# DRAFT

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## RISK BASED END STATE VISION

Version 2

INHALATION TOXICOLOGY LABORATORY

Albuquerque, New Mexico

January 30, 2004

DRAFT

**January 30, 2004**

Risk-Based End State Vision for the

Inhalation Toxicology Laboratory

# Executive Summary

The Inhalation Toxicology Laboratory (ITL) (formerly the Inhalation
Toxicology Research Institute), is a part of the Lovelace Respiratory
Research Institute (Lovelace) and is operated by the non-profit Lovelace
Biomedical and Environmental Research Institute. ITL is located on the
southern edge of Kirtland Air Force Base (Kirtland) in Albuquerque, New
Mexico.

ITL was established as a DOE biomedical research facility in 1960 under
a traditional Management and Operating contract. However, since 1996 ITL
has, with DOE assistance and support, functioned as a private research
facility. It is anticipated that ITL will continue as a private facility
for the foreseeable future.

As a result of environmental contamination resulting from DOE funded
research activities and remediation efforts under the Environmental
Management (EM) Project, four hazard areas are expected to remain at ITL
after the completion of the EM mission. Two of the areas contain
residual soil radioactive contamination consistent with the current and
anticipated industrial land use. The other two areas are groundwater
plumes which are currently being remediated through monitored natural
attenuation. None of these areas pose a significant environmental or
human health risk.

The remaining scope at ITL consists of cleaning legacy waste and
contamination out of about 30 laboratories and miscellaneous work areas.
This involves characterizing and disposing of about 17 metric tons of
hazardous and 230 cubic meters of radioactive waste and surface
decontaminating the work areas, rendering them available for ITL's
future research use. Decontamination of drains and ducts and ultimate
decommissioning of the buildings is not considered as the end state. It
is assumed that ITL will remain an active laboratory for the foreseeable
future.

The remaining scope could be completed within a 12 to 18 month period.
However, current funding targets do not support an accelerated closure
schedule. If sufficient above target funding is identified, the ITL EM
mission could be completed as early as FY 2005 or FY 2006. If not, and
the current funding profile is realized, the project will be completed
in approximately FY 2010.

The current state of ITL, as discussed above, reflects the remaining
work to be done to collect and dispose of legacy waste, surface
decontaminating the work areas, continued groundwater monitoring and
maintaining access controls for the four remaining hazard sites. The
Current Cleanup Baseline State will result in all of the legacy waste
being removed from the ITL facility and the entire facility being
surface decontaminated consistent with ITL's intended use. This cleanup
baseline state includes a continuing need for groundwater monitoring and
reporting and maintaining institutional and land use controls for the
four hazard areas that will remain. The Current Cleanup Baseline State
reflects the current and projected land use for the ITL site, is based
on site risk, is sustainable, and is appropriately protective of human
health and the environment.

A Risk Based End State (RBES) would be modestly different from the
current Cleanup Baseline End State. Under the RBES, cessation of
monitoring for the Sewage Lagoon Site would be proposed. This would be
pursued according to the procedures set forth by the New Mexico Water
Quality Control Commission and would be based on the low risk associated
with the Sewage Lagoon Site. All other scope items related to the
cleanup baseline state would remain under the RBES.

The identification of a landlord organization to assume responsibility
for long term response actions at ITL remains an issue. Although the
Office of Science

(Science) is the historical landlord and is listed on the Facility
Information Management System as the Site Owner, Science has no
continuing mission at the now private ITL facility and has not accepted
responsibility for ITL once the EM mission is complete.

The principal stakeholders for the ITL EM Project include the New Mexico
Environment Department (NMED) and the Pueblo of Isleta. Comments are
being sought from these entities on this vision document and the
document has been posted on the NNSA Service Center's Environmental
Restoration Division's web site: <http://www.doeal.gov/erd/default.htm>
Relationships with the stakeholders have historically been very
positive.

**Introduction**

The Inhalation Toxicology Laboratory (ITL) (formerly the Inhalation
Toxicology Research Institute), is a part of the Lovelace Respiratory
Research Institute (Lovelace) and is operated by the non-profit Lovelace
Biomedical and Environmental Research Institute. ITL is located on the
southern edge of Kirtland Air Force Base (Kirtland) in Albuquerque, New
Mexico. The site occupies 240,000 square feet of building space on 144
acres of land which has been withdrawn from the Bureau of Land
Management by the Air Force and permitted to DOE.

DOE's Office of Science (Science) built the ITL facility to conduct
biomedical research for DOE. ITL conducted research for Science and
other DOE entities under a traditional management and operating
contractor relationship until 1996. Since 1996, Lovelace, with DOE's
assistance, and through a Cooperative Agreement, has sought to turn ITL
into a private research facility. Under the terms of the current
Cooperative Agreement, DOE is to fund legacy waste removal, surface
decontamination and groundwater monitoring and reporting at the site.
DOE also is to temporarily provide excess capacity funding to ITL to aid
in the costs of occupying the ITL facility.

The current land use designation is industrial. The industrial land use
designation is projected to continue indefinitely and will likely
continue as long as ITL occupies space on Kirtland. A Baseline for
Future Use Options report was developed in 1996 by a stakeholders group
which included representatives from DOE, ITL, and the Air Force. The
purpose of the DOE Future Use Initiative was to define appropriate short
and long-term future uses for DOE land facilities by including
significant public input. The report covered DOE facilities and lands on
Kirtland Air Force Base.

For ITL, the group recommended a risk-based cleanup to an industrial
level. The report noted that the ITL facility had undergone cleanup to
an industrial land use level based on prior agreement with EPA and NMED.
While the report recommended cleanup to an industrial level, it
indicated that natural deterioration of the remaining (radiological)
contaminants will result in residential cleanup levels by about 2030.

The ITL Environmental Management (EM) project is managed by the
Environmental Programs Department of the National Nuclear Security
Administration (NNSA) Service Center in Albuquerque, NM. The scope of
the ITL EM mission is nearly complete. However, the current target
funding does not support the accelerated closure of the project. If the
additional funding is obtained, the EM mission at ITL could be completed
as early as FY 2005 or FY 2006. If funding beyond the currently planned
targets is not obtained, the project will be completed in approximately
FY 2010.

Upon completion of the EM mission, the ITL site will be turned over to
the landlord to continue long term response action activities. The scope
of these long term activities is anticipated to be limited to
groundwater monitoring and reporting at two sites, the Sewage Lagoon
Site and Diesel Spill Site, and maintenance of institutional controls
and land use restrictions. These institutional controls will ensure that
there is no unauthorized access or use of the hazard sites. In addition
to the groundwater contamination, there is residual radioactive
contamination in the soils at two sites, the Sewage Lagoon Site and the
Hot Ponds Site. These sites have been remediated to the current
industrial land use standards. Continuing the current institutional
controls and land use restrictions are considered to be sufficient long
term response actions to monitor these soil sites.

Identification of a landlord organization to accept responsibility for
the long term response actions is not yet complete. Science is the
historical landlord and is listed in the Facilities Information
Management System as the site owner. However, Science has no continuing
mission at ITL and considers ITL a private facility. Therefore, Science
has not accepted responsibility for long term response actions to be
conducted after the completion of the EM mission. These responsibilities
are expected, in the near term, to include continued groundwater
monitoring and reporting and maintaining institutional and access
controls. Ultimately, the responsibilities may include decontaminating
and removing the facilities consistent with the terms of the lease
between the Air Force and DOE. The NNSA Service Center and EM
headquarters are continuing to work the landlord issue.

The ITL EM mission activities are regulated by the New Mexico
Environment Department (NMED) and DOE Orders related to radioactive
contamination. The two contaminated groundwater plumes that are
projected to remain at the completion of the EM mission are regulated by
two different NMED Bureaus. Relationships with both of these bureaus
have been and continue to be positive.

The Groundwater Water Quality Bureau, which regulates the Sewage Lagoon
Site, agreed in 2002 to the DOE/Lovelace proposal to reduce monitoring
requirements. The Underground Storage Tank Bureau, which regulates the
Diesel Spill site, unilaterally reduced the monitoring requirements in
January of 2003 from three wells to two and from quarterly to semiannual
monitoring. The radioactive contamination at the two soils sites has
been remediated to industrial standards pursuant to DOE Orders.

The other major stakeholder is Isleta Pueblo, which is immediately
adjacent to the ITL site. The Isleta land adjacent to the ITL site is
not inhabited. There are three groundwater monitoring wells on Isleta
land to monitor for the spread of any contamination from the ITL Sewage
Lagoon Site. No contamination from ITL has ever been found.
Relationships with Isleta have always been good. Isleta tribal officials
were consulted in 2002 by Lovelace and DOE staff for their input on
plans to reduce monitoring requirements for the Sewage Lagoon Site and
they agreed with the changes. No other stakeholder groups have expressed
an interest in the ITL EM Project for several years.

Comments on this vision document are being sought from the state
regulators, Isleta Pueblo and the Air Force and posted on the NNSA/SC
Environmental Restoration Divisions website:
<http://www.doeal.gov/erd/default.htm> for the benefit of any other
interested stakeholders. This vision document reflects remediation and
stewardship activities commensurate with the current and projected land
use. It does not represent a departure from historical EM Project goals
and objectives.

**Organization of this Report**

This report is comprised of this introductory section, a series of
regional and site maps which provide information on the greater
Albuquerque and north central New Mexico region and the areas
surrounding and hazards associated with the ITL facility. The maps are
followed by a section containing brief narrative explanations of each of
the maps. Next, the report contains Conceptual Site Models and narrative
descriptions which describe the risks and pathways associated with the
four ITL hazard areas expected to remain after the completion of the EM
mission. Finally, there a variance summary between the currently planned
end state and a risk based end state included as an attachment.

**Site Mission**

Since 1960 ITL has conducted research for DOE on the health effects of
inhaling airborne contaminants (radioactive and other energy-related
pollutants). ITL continued DOE's mission as a government laboratory
operating under a traditional Management and Operating contract until
1996 at which time it was slated for closure by DOE.

In response to Lovelace's desire to become a private research facility,
DOE approved a 5 year privatization plan. As a mechanism to begin the
process of privatization, DOE replaced the M&O contract approach with a
Cooperative Agreement. The Cooperative Agreement, in contrast to the M&O
contract, allows, and indeed encourages, ITL's solicitation of research
projects from non-DOE entities. DOE and Lovelace entered into a new 25
year lease for the ITL facility effective October 1, 2001. The
Cooperative Agreement requires DOE to fund removal of the legacy waste
and surface contamination from the laboratory facilities to facilitate
reuse by ITL. DOE is also to fund groundwater monitoring and reporting.

Lovelace continues to perform essentially the same type of research at
ITL but DOE, which historically funded 100 percent of the research,
currently funds less than 10 percent. Other government agencies such as
the National Institutes of Health and Environmental Protection Agency
fund research at ITL as do numerous private and other government
entities. It is anticipated that ITL will continue to operate as a
private research facility indefinitely. Through the Cooperative
Agreement, DOE is to provide funding for facility support through 2005.

**Status of Cleanup Program**

There are four hazard areas that will remain following the completion of
the EM mission. These consist of the Hot Ponds and Sewage Lagoon sites,
which both contain residual radioactive soil contamination and two sites
with groundwater contamination, the Sewage Lagoon and Diesel Spill
sites.

In response to contamination resulting from past ITL research
activities, the DOE-AL Environmental Restoration Division and ITL
conducted remedial action on several sites. The remedial actions were
completed in 1997. The remaining scope is comprised of continuing
groundwater monitoring and reporting at two ITL sites and completing
legacy waste collection and disposal from approximately 30 laboratories
and miscellaneous areas and surface decontaminating these areas.

There are three areas at ITL which required soil remediation, (1) the
Hot Ponds site, (2) the Sewage Lagoon site, and the (3) Diesel Spill
site. The Hot Ponds and Sewage Lagoon sites contain residual radioactive
contamination and are considered hazard areas. In addition to these soil
sites, two sites, the Sewage Lagoon and the Diesel Spill sites have
residual groundwater contamination and require groundwater monitoring
and reporting. The remedy approved by the New Mexico Environment
Department for both sites is Monitored Natural Attenuation. These two
groundwater sites are also considered hazard areas, bringing the total
number of hazard areas at ITL to four.

[SOILS]{.underline}

[Hot Ponds Site]{.underline}---This site is a one-half acre area located
about one-tenth of a mile east of the ITL site. The site consisted of
two small concrete-lined evaporative sumps (commonly referred to as the
"Hot Ponds"), two metal buildings and assorted support equipment.

Remediation was completed in 1997 and consisted of removing and
disposing of the two sumps, both of the buildings, and concrete and
surrounding soil as low-level radioactive material at Envirocare of
Utah. The soils were remediated in accordance with DOE Order 5400.5
(Radiation Protection of the Public and Environment) and DOE Order
5820.2A (Radioactive Waste Management, currently known as DOE Order
435.1).

Based on risk assessments, remediation has reduced the potential dose
due to residual radioactive contamination of the soil due to cesium-137,
strontium-90 and other radionuclides to below acceptable limits. DOE has
determined that the acceptable exposure limit is 15 millirem per year
under the most reasonable exposure scenario. Total dose and isotope
contributions were modeled for both the industrial/commercial scenario
and residential farming scenario after remediation. Because of the
location and nature of the current and projected role of ITL, the most
reasonable exposure scenario was determined to be the
industrial/commercial scenario. Current residual radioactivity is about
9 millirem/year under this industrial land use scenario. Through natural
decaying of the radionuclides, the Hot Ponds area is expected to decay
to 12 millirem/year under a residential farmer land use scenario by
about 2030, rendering the site suitable for unrestricted use.

The Hot Ponds area has been restored to a natural terrain and
revegetated with native grasses.

[Sewage Lagoon Site]{.underline}---This site is located immediately west
of the ITL site and consisted of six sewage lagoons. Elevated levels of
cesium-137 and strontium-90 among other radionuclides were found in the
former lagoon residual soils.

Between 1963 and 1992 sanitary sewage was discharged to the lagoons
which consisted of six cells within a 10-acre area. Lagoons 1, 2, and 3
had asphalt berms and were lined with polyethylene over a compacted
bottom. Lagoon 4 had no synthetic liner but was constructed with a
compacted bottom and asphalt berms. Lagoons 5 and 6 were constructed
with impermeable clay bottoms and concrete berms. DOE took the lagoons
out of service in May of 1992, when ITL began using the city sewer
system.

The total area of residually contaminated soil for this site is 7 acres.
The site was remediated in 1997. The soils were remediated in accordance
with DOE Order 5400.5 (Radiation Protection of the Public and
Environment) and DOE Order 5820.2A (Radioactive Waste Management,
currently known as DOE Order 435.1). The sludge portion was remediated
pursuant to State of New Mexico regulations.

Remediation consisted of excavating the contaminated soil and dried
sludge and disposing of it off-site at Envirocare of Utah. As with the
Hot Ponds Site, total dose and isotope contributions were modeled for
both the industrial/commercial scenario and residential farming scenario
after remediation. Because of the location and nature of the current and
projected role of ITL, the most reasonable exposure scenario was
determined to be the industrial/commercial scenario. Residual
radioactivity is currently under 15 millirem/year under the current
industrial land use scenario. By about 2030 the radioactivity is
expected to decay to under 15 millirem/year under a residential farmer
land use scenario rendering the site suitable for unrestricted use
suitable for a residential farmer land use scenario.

[Diesel Spill Site---]{.underline}This site is approximately 0.3 acres
located within the main ITL site. The site consisted of contaminated
soils due to leaks of diesel fuel from underground tanks and fuel lines.
The underground storage tanks were removed in 1993. The contaminated
soils were remediated through excavation and bioremediation. All
excavated soil was placed in a local permitted landfill offsite. No
further remediation or monitoring is required for Diesel Spill Site
soils.

### Groundwater

[Sewage Lagoon Site]{.underline}---Although the soil has been remediated
at this site, residual groundwater contamination remains. The
remediation strategy accepted by the New Mexico Environment Department
(NMED) Groundwater Quality Bureau is monitored natural attenuation.
Current monitoring and reporting requirements, as directed by Discharge
Permit (DP-519), consist of monitoring for four parameters (Total
Dissolved Solids (TDS), Sulfate, Chloride and Nitrate) for eight on-site
wells on a semiannual basis and three off-site wells on an annual basis.

The terms of the Discharge permit are consistent with the accepted
remedy of Monitored Natural Attenuation. NMED can modify the permit
requirements if it determines that requirements of state law are being
or may be violated, or the relevant state standards are being or may be
violated. Under the terms of the Discharge Permit, monitoring is to
continue until all contaminants remain below New Mexico Water Quality
Control Commission (WQCC) standards for four consecutive semiannual
(twice a year) periods. These standards represent state groundwater
standards. Currently two contaminants, TDS and Sulfate, are above WQCC
standards. TDS is above the standard in three wells and Sulfate is above
the standard in two wells.

The contaminated groundwater covers about 15 acres. Depth to groundwater
in the Sewage Lagoons area is approximately 80 feet.

As the groundwater exceeds the WQCC standards, it is not available for
drinking water, nor is the need to access this water for drinking
purposes anticipated. The Sewage Lagoon Site is located within the ITL
facility itself, which is totally encompassed by fencing. Institutional
and access controls are in place to prohibit accessing this water for
drinking water purposes.

[Diesel Spill Site]{.underline}\-- Although the soil has been remediated
at this site, residual groundwater contamination remains. The
remediation strategy accepted by the NMED Underground Storage Tank (UST)
Bureau is monitored natural attenuation. Current monitoring and
reporting requirements, as directed by NMED UST Bureau consist of
monitoring one well on a semiannual basis for Polyaromatic Hydrocarbons,
1,2 DCB; 1,3 DCB, 1,4 DCB and BTEX. As with the Sewage Lagoon Site, the
conditions imposed by the UST Bureau are consistent with the accepted
remedy of Monitored Natural Attenuation. Monitoring is to continue until
all contaminants remain below WQCC standards for 8 consecutive quarters
or four consecutive semiannual periods. In the latest sampling
semiannual event which was reported in December, 2003, one contaminant,
methylnaphthalene, was above the WQCC standard.

The contaminated groundwater covers about 0.3 acres. Depth to
groundwater in the Diesel Spill Site area is approximately 110 feet.

As with the Sewage Lagoon Site, the groundwater at the Diesel Spill Site
exceeds the WQCC standards, and is not available for drinking water, nor
is the need to access this water for drinking purposes anticipated. The
Diesel Spill Site is located within the ITL facility itself, which is
totally encompassed by fencing. Institutional and access controls are in
place to prohibit accessing this water for drinking water purposes.

#### [WASTE MANAGEMENT and SURFACE DECONTAMINATION]{.underline}

Although the remaining scope of work at ITL will not result in the
identification of any further hazard areas, this scope is discussed
below to provide information on the work to be accomplished to complete
the EM mission at ITL and reach the end states described in this
document.

There are four areas for which work scope remains. These areas are (1)
Miscellaneous Labs and Areas, (2) Analytical Chemistry Building, (3)
Beta Gamma Wing, and (4) Castle Area. For each of these areas, hazardous
and low-level radioactive waste will be identified and removed and the
surfaces will be decontaminated. The Beta Gamma Wing is expected to
continue to be used for radiological research and as such will remain a
restricted use area. The other areas are expected to be decontaminated
to be made available to ITL for its research use without radiological
restrictions.

The hazardous and low-level radioactive legacy waste from DOE operations
is being removed from ITL and disposed of on an ongoing basis. No
treatment or disposal is done on-site. Legacy waste is collected and
packaged for disposal off-site. ITL is a small quantity generator under
RCRA. Once the waste is collected and removed from an ITL laboratory or
facility, the floors, walls, and counters are surveyed for radiological
contamination through a modified Multi Agency Radiological Site Survey
Investigation Manual approach. The affected facilities are cleaned and
surface decontaminated, if necessary, to be made available for ITL's
use. Residual contamination within the drains, vents, and ducts are not
surveyed as part of this process. However, surveys are conducted at the
entrance to the drains, vents and ducts to ensure there is no residual
radiological risk to the laboratory staff. Complete decontamination and
decommissioning, which could include removing the buildings and
restoring the lands, is beyond the scope of the EM program.

The remaining inventory includes approximately 230 cubic meters of Low
Level Waste (LLW), 17 metric tons of hazardous waste (HW), 3 or 4 drums
of Transuranic (TRU) waste, 500 radiological sources, and 500
source-like materials. The source-like material includes a very small
amount of Special Nuclear Materials (SNM).

#### [Decontamination and Decommissioning]{.underline}

DOE has a long term responsibility for decontaminating and
decommissioning (D&D) ITL facilities as they become excess. Because of
extensive use of these facilities by DOE, it is expected that virtually
all research buildings will require D&D for radiological contaminants in
the drains and duct work, in addition to the surface decontamination
being conducted as part of the EM mission.

In addition to DOE's responsibilities for D&D of facilities determined
to be excess, the land use permit between the Air Force and DOE requires
DOE to restore the premises at the end of DOE's permitted use of the
property. This could include demolishing the existing facilities and
restoring the entire site, buildings and land.

The permit between DOE and the Air Force is currently in full force and
effect and will remain so until such time as either party terminates the
agreement or it is cancelled by the Secretary of Defense. The current
lease expires in 2025.

Currently, however, the ITL laboratories and facilities that are being
cleaned out and surface decontaminated are available for ITL's use and
no buildings have been determined to be excess. It is anticipated that
any buildings determined to be excess and requiring D&D in the future
will be the responsibility of the landlord organization, not the EM
program.

#### End States

The remaining scope at ITL consists of cleaning legacy waste and
contamination out of about 30 laboratories and miscellaneous work areas.
This involves characterizing and disposing of about 17 metric tons of
hazardous and 230 cubic meters of radioactive waste and surface
decontaminating the work areas, rendering them available for ITL's
future research use.

The current state of ITL reflects the remaining work to be done to
collect and dispose of legacy waste, surface decontaminating the work
areas, continued groundwater monitoring and maintaining access controls
for the four remaining hazard sites.

The Current Cleanup Baseline End State will be achieved when all DOE
legacy waste has been collected and disposed of and when all laboratory
and facility surfaces have been decontaminated. Under the Current
Cleanup Baseline, as indicated in the Accelerated Project Plan, there
will be a continuing, indefinite need for groundwater monitoring and
reporting for both the Sewage Lagoon and Diesel Spill Sites and
maintaining institutional and access controls to ensure there are no
receptors for the groundwater. These functions would become the
responsibility of the landlord organization upon completion of the EM
mission. It is assumed that ITL will remain an active laboratory for the
foreseeable future and that the current industrial land use designation
will not change during the 25-year period of the current lease.

In addition, there will be a continued need to maintain institutional
controls to ensure industrial usage at the Sewage Lagoon Site and old
Hot Ponds site because of the residual radioactive contamination present
at these sites. These controls will have to be maintained until about
2030, when radioactive decay is expected to render these sites suitable
for unrestricted use.

Decontamination of drains and ducts and ultimate decommissioning of the
buildings is not considered as the end state.. As facilities become
excess to ITL's needs, the DOE landlord organization may be required to
D&D these facilities. However, the end state vision is based on
continued use of the facility as a laboratory and does not include D&D
of the facilities.

The Current Cleanup Baseline End State is risk based in that it
calculates potential radiological exposure consistent with the current
and projected industrial land use for the soils sites. These soil sites
are unoccupied and no buildings are constructed or contemplated for
these areas. Industrial and access controls are in place to reduce risk
to potential receptors. With regard to the groundwater sites, monitoring
is continuing to ensure the contamination does not migrate and
institutional and access controls are in place to ensure that there is
no risk to potential receptors.

The Risk Based End State (RBES) for ITL would vary modestly from the
Current Cleanup Baseline End State. Under the RBES, a variance in the
form of an Alternative Abatement Standard for the Sewage Lagoon Site
would be sought from the WQCC. WQCC regulations accommodate applications
for Alternative Abatement Standards and can approve them under certain
conditions, including demonstration that the alternative standards would
not create a present or future hazard to public health or undue damage
to property. DOE and ITL, in seeking these alternative standards, would
follow the procedures detailed in the WQCC regulations at NMAC
20.6.2.4103. In all other respects, the RBES would be identical to the
Current Cleanup Baseline State.

**Variance**

There is a modest variance between the Current Cleanup Baseline State
and the RBES. If an application for Alternative Abatement Standards is
sought and granted, the baseline costs for groundwater monitoring and
reporting would be reduced from approximately \$70K per year to
approximately \$10K per year .

Lack of commitment from the Office of Science or other program to serve
as the landlord may impact the ability to transition long-term
responsibilities for the site, but will not impact the risk-based end
state. If ITL were to cease operation, under the terms of the permit
with the Air Force, the facilities may require D&D if they are
determined to be excess to DOE's needs. In this case, a variance would
exist against the Current Cleanup Baseline State. Funding in the amount
of approximately \$18 million (in 2004 dollars) would be needed to
remove the buildings and restore the land to its state at the time the
permit was originally granted by the Air Force and the ITL facilities
were built.

The current funding profile does not support accelerated completion of
the EM Project at ITL. Under the current funding profile, the Project
will be completed in approximately 2010. Under an accelerated funding
profile, the Project could be completed in 2005 or 2006.

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Map Narratives

1.  [Regional Physical and Surface interface]{.underline}

The Inhalation Toxicology Laboratory (ITL) is located in Albuquerque,
Bernalillo County, New Mexico in the southeastern portion of Kirtland
Air Force base (Kirtland) , at its southern edge. Kirtland is located
immediately to the south and west of Albuquerque proper. ITL is located
10 miles from the northern boundary of Kirtland on land withdrawn from
the Bureau of Land Management by the Air Force and permitted to DOE. It
is bounded on the south by the Pueblo of Isleta, a community of
approximately 4,000 residents.

Kirtland is located on a high, arid mesa about 5 miles east of the Rio
Grande River. The area surrounding ITL is relatively flat sloping gently
westward towards the Rio Grande. The mean elevation of Kirtland is 5348
feet.

2.  [Regional Human and Ecological Land Use]{.underline}

The Albuquerque metropolitan area is comprised essentially of land
designated for residential commercial/industrial use. The land
surrounding Albuquerque is largely designated as non-agricultural,
vegetated with the exception of large portions of Kirtland Air Force
Base which are designated commercial/industrial. The land upon which the
Inhalation Toxicology Laboratory is located is designated
commercial/industrial land use.

3.1 [Site Physical and Surface interface]{.underline}

There are 8 groundwater monitoring wells on or near the ITL property and
3 groundwater monitoring wells south of ITL property on Isleta Pueblo
land that are used to monitor contamination from the ITL Sewage Lagoon
Site.

One well, MW-16 is associated with the Diesel Spill and is monitored
semiannually.

3.2 [Site human and ecological land use]{.underline}

ITL is located on land designated for commercial, industrial, or
transportation use. The surrounding area is non-agriculture vegetated
land.

3.3 [Site legal ownership]{.underline}

ITL is on the southern edge of Kirtland Air Force Base and is located on
land the Air Force has withdrawn from the Bureau of Land Management and
permitted to DOE. The Pueblo of Isleta bounds ITL on the immediately
south. The South Fence Round depicted is on the boundary of Kirtland Air
Force Base and the Isleta Pueblo.

3.4 [Site demographics]{.underline}

According to the 2000 census, Albuquerque is the largest city in New
Mexico with an estimated population of 450,000. The greater Albuquerque
area, which includes Rio Rancho and surrounding communities has an
estimated population of 550,000. The 2000 Metropolitan Statistical Area
(MSA) estimated population, which includes Bernalillo, Valencia, and
Sandoval counties, is 712,000. The Bureau of Business and Economic
Research at the University of New Mexico estimates that by the year 2025
that the MSA population will grow to approximately 1,028,000. As shown
in Map 3.4, the area around ITL is very sparsely populated. The
projected growth of Albuquerque is not expected to impact ITL due to the
laboratory's remote location, completely surrounded by Air Force and
Isleta Pueblo property.

4.0 [Site-wide hazards]{.underline}

Map 4.0 depicts the four ITL hazard areas. The risk to human health and
the environment posed by these hazard areas is below accepted standards
for industrial use.

4.1 [Hazard Area 1]{.underline}

Map 4.1 shows the location of the ITL hazards related to contaminated
groundwater. There are two sites, the Sewage Lagoon Site and the Diesel
Spill Site.

[Sewage Lagoon Groundwater]{.underline}

The groundwater plume on the western side of the ITL facility represents
groundwater contamination from the Sewage Lagoons. The remediation
strategy accepted by the New Mexico Environment Department (NMED) is
monitored natural attenuation. Current monitoring and reporting
requirements consist of monitoring for four parameters (Total Dissolved
Solids (TDS), Sulfate, Chloride and Nitrate) for eight ITL wells on a
semiannual basis and three Isleta Pueblo wells on an annual basis.

Under the terms of the NMED Discharge Permit, monitoring is to continue
until all contaminants remain below New Mexico Water Quality Control
Commission (WQCC) standards for four consecutive semiannual periods.
Currently two contaminants, TDS and Sulfate are above WQCC standards.
TDS is above the standard in three wells and Sulfate is above the
standard in one well.

The following summarizes the latest (December 2003) monitoring data with
regard to contamination at the Sewage Lagoon site:

+-----------------+-----------------+-----------------+-----------------+
| Well            | Contaminant     | WQCC Standard   | June 2003       |
|                 |                 |                 | Result          |
|                 |                 | (ppm)           |                 |
|                 |                 |                 | (ppm)           |
+-----------------+-----------------+-----------------+-----------------+
| MW-4            | TDS             | 1000            | 2100            |
+-----------------+-----------------+-----------------+-----------------+
| MW-4            | Sulfate         | 600             | 750             |
+-----------------+-----------------+-----------------+-----------------+
| MW-17           | TDS             | 1000            | 1400            |
+-----------------+-----------------+-----------------+-----------------+
| MW-17           | Sulfate         | 600             | 690             |
+-----------------+-----------------+-----------------+-----------------+
| MW-19           | TDS             | 1000            | 1400            |
+-----------------+-----------------+-----------------+-----------------+

[Diesel Site Groundwater]{.underline}

Although the soil has been remediated at this site, residual groundwater
contamination remains. The remediation strategy accepted by the NMED
Underground Storage Tank (UST) Bureau is monitored natural attenuation.
Current monitoring and reporting requirements, as directed by NMED UST
Bureau consist of monitoring one well (MW-16) on a semiannual basis for
Polyaromatic Hydrocarbons, 1,2 DCB; 1,3 DCB, 1,4 DCB and BTEX.
Monitoring is to continue until all contaminants remain below WQCC
standards for 8 consecutive quarters. Currently one contaminant,
methylnaphthalene has been above the WQCC standard.

4.2 [Hazard Area 2]{.underline}

Map 4.2 shows the location of the ITL hazards related to residual
radiological contamination in soils. There are two sites, the Sewage
Lagoon Site and the former Hot Ponds Site.

[Sewage Lagoon Soils]{.underline}

Soils and sludge from this site were excavated and disposed of off-site.
Residual radioactive contamination remains due to Cesium 137, Strontium
90 and other radionuclides. The site was remediated to result in an
exposure of under 15 millirems per year under the current and projected
industrial/commercial land use designation. The Sewage Lagoon site has
been restored to a natural terrain and re-vegetated with native grasses.
It is encompassed by chain link fencing.

[Former Hot Ponds Site]{.underline}

This site is a one-half acre area located about one-tenth of a mile east
of the ITL site. The site consisted of two small concrete-lined
evaporative sumps (commonly referred to as the "Hot Ponds"), two metal
buildings and assorted support equipment.

Remediation was completed in 1997 and consisted of removing and
disposing of the two sumps, both of the buildings, and concrete and
surrounding soil as low-level radioactive material at Envirocare of
Utah. The soils were remediated in accordance with DOE Order 5400.5
(Radiation Protection of the Public and Environment) and DOE Order
5820.2A (Radioactive Waste Management, currently known as DOE Order
435.1).

Based on risk assessments, remediation has reduced the potential dose
from residual radioactive contamination of the soil due to cesium-137,
strontium-90 and other radionuclides to below acceptable limits.
Residual radioactivity is currently about 9 millirem/year under the
existing industrial land use scenario. Through natural decaying of the
radionuclides, the Hot Ponds area is expected to decay to 12
millirem/year under a residential farmer land use scenario by about
2030, rendering the site suitable for unrestricted use.

The Hot Ponds area has been restored to a natural terrain and
revegetated with native grasses. It is not fenced but is in close
proximity to ITL and under its administrative control.

![](media/image10.wmf){width="5.996456692913386in"
height="5.231889763779527in"}

![](media/image10.wmf){width="5.996456692913386in"
height="5.231889763779527in"}

Conceptual Site Models

Figures 4.1b2 and 4.2b2 represent the Conceptual Site Models for the
four hazard areas that are expected to remain at the Inhalation
Toxicology Laboratory at the completion of the EM mission. The
Conceptual Site Models are identical for both the Current State and the
Risk Based End State. The two groundwater hazards are depicted together
in and Figure 4.1b2 and the two soils hazards are depicted together in
Figure 4.2b2.

The Conceptual Site Models were developed based on the assumption that
the current industrial land use designation will continue indefinitely
and that the terms of the lease between DOE and ITL will remain as
intended at least until the current lease expires in 2025.

Information for the Sewage Lagoon Site is taken from the Inhalation
Toxicology Research Institute (ITRI) Sewage Lagoon Closure Report
(October 1996). Information for the Hot Ponds is taken from the ITRI Hot
Ponds Site Closure Report (September 16, 1997). Information for the
Diesel Spill Site is taken from the ITRI Hyrdogeologic Investigation
Report for the Diesel Oil Release Assessment Program (July 21, 1993).

The following is a discussion on each of the hazard areas:

**[Sewage Lagoon Soils]{.underline}**

[Description]{.underline}

The former Sewage Lagoon cells are depicted in blue on map 3.1. Between
1962 and 1992 sanitary sewage and waste water was discharged to the
lagoons which consisted of six cells within a 10-acre area. The
discharge consisted of 15 percent kennel-wash water, 15 percent cage
wash water, 20 percent sewage, and 50 percent mechanical use water. The
waste material in the lagoons was allowed to degrade by normal microbial
processes, and the water was allowed to evaporate.

Lagoons 1, 2, and 3 had asphalt berms and were lined with polyethylene
over a compacted bottom. Lagoon 4 had no synthetic liner but was
constructed with a compacted bottom and asphalt berms. Lagoons 5 and 6
were constructed with impermeable clay bottoms and concrete berms. DOE
took the lagoons out of service in May of 1992, when ITL began using the
city sewer system.

The total area of residually contaminated soil for this site is 7 acres.
The site was remediated in 1997. The soils were remediated in accordance
with DOE Order 5400.5 (Radiation Protection of the Public and
Environment) and DOE Order 5820.2A (Radioactive Waste Management,
currently known as DOE Order 435.1). The sludge portion was remediated
pursuant to State of New Mexico regulations.

Verification sampling indicates that residual radioactivity due to
Cesium 137 and Strontium 90 is present in all six lagoons with
activities ranging from 1 pCi/g to 24 pCi/g. The activities noted above
15 pCi/g represent hot spots, all of which were below the PRG of 45
pCi/g.

The radiological risk assessment performed at site closure indicates
that

residual radioactivity is currently under 15 millirem/year under the
current industrial land use scenario and is suitable for exposure under
that scenario. The residual radioactive contamination is primarily due
Cesium 137, the dominant radionuclide of concern. As minor amounts of
Strontium 90 are believed to be present, Strontium 90 is considered a
potential radionuclide of concern.

By about 2030 the radioactivity is expected to decay to under 15
millirem/year under a residential farmer land use scenario rendering the
site suitable for unrestricted use suitable for a residential farmer
land use scenario.

# 

With regard to non-radiological contaminant risk, nitrate was determined
to be the only contaminant of concern. However, since the hazard indices
was determined to be orders of magnitude below the critical value of 1,
the likelihood of adverse effects from the presence of nitrate in Sewage
Lagoon soils is very low.

Protection of current and future receptors is accomplished by the use of
access and institutional controls. The Sewage Lagoon site is encompassed
by chain link fencing. The site is suitable for industrial use but is
currently uninhabited. There are no plans to expand ITL operations on
the site and controls are expected to continue. As noted earlier,
radioactive decay will render the site suitable for unrestricted access
by the year 2030.

# Primary and Secondary Sources

The primary sources of contamination were waste water and sewage
discharged from the ITL facility from the period 1962 to 1992. The
secondary source is the groundwater approximately 80 feet below the
sewage lagoons to where nitrate, chloride, total dissolved solids, and
sulfate have migrated.

# 

# Release, Transport, and Exposure Mechanisms

Potential radiological exposure pathways are inhalation of particulate
matter from wind-eroded lagoon bottom material, ingestion of and dermal
contact with the bottom material, and ingestion of contaminated
groundwater. Ingestion of groundwater was determined to be an incomplete
pathway because groundwater data did not indicate that Cesium 137 had
migrated from the lagoons. In addition, the ITL groundwater is not used
for drinking nor is it near any drinking water wells. As Cesium 137
contamination was localized in the lagoon bottom material, other
exposure pathways are limited.

The non-radiological contaminants, nitrate, sulfate, total dissolved
solids, and chloride have reached groundwater through leaching of lagoon
water to the groundwater which is approximately 80 feet below the
lagoons. This is discussed the in Sewage Lagoons Groundwater section,
below.

# Temporary Barriers and Controls

The Sewage Lagoon Site is an integral part of the ITL facility
encompassed by chain link fence. It is currently uninhabited and there
are no plans for constructing facilities on the site. The access and
institutional controls are expected to continue indefinitely.

# Failure Analysis

A comprehensive failure analysis to ascertain the consequences of the
temporary barriers and controls had not been conducted. Failure of these
controls could result in unauthorized access or construction at the
Sewage Lagoon Site. However, as the Sewage Lagoon Site is an integral
part of the ITL facility, this is considered highly unlikely. Exposure
exceeding risk based standards could occur if the current controls fail
and residential construction and occupation in the Sewage Lagoon Site
are realized.

# Remediation, Mitigation, and Other Interventions

Remediation was conducted in September and October of 1995 and consisted
of excavating the contaminated soil and dried sludge and disposing of it
off-site at Envirocare of Utah. The remediation of lagoons 1 through 4
involved excavation of approximately 3,500 yards of contaminated soil.
Lagoons 5 and 6 did not require excavation because surveys and analyses
indicated that no materials were present that exceeded the Cesium 137
PRG of 15 pCi/g. The remediation also included removal of all concrete,
drainage pipe, telephone poles, electrical equipment, and the
abandonment of two groundwater leak detection wells.

[Receptors]{.underline}

ITL is located on the southern edge of Kirtland Air Force Base, 10 miles
from the northern boundary. Access to Kirtland is controlled through
guarded gates requiring proper identification. The Sewage Lagoon Site
itself is an integral part of the ITL facility. Access to the ITL
facility itself is controlled and visitors are escorted. As a result,
exposures to visitors or potential trespassers are highly unlikely. ITL
workers occasionally visit the site for routine groundwater monitoring
activities. No risk studies have been performed specifically focusing on
ecological risk.

**[Former Hot Ponds Site]{.underline}**

[Description]{.underline}

The former Hot Ponds site is a one-half acre area located about
one-tenth of a mile east of the ITL site. The Hot Ponds consisted of two
29 square foot sumps (commonly referred to as the "Hot Ponds") that were
used as holding ponds for liquid, low-level radioactive waste received
from ITL operations from 1963 to 1985. There were also two buildings at
the site. One was a 660 square foot building, which was routinely used
for the compaction of radioactive materials. The other was a 180 square
foot building that housed mechanical equipment associated with the
operation of the Hot Ponds. There was also an above ground propane tank,
some unused concrete tank supports and miscellaneous pipes telephone
poles, and small utility structures.

Based on risk assessments, remediation has reduced the potential dose
due to residual radioactive contamination of the soil due primarily to
Cesium-137, as well as strontium-90 and other radionuclides, to below
acceptable limits. The dose assessment completed on the Hot Ponds site
confirmed that doses will be below the 15 mrem/year for the current
industrial and future residential farmer land use scenarios. Residual
radioactivity is currently about 9 millirem/year under the existing
industrial land use scenario. Through natural decaying of the
radionuclides, the Hot Ponds area is expected to decay to 12
millirem/year under a residential farmer land use scenario by about
2030, rendering the site suitable for unrestricted use.

The Hot Ponds area has been restored to a natural terrain and
revegetated with native grasses. It is not fenced but is in close
proximity to ITL and under its administrative control.

# 

# Primary and Secondary 

The primary sources of contamination were liquid, low-level radioactive
waste received from ITL operations from 1963 to 1985. The potential
secondary source is the groundwater approximately 80 feet below the Hot
Ponds surface to where radionuclides could migrate. However, no
radionuclides have been detected in the Hot Ponds groundwater.

# Release, Transport, and Exposure Mechanisms

Potential pathways include direct exposure to external radiation from
contaminated soil material, internal dose from inhalation of airborne
radionuclides, internal dose from ingestion of plants foods grown in the
contaminated soil and irrigated with contaminated water, meat and milk
from livestock fed with contaminated fodder, and drinking water from a
contaminated well or pond. These pathways are not complete because the
site has been remediated to industrial standards, groundwater has not
been effected, and the site is under institutional and access controls

Because ITL is located on government property which has been designated
as industrial land use and is expected to remain so for at least the
next 25 years, the

industrial/commercial land use scenario was used as the most likely
future land use scenario for purposes of establishing soil cleanup
guidelines.

[Temporary Barriers and Controls]{.underline}

The Hot Ponds Site is located on the ITL facility. It is currently
uninhabited and there are no plans for constructing facilities on the
site. As mentioned before, ITL is located within the controlled access
area of the Kirtland Air Force Base. This control is expected to
continue indefinitely.

# Failure Analysis

A comprehensive failure analysis to ascertain the consequences of the
temporary barriers and controls has not been conducted. Failure of these
controls could result in unauthorized access or construction in the Hot
Ponds Area. However, as the Hot Ponds Site is immediately adjacent to
the ITL facility, this is considered highly unlikely. Exposure exceeding
risk based standards could occur if the current controls fail and
residential construction and occupation at the Hot Ponds Site are
realized.

# Remediation, Mitigation, and Other Interventions

The removal action at the Hot Ponds site commenced in October of 1995.
The two buildings were demolished and commercially available remote
control demolition equipment was used to break up the apron and sump
concrete. All materials removed from the Hot Ponds area (concrete, metal
etc.) were surveyed to determine if they were contaminated or were
suitable for unrestricted use.

Contaminated soil i.e. soil with radioactivity above the PRG was
excavated from all areas until all contaminated soil was removed.
Contaminated materials were disposed of at Envirocare of Utah. After the
collection of confirmatory samples, the Hot Ponds were then backfilled
and the site was landscaped and reseeded.

Remediation was completed in 1997. The site was remediated in accordance
with DOE Order 5400.5 (Radiation Protection of the Public and
Environment) and DOE Order 5820.2A (Radioactive Waste Management,
currently known as DOE Order 435.1).

Although the site is not fenced, it is in close proximity to the ITL
facility and is under ITL administrative control. Access and
institutional controls are in place to ensure there are no unauthorized
or unescorted visitors. Although the site is suitable for industrial
uses, there are no plans to develop or occupy facilities at the Hot
Ponds site.

[Receptors]{.underline}

ITL is located on the southern edge of Kirtland Air Force Base, 10 miles
from the northern boundary. Access to Kirtland is controlled through
guarded gates requiring proper identification. The Hot Ponds site itself
is located on the ITL facility. Access to the ITL facility itself is
controlled and visitors are escorted. As a result, exposures to visitors
or potential trespassers are highly unlikely. ITL workers occasionally
visit the site for routine groundwater monitoring activities. No risk
studies have been performed specifically focusing on ecological risk.

**[Sewage Lagoon Groundwater]{.underline}**

# Description

As noted above, the former Sewage Lagoon cells are depicted in blue on
map 3.1. Between 1962 and 1992 sanitary sewage and waste water was
discharged to the lagoons which consisted of six cells within a 10-acre
area. The discharge consisted of 15 percent kennel-wash water, 15
percent cage wash water, 20 percent sewage, and 50 percent mechanical
use water. The waste material in the lagoons was allowed to degrade by
normal microbial processes, and the water was allowed to evaporate.

Results of monitoring wells indicated that nitrate-nitrite, total
dissolved solids, sulfate and chloride were present and attributable to
leaching of lagoon water to groundwater.

The groundwater plume on the western side of the ITL facility shown in
Hazard Map 4.1 a/b represents the estimated extent of groundwater
contamination from the Sewage Lagoons. Current monitoring and reporting
requirements consist of monitoring for four parameters (Total Dissolved
Solids (TDS), Sulfate, Chloride and Nitrate) for eight ITL wells on a
semiannual basis and three Isleta Pueblo wells on an annual basis.

Under the terms of the NMED Discharge Permit, monitoring is to continue
until all contaminants remain below New Mexico Water Quality Control
Commission (WQCC) standards for four consecutive semiannual periods.
Currently two contaminants, TDS and Sulfate are above WQCC standards.
TDS is above the standard in three wells and Sulfate is above the
standard in two wells.

The following summarizes the latest (June 2003) monitoring data with
regard to contamination at the Sewage Lagoon site:

+-----------------+-----------------+-----------------+-----------------+
| Well            | Contaminant     | WQCC Standard   | June 2003       |
|                 |                 |                 | Result          |
|                 |                 | (ppm)           |                 |
|                 |                 |                 | (ppm)           |
+-----------------+-----------------+-----------------+-----------------+
| MW-4            | TDS             | 1000            | 2100            |
+-----------------+-----------------+-----------------+-----------------+
| MW-4            | Sulfate         | 600             | 750             |
+-----------------+-----------------+-----------------+-----------------+
| MW-17           | TDS             | 1000            | 1400            |
+-----------------+-----------------+-----------------+-----------------+
| MW-17           | Sulfate         | 600             | 690             |
+-----------------+-----------------+-----------------+-----------------+
| MW-19           | TDS             | 1000            | 1400            |
+-----------------+-----------------+-----------------+-----------------+

# Primary and Secondary Sources

The primary sources of contamination were waste water and sewage
discharged from the ITL facility from the period 1962 to 1992. The
secondary source is the groundwater approximately 80 feet below the
sewage lagoons to where nitrate, chloride, total dissolved solids, and
sulfate have migrated.

# Release, Transport, and Exposure Mechanisms

The primary release and exposure mechanisms for Sewage Lagoon Water are
direct access to the groundwater for drinking or migration of the
groundwater to domestic drinking wells.

[Temporary Barriers and Controls]{.underline}

The Sewage Lagoon Site is an integral part of the ITL facility
encompassed by chain link fence. It is currently uninhabited and there
are no plans for constructing facilities on the site. The access
controls are expected to continue indefinitely.

# Failure Analysis

A comprehensive failure analysis to ascertain the consequences of the
temporary barriers and controls has not been conducted. Failure of these
controls could result in unauthorized access to and use of groundwater
which exceeds state groundwater limits for drinking water purposes.
However, as the Sewage Lagoon Site is an integral part of the ITL
facility, this is considered highly unlikely.

# Remediation, Mitigation, and Other Interventions

The remediation strategy accepted by the New Mexico Environment
Department (NMED) is monitored natural attenuation. In addition, there
are institutional and access controls in place to restrict access to the
site.

[Receptors]{.underline}

ITL is located on the southern edge of Kirtland Air Force Base, 10 miles
from the northern boundary. Access to Kirtland is controlled through
guarded gates requiring proper identification. The Sewage Lagoon Site
itself is an integral part of the ITL facility. Access to the ITL
facility itself is controlled and visitors are escorted. As a result,
exposures to visitors or potential trespassers are highly unlikely. ITL
workers occasionally visit the site for routine groundwater monitoring
activities. No risk studies have been performed specifically focusing on
ecological risk.

**[Diesel Site Groundwater]{.underline}**

# Description

The Diesel Spill Site is shown in hazard map 4.1 a/b and is an
approximately 0.3 acre site located within the fenced portion of the
main ITL facility. The site soil and groundwater contamination
originated from leaks of diesel fuel from underground tanks and fuel
lines. All of tanks were known to contain diesel fuel exclusively.

Current groundwater monitoring and reporting requirements, as directed
by NMED UST Bureau consist of monitoring one well (MW-16) on a
semiannual basis for Polyaromatic Hydrocarbons, 1,2 DCB; 1,3 DCB, 1,4
DCB and BTEX. Monitoring is to continue until all contaminants remain
below WQCC standards for 8 consecutive quarters. Historically,
naphthalene has been noted in concentrations as high as 130 parts per
million. Currently one contaminant, methylnaphthalene, is above the WQCC
standard.

# Primary and Secondary Sources

The primary sources of contamination were diesel fuel leaked from
underground storage tanks and fuel lines beginning in 1983. The
secondary source is the groundwater approximately 110 feet below the
contaminated soil site to where naphthalene and methylnaphthalene have
migrated.

# Release, Transport, and Exposure Mechanisms

The primary release and exposure mechanisms for Diesel Spill site
groundwater are direct access to the groundwater for drinking or
migration of the groundwater to domestic drinking wells. No migration
has of contamination has been observed since groundwater monitoring
began at the ITL site in 1993.

[Temporary Barriers and Controls]{.underline}

The Diesel Spill Site is an integral part of the ITL facility
encompassed by chain link fence. The surface above the contaminated
groundwater is covered with asphalt. There are access controls to the
ITL facility itself which preclude unauthorized access to the Diesel
Spill site. The access controls are expected to continue indefinitely.

# Failure Analysis

A comprehensive failure analysis to ascertain the consequences of the
temporary barriers and controls has not been conducted. Failure of these
controls could result in unauthorized access to and use of groundwater
which exceeds state groundwater limits for drinking water purposes.
However, as the Diesel Spill Site is an integral part of the ITL
facility, this is considered highly unlikely.

# Remediation, Mitigation, and Other Interventions

The last of five underground storage tanks and associated piping were
removed in 1993 and the soil was remediated through excavation and
bioremediation. Although the soil has been remediated, residual
groundwater contamination remains. The remediation strategy accepted by
the NMED Underground Storage Tank (UST) Bureau is monitored natural
attenuation.

[Receptors]{.underline}

ITL is located on the southern edge of Kirtland Air Force Base, 10 miles
from the northern boundary. Access to Kirtland is controlled through
guarded gates requiring proper identification. The Diesel Spill Site
itself is an integral part of the ITL facility. Access to the ITL
facility itself is controlled and visitors are escorted. As a result,
exposures to visitors or potential trespassers are highly unlikely. ITL
workers occasionally visit the site for routine groundwater monitoring
activities. No risk studies have been performed specifically focusing on
ecological risk.

Attachment 1

Inhalation Toxicology Laboratory

Variance Summary

+----------------------+---------------+---------------+---------------+
| Description of       | Scope, Cost,  | Barriers in   | Re            |
| Variance             | Schedule and  | Achieving     | commendations |
|                      | Risk Impacts  | Risk Based    |               |
|                      |               | End State     |               |
+----------------------+---------------+---------------+---------------+
| The current          | There would   | A Baseline    | Pursuit of    |
| agreement with the   | be a          | Change        | the           |
| state involves       | relatively    | Proposal      | Alternative   |
| continued            | modest        | would likely  | Abatement     |
| semi-annual          | (\~\$25K)     | be needed to  | Standards     |
| monitoring of the    | initial       | fund          | would require |
| Sewage Lagoon Site   | expense in    | developing    | headquarters  |
| until contaminants   | developing    | the           | approval of   |
| are consistently     | the           | application   | the BCP.      |
| below Water Quality  | application.  | to WQCC.      |               |
| Control Commission   | This would    |               | Action: If    |
| Standards. WQCC      | include a     | The           | approval is   |
| regulations allow    | more detailed | application   | received, DOE |
| for an application   | risk          | for           | and ITL would |
| for and granting of  | assessment    | Alternative   | begin the     |
| Alternative          | and           | Standards     | application   |
| Abatement Standards  | statistical   | would need to | process.      |
| if several           | evaluation.   | be approved   |               |
| conditions are met   |               | by WQCC to    |               |
| including            | If monitoring | achieve the   |               |
| demonstration that   | could be      | Risk Based    |               |
| the Alternative      | discontinued, | End State.    |               |
| Standards are        | monitoring    |               |               |
| protective of human  | costs of      |               |               |
| health.              | about \$60K   |               |               |
|                      | per year      |               |               |
| Under a Risk Based   | would be      |               |               |
| End State, ITL and   | avoided.      |               |               |
| DOE would seek       |               |               |               |
| Alternative          | As there are  |               |               |
| Abatement Standards  | no receptors, |               |               |
| for two              | no additional |               |               |
| contaminants.        | human health  |               |               |
|                      | or ecological |               |               |
|                      | risk is       |               |               |
|                      | anticipated.  |               |               |
+----------------------+---------------+---------------+---------------+

#