 4.2.8 and Appendix A - Section 2.2.1