9A032F 1EG l

1 SSFL WORKGROUP FOR THE

2 BOEING-ROCKETDYNE SITE

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10 TRANSCRIPT OF PROCEEDINGS, taken a t

11 GRAND VISTA HOTEL, the SIMI-CONEJO ROOM, Simi Valley ,

12 California, commencing at 6 :30 p .m ., TUESDAY, MAY 16, 2000,

13 before AMY L . SLADE,` CSR NO . 10981 .

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21 - ATKINSON-BAKER, INC .

COURT REPORTER S

22 330 North Brand Boulevard, Suite 250Glendale, California 9120 3

23 (818) 551-730 0

24 REPORTED BY : AMY L . SLADE, CSR NO . 10981

25 FILE NO : 9A032F1

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1 SIMI VALLEY, CALIFORNIA ; TUESDAY, MAY 16, 2000 I2 6 :30 P .M . 23 34 MR. CAIN: Good evening We would like to begin our SSFL 45 workgroup meeting . 56 My name is Steve Cain . And I'm a representative for 67 the Department of Toxic Substances Control , and I'm here 78 today substituting for Vicky Semones as facilitator . 89 In my conversation with Vicky today, she wanted -- 9

10 she said she wasn' t able to make it here tonight because of 1 011 some illness . an d she wants .everyone to know she sends her 1 112 best wishes , and she wishes she could be here tonight . 1 213 Welcome to the May 16th , 2000 meeting of the Santa 1 314 Susana Field Laboratory Workgroup for the Boeing - Rocketdyne 1 415 site . And once again. I'll be acting as facilitator for the 1 516 meeting . 1 617 Before we begin . I'd like everyone to take a moment 1 718 to sign in at the sign-in table . By doing so . you c an assure 1 819 yourself that you will be getting announcements and 1 920 information sent out by the -U .S . EPA regarding S an ta Susana . 2 021 If you haven ' t, please do so during the break . We'd 2 122 appreciate it very much . 2 223 I think we will quickly review the agenda for 2 324 tonight . and we will go into the topics that are listed . The 2 425 meeting tonight is scheduled to run from 6 :30 to 10 : 00 p .m . 2 5

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We will be ending at 10 :0(1 p .m . tonight to assist people whohave arran ged for child care and have to get up tomorrow andgo to work .

The agenda topics are as a result of a number ofconference calls during which all workgroup members haveagreed to the topics and agreed to the time limits . We willtry to respect those time limits . We underst an d tha toccasionally we do have to modify them . but we will try tofollow the agenda as closely as possible to the time limitsbecause this is a very ambitious schedule tonight .

First, we will begin with administrative topics .introductions. and announcements . Then we will go to theapproval of the agenda actions, setting the next agenda --setting the next meeting date . As always , we have a veryambitious agenda . So we can get through the agenda . we willbe structuring the presentations on each topic by the leadagency or lead spokesperson . After their presentations . itwill be opened up for discussions and questions among theworkgroup members . Following that. there will be aten-minute question-and-answer period for the members fromthe-audience . About halfway through the meeting, well betaking a ten- or fifteen-minute break, followed by a20-minute general question - and- an swer period for the membersof the board and audience for nonagenda items. So we cankeep on track, it will be very appreciated if the audience

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members could be very specific and very direct with thei rquestions. And it would be very appreciated if they wouldfollow the ground rules that are posted by the microphone .

This meeting is being recorded by a court reporter .And a final official transcript will be sent to the workgrou pmembers to be reviewed for the correctness of the informatio nprovided and to correct any identification of unknownspeakers . Corrections will be made errata, and they will befiled with the original transcript, which will be madeavailable to the community approximately 30 days afte rtoday's meeting . No rough draft will be available thisevening . However, if you wish to speak to our cour treporter, she'll be able to provide you with a copy of thetranscript once it's final -- made official .

The workgroup is refining some ground rules for th econduct of these meetings. And although the wording of th eground rules are yet to be finalized, we are hoping tha teveryone will conduct themselves in the spirit of thos eground rules. In particular. we'd ask that members of theworkgroup and members who speak from the audience conduc tthemselves with respect for each other and for the members o1 'the group . It will be very appreciated if there will be n opersonal attacks or derogatory language used during thi smeeting .

At this time. I would like to in troduce Tom Kelly of

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I the U .S . EPA .

2 MR. KELLY : Hello . I'm Tom Kell . EPA project manager3 for the Boeing-Rocketdyne Lab .4 Do you want to go ahead with the introductions' '

MR . CAIN : Okay . Being in Southern California . there's6 always celebrities in the audience . And today th e7 celebrities that are present are some legislative8 representatives .9 If you can introduce yourselves.

10 MS. PLOTKIN : I'm Laura Plotkin from Assembly memberI I Sheila Kuehl's office .12 MR. CAIN : Welcome . If the members of the workgroup team13 could introduce themselves . And if you're affiliated with a14 regulatory agency or organization, please state what they

15 are .

16 MS. BATARSEH : I'm Pauline Batarseh with the Department17 of Toxic Substances Control .18 MR. HIRSCH: Daniel Hirsch with the Committee to Bridge19 the Gap .20 MR. ABRAMS : Gerard Abrams with the Department of Toxic21 Substances Control .22 MS. JOHNSON: I'm Barbara Johnson, Rocketdyne Cleanup23 Coalition and Santa Susana Knolls Association.24 MR. CAIN: I'm Steve Cain with California Department of25 Toxic Substances Control .

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I MR. KELLY: I'll pass. 12 MR. LUPO: Roger Lupo with the Department of Health 23 Services, Radiological Branch . 34 MR. HSU: Steve Hsu . also with the same organization 45 which is the Department of Health Services, Radiological 56 Branch. 67 MS. SUTHERLAND: Donna Sutherland with the U.S . 78 Department of Energy . 89 MR. LOPEZ : Mike Lopez with the Department of Energy . 9

10 MR. KELLY: Thank you . 1 0I I MR. CAIN: Thank you . We have an agenda before us . 1 112 Could we have an approval of the agenda. or does anyone want 1 213 to make any additions or changes to the agenda? 1 314 1 take that as a resounding approval . 1 415 Before we get to the meat of the matter, are there 1 516 any action item updates any member would like to bring before 1 617 the group? 1 718 Okay . The first item that we need to do is to set 1 819 the next meeting date . It should probably be in late 1 920 August . If everyone will bring out their calendars -- 2021 Traditionally . the meetings are held on Wednesday . 2 122 MR. KELLY: Usually . but we can be flexible. if need be . 2 223 MS. BATARSEH : Steve. if we can go to the first week of 2 324 September. August is when my vacation starts . Unless its 2425 okay with everybody else . I might not be able to make the 2 5

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last week of August .MR . ABRAMS : That w ould be a big help

3 MR. LOPEZ : Let's look --MR . CAIN : Lets look at the -- the 4th is Labor Day .

Shall we look at the I 1 th -- the week of the I I th "MR . KELLY Does anybody have a problem with that' 'MR. CAIN The week of the I ] th .

8 Traditionally. it's on Wednesday . We can look at9 the 13th of August or September .lu Any comments.' Ave or nay'?I I I guess we're done .12 MR. KELLY : We're only looking for nays . September 13th13 is a tentative date . Sometimes we have to adjust thes e14 things based on the meeting room availability and a number of'15 other factors . Occasionally . things come up for wvorkgroup16 members .17 UNIDENTIFIED SPEAKER: Is that Tuesday ?18 MR. CAIN: The first agenda item is Building D&D . The19 lead agencies to speak on it are DOE . DHS . and EPA . There's20 15 minutes allotted for the presentation . 40 minutes for th e21 discussion . and then ten minutes for questions from the22 community .23 MR. KELLY : Just for the workgroup members . we really24 haven't talked about time frames this time around -- Steve25 had missed the last call -- so I think we'll play it by

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I presentation on the project status . I f you want to get into2 the project status or --3 MR. CAIN: What would the workgroup members like to do''4 Would they like a complete package of information . or would

you like to divide it into sections' '6 Okay . The complete information . please .7 MR. LOPEZ: You want to go through the --8 MR. CAIN: The full nine yards .9 MR. LOPEZ : First . the other building list has the other

10 buildings that have to be signed off. and they have to giveI I us their status . What we plan on doing with them is to12 demolish them . There are some that are selected for13 transfer . And it also has a column for NEPA status --14 THE COURT REPORTER: Would you repeat that, please .15 MR. LOPEZ : N-E-P-A . I'm sorry .16 1 don't know why it doesn't lend itself. that form17 or that sheet, to the graph . I put it on . If people want to18 see it, it's available as a handout . And people can just as k19 questions. I guess if you want to go into the next step,20 that's just to give people the project -- I'm sorry --21 UNIDENTIFIED SPEAKER : What does "CX" mean?22 MS. SUTHERLAND : It's a level of --23 UNIDENTIFIED SPEAKER : What level' ?24 MR. CAIN: If we can have the presentation from the25 workgroup first. and then we'll have questions later .

PAGEear . I'm not sure where these times got added, but theyweren't discussed in any of our conference calls . so I thinkwe're just going to be flexible and see how the informationexchange goes . Hopefully, we can keep close to these timelimits . but we haven't really talked about these before .

MR. CAIN: Okay .MR. KELLY : DOE, are you guys ready to start on this

one?

MR. LOPEZ:' I guess we can start with the handout that wehave provided to everyone on the radiological facilit ystatus. Other minor information was requested . and weprovided some additional columns here with some of theinformation that have been requested . - I believe that the twoadditional columns are the EPA's status of their inspectionof the facilities and the building demolition dates . Thistime it's divided . and that resolves the question about thedates.

Go on?MR. CAIN: Yes .MR. KELLY: I'm sorry . There's a question .MR . CAIN : What do you want to do'?MR. KELLY: Do you want to have questions and --MR . CAIN : Do you have additional information to present .

or how would you like to --MR. LOPEZ: We have another building list . and we have a

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1 MR. LOPEZ: Okay . Cops, a wrong view .2 I have it divided up by fiscal years.3 The Fiscal Year 00 is October 1 to September 30 .4 SCTI, we've got the sodium component testing installation .5 It's a sodium facility, not a radioactive facility . We are6 in the amidst of demolishing the facility . We started it7 sometime ago previous to this year .8 There is the burn pit --9 THE COURT REPORTER: Sir, would you please speak into the

10 microphone .I I MR:LOPEZ: -- a former sodium disposal facility . and the12 interim removal action that was approved by DTSC . And we are13 projecting the signing of the interagency agreement with EPA14 for the survey work . We have some details to work out on15 that.16 Next year we start with Building 4059 building17 demolition . We have notified EPA that it's available for18 their surveying . We're looking at the completion of the19 sodium component testing installation -- Building 59 , for20 example . was originally going to --21 I have a feeling I'm fading in and out --22 -- Building 59 was originally scheduled for thi s23 year. and it is one item that has had its schedule changed24 because of the decision to do an environmental assessment of25 the site Hopefully- next year we'll get down to a workplan

PAGE 1 2I FY04, you will see a continuation of D&D of the2 sodium pump-test facility . Were hoping to complete the D&D3 or decontamination of RMHF an d begin the RFI implementation4 phase .5 FY05 . complete D&D of the SPTF and just a

6 continuation of the existing activities that we've talked7 about. And then Building 24, which is also a radiologica l8 facility, we will start D&D that year .9 Lastly, we'have the RCRA cleanup for the RMHF . And

10 we have RFI complete implementation phase .11 There is a possibility you will see a slippage t o12 the next year because of the budgetary constraints or othe r13 issues that will come up, like TRU waste, like environmenta l14 assessments/CIS .15 That gives you a broad brush on the project -- on16 the major facilities they're scheduled for the balance o f

17 that project .18 Go right ahead .19 MR. CAIN : Are you done with your presentation?20 MR. LOPEZ : Yeah .. I th ink so .21 MR. CAIN : Would any members like to discuss --22 MR. PLOTKIN : 1 just have some comments here .23 What kind of standards are you using for your24 cleanup level'? Are you using DOE's standards or EPA' s

25 standards? It's been a big hassle as I --

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for the EPA survey -- actually . have EPA prepare theworkplan .

Another DTSC item is the submission of the RFlreport .

And this one -- the last item has a few questionmarks with it . TRU waste . that's transuranium waste .There's a number of issues to be resolved with that one .This is a plan . not anything cast in concrete at this time .

And. Gerard . You might -- I don't know if you'l lagree with what we're projecting . as scheduled on our packet .but we hope to get into the corrective measures study . RFI :two. RMHF. which is radioactive materials handling facility .will begin the radiological decontamination and demolition inthat year .

And TRU waste disposal -- you will see transuraniumdisposal spread out over a number of years . And I thinkthat's meant to cover a lot of uncertainties associated withthat material at this time .

Then the next Fiscal Year 03 . we have the last ofSPTF, the sodium pump test facility . We plan to begin thedemolition -- decontamination and demolition of thatfacility . And RMHF. we will continue the D&D forradiological contamination and packaging TRU waste. Again .with TRU waste. there's a lot of issues related withpackaging and transportation .

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1 1 MR. LOPEZ: Yes . for the radiological facilities . we hav ecommitted to the EPA survey and doing an assessment after theEPA survey is completed. and --

MR. PLOTKIN : I didn't ask about a survey : I asked abou tstandards you're going to use tell us the standards were

(, going to use which mean s an ybody building a house . after7 you're through and so forth . they have to put the bedrooms on8 the second floor. they can't put them on the bottom floor:9 isn't that so ?

10 MR. LOPEZ : 1 don't believe th e second-floor analogy is

II correct .12 MR. PLOTKIN : But the standards between th e DOE standards13 that you' re using and th e EPA standards vary by orders o f14 magnitude, in fact . sometimes by m any orders of magnitude .15 MR. LOPEZ : I th ink EPA and DOE has been working on16 resolving the differences, and that's what we're --17 MR. PLOTKIN : Are you going to let them use the DOE18 standards or insist on using your standards ?19 MR. KELLY : As Mike said, they're going to do an

20 assessment for us .21 MR. PLOTKIN : Who's doing the assessment`? What happened

22 to the assessment Greg was going to do? And I thought w e

23 were going to have Greg here to talk about -- we got in24 later . We'll get into --25 MR. fflRSCH: The Dempsey assessment has been sort of

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1 scotched .

2 MR. LOPEZ : That will be based on the information3 provided by Greg Dempsey .4 1 also want to add -- we're certainly interested i n5 being involved in any future soil remediation that goes on6 from this point forward .7 MR. PLOTKIN : We got this memo from Greg saving that he's8 not going to be involved in doing any future cleanup . He' s9 going to be doing a postcleanup evaluation or something .

10 That was supposed to -- I got this copy from Dan . It was

I 1 dated .the 1st of May, yet the date received from you is lik e12 this morning . You sent one copy to Dan . And I talked to him13 by accident, and he sent me a copy . And Barbara doesn't have14 a copy .15 MS. JOHNSON : I do .16 MR. PLOTKIN : Greg . he's only going to do the final17 status verification . He's not going to be involved in the18 first--19 MR. LOPEZ: I thought what was asked of Greg was to20 survey the site . And that's what he will be doing .21 The reason why -- the reason why that got sent out22 late was because it wasn't until yesterday I found out that23 Greg couldn't make it . I thought we were going to have Greg24 at this meeting . I found out yesterday he had been called25 away on duties related to the fire at the Los Angeles --

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1 find out it's not being done right .2 Personally. I feel a certain kind of responsibility3 to the community here . And what's happening is that there's4 all these loose ends around us . so we hassle this out with5 Greg and refer him to your document on report on -- I don't6 know -- status of everything et cetera . You said in her e

7 that, back in 1997, there was a problem with the survey --8 radiological characterization study, and there was a lot of

9 question about that.10 MR. LOPEZ : That's with Boeing .11 MR. PLOTKIN : - That s right. This is the study that' s12 used in order to do the characterization study Mike is now13 telling us it's all in full swing and all their plans and e t

14 cetera.

15 And then it was agreed that EPA conduct its ow n16 survey . and that was -- I wasn't aware that was arranged . I

17 thought that -- well. whatever . And we've been howlering

18 about that all the time . So we're going back several years

19 here trying to get Greg in there to do an independen t

20 characterization study to see if what Mike is talking about21 is really adequate . And we've got some serious concerns . I22 think they're pretty well grounded . At least in our

23 experience. things haven't been characterized properly fro m24 the community's standpoint . And this business of EPA and DOE25 standards and so forth is just a small part of the whol e

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Los Alamos Lab and couldn't make it. I thought it would berelatively important to not send it until I heard yesterdayhe couldn't make the meeting today . and he'd in' to by aconference call .

MR. PLOTKIN : As you know . \e'\c been hassling about thissince the beginning .

MR. LOPEZ Because --MR. PLOTKIN : Just a minute . Lets go back a littl e

9 bit . In the first place . the area was characterized by11) Rocketdvne and/or DOE allowed Rocketdvne to do it . howeverI 1 that was done . and we've been howlering about that from the12 very beginning . characterizing what cleanup was supposed to13 be and what the problems really were . And we've been14 howlering for somebody like Greg or somebody else who's15 independent of government agencies and independent o f16 Rocketdvne to come in there and do this assessment. I mean .17 we wouldn't send a fox to into the chicken coop to examine18 and find out how it has to be repaired . which is a pretty19 good analogy .20 So they've gone through with the cleanup a s21 Rocketdvne's characterization specified et cetera . an d22 then -- when was it'? -- a year or two ago . Greg got in to do23 some kind of an evaluation . And lo and behold, he's got a24 lot of criticism . Every time he gets his hands on something25 that's being done . there's all kinds of criticism . and we

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thing . There' s much more to it than that .2 So now we find a memo from Greg saving he -- well .3 we were told or I was told -- what I understood -- put i t4 that wax -- was Greg was going to go in and resurvey the5 whole thing, and we were trying to arrange it . First. the6 schedule wasn't proper . then he didn't have enough money

Finally . he's got the monex . He's able to do tests . Now . we8 find out he isn't going to come and do that at all .9 MR. CAIN : Mr. Plotkin . do you have a question for the

I)) DOE?11 MR. PLOTKIN : Yeah .12 Is there any way to stop this whole thing and start13 the whole thing over and investigate what you're doing? Do14 we have any opportunity, or are we just being cut out of this15 whole thing`?16 MR. LOPEZ: I'm not sure --17 MR. PLOTKIN : I'm about as upset --18 MR. LOPEZ: That's fine . I'm not sure if the descriptio n

19 that Greg is not doing anything is quite accurate .20 MR. PLOTKIN : I didn't say he wasn't going to do

21 anything . I said he was going to do the final statu s

22 verification . He's going to do the resurvey characterizatio n

23 study is what his memo said and what the agreement was . And24 what the pl ans were for the last several years has been h e25 was going to go in and resurvey that characterization so you

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I can be cleaning -- your group could be cleaning up to the I

2 proper community-accepted standards . 2

3 MR. LOPEZ : We were the ones who suggested Greg to come 3

4 in and -- 4

5 MR. PLOTKIN : That's very nice . We'd like to see if we 5

6 can follow through and maybe change this around. Or can't we 6

7 do that? 7

8 MR. LOPEZ : We're still going to work with Greg and Tom 8

9 and get him on site -- 9

10 MR. PLOTKIN : Can we have him do a recharacterization of 1 0

I I this area.and .so forth to see that .the proper standards are 1 1

12 being used in the cleanup and that the techniques that are 1 2

13 being used are adequate and satisfactory from the community's 1 3

14 standpoint? That's what we're talking about. 1 4

15 MR. LOPEZ : Well -- 1 5

16 MR. PLOTKIN : That's not to Rocketdvne's satisfaction but 1 6

17 to the community's satisfaction . 1 7

18 MR. LOPEZ: The easiest way to resolve this is to try to 1 8

19 set something up with Greg so he can explain better to you 1 9

20 what lids going to do . where he is in the process -- 20

21 MR. PLOTKIN : He's going to do a recharacterization of 2 1

22 this thing'.) 22

23 MR. LOPEZ: Let's ask him . He was the one who criticized 2 3

24 the area for the investigation . This was the result of 24

25 that . This was trying to fill that, hole . Fix that -- 2 5

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MR . PLOTKIN : If there was any possibility of him doing

that. then Mike couldn't put up years and the timetable ofwhen they're going to be tearing down buildings and moving

stuff off and everything else because he wouldn't know whatthe standards were that they were going to clean up to an d

what kind of work was involved and what kind of techniquesthey should be using .

8 MR. LOPEZ: Excuse me . Those are projections based on

9 the currently available data . They can obviously change .

10 MR. PLOTKIN : All right .I I MR. LOPEZ : They do know some areas where they have high12 levels . Greg's work is to insure they do a thorough job .

13 MR. PLOTKIN : I don't mind going ahead and cleaning up14 whatever . But the fact is a lot of buildings have been tor n

15 off before they have been examined properly . As far as we

16 know. a bunch of laws have been violated by the radioactivity

17 level of the those building structures that have been haule d

18 off to Kettleman Hills .19 MR. CAIN : Santa Clara .20 MR. PLOTKIN : A couple of commercial landfills and waste

21 disposal places have been used for that, and they haven' t22 been used properly in the -- from the community's standpoint .

23 MR. KELLY : From the regulatory standpoint, did anything

24 illegal go to wrong waste sites from the buildings ?

25 MR. LOPEZ : No, they did not .

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PAGE 2 0MR. KELLY: DHS?MR. HSU: What we have down is to verify their fina l

survey results, and we were able to verify that they met th e

current standards for the release of the buildings, so th ebuildings were -- some of the buildings, not all of them, I

want to clarify --

MR. PLOTKIN : To DOE' s st andards or EPA' s standards "

MR. HSU : We use our on standards .MR. PLOTKIN : How does your standards compare with

EPA's?MR . HSU : .I don't even know if EPA has surface

contamination standards .MR. PLOTKIN : Don't you have surface standards . Tom`?

MR. KELLY : For debris , things like concrete and steel .

no. we don't .MR. ABRAMS: You use the NRC standards : right?

MR. KELLY: Yeah , we'd use the NRC standards .

MR. HSU: Where we have the issue with DOE is on soi l

contamination standards . The difference in st andards is the

NRC has 15 millirems per year for standard --MR. KELLY: No. it's more complicated th an that .

Rocketdvne committed to 15 millirems per year prio r

to the promulgation of the NRC criteria . They voluntaril y

reduced it from 25 to 15 . And at that time . EPA' s proposal

was also 15 .

I MR. HSU : So based on that . we were able to derive the

Z. soil concentrations that would correspond to 15 mill i

3 year was all the site-specific barometers included in th e

4 modeling . And we have had discussions with EPA and DOE .

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I guess we need to go back to the question where

Dr . Plotkin wanted to know whether or not the standards DH S

7 used or uses are consistent with either EPA or DOE .

8 I can tell you. between DOE. NRC . and DHS. we use

9 almost equivalent surface contamination limits .

11) MR. ABRAMS: I'm sorry, Steve. We're talking about the

11 cleanup of soil and concrete and stuff like that . That' s

12 buildings that are broken down .13 MR. HSU Dr. Plotkin asked about surface contamination

14 limits for the release of buildings .

15 MR. CAIN : If I can interrupt for a minute . We have

16 drifted off the topic a bit . I'd like to conclude with DOE's

17 presentation . And we have DHS and EPA to speak --

18 MR. HIRSCH : I just want to say that the discussion was19 very important because the distinction between the cleanup -20 levels for the soil and the soil contamination from th e

21 debris has not really been made clear for anybody, and I

22 think this discussion is very important . I don't think maybe

23 tonight is a good time to clarify what standards NRC . DHS,

24 and DOE are using and how will this change what you think25 EPA's role should be, taking into consideration that you kno w

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I NRC's existing stan dards . Because if we don ' t make this2 distinction between surface contamination and soil cleanup3 levels , then the picture is always going to be vague in the4 minds of everyone . Listen to what's said tonight, whether5 we're talking about soil cleanup levels or surface6 contamination or whether we're talking about buildings that7 are going to be demolished and whether EPA is there or8 whether we are going to talk about the final cleanup levels9 for the site and what is acceptable and what is not . I just

10 want to make this point : I don't think it's really11 appropriate to discuss it tonight , but I'd like to put it on12 the agenda and get into the details so everybody knows what13 - we're talking about .14 MR. CAIN : Any other work-group members ?15 MR. HIRSCH : And there are several other items I'd like16 to quickly go through them as well .17 1 think there ' s a -- you have it in the handout18 things . the stuff you gave to us . You identified at leas t19 some of the locations that received debri s from the buildings20 that were torn down. I was wondering why that wasn' t21 presented. and if we can ask some questions about --22 MR. LOPEZ : Just because I forgot .23 MR. HIRSCH : Why don' t you go through --24 MR. LOPEZ : Maybe Barbara can ask her question while 125 find my --

I MS. JOHNSON : There's been some debate about cleaning up2 to the DOE's standards or cleaning up to the higher standard s3 of EPA. When people's health are in jeopardy here . it would4 seem to me . iI'vou were to error . you should error on the

side of caution and to accept the highest standards rathe r6 than to accept the lowest standards . And I keep hearing7 "acceptable levels ." Acceptable to whom'' And why couldn't8 DOE clean up to EPA's standards' '9 MR. LOPEZ: Would you like me -- should yye go into that

10 now. or should we -- maybe I should since you asked theI I question or --12 MS. JOHNSON: I'll wait and let you go into this first .13 MR. LOPEZ: Okay . This view graph shows where the14 material has gone . There's the Bradley Landfill i n15 San Fernando Valley : there's the Kettleman Hills Landfill16 which is operated by chemical waste management : there' s17 Hugo-Neu Prowler. a metal recvcler_ in San Pedro : and there's18 Santa Clara Ranch where we put some material --19 MR. HIRSCH : Where is the ranch' ?20 MR. LOPEZ : It's somewhere along Santa Clarita . I think .21 I'm sorry . I don't recall the exact location., I can ge t22 that for you at break. if you'd like .23 MR. HIRSCH : I'd appreciate that .24 You said "some material" was given to a ranch . What25 was given to that ranch`?

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1 MR. LOPEZ : Concrete blocks .2 MR. HIRSCH: Now, this is in addition to the trailers3 that went to the schools and to the wildlife waste station4 and to the third location ?5 MR. LOPEZ : Yes . this is separate from them . I'm not6 sure what third location you're referring to is .7 MR. HIRSCH : We were informed , in addition to those two8 places , they went to a place where --9 MR. LOPEZ : Oh, Profile . They were -- they just happened

10 to be the o riginal m anufacturers of the trailers , but they11 were also the -firm -that was hired to move the trailers from

12 SSFL to the wildlife waste station .13 MR. HIRSCH : The trailers are no longer at the schools .14 A part of them has gone to a hazardous waste site due to15 asbestos . But the wildlife waste station and this Profil e16 company --17 MR. LOPEZ : Yeah, we're trying to work out the details18 of -- detail access with the wildlife waste station so we c an19 demolish the trailers .20 MR. HIRSCH : Are these the only locations which received21 debri s from the structures that have been torn down i n22 Area IV . or is this just a sample of them ?23 MR. LOPEZ : I think these are the only facilities that24 received materials from former radiological facilities .25 MR. HIRSCH : Where in S an Fernando Valley is Bradley ?

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23

I MR. LOPEZ : North San Fernando Valley -- I'm sorn . I2 didn' t go to a map and look it up . May be somebody -- it '3 there' s somebody in the room that lives in the area . perhaps

they can tell me .MR . HIRSCH : There's a metal recvcler in Ventura County

that was cited some months ago for radioactive waste . And7 apparently . they didn't know it was radioactive until the8 material sta rted leaking out . Where did that radioactiv e9 material come from? Do you know if historically any of the

10 records that show DOE provided materials to scrap dealers orI I metal recvclers other than this Hugo-Neu Prowler"12 MR. LOPEZ: Not to my knowledge . But if you give us th e13 name. we'll look it up .14 MR. MRSCH : And is this practice going to be stopped15 pending the completion of the environmental assessment . the16 practice of taking materials from the demolition of17 radioactive buildings --18 MR. LOPEZ: Yes .19 MR. HIRSCH : Even both surface and volumometric' ?20 MR. LOPEZ : Well, there isn't any volumometric that I'm21 aware of at the current time that ' s been -- that's ready for22 staging . Building 59 has some volumet rically - contaminated23 mate rial , but we're not going to start that job until after24 the environmental assessment has been completed .25 MR. HIRSCH : Well . I'm confused then because --

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1 MR. LOPEZ : Which waste do you think is volumometric -- I2 MR . HIRSCH: No, I'm not following your statement that is 23 being stopped . Is there a writing somewhere that says that 34 will be stopped? 45 MR. LOPEZ: That were not going to ship any materials 56 from these facilities while the chemical tests are in 67 process? 78 MR. HIRSCH : Hopefully, from any facilities. I don't 89 know which ones are these . But the practice of taking 9

10 contaminated materials from D&D sites to municipal landfills 1 011 and metal recyclers and private properties will stop during 1 112 the environmental assessment . I thought that's what you 1 213 said . 1 314 MR. LOPEZ : From former radiological facilities . that's a 1 415 true statement . 1 516 MR. HIRSCH : Is there a writing somewhere`' 1 617 MR. LOPEZ: Is it in writing somewhere." No . not at this 1 7l8 point . 1 819 MR. HIRSCH : Could you get it for me . if possible . 1 1 921) would-really appreciate it . 2021 MR. LOPEZ : How about if we give the letter to Tom`? 2 122 MR. KELLY : Would there be sufficient documentation' .) 2223 MR. HIRSCH : If it's clear enough . 2 324 The reason I'm surprised is that there's a letter 2425 sent out by Rocketdvne . And I know this is being slowed up a 2 5

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bit . Rocketdvne sent the letter a few weeks ago .MR. LOPEZ: The conservation letter ?

MR. HIRSCH : Yeah .So the audience is aware . the letter was sent by

Rocketdvne to Gerard at DTSC . It basically says some debrishas been found at the -- what's called an old conservationyard . And they're trying to do some soil sampling in th eyard and intend to remove the debris . And the scrap metalwill be placed in the metal recycling bins . and the debrisfrom the excavation will be placed in the roll-off bins andwill then be sent to proper disposal facilities, and theywere intending to do that this month . So if this practicehas stopped, I'm a little confused why --

MR. LOPEZ: I don't think -- I'm not sure .Well, one the areas that this debris was found is

not a part of the former radiological facility . It's next toit. And I don't think DTSC and DHS and DOE and EPA have everagreed as to the final steps.

I believe that letter that you saw was more of apreliminary information . And you know, the work plan . it wasa proposal, and we needed to take a look at it .

We also asked Boeing to submit some radiologicaldata survey to EPA and DHS for their review, and they'regoing to take a look at the data, and we're going to go outand walk the area . There hasn't been a decision made on how

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I recyclers . And some metals get put into consumer goods . som e

2 surplus goods are absorbed as surplus . And so there's a

3 concern about materials that may have what's called "residua l

4 radioactive measurable background" but still below .supposedly . the level that DOE has been using as a n

6 acceptable level of materials that may have some residual7 radioactivity and sending it out into commerce . Tha t

8 practice is very controversial . It needs to be thoroughly

9 reviewed .10 I'm trying to get a very clear written statement o fI I precisely what you're going to do and what you're not going12 to do without uncertainties in some areas . I think that13 practice has to stop . And so I am glad to hear that you're14 going to stop . I hear all of that practice is going to stop .15 but I'd like to see it in writing . And I'd like it to be16 specific so we know for sure .17 And I want to talk about the sodium burn pit . That

18 has residual radioactivity as well . Is that encompassed in19 your decision not to ship off materials that has20 contamination during this EA ?21 MR. LOPEZ: Well, the sodium facility is not considered

22 radioactive --23 MR. HIRSCH : Which facility?24 MR. LOPEZ : The bran pit soil .25 MR. HIRSCH : That we'll discuss in a moment. I believe

PAGE 2 8we're going to proceed , but I believe -- Mike an d Tom, yo ufolks spoke . And I believe that for the RFI investigatio nwork, the metal debris wasn't going to be sent off site to arecycler . It was going to be held on site until you folk sworked out the protocol : is that correct ?

MR. KELLY: That' s what we had talked about . and I guessthe question -- what's in question is . Is this debris from aradiological facility, and what's the potential for them ?

MR. HIRSCH : What' s the potential for them ?MR. KELLY : Do you know where the debri s is from ?

MR. LOPEZ: I'm not sure we know at this time . My gues s

is the debris will be held on site until the EA is completed.I guess .

MR. HIRSCH : I don't want a guess.MR. LOPEZ : I'm sorry . That was a poor choice of words .MR. HIRSCH : You know nothing about the debris until yo u

dig it up and look at it. you don't really know for sure . andyour assumption is that, usually, in these types o finvestigations, you assume the worst and then move forwar dfrom there'?

Let me explain why this is so importan t . We lea rne dearlier this year some of the debris from the radioactiv ebuildings that were being dismantled and reconditioned hadbeen shipped off the site . some of them are sent to th emunicipal landfill . some of the metals go to meta l

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1I voure very much in error in that .

22 Na. LOPEZ : I underst and your position on that All I' m.33 saving --

' 44 MR . HI RSCH . We ll get to that in a moment That's what.55 I w ant to do .66 Will any material soil that has a measurable77 radioactive contamination with measurable radioactivity above88 background be permitted to leave this site during the EA ?

" 99 "EA is environmental assessment . Maybe I'll --1 010 MR. LOPEZ : I think we need to look into that before we1 111 can make a statement like that,1 212 MR. HIRSCH : I would appreciate a response on that This.1 313 whole practice of sending off radioactively contaminated1 414 materials to facilities not licensed to take radioactive1 515 materials is very troubling .1 616 Yes. I would appreciate a very clear answer on all1 717 of these issues . all of -- and whether those are going to be1 818 still moving during this peri od of the EA . Okay"1 919 MR . CAIN : Mr. Hirsch your question was an swered`?,2 020 MR. HIRSCH : Not an swered . but noted .2 121 MR . CAIN : So far we have two action items : The request2 222 for the letter of the status in writing . Also if I c an be so2 323 bold . it sounds like Mr . Plotkin wanted Greg Dempsey to be on2424 the agenda also .2 525 MR. HIRSCH- First of all . you gave us some mate rials

31 1

I from transparencies . And you must provide -- you're supposed2 to get those to us two weeks in advance . It's hard for us t o3 know what questions to ask if we didn't see that stuff --

MR. LOPEZ Which material ?MR. HIRSCH The transparencies. your plans for each

l'iscal year .MR. LOPEZ: I apologize . I thought it had gone out . but

8 1 was in error on that projection . I did send the other9 material .

1( ) MR. HIRSCH : I understand . But that's the material II I only say just now .12 A few quick questions . If you've already covered13 this . I apologize for asking it again .14 When does the government fiscal years begin and when15 does it end''16 Fiscal Year 00, are we in Fiscal Year 00? Is that17 what begins in October?18 MR. LOPEZ : Yes . It began October 1st of 1999 .19 1 apologize . Maybe I took too much --20 MR. HIRSCH : You said you were going to start Building 5921 in Fiscal Year 01 . which you said you were-going to comply22 with the decision to not ship debris from the site until th e23 EA is done. But the Fiscal Year I begins in a few months and24 lasts only a year . obviously . and DOEA is going to take like25 a year . How can you be committed to starting sometime in the

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PAGE 37next month ?

MR. LOPEZ : That projection for Building 59 . the fiscalyear goes through September 30th of 01, okay? And thatassumes that EA is completed. Our projecting a year for theEA, and that's August -- excuse me -- May, just fordiscussion purposes, and that will give us a few months tostart the D&D on that facility .

MR . HI RSCH : You suggested to me some prejudgment aboutDEA and a schedule , I think, unlikely to be met for DEA .

Let me go on . There 's also some buildings missing .I can't read the last page of facility chart . an d we'd lik eto understand what 's going on .

MR . LOPEZ : What was dropped?MR . HI RSCH : Building 12 . for example . Your chart says

the demolition date is 2001 . This radioactive facilitystatus -- but I didn 't see that quickly in your overheads .

MR. LOPEZ : Okay . I did not intend to give a hundredpercent of the buildings . I was trying to -- you ' re right .Building 12 would come approximately in 2001 . but I wasn'ttrying to give a hundred- percent coverage .

MR . HI RSCH : Could we somehow get not .just the buildingsbut an overall clean up. that kind of a schedule? It' ssomewhat frustrating to the members of this workgroup and thepublic when hundreds of millions of dollars are being spen ton the clean up , and vet we see two items on the fiscal year .

And I don ' t hear much discussion of what ' s going on with thesoil discussion .

Is there some way of giving us . in writing . clearlywhat you're doing this 'ear . next year . the following year oneach item . not just the buildings but. you kno . ol dlandfills and soil contamination and watersheds so we can se e

7 the picture and who . when . what youre going to stop --8 MR. LOPEZ: Those are just the key milestones we9 presented .

-1)) MR. HIRSCH : It will be helpful to see the details forI I EPA so they can get out to do the double -check --12 MR. LOPEZ : The discussion of the RFI . for example .13 covers the solid waste management and groundwater level . I14 could have made that more clear . but I didn't .15 MR. HIRSCH : RFI is on the chemicals . I'm still16 interested in the work you're doing on the radioactiv e17 contamination . So if you can give us a detail of what you're18 doing on this and what you will be doing next year and what19 you will be stopping and what you 're going to be doing during20 the pendency . in writing -- could you do that ?21 MR. LOPEZ : Yes.22 MR. HIRSCH : And on this cha rt, it says Building 9 . which23 says organic radiosodium graphite is not available fo r24 survey . It says the building demolition date is not yet25 planned . Why is that not available for survey?

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1 MR. LOPEZ : It's a Boeing, B-o-e-i-n-g, building .2 MR. HIRSCH : Was this a DOE building ?3 MR. LOPEZ : I believe there was some DOE contamination at4 one point that was removed, and now its used by Boeing5 for -- I'm not sure what they use it for .6 MR. HIRSCH : Well, if I c an ask the regulatory agencies,7 if the building is now Rocketdyne ' s, what requirements are8 there for compli ance with , you know, the cle anup standards9 before it c an be released, demolished , put out into th e

10 environment?11 MR- HSU : If it is a Rocketdyne building, it is under the

12 California Radioactive Materials License . They will ask13 release -- they will request the release from the Department14 of Health Serv ices Radiological Health Bran ch . And what we

15 will use is the -- for above soil, if there is above soil for16 that building , well use the 15-millirem site-wide release17 c ri teria . If its only surface . well use the surfac e18 contamination limit that is "tied ." quote. unquote or19 incorporated into their existing Califo rnia Radioactive20 Materials License . Because they have commi tted to a surface21 contamination limit years back . that was tied to thei r22 license.23 When the new commission rule came out by NRC . in24 1997 . we. DHS . have taken this regulato ry position that we25 would want to be consistent with NRC . Because we've been in

PAGE 3 6

1 UNIDENTIFIED SPEAKER: It's the whole Building 9 .2 MR. HIRSCH : Which one is the --3 MR. HSU : I don't recall everything, okay'? There are4 many buildings . They're years of work .

5 So which building now is partially released? There6 was a building --7 UNIDENTIFIED SPEAKER : Building 59 ?8 MR. HSU : Building 59 . They all have a "9" in there .

9 But what I'm getting at is that building then must10 have been released by DHS . Building 59 was partiallyII released by us.12 MR. CAIN: If I can interject for a moment . We're now an13 hour into the meeting, and we've accomplished only one-third14 of the first topic . What is the will of the workgroup . to15 move forward or to continue with this discussion')16 MR. HIRSCH : If I can, and --17 Tom identified a building that has been released by18 DHS and has not been checked by EPA . And where this table19 says it's not available for survey . I would like for you t o20 tag why it can't be surveyed by you . It had two fairly big21 reactors in it .22 MR. KELLY : I think this might have been a building that23 Boeing identified to us in their letter . And I can' t24 remember the specific reason . I imagine it gets to testing25 that's going on inside the building . Maybe there's a way o r

34

I agreement with NRC . we were required to be compatible .2 Like I had indicated in the January meeting . DHS has3 been putting together a regulation package that is going to4 be submitted to OAL . I guess --

I take a step back . Were going to take notice of0 proposed rulemaking . So the last time I mentioned that I7 will give you the name of the person and his phone number and8 e-mail address so that you can call him or e-mail him to ge t9 on the list. that is just to -- answer some of the

10 questions -- unresolved questions from the last meetingI I regarding the e-mail .12 Going back to the release . Rocketdvne -- i f13 Rocketdvne is the owner and the building is listed under14 their California license . they would have to seek or make a15 request to DHS for the release of the site for unrestricted16 use from DHS .17 MR. HIRSCH : This building I'm referring to, you signed18 off last year already .19 MR. HSU: No .20 MR. HI RSCH : That's what it says .21 MR. HSU: That chart is not totally complete . I believe-22 if you -- well . I know Rocketdvne is not a member of thi s23 work-group now, as a working group, but Rocketdyne people are24 out there . We only have the survey and the release portio n25 of it . It's not the whole Building 9, is it'?

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expected-way that can be worked . I f that testing were to enddown the road . they can give us a notification of that . an dwe can go back and do a survey at that time . I think there'sways we can address this problem and get into it -- into thisbuilding down the road . Even with what's going on right no\\

today might restrict us from getting in there and definitelytry to avoid a situation where the building is knocked downbefore we have a chance to look at it .

MR . HI RSCH: Thank you .UNIDENTIFIED SPEAKER : If we have questions on the

current topic, do we have to hold them all till the end'?MR. CAIN: Till the end of the topic .UNIDENTIFIED SPEAKER : So is this the end?MR. CAIN: No . it isn't .

DHS , you're next on the list .MR. HSU: I was going to finish what I was saying

earlier . If you're interested in getting on the list so youwill be mailed this proposed rulemaking .. I can tell you thisperson's name is Phil, Philip Scott . His phone number is _

(916) 324-3275, and his e-mail address is pscott@dhs .ca .com .

I'm finished with that part, but I'd like to talkabout the DHS part on the agenda No . 1, or I should sayNo. 2 -- the topic No . 2 ?

Since the last meeting in January, DHS, RadiologicalHealth Branch has not confirmed any condition of any

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1 buildings or any facilities to be released for a restricte d2 use . However, with each survey of those trailers at Shan don

3 School , an imal waste station, and Profile Structures. Inc . .4 the survey readings indicated that they're no different5 than -- they're basically in the background range for the6 survey for the radiation level reading .7 And we also took soil samples at the Sh andon ,8 S-h-a - n-d-o-n . School . After the building was demolished .

9 the school wanted to use the lot for some purpose . And so

10 the soil sampling was performed , an d DHS obse rved the soi l

11 sampling and took some split samples at Shandon .School while

12 the DOE- Rocketdyne contractor was doing that , an d we have13 gotten a prelimina ry gamma sc an level . They basically showed

14 concentration similar to that of the background . We ar e15 still waiting for the re-analysis of the soil involved at16 Shandon School .

17 We also took surface wipes at the surfaces of those18 trailers at the animal waste station an d Profile structures .19 Basically . their wipe results indicated levels similar to20 that of the background .21 Other than that. DHS has not done anything else in22 the last quarter.23 MR. PLOTKIN : What background are you using ?24 MR . HSU : The soil samples . I believe . were taken away25 from the building site somewhere . I don't have the repo rt in

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front of me I can't tell you where exactly . but they'reaway from the impacted area in the survey, the wipe s

A typical thing that a sanitation and radiationlaboratory does is they will put in a blank filter wipe whenthey come -- a laboratory blank control .

MR. PLOTKIN That's in the laboratory analysis . though?

MR . HSU : Right .MR. PLOTKIN- I was asking about what kind o f

9 background -- you're taking a surface wipe . and you're going11) to go to a laboratory and take measurements and so forth . andI I you're going to compare that with the background ?12 MR. HSU : Let me clarify that .13 For radiation level surveys, obviously . you know . is14 the reading from -- we take a reading from the impacted15 area . Then we go inside and then take a reading off th e16 surfaces . When we take wipes . what we do is we use a typical17 47-millimeter filter paper . Fiberglass . and wipe off th e18 surfaces of the trailer . And then with some . we use the same19 fiberglass filter paper without being used and put on th e20 counter as a blank control .21 MR. PLOTKIN : So there's -- there are apparatus to see22 they're functioning all right . but in the end. you're going23 to take some kind of reading and compare it with a background24 of some sort and to pass judgment whether its okay or no t25 okay?

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1 MR. HSU : The background is -- usually, what we do is we2 will go to the same area and take a wipe -- take a reading --3 first , okay , we take an instrument reading and then we take4 wipes for the removable of the contamination . If that wip e5 picks up something , then we know what it is . Then we compare6 that to the background that is established at a laboratory .7 It is the absolute background . the instrument background .8 Then we subtract those . If the resulting number exceeds the9 surface contamination limit, then we would not --

10 MR. PLOTKIN : Yeah, well, but the background is all11 important . Ifyou 've .got a background say taken very --12 rather close to --13 MR. HSU : We would -- what I didn 't finish is . I said14 earlier, we would take a wipe now in an impacted area , too .15 so16 MR. HIRSCH : Everything is impacted when you 're talking

17 about radioactivity . When things are airbo rne --

18 MR. HSU : Not necessarily' Th e building itself is

19 impacted . okay ?20 MR. HI RSCH : That's right . Okay .21 MR. HSU: Were assuming its impacted . We don' t know .

22 MR. HI RSCH : Okay . All right .23 MR. HSU : So we go in and wipe it off to see if there's24 any removable contamination . If there 's no removable25 activity anywhere close to the surface contamination limit .

21 comparing it to a sire background . When you take a wipe, you22 take a wipe and you make sure it is compared to a background23 which would give you a minimum -- minimum detectable ,24 95 percent confidence level. So you know your measurement is25 sensitive enough to measure down to that level . Then you ca n

19 Court reporter . she only has two hands .20 MR . HSU : Normally . when we use wipes ., we're not

I we would agree that there' s no removable surfacecontamination .

? MR. HIRSCH : Okay . But there' s some kind of a reading .

4 and you're going to compare it with a background -- to the

background in a nonimpacted area . you can assume the area0 outside the building is not impacted?

7 MR. HSU : No . I'm not making that assumption .8 MR. HIRSCH : A person could . And if they did use that

well have been9 background . that background might very10 contaminated. And you 're going to take the background with aI I higher level and compare it with the reading from th e12 building . and you're going to say the same when the13 background --14 MR. HSU : 1 guess --15 THE COURT REPORTER: Gentlemen, please speak one at a16 time .17 MR. CAIN : Yes . Maybe I can help the court repo rt er.

1 8 I f you can. please don't talk at the same time. The

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l subtract that, and then you get -- if your background is2 really, really low you're getting the more conservative3 answer, okay ?4 MR. HIRSCH: This whole thing -- the trailers were given

5 without being monitored for radioactivity first . They've now

6 gone to the schools for monitoring it . But if it was known

7 before it was given to the schools it contained asbestos an d8 lead and parts of them have been taken to the hazardous waste9 sites because of those constituents, which agency i s

10 responsible so that kind of thing doesn't happen?11 MR HSU : .I don't think we have jurisdiction in .

12 regulating asbestos .

13 MR. HIRSCH : Who does ?14 MR. ABRAMS: Ventura County .15 MR. HSU: It was transferred from and to16 San Luis O'Bispo .17 MR. HIRSCH : Then it would be a local facility that

18 received it?19 MR. ABRAMS: There's usually asbestos in olde r

20 buildings . And so when they are sold, they're usually --21 there's usually an asbestos survey done that's noted to the

22 buyer so that . when the construction work is done . the23 building owner knows that there was an asbestos issue

24 associated with it. and they'll hire a licensed contractor to

25 do the contracting work .

PAGE 4 4

I MR. HIRSCH : That topic has been long enough.

2 MR. LOPEZ: I thought I might mention briefly th e3 Department of Emergency has put on a number of buildings fo r

4 EPA to look at in the summer of this year because they ha d

5 indicated that they would be tearing down Building 59, that

6 is the building that I had started and the work for a

7 contractor to work out -- I need to work out a date with

8 Boeing , but hopefully that can happen in the next month to

9 two months: the other buildings, probably towards the end o f

10 the summer.11 MR. HIRSCH: This is also because EPA has been asked to

12 come and do independent surveys on buildings with

13 unrestricted use . and a number of the buildings had already

14 been torn down .15 I understand there's an effort by Fellish Daz e

16 [phonetic] Market to get comments from DOE and Rocketdyne .

17 that you will get advance notice of any potential action s

18 that you need to know to be able to check if there could be a

19 release.20 I'd like to note the status of the correspondenc e21 that I've seen seems to have some large gaps in it as t o22 which things they committed to give you notice for and whic h

23 thing they did not . Now, is it a universal commitment, or i s

24 there still any uncertainty about what you will be notified

25 about' ?

42

MR . KELLY : Can I give it a try to --2 This is -- this isn't too definitive . We have tried3 to work with the Department of Energy to come to an agreement4 on the applicability of CERCLA which were not off-site rules .

5 and this would definitely have potential to impact -- impac t

h anything there . And CERCLA has substances that can take the7 whole discussion quite a while to figure out where this i s8 going . I think maybe we can move on to different issues .9 It's not clear exactly how that rule would affec t

I O things. Certainly . if its a waste . the rules woul dI I determine that it go to a facility allowed to handle that

12 waste . It is a graver area .

13 MR. HIRSCH: Obviously, something broke down here . The14 trailers with asbestos were given to them, the schools were15 cutting it apart, and someone from the office saw a person16 cutting a post and contacted them . Now. they've been taken17 to a hazardous facility . I want to make sure it doesn' t18 repeat itself again . And hazardous waste being received by

19 recipient counties' hands doesn't do any good if they don't20 know they're getting the stuff . Maybe they can report back

21 o-r someone can as to how to resolve this issue so it doesn't22 happen again . Anyhow --23 MR. CAIN: Thank you very much .24 And Building D&D, Dan, did you want to add25 anything?

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MR . LOPEZ : We received a letter from EPA requesting

3notification for the demolition of former Rad buildings. and

we responded with a letter saving we will give a commitmen t

5of a 120 days' notice .

MR . HIRSCH : As I read the letter . you specificalh

6 identified the buildings . so that raised the question as to

17 the other areas of the cleanup that might be excluded Fro m

18 the commitment . Am I not right''

9 MR . KELLY : That' s correct . And that was essentially - -

10 1 was mostly concerned about the buildings that had beenII released already . and those are the ones that they wrote bac k

12 on and said they ' d give us that notice .

13 1 guess what's left out is the buildings where14 you're going through the D&D process. as we speak or 1 . Bu t

15 some of the ones that are planned a year from now . w e

16 ce rtainly have the time to work out the issues there .

17 MR. LOPEZ : Are you talking about Building 12 or RMHF ?

18 MR. KELLY: Yeah .19 MR . HIRSCH : Just about these three buildings that you -

20 had identified or - -21 MR . LOPEZ: The buildings -- I don't believe i s22 restricted to those buildings .

23 MR . HI RSCH: The way that letter read, to me . it could be

24 restricted .25 MR . LOPEZ : Whatever the intent was, we'll take another

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SHEET % PAGE 4 61 look at the letter later .2 MR. HI RSCH : I would appreciate a letter that does3 reflect a broad commitment .4 MR. KELLY : The issue we raised for them was the five5 specific buildings because they've been released already .6 MR. HIRSCH : We're certainly doing our very best to make7 sure that doesn't happen again . Our feeling is that it8 shouldn't be restricted as to just those five . We don't want9 the buried debris from the conservation yard to be moved

10 without EPA's approval . I got a glance of the1 l correspondence. EPA didn't approve the removal of the debris12 from the conservation yard. Something is not working here .13 And you had given Tom a call so -- and you ha d14 correspondence before I did . And it said they would start in15 May . If we had not been able to slow that down. To m16 wouldn't --17 MR. LOPEZ: That was a work plan . and we need to review18 it . The letter mentioned it would start in May . but that19 might be a wishful thinking on their part .20 MR. HIRSCH: All I'm saying is . for this to work. EPA21 needs a clear notice . And they can double-check it before22 everything moves off .23 MR. CAIN : Thank you very much .24 With the approval of the work-group . I'd like to open25 up the mike to public comments . Is that okay with the

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I group' .'If you can come to the microphone . state your name

clearly for the court reporter . please . And if you can .4 please adhere to the rules that are in front of the mike .

MS . HUSH I'll be very quick .My name is Lisa Beth Hush . L-i-s-a --

THE COURT REPORTER Would you please spell your nam eN again .y MS. HUSH : L-i-s . as in Sam . a . as in apple . B-e-t-h .

10 H-u-s-h .I I I would like to make an action item out of12 Pauline's comment .13 What you said was very meaningful to me . It was14 like a broad -- would you repeat that to make an action item15 out of it because it became very indefinite .16 MR. CAIN: I'll make sure that gets on the agenda list .17 and --18 MS. HUSH : And the last one that's an action item . he's19 going to get a letter from them or a clarification of --20 MR. CAIN: The last one was just --21 MS. HUSH : I'd like to hear something . ,22 MR. CAIN: The last one was a complete cleanup schedule23 from DOE , in writing, then a letter establishing the off-site24 transported materials on --25 MR. LOPEZ: I think that's Dan's clarification of a

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1 letter to EPA regarding what that letter covered .MR. HIRSCH : Encompassing the materials that can moved

3 off the property . That is not just restricted to the five4 buildings mentioned in the letter .5 MS. HUSH: And my last thing is regarding the wildlife6 refuge. The trailer or trailers are still there, but there' s7 no asbestos, there's no radiation, is this correct ?8 MR. LOPEZ : Well, there's no radiation in those9 trailers . We had those tested .

10 MS. HUSH: So they're going to stay there ?11 MR. LOPEZ: No. There are plans to have them demolished12 and removed .13 MR. HIRSCH : Which comes first`- Demolished and removed14 or removed and demolished ?15 MR. LOPEZ: Demolished and removed .16 MR. HIRSCH: Why would you demolish it there?17 MR. LOPEZ: Because there are a lot of issues . The18 trailers are not very stable . They've already been moved19 several times. It just makes better sense to demolish them20 there . We would have a qualified asbestos abatement company21 come in and do the asbestos removal and removal of mercury22 and other contaminants.23 MR . HI RSCH : There was mercury in them :'24 MR. LOPEZ : There was mercury, and led paint .25 MR. HIRSCH : What was the mercury for?

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MR. LOPEZ I believe it was in the cooling and heating2 system . It was a small amount .3 MS. HUSH: Where they use them --

MR. LOPEZ No .MS . HUSH : -- anywhere near where the endangered species

6 are in there ?

i 7 MR. LOPEZ : No .8 MS. HUSH : When do you intend to demolish them '' Is that9 this year?I O MR. LOPEZ : Within the next month or so .II MS. HUSH : Thank you .12 MR. LOPEZ : It's my position that EPA's rules . in fact .13 prohibit the release of those buildings based on the14 standards DHS was using . It only applies if the building was15 going to stay in place , not if they are going to be released16 into the environment . Since they're being torn down and sent17 out to ranchers and municipal landfills , the EPA CERCL A18 guidance . which is considerably stricter than the standards19 DTSC and DOE have been using, must apply . That's on the20 agenda. I didn't want the record to go by without making21 that clear. -22 MR. KELLY: Okay . I'll just acknowledge that that' s23 something that I know you raised to me , and you raised it to24 Julie Anders, who is a director in my division . And I25 think -- I've been working with some atto rneys in o ur

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1 office -- with our headquarters. I think we'll try and write2 you something specifically, so you can leave the action item3 loose .4 MS . MASON : I'm Marv Mason, M-a-s-o-n .5 My comment is to DOE . When Hannibal was here, he6 spoke about children having to sleep on the second floor . So7 I'm concerned about what standards you're using . I think we8 should error on the side of caution .

9 MR. CAIN: Thank you. Any other members -- we have a10 third speaker .11 MR. LEUSSIER: Matthew Leussier, L-e-u-s-s-i-e-r .12 I've got a question for the people at the Department13 of Public Health . There's been a lot of talk about thing s14 moving off the site now . Have you changed any of the -- of15 your procedures in view of what happened with the trailers16 and talk about moving a lot of other items? You're going to17 take a more aggressive approach in monitoring things and18 moving?19 MR. HSU: Under the current policies and procedures . when20 we release a facility, we release the facility fo r21 unrestricted use because the residual level of radioactivity .22 either in the form of surface contamination or in the soil .23 we assume that whatever residual radioactivity level staying24 where they are will not impose a radiation risk that's higher25 than the acceptable risk . That corresponds to 15 millirem s

I per year at the Boeing site . Not to mention that NRC did go2 through the rulemaking process. they held workshops . they3 have given comment periods to people to comment. and also4 held a public hearing . They went through a federa l

rulemaking process and promulgated that 25-millirems-per-yearE' dose . That 25 millirem is calculated -- was the7 consideration included of all pathways impacted . which means8 the surface contamination could be a source of contamination .9 but it may have levels so low that it will not come up with

1 0 the risk that would not be acceptable .I I MR. LEUSSIER: I got a bit concerned when you mentioned12 that you had only been up there one time . or the only survey13 you've recently done was on this trailer . I guess the14 question is . Have you put in any monitors in the area they're15 taken off from'' I mean . you can't check every last item --16 we know that -- but maybe there should be some kind o f17 detection procedure put out . Maybe if there's a mistake . you18 folks might catch it .19 MR. HSU: We have thermal luminescent dosimeters at the20 sites. We monitor with DTLD devices that will registe r21 instant radiation . And if there is any abnormality, we would22 catch it . But we also have a routine inspection in our23 building program that inspect radioactive materials licensed24 facilities . Through those inspections and contacts we have25 had. we believe, at this point, we -- well, increase d

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I activity was certainly well proportionally increased in our2 efforts . But obviously . we have increased a lot of efforts3 here on this issue .4 MR. LEUSSIER: But is there a permanent person that's5 currently --6 MR. HSU: No. We don't have a permanent site inspector7 or a resident inspector .8 MR. LEUSSIER: Can one of these trailers go off, and9 whenever you pick it up by TLD but DTLD may not even pick it

10 up --11 MR. HSU: As I said, there's an instant radiation reading

12 device . And we have TLD, but it won't pick up until a period13 of three months so --14 MR. LEUSSIER: So you'll know after three months --15 MR. HSU: -- it may not.16 MR. LEUSSIER: Can we review this procedure from the17 public health point of view and maybe get a little more19 aggressive? Maybe that requires our people from the public19 offices here to put some pressure on the folks from th e20 Public Health to really -- we really need them . We need a21 bulldog sitting out at the end of the driveway area when22 these trucks take off. making sure nothing is going out .23 MR. CAIN: Thank you for your comment .24 MR. HIRSCH : Just a quick response .25 I thought that was a marvelous suggestion . You wil l

5 0

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I see it in the next discussion as well . We don't have a2 full-time bulldog watching out there . The amount of time you3 have been on the site checking something has got to be a -- a4 few days out of a year . And the standards he's checkin g5 against is 25 millirems . That means it would be okay for you0 to have what would be equivalent to two and a half chest7 X-rays each year. And there's no antinuclear committee . no8 regulatory agencies . no rulemaking groups watching them . EPA9 commented and said that standard was completely unprotective

-10 of the public's health and asked why there was unprotectedI I status given to radiation . I just share your concern tha t12 there should be someone independently checking even, shipment13 going out and what's going on . on a day-to-day basis .14 MR. CAIN : Thank you.15 MR. HSU : The 25-millirem rule was promulgated by NRC .16 If EPA has expressed concerns . it should be between EPA and17 NRC at a national level as an agreement . As a state, we need18 to maintain our agreement status to make sure we hav e19 compatible regulations . So like I said, California is going20 through the rulemaking process right now. Here is the time21 for people to come and comment -- and have comments to be22 considered.23 MR. HIRSCH: What public comment ?24 MR. HSU : The notice of proposed rulemaking hasn't been25 issued yet. It's in the process of being understood . It's

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I probably the Department of Finance -- there's Form 399 --2 anyway . I don't need to go into that .3 What I'm trying to say is that it is an existing4 guideline that if people want to go through the rulemaking5 process to object to that or petition for another6 rulemaking -- that's outside of this discussion here .7 MR. CAIN : Thank you . Mr. Hsu.8 We're at the halfway point of the meeting . Before9 we move to Agenda No . 3, the interim measures for the sodium

10 burn pit, if we can take a ten-minute break so we can prepar eI I ourselves for that discussion . - We'd appreciate the committe e12 members and audience members committing to ten minutes only .13 Thank vou .14 (Recess. )15 MR. CAIN : Thank you everyone for being so sensitive .16 During the break, it was requested that we go17 directly to the public-comment period on nonagenda items. If18 that is okay with the workgroup . I'd like to move to that19 point so the community members can have an opportunity to20 comment on the items on their minds . What does the workgroup21 say' '22 In the interest of saving time. I'm going to limi t23 public comment to five minutes total . Once again, if you'd24 like to come to the microphone and state your name for the25 court reporter and adhere to the speaker rules . it'd be much

54

4

appreciated . Does anyone in the audience wish to speak onnonagenda item s

MS . HUSH No opportunity should go untaken .I'm Lisa Hush . H-u-s-h The organization I

represent is CAUS .At the last meeting of this group . there was an

action item I brought up . I don't see anybody here that 18 recognize . It was about getting the Hanover phoneti c9 Report to show how much in compliance we are with NEPA . And

1) there was another agency name that was -- Dan could probabl yii figure--2 MR. HIRSCH : CEQA' '13 MS. HUSH : I asked what Washington Hanover stated had to14 produce in terms of respectability versus what we were15 required to produce . I wonder whatever happened to that`? It16 was an agenda item . It's a simple question . You've now been17 asked to do environmental assessment . Can vou tell us if any18 other DOE facility has done it like Hanford or Oakridge o r19 Livermore that has done its review at the minimum level of2)) assessment as opposed to CERCLA's review? This is a DOE21 facility . What other DOE facilities --22 UNIDENTIFIED SPEAKER : There used to be Los Alamos --23 MR. CAIN: Thank you .24 Am' other comments from the public ?25 UNIDENTIFIED SPEAKER: That wasn't the end . was it?

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PAGE 5 e1 MR. CAIN : It's on the agenda under Item 7 . If we get2 there this time , we'll bring it up again . If not, we'l l3 bring it up next time .4 MS . FERKINES : I have a couple of--5 MR. CAIN : Madeline, could you please state your name .6 Can you hear me?7 MS. FERKINES : Madeline. M-a-d-e-I-i-n-e: Ferkines .8 F-e-r-k-i-n-e-s .9 The representative to the Army Corps of Engineers is

10 not here. so I can't ask the questions in order to notify my1 .1 friends of an swers . So I have a couple other things I need12 to bring to your attention.13 I spent this morning on the telephone with th e14 Agency for Toxic Diseases Registry in the regional office in15 San Francisco with Director Bill Nelson . And among the16 topics we discussed. the most important one to me when I17 contacted him was the fact that I have been going over the18 Agency for Toxic Substances Diseases' registry preliminary19 draft dated December of 1999 . And in the preliminary draft .20 they conducted a review of the California Department o f21 Health Services Worker Study on the Rocketdyne-Santa Susana22 Field Lab area . And my concern is this . It is a review o f23 already-written reports. 1990 and 1992 . Specifically, what24 caught my eye was the people who were left out of the report .25 page 15 -- you might want to make a note of this-- on the

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preliminary draft, the bottom paragraph . it says. "The secondcommunity health study' was conducted as a follow-up inresponse to recommendations made in the 1990 investigationdescribed above . California Department of Health Services1992 . In this investigation, the 1990 study data were

re-analyzed after including a more homogeneous study ofhospital population ." I quote. "IC . invasive cancers amongHispanics" --

THE COURT REPORTER : Would you please slow down .MS . FERKINES: -- "non-Hispanics. and the Whites .

stratified by sex ." end of quote .Did evervbody hear that?Now, also according to the Agency for Toxic

Substances Registrv . the compilation of data was taken fromthe 1990 United States census . In that census and accordingto the ATSDR review, on their graphs they point out the factthat. within one mile of the Santa Susana facility .13 percent of the residents living in that area areHispanic . Now, mathematically . that means one out of sevenpersons . My point is this . The lack of notification on al lof this has been willfully negligent all along . But myconcern is that it is the most extreme example of not beingin compliance of the Civil Rights Act Title 6 . 1964 . theCivil Rights Act Title 7 and Title 8, all blended togetherwhich creates the Fair Housing Act, which also includes laws

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1 against discrimination of an individual or a group of2 individuals based upon race, color, creed, triba l3 affiliation, sex, religion, political affiliation ,4 socioeconomic status or background, national origin, et

5 cetera .6 Now, when I heard about the notification of all o f7 these hearings and the initial guilty plea by Rocketdyne of8 the illegal handling and disposal of radioactive waste -- I9 hear it is common knowledge . No, it is not commo n

10 knowledge -- is when I saw the media kits and IAS meetings

11 regarding . the preliminary draft of this site study I did12 not see it on KMEX, which is the largest radio station in

13 Los Angeles. I did not see on Univision [phonetic] . I did not14 see in Christian Science Monitor, and I did not see it i n15 Awake or the Watch Tower. Exercising constitutional and

16 civil rights in this country are individuals and groups o f

17 individuals who publish their own newspapers. among some of

18 those I already told you about . and this does not include19 people who read only any of certain items or any articles or20 am, publications only printed by Oregon Catholic Press .

21 Now. 1 have a real concern by looking at the turnout

22 at this meeting and of the one on the 1st of May that23 everybody in this room does not represent this community .24 And this community regarding this toxicity does not just

25 include Susana Knolls . Simi . Chatsworth . or Box Canyon .

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I De Soto to Ventura Boulevard -- I took Ventura to De Soto .2 Blackhawk to Owensmouth back up to Topanga than to Simi3 Valley to this point . And I came across and passed seven

4 Kingdom Halls, four Church of Christ. and three Christian5 Science reading rooms . That should give you an indication of6 the kind and amount of people that may never be privy t o7 these little flyers that are handed out to people that says .8 you are, by special invitation, invited to the Santa Susana .

9 Field Lab Workgroup. So I want the information to get out .

10 Thank you for your time .11 MR. CAIN: Thank you very much for your comment .12 We have exhausted the period allotted for public

13 comment . So if we can move to the Agenda Item No . 3 . interim

14 measures for the sodium burn pit . the agency that is to lead15 that is the Department of Toxic Substances Control .

16 MR. ABRAMS: Can everybody hear me okay ?17 Just a little background for the former sodium bum

18 pit or former sodium disposal facility . It was used to treat

19 components from reactive research . Primarily . they used t o

20 treat components with sodium metal in it. What they would do

21 is to put it in a sort of a swimming pool-bath . and th e22 sodium metal would react with water and combust and react

23 off.24 The guess is that the radiation that was in th e25 soils at the FSDF was from the DSRE reactor . The problem

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There are all kinds of people who are not aware of what'sgoing on and who have never been notified .

And one other item regarding the ATSDR preliminan

draft is the water slides shown by Mr . Burt Cooper . theindustrial hygienist . at the Clarion Hotel in December. Thewater grafts and plumes were shown from 1988 to 1993 and1995 . That's fine and dandy . But I want every body in thisroom to know who may not be aware of the fact that . up unti l

9 1969 , we had no pipelines . This entire valley was fed by

10 water through wells . The entire agricultural community wa sI I fed through wells . through the Simi Mutual Water Agency . The12 pipeline from San Fernando Valley came to Santa Clarita from13 San Fernando Valley in 1969 . the first waterline . Then we14 had blended water until the second waterline came in . Now .I5 all of our water is imported . So I'm researching that right16 now with Callegus because the water well contamination of17 these radionuclides was much higher . We had a building18 moratorium in the early 1960s . and it's because we did not19 have enough water to meet the agricultural and fire needs .20 And so I want to make sure who has lived here throughout21 childhood or adulthood or several generations or multiple22 generations is notified of exactly what toxins they've been23 exposed to because these few-and-far-in-between . fly-by-night24 press releases to local newspapers just does not cut it .25 To attend this meeting . I had to drive here fro m

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h )

I that occurred in 1959 . I understand or heard. is that those

2 components were placed in there . So when they went in . in

3 1991 . and did the initial removal action in the lower pond .

4 during the survey . they encountered radiation components in

the soils . Also in the soils for our department -- we'r eh removing the soils because of the chemical contamination .

7 They also used these impoundments for disposal of8 solvents . and they set those solvents on fire . An d

9 typically . when you bran chlorinated solvents . some of the

10 residual material left behind is dioxins . Also I understandI I that they used prophenal oils they left in the impoundments

12 as well . and they contained PCB's . So the contaminants we

13 find in the soils is the reason we're removing the soils and14 because of the elevated levels of PCB's, dioxins . and some15 mercury that's found there above health base cleanu p

16 members .17 Just to give you an orientation here, this is a

18 slide of the sodium bum pit . This was referred to as the19 "lower pond" or "impoundment ." This is the upper

20 impoundment . This is the western area . And what you have

21 here are channels where the natural drainage runs away from22 the former impoundments .23 Just to get everybody oriented a little bit better24 here, this is the lower pond, this is the upper pond . th e

25 western area . Going this way is to the west, and this way is

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I to the east, towards Chatsworth . This is to the north. and2 these are the -- this is referred to as Channel A. this i s3 Channel B . and about a thousand-feet distance from th e4 impoundment here the two channels join up to Channel C .5 Let me give you a rundown of what's been going on

6 with interim measures . Work crews began removing soils from

7 the lower channels, Channels A . B. and C, a couple of weeks

8 ago. They've pretty much removed most of the soil that was9 outlined in the work plan down a distance of 1,500 feet or

10 close to a quarter mile from the upper impoundment .II -Based on their current rate of activities, they'll12 probably finish up removing the soils from the channels in

13 the next week or a week and a half . This week they'll be14 removing soils from the lower part of Channel B and going in15 and removing the loose soil debris from the exposed bedrock16 where they've already gone through and removed the soils.17 Ongoing for the rest of the schedule for the interim

18 measures . beginning in June . they'll start the excavation i n

19 the main impoundment area . That excavation activity should

20 probably last through the month of June . roughly, three to

21 four weeks . We can expect the transportation of the soils to22 begin towards the later part of June . And in August. if this

23 current schedule holds . they should finish with the

24 excavation in the main impoundment area . At that point.25 they'll sweep and go through the upper impoundment and remove

PAGE 6 4

1 The elements of the infiltration monito ring work2 plan are important to mention here . One component is the3 installation of four piezometers on the uphill side of th e4 impoundment area because we're interested in finding ou t

5 what's going on in terms of water flowing around the bedrock

6 contacting the bedrock potentially into this part of the fil l

7 material .8 Another component is the installation of soil an d9 moisture probes. And this is for FSDF . There ' s going to be

10 clusters of soil moisture probes . In this case, they will be

.11 set at discrete -depths through the thickness of the compacted

12 clay material . Those moisture probes will give us13 information on the moisture content through seasonal

14 chan ges .15 As we go into the winter months and we encounter

16 rain events , the moisture probes will tell us what ' s going on

17 in terms of ch ange in the moisture content in the backfil l

18 materi al and give us an indication of the performance of the

19 backfill .20 And lastly, another element of the infiltration

21 monito ring work plan is referred to as P an Lysimeters . That

22 can tell us the ch ange in the moisture content . track changes

23 of moisture . if they made them through . The Pan Lysimeter

24 will be able to quantify any moisture that collects . that

25 makes its way down through the backfill material .

62

1 all the loose debris from the bedrock material . get down into2 the cracks . and remove that material as well .3 At that point . they'll go in and survey the exposed4 bedrock . They'll do a mapping for stained areas. identity

fractured areas . map the geology At that point. we'll go in(' there as well and identify clearance and confirmation- samples.8 Towards August . %\e should see emplacement of the9 engineered backfill cover design . And once the soil i s

1 0 removed from the bedrock, the bedrock will be exposed . andI I they'll scrape it with the excavator to remove any staine d12 areas as much as they can . It should look something like

13 this when its done .14 This is the removal activity that occurred in 199 115 for the lower pond . You can see here the exposed bedrock

16 material . This is a part of the tarp that's covering th e17 upper impoundment where there's still contaminated soil s18 remaining . You can see a couple of the monitoring wells that19 exist around the impoundment area .20 In August. they'll place the engineered backfil l21 cover. There's a couple of important components of the22 backfill that are worth mentioning . When we approved the23 interim measures work plan in December. we required that they24 submit -- Boeing submit an infiltration monitoring plan, an d25 they did that in April .

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I It's probably worth pointing out as well that . fo r

2 the FSDF . there ' s two groundwater extraction wells in place .

3 They' re currently pumping and treating and removing th e

4 contaminated groundwater . which is located beneath theimpoundment when the facility was open and in operation .

6 As I mentioned. one of the components of th e

7 infiltration monito ring network will be moist ure probes .

8 These probes -- this is the type of probe that will be used .

9 It has sensors along its length . information is translate d

1 0 to a data logger . The information will be transmitted evenI I four hours . 24 hours a day . 365 days a year. So there will

12 be a fair amount of information that will be gathered on the

13 moisture content in the backfill .14 That information then can be taken and plotted u p

15 and what we might expect to see during a normal winter would16 be. For the probes that are near the surface, we migh t17 expect to see . During a rain event, the moisture content18 kicks up near the surface . And as the storm passes .19 evapotranspiration takes place . and suction takes effect. _

20 That moisture will be pulled back out of the system . What

21 we'd expect to see at a deeper depth would be the moisture22 content to remain fairly stable if the cover is performing as23 planned .24 The other component of the monitoring system is a25 Pan Lysimeter. This is an example of a similar type of

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1 Pan Lysimeter. The design that will be used for this2 backfill cover design will be a li tt le bit different . I t3 will be a rectangular, ten-feet-by -ten-feet -- but the idea4 is the same -- STP liner set at the base of the cover, and5 it will collect any moisture that makes its way down. It can6 be collected and quantified .7 There were concern s expressed in the public comment

8 period about the effectiveness of the design that wa s

9 chosen. We looked at a couple of designs fairly carefully .10 Before we selected the design we did, we contacted th e11 Regional Water Quality Control Board . And they said they

12 have implemented these monolithic cover designs on a couple13 of sites in Southern Californ ia .14 One of the proposals was to go with what's then15 referred to as a RCRA coverdesign. which the components of16 that consist of about two feet of clay overlain by a liner .17 And then there's about another two feet of soil over that18 where there' s a vegetative cover . The line and the clay19 provide the barrier . Unde rneath these components is simply

20 just a clean backfill soil . but it has no protection in term s21 of low permeability .22 One other design we had in looking at this type of23 interim measure cover was that it might not address th e24 lateral under flow that we think is happening out at the FSDF25 burn pit . So the whole concern that was expressed in th e

comment period was that the cover needs to preven t2 infiltration into this bedrock zone here where there might3 still be some mass held up and continue to impact th e4 groundwater .

We went with the other evapotranspiration design .r, And we spoke with the Los Angeles Water Quality Control7 Board . and they implemented that type of design at a couple8 of municipal landfills in Southern California . There ar e

9 three examples : Milliken Landfill, Phelan Landfill . and

10 Coyote Canyon Landfill . They collected good five or si xI I years of data on the performance of this type of design . and12 they found excellent results . Milliken. M-i-1-1-i-k-e-n . not13 fore the Phelan Landfill, they're getting permeability in the14 range of ten to minus eight . And for the Phelan Landfill .15 ten to minus eight That's pretty good performance compared16 to anybody's standards .17 Sandia National Labs also conducted a cover

18 demonstration . They looked at a number of different cover19 designs including RCRA Subtitle C . which is for hazardous

20 landfills . RCRA Subtitle D is for municipal landfills . which21 we adopted for this interim measure activity . What they'v e22 found with their demonstration project was the performance of

23 the RCRA cover is at least as good as the RCRA cover design .24 These types of cover designs are also being implemented by a25 number of different municipalities in Southern California.

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1 So they're nothing new . They're out there, and they seem toPAGE --, S

2 be operating pretty well .

4 during the comment period and afterwards, there were some3 One last issue I'd like to address and that was .

5 comments made that the Department has relaxed their standard s

9 outlined. And then from the October 10th. 1997 memo -- an d8 established earlier? And those protective requirements wer e7 Why has DTSC retreated from more protective requirement s6 based on other earlier criteria . Actually, the comment was .

12 how we intend to stop the migration of moisture going throug h11 department memo said that the interim measures must addres s10 here' s the comments from that memo . The first was that our

16 bedrock, we're placing an engineered low-permeabilit y15 that, to stop the continuous migration of moisture to th e14 And what we've done here with this cover design i s13 the bedrock .

18 15 feet through the center of the impoundment . When we do

19 the modeling, also when we look at the performance of othe r

17 backfill cover . Its thickness ranges from roughly seven t o

22 project. it performs pretty well . This particular backfil l21 information from Sandia National Labs on their demonstratio n20 similar types of designs with the Water Board . the

23 cover will perform pretty well -- will perform very well . It

24 will essentially pretty much minimize any type of moistur e

25 infiltration through the cover . We also have a -- we also

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I have monitoring to monitor the performance of the backfill .

2 So if its not performing . we'll know. Also there's a3 groundwater extraction treatment operation to remove th e

4 contaminated groundwater underneath the impoundments right5 now .6 And lastly . another component is that there will be7 a characterization work plan which will be submitted to8 characterize the bedrock beneath the landfill or th e

9 impoundment .'lo The other point made in the memo was regarding theI 1 provision of the backfill strategy designed cap line r12 preclude the infiltration of a rainfall . The improved cover

13 design will do that.14 And the last comment is the provision of adequate15 monitoring of the underlying fractured bedrock . And this

16 is . again. what we have here for monitoring, upgradient17 piezometers. to get an idea of what's going on in terms o f

18 soil or groundwater movement . We've got the piezometers that

19 have the ability to quantify in terms of what's going on in _20 terms of performance . We have the cluster moisture probes.

21 and we've got two groundwater extraction wells operating out22 there as well as even monitoring the wells to monitor th e

23 existing water quality and any changes in water quality24 around the impoundment .25 That pretty much concludes the presentation .

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1 MR. CAIN : Thank You very much . I2 Before I ask for questions from the p anel members . 23 I'd like to note that -- its hard to notice with the light 34 shining -- we have some more legislative reps in the 45 audience . 56 Would you like to introduce yourself? 67 MS . WILLIAMS : I am Johanna Williams . And I'm here as a 78 representative of U.S . Senator Barbara Boxer . 89 MR. CAIN : Thank you very much. 9

10 We'd like to open the p anel discussion . 1 0II MR HIRSCH: I'd like. to present an opposing point of 1 112 view for a moment. 1 213 Gerard has made courageous efforts to put the best 1 314 face on after a complete back-down by his agency to protect 1 415 that bum pit . That pit was contaminated with radioactive 1 516 materials an d chemicals because they used the pit to bu rn 1 617 chemicals when radioactive materials or chemicals which 1 718 weren't supposed to be burned in it in the first place . 1 819 As he mentioned. the groundwater has become 1 920 contaminated . Now. how did they manage to do that '.) It went 21)21 through the soil . and it went through the fractures in the 2 122 bedrock . There' s still that contamination in the fractures . 2 223 And for the moment. its not clear if anything will be done 2 324 to get that stuff out of the fractures . so its going to 2 425 continue to contaminate the groundwater . His own department 2 5

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I mentioned it obliquely regarding -- this memorandum had2 recommended that there has to be a cap. a permeable synthetic3 cap . which is basically a thick piece of plastic . to put over4 the top of it . so every time it rains. that rain wouldn't go

into the contaminants and cam it down to the groundwater .I believe pressure was applied by Boeing to senior

personnel at the highest levels of the Department . and th e8 Department did a reversal and said you can simply go and take') dirt from another place on the property and put it there .

Ili And you don't have to put an impermeable synthetic cap overI I it . Just take some dirt and have some vegetation grow on top12 of it . And the argument is . even, time it rains . the water13 will come down a little bit. and a hundred percent will go14 back up. None of that water will go through that soil an d15 through the rocks and into the groundwater. If that were the16 case. there would have been no contamination of the17 groundwater in the first place .18 This was a backing down, in my view . in order to19 save this company money and in order to make it easier for20 this land to be sold because it will be much tougher to sell21 this land for residences and other purposes .if you have a22 bunch of toxic pits with plastic caps on it that have to be23 maintained indefinitely .24 I am extremely troubled. Instead of putting in a25 protective measure . which the Department itself had

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I If we move forward and install this design . when we2 have to go back out there and drill through it . ho w3 protective is that going to be? It's going to shoot the hec k

out of this thing by poking holes through it . I just don'tsee how this is a protective design when we've got anotheroption with the performance . I think what we get out of that

is virtually no infiltration through the cover . So how i sthat -- I don't see where we've lost here .

9 MR. HIRSCH : There will be no infiltration through that10 dirt . did you say'.'11 MR. ABRAMS: We'll have the data to back it up .12 MR. HIRSCH : You already proved . by doing it this way .

13 there's a lateral flow problem with the plastic cap . and this14 doesn't give you --15 MR. ABRAMS: That's the RCRA style cover right here .16 right . This has 22 feet of clay fill up here with the17 plastic on top of it and backfill . That's the RCRA style18 design .19 MR. HIRSCH : And you have no plastic .20 MR. ABRAMS: The RCRA type design. you would have21 plastic .22 MR. HIRSCH : But your department vetoed that .23 MR. ABRAMS : For the design we selected, you've got24 15 feet --25 MR. HIRSCH : Please be careful with the public here .

P.=!,GE 7 2recommended , the Department is now basically saying go aheadand just put some dirt on top and hope that there will b esome vegetation growing back . And this flaky theory thatthere is somehow a zone flux reversal so the rain comes down,and gravity stops working so all of it goes back up . none o f

it will continue on through the bedrock . I am extremely

concerned this will be done throughout the whole property .And that' s one of the key things as members of the

public has to watch which has to do with the RCRA waste

facility . And there will be a great incentive to come upwith a model-and a theory which says, we don't have to cle anit up . We don 't have to put a synthetic cap on. We can justput dirt on top . If this process were somehow a little bitmore equal and a little less political, you would be moreprotected . But in this case, even the Agency evenrecommended doing the right thing, and that somehow gotvetoed .

MR . ABRAMS : Nonsense . First of all, let' s back up . Therecommendation for a so-called RCRA soil cover was first madeas a final remedy . And then it got worked into the interimmeasures remedy . I pointed out we're still in the inte ri mmeasures stage here . This is not the final design . But i fwe went forward with this cover design that we're proposing .then how is it protective with the lateral groundwater fl ow''We still need to do the bedrock characte rization .

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l MR. ABRAMS: No. its clay, Dan. 12 MR. HIRSCH: And is that soil taken from elsewhere on the 23 site? 34 MR. ABRAMS: It's taken from the borrowed site, which is 45 clay . 56 MR. HIRSCH : It had clay in it . It's not -- come on . 67 You gave us a sample of that . Its soil with clay content to 78 it . It's not pure clay-. right? What percentage of it is 89 clay? 9

10 MR. ABRAMS: A hundred percent . It's classified as 1 011 clay . 1 112 MR. HIRSCH : As clayey soil . 1 213 MR. ABRAMS : No, its classified as clay . 1 314 MR. PLOTKIN : Aren't there two problems here : One is the 1 415 water comes down and goes straight down, and the other is 1 516 water comes down the side and goes laterally? Aren't these 1 617 two separate problems`? 1 718 MR. ABRAMS: Yes . 1 819 MR. PLOTKIN : So all of that. that 7 to 15 feet you're 1 920 talking about . if that whole thing is solid clay . its an 2 021 impermeable clay . the same as plastic? And water can't come 2 122 sideways either because it's going to hit the clay? 2 223 MR. ABRAMS: Exactly . You said it . That's why this is a 2 324 better design . 2 425 MR. PLOTKIN : And where does this clay come from? 25

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Southern California with three landfills that were closed bythe Water Board. They've got five years of data to back themup. We also have a monitoring system to back this up . Ifit's not performing, we'll know it . We're going to have thedata .

MR. PLOTKIN : What happens if it doesn't perform? Fromwhat you've said, those moisture sensors and so forth arecompletely and totally unnecessary . You don't need them .There isn't going to be any moisture there . This is clay .Nothing goes through it .

MR. ABRAMS: Probably not . But we're going to monitor --we're going to monitor the performance of it .

MS . JOHNSON : I'm confused . You say this is totally clayon top . but then you talk about planting some foliage o ntop : How will the foliage grow in clay ?

MR. ABRAMS: There will be a laver of engineered claythat will be laid down and compacted . It would be just like

any landfill -- engineered landfill would be . We would thenplace the upper 12 inches to 18 inches with soil material forthe vegetative cover to be planted .

MR. HIRSCH : I do think we need to move on . But claysshrink and expand. they dry out . fractures occur. water goesright through those fractures . but it is simply cheaper . I tis a political move . in my view . And 1 will make you aprediction .

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MR. ABRAMS Comes from the on-site borrowed source .which is clay .

MR. PLOTKIN- It's been tested . and no water -- you cantake a laver of this stuff and put it in a puddle of water .come back a month later . and there's no water underneath it ?

MR. ABRAMS: That's right . Samples were sent to ageotechnical lab . they were run -- they were compacted .moisture added -- the moisture content that this was placedin compacted to 90 percent, which this material will becompacted to . And then a permeability test was done on thesoil . It came out to ten to minus six permeability . which isclay .

MR. PLOTKIN : Well . but if it were a piece of plastic . itwon't --

MR. ABRAMS: The problem with plastic is that itstretches --

MR. PLOTKIN : You don't -- you don't buy --THE COURT REPORTER : Please speak one at a time .MR. CAIN: Could you not talk over each other, please .MR. ABRAMS : -- it has to be welded together. You know

there's imperfections in it. -You saw that Sandia National Labs study where they

compared the performance of a RCRA style cover to that of anevapotranspiration cover . and you saw that performance wasequal . And were saying that same performance can be seen in

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You say this is an interim measure''MR. ABRAMS: Yes . it is .MR . HIRSCH : I believe politics has entered into their

decision to reverse the Agency's own recommendation to usethe plastic cap and to go with clay soil . And I predict youwill not require them to clean up the contaminants that arehung up in the fractures . Prove me wrong . Not today . butprove me wrong .

MR. ABRAMS : Let me suggest this : First of all . we're

going to have the monitoring data to back up the performanceof this cover . We also need to step through thecharacterization of the bedrock . Now. it may be . as we stepthrough that characterization . we're going to have to selec ta final remedy .

Now, the remedy could be a cover . it could be vaporextractions to remove the contaminants from the bedrock, itcould be other technology that could remove the mass from thebedrock . Hopefully, we don't have to leave the mass there .Hopefully, no water has migrated to where the contaminantsare . and the cover will encapsulate it forever.

MR. HIRSCH : Gerard, did you say maybe we'll have toselect a final remedy'? I heard you to say, "Maybe, we'llhave to select a final remedy ." That suggests to me you'reclearly thinking that this is the end. It may not be . Ithought this was an interim measure .

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I MR. ABRAMS : I'm sorry . I take it --2 MR. HIRSCH : I will predict this is the final .3 MR. ABRAMS : Actually, the process is this : We need to4 step through and complete the cleanup of the sodium burn5 pit . When we do that , we then need to step into th e6 corrective measures study phase, that is, to look at the7 remedial options . Everything is on the table. That is a8 very public process . You'll have plenty of opportunities to9 comment on that .

10 MR. HIRSCH : He's in negotiations behind closed doors11 with Boeing, after you ve made the decisions , and the public12 receives letters -- it's not a public process. But you're13 telling us that there's a ch ance after having them take these14 soils from elsewhere on the propert y and fill it in . plan t15 vegetation . you will , in a few years , tell them to dig it all16 out again and deal with the contamin ants in the fractures?17 I'd like to see it . I hope that is indeed what you're going18 to do . I'm skeptical .19 MR. ABRAMS : We need to step through the corrective20 measures study process in a way that is the best remedy for21 this impoundment . If we c an go in with the vapor extraction22 system or some other treatment system and remove the mass.23 why not'.) Why . we do it elsewhere . Why leave this mass24 there `' I mean. there' s a plenty of options . We don't know25 where the data is going to take us . We need to step through

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1 This is my take . It's an interim measure . And I2 know Dan disagrees, but why would we do additional work and3 require additional work pl an if this is the end? But really4 it's -- it's an agreement . not an opinion at this point.5 UNIDENTIFIED SPEAKER : If I c an ask one question ?6 MR. CAIN : Before we go to public comment . does any other7 workgroup member like to make a comment on this topic "8 Go ahead.9 MR. HI RSCH: Gerard, I don't believe you indicated how

10 they're going to start moving the di rt out of this burn pit11 in the next several months . You indicated there wa s12 radioactive contamination and chemicals . I underst and your13 agency has w ritten to DHS as to whether there ' s any evidence14 of radioactivity in the soil . If there is. I understan d it' s15 considered as mixed waste, which is prohibited to go to where16 they're about to send this stuff to, which is Kettlema n17 City . We're about to have presentation whether there is18 radioactivity . If you lea rned there is radioactive wast e19 above the background level, are you going to stop it from20 going to Ke tt lem an City which has no license to take mixed21 waste?22 MR. ABRAMS : Let me give you a little background. In23 1991 . when they did the first removal activity . they removed24 10.000 yards of soil . That material was from the lower pond .25 the upper pond. and the western area . They went through tha t

I it svstematicall y2 MR. HIRSCH We 've gone through this enough . I'm lust3 giving you my understanding and thoughts on it . I hope it's4 clear to the publi c

Maybe we should go on to the --r MS . BATARSEH I just want to emphasize . at this point .

there is additional work that is being done . the infiltratio n8 monitoring work is being done . and we are receiving and9 collecting data . The beta zone characterization plan is to

10 be submitted in June .I I I know there' s an agreement and disagreement12 regarding whether this is an interim measure or a fina l13 remedy . but I think we shouldn ' t forget we are working on14 additional measures for the area . We are working hard to15 really understand what's going on regarding the infiltration16 or the lateral migration of water .17 And also we want to really understand what i s18 happening in the bedrock . This is a challenge for us. but19 this is , again - the biggest comment that we've got regarding20 this interim meas ure . You know, what is the residua l21 contamination in the bedrock? How will it affect the22 groundwater '? As Dan said. yes . it is true, there is . We23 need to better understand what ' s happening before we make the24 final decision on what is protective to the public health an d25 the environment .

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I material . a yard by yard . and they separated -- I understand2 you have a disagreement over how they did that . The question3 is. If the material is above the background level . will w e4 not send it off to Kettleman'' The call is really from DHS .5 They regulate disposals of the Rad material .0 MR. HIRSCH : Don't you regulate mixed waste? That's your7 responsibility .8 MR. ABRAMS: If its classified as mixed waste . but --9 MR. HIRSCH: You know it has chemicals in it . The only

II) question is whether it's mixed with radioactive material . If11 it's mixed with radioactive material . its not thei r12 responsibility : it's yours . If we have evidence in the next13 20 minutes there is radioactivity above background . are you14 going to stop shipping them to facilities not licensed -- to15 the unlicensed facility ?16 MR. ABRAMS: Whether to call it a mixed waste or not . DHS17 will make the call .18 MR. HIRSCH : As I understand CERCLA transferred that duty19 or delegated that to DTSC, not to DHS ; am I right? _20 MR. KELLY: Its actually RCRA . That's the program we've21 delegated to DTSC .-But in determining the radioactiv e22 component of that material, it's DHS regulations and NRC23 regulations which guide what is considered as radioactive24 waste . So once it's considered as mixed waste, it' s25 regulated by DTSC . But certainly, they need to look to DHS .

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1 just like EPA would look to NRC, as to how radioactive2 material is defined. And you know, essentially, what gets3 classified as radioactive waste because we don't have rules4 on -- I don't want to say any rules, but we have relatively a5 few rules on radioactive waste .6 MR. HIRSCH : We have asked whether they have rules as to7 what constitutes radioactive waste or not . Apparently, that8 issue has been bypassed because you're asserting there's no9 radioactivity above background level for soil -- why don' t

10 we move into that -- if not, DISC needs to think twice about11 permitting it to go to unlicensed facilities .12 What we have learned in January of radioactive waste13 going out to places not licensed for the radioactive --14 MR. CAIN: Before we progress. I would like to open up15 the microphone to audience comment .16 Is there anyone that would like to make a comment at

17 this point ?18 MS. KOWALSKI: Yeah .19 MR. CAIN: If you could be so kind as to state your name20 and spell your name .

21 MS. KOWALSKI: My name is Dawn Kowalski .22 K-o-w-a-l-s-k-i .23 Gerard. I'm still very concerned with the sodium24 burn pit and the lateral flow and clay and gases . The fact25 is that clay does dry out .

I've lived close to a wielded lphoneticI land i nEngland for many years . I've seen how clay dries out in thesummer in England where we don't get a lot of heat . We'retalking about California- huge cracks here . So I'm veryconcerned with that because I live downhill . and I have astream that comes down the yard . And one of the concerns wehave in Simi is the groundwater contamination . I have a

8 flowing stream that comes over those hills- so I'm not9 convinced --

10 I don't like the idea that you have one idea, and1 1 you went to Boeing . and now you have another idea . That12 sends a huge red flag up to me. And I'm disgusted as usual13 how all the agencies aren't doing hot potato . Everyone is14 just passing the buck . DISC says, we won't decide whether15 this is mixed waste . We'll ask DHS . DHS says. ask DOE .16 Then DOE says, well ask EPA . And EPA doesn't give a damn17 about it anyway so --18 MR. ABRAMS: Thanks . Dawn .19 MR. CAIN: Any other comments from the public ?20 MR. ABRAMS: Actually, you're right . Clays do shrink .21 And that's actually one of the problems with the RCRA cover22 design . In an arid environment such as Southern California,23 what they use is a -- not to get too technical, but what' s24 called fat clay . And when it maintains its moisture content .25 it works fine . It's very permeable. When it begins to dry

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2 The clay that is being used at the FSDF from th eI out over time, then it will shrink .

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9 MR. ABRAMS : This is an interim measure, again. And8 stuck .7 UNIDENTIFIED SPEAKER : If it doesn t, our grand kids are6 low-shrinkage coefficient , so it should perform very well .5 they were measured in the laboratory . They have a4 elastic content. And you can measure these parameters . an d3 borrowed source is a leaner clay . It doesn' t quite have the

19 MR. CAIN : She's asking if there ' s better clay somewhere18 UNIDENTIFIED SPEAKER : Never mind . I was asking --17 with most elasticity .16 MR. ABRAMS: Yes, it is . Its the best kind you c an ge t15 . Is this on-site clay ?14 UNIDENTIFIED SPEAKER : Just real quick .13 please come to the microphone .12 MR. CAIN: If the members of the audience wish to speak .11 UNIDENTIFIED SPEAKER : Is this local clay ?10 were still in the process --

25 45 minutes left in this meeting tonight . We have seven24 close this topic and move on to the next item" We hav e23 MR. CAIN : With the permission of the workgroup. may w e22 be a very good clay for what we want to do with it .21 MR. ABRAMS : The clay we 're using actually turn s out to20 and getting something from off site --

I topics left . And the next one is RFI .

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2 MR. KELLY I think what folks are waiting for is DHS to3 do their part of the discussion unless I'm getting it wrong .4 MR. HIRSCH They're going to tell us whether that soil

is radioactive .0 MR. CAIN: Okay- . Go for it .7 MR. HSU: Okay . Roger will explain the comparison we had8 done. And based on our review and the analysis . he's going

9 to be able to tell you what our viewpoint is .10 And I'd like to mention to the group, the panel, andII also the audience . when DHS released the former sodium12 disposal facility for unrestricted use, without radiological13 restrictions, that decision was_based on the fact that the

14 residual radioactivity in the soil was much less than the15 sitewide release criteria . The sitewide release criteria .

16 which basically is 15 millirems per year, for all impacted17 pathways analysis for the maximum exposed individual on18 site . So in other words, if the concentration is less than19 what that sitewide release criteria of concentration -- for _20 instance, if there's only one radioisotope, if it's belo w21 that number, basically, it can be left on the site because of22 the pathyway analysis, the modeling that we have done in23 concluding that it will provide less than or equal t o24 15 millirems. But then back to this finding of the soil25 concentration, the soil concentration we found for some

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I radioisotope is much less than -- its maybe about two orders2 of magnitude less th an what the sitewide release criteri a3 concentration is . And I just want to bring that out to you4 so that you understand our decision to release that facility5 for unrestricted use was based on the DHS -approved sitewide6 release crite ri a , which is incorporated into Rocketdyne' s

7 radioactive mate rial license .

8 Thank you .9 MR. LUPO : We'll take another shot at the former sodium

10 bum pit facility . This is showing the graded areas for th e11 upper -western area, the lower pond , and the two drainage12 channels . What we did was we had the data from 1993 . I13 believe, from the Kaiser sampling pl an they did which covered14 th e site . and seven to eight samples which we reviewed that15 document data and went out to make confirmation su rv eys and16 collected surveys at the locations where I ' ve indicated wi th17 X's to get down to the bedrock . so we'd get a layered look at18 th e soils an d see what elements we might find . Now, this was19 done -- that was done in 1977 ,20 UNIDENTIFIED SPEAKER : 1977 ?21 MR. LUPO Excuse me . '97 . I was still in school in22 '7723 That data has been compiled for a se ries of isotopes24 that's in the handout that was laid on the table . And 125 believe --

And . Dan . I ' m som it was late getting to you .MR . HIRSCH I've seen it ten minutes ago . Thank you

en much .MR. LUPO You're welcome . I finished it this morning .MR. HIRSCH We do have a rule were supposed to receive

! them to weeks prior so we can ask sensible questions .MR. LUPO You did have the package two weeks ago .

8 MR. HIRSCH: It's different than th e data package .99 MR. LUPO Its a re-look at the same data .I u Now. what this is a compari son table of th eI I background data collected by McLaren-Hart study -- the12 national background is in the literature -- Boeing data13 collected with CIF Kaiser 78 samples . and DHSSdata of Point 514 dormitory samples that we took . and of these . the thoriu m15 232. 237 -- let me explain what -- "NA ." they were not16 available data to be put into the chart here .17 The DOE data here is the sitewide release crite ri a18 data for these radionuclides is 15 millirems . The EPA column19 is a risk number , and that concentration in soil that wil l20 give you ten to minus six . That was generated by Tom Kelly21 at EPA .22 Just a general comparison of the numbers here o f23 natural background or natural isotopes of thorium 232 . 230 --24 Oh. back to what I was going to say about no t25 available was DHS -- our lab does not give us 230 isotop e

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I numbers . It's a daughter of ur anium 238 . So when they give2 us 238, the uranium isotope activities , that includes th e

3 daughter activities. But when normally the two is i n4 equilibrium , the numbers that you see in the 238 column could5 be placed into the 230 column .6 Now, to get a graphical look of how the variou s

7 isotopes compared to the background data from McLaren-Hart .8 and not national levels. I've prepared a series of graphs .9 And I'm sure this is -- now , this is potassium 40 which is --

10 that' s in the ground everywhere . The national background is

I I in the range-showing in the red here. The local background

12 was found from th e McLaren-Hart studies. and it's in the

13 blue . And the individual points is the sample data from the

14 DHS samples taken .15 Now. the variability of the potassium for the bum16 pit. as you can see, it varies quite a ways of the six areas17 where the local background was taken . It's a very small --18 limited area for the potassium 40 --19 MR. ABRAMS : Roger . c an we stop for a second . I think2 0 it's important to note this potassium 40 is normally

21 occurring : right'?22 MR. LUPO : Correct .23 MR . HIRSCH: The data in the local background range . a24 few of them are out of place . So th is is naturally occurring25 potassium 40 . and you see that type of variability on th e

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We've got the national background -- this material

which I hadn't seen it till now, the regular backgroundaround the country is about two and a half picocuries pergram : is that correct?

reactors?MR. LUPO : Sodium .MR. HIRSCH : Sodium-potassium --MR. PLOTKIN : I have a question .

data?MR . LUPO. Right .MR. HIRSCH How come the local background ranges have

spikes around 3)) like the three samples up there''

Differences in the rock type'?MR. LUPO Differences in the rock type- differences in

the sediments .MR . HIRSCH : Number of samples collected .

MR . LUPO : Number of samples collected, also laboratorymethods used to analyze the samples .

MR. HIRSCH : Is there any way those three samples couldhave resulted from a release from activities when DHS sendsin the field lab ?

MR . LUPO : No vaccine -- potassium 40 is not a fissionproduct . so it will not be due to any activity atRocketdyne .

MR. HIRSCH : What kind of coolant was used for th e

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1 MR. ABRAMS : No . there's a range , about two and a half to2 30 .3 MR. HIRSCH : The local background is higher than anywhere4 in the country ?

5 MR. PLOTKIN : The local background is several picocuries

6 per gram higher than the national background . If we go to

7 take an average in there, say like ten, just for the argument8 sake , and were up at the 20 to 23, so for the local9 background 20 to 23, that's almost double what the average

10 national background is . Am I reading this wrong ?11 MR-LUPO : You're reading-it correct .12 MR. PLOTKIN : So we got a huge local background here .

13 The background here locally for potassium 40 is gig anti c14 compared to the national .15 MR. HSU : No . It depends on when they did it, where they16 took the samples, how large the sample size was . You just17 cannot compare , that' s the local background range . and that's18 the national background range, and it's higher . It depends19 on the reference . when they did the national background

20 study . they are done -- they were done at different places --

21 Yes. how c an -- did I answer your question ?

22 MR. HIRSCH : I think we shouldn 't focus on potassium 40 .

23 But I think in the graph you just put up. the background i s

24 larger than anywhere else in the country, an d the four data25 points are higher than anywhere found in the bum pit site .

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I think it's a dangerous --MR. ABRAMS : Can potassium occur from --MR. LUPO It's naturally occurring .

MR. HIRSCH : What happens when you radiate it withneutrons'.)

MR. LUPO: When you radiate it with neutrons . it nolonger has sodium .

MR. HIRSCH : You don't convert all of it into somethingelse?

MR. LUPO: If it's potassium and you radiate it withneutrons . you change the atomic number . It's no longersodium -- I mean, no longer potassium .

MR . HIRSCH: What does it get back into''MR. LUPO: If it's released . beta or gamma. I'd have to

look that up for you --MR. HIRSCH : Were losing the audience .UNIDENTIFIED SPEAKER : No, you're not .MR. HIRSCH : What decays into potassium 40? How do we

get it ?MR. LUPO: It's cosmogenically generated, so it's around

us all the time. It's here. -MR . HI RSCH : It's produced by cosmogenic or by

something --MR. LUPO: Correct .MR. HIRSCH : The reason people are asking is do you

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I remember the famous situation Demsey asked? We don't measure2 for triennium because we couldn't possibly have any . An d3 they came up with a dozen possible sources of triennium . You4 assumed there's not unnatural potassium 40 . If that's th e5 case, I don't know why you measured for it . And it seems

6 like -- otherwise, why would you measure for it when you do7 these cleanups ?8 What produces potassium 40, Steve?

9 MR. HSU : Didn't you just say that? Cosmogenic .

10 MR. HIRSCH : It's not natural ?11 MR. HSU, I don't know . I need to look at -- well . I'm

12 giving you my answer at this point . I'm being honest. but 1

13 need to have my reference book .14 UNIDENTIFIED SPEAKER : You need to be doing your15 homework, and you're not .

16 MR. CAIN: One moment, please .17 MR. HSU: We didn't bring our reference books .

18 MR. CAIN: Could we focus the conversation to the

19 workgroup?20 MR. HSU: If the chair could control the audience first .21 then I'd --22 MR. CAIN : I will do that . Thank you .23 MR. HIRSCH : Could we ask you to focus on the cesium and

24 triennium .25 MR. LUPO: Oh. yes .

9:,

1 MR. HIRSCH : Those are clear fission products . They're

2 very dangerous in terms of bio-accumulation toxicity . So3 let's see what --4 MR. LUPO : The next one I have is cesium . The sampl e

background ranges up to a maximum 3 .5 . the local background .o as you can see in this chart . is down -- I think it's .27 at7 the top end .8 MR. HIRSCH : You're incorrect . It's .21 .9 MR. LUPO: The line isn't at .5 . It's below .

10 MR. HIRSCH : Your comparison chart was wrong .I I MR. LUPO: Thank you . Okay. But as you can see . cesium

12 numbers are all similar numbers for background and all withi n

13 the national range .14 MR. HIRSCH : We'll let you finish. but we'll come back to15 that .16 MR. PLOTKIN : The first chart that you had -- th e17 compa ri son chart you had EPA st andards versus DOE standards18 for a one - in-a-million ri sk of getting cancer which is a19 common standard that's used for matters , and that's what EPA

20 uses . Up there at the top line, for cesium 137, you have .0 1

21 picocuries per gram as the maximum acceptable by EPA ; is that

22 co rrect ?23 MR. LUPO : That's what the n umbers come up with, ten to

24 the minus six .25 MR. PLOTKIN : One in a million which is the stan dard

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1 criteria for acceptable exposure?2 MR. LUPO : Not necessarily by the NRC commission rules .3 MR. PLOTKIN : I'm talking about what I've heard from just

4 community comment over the years as to what's acceptable for5 radiation exposure. and the risk of one in a million is th e6 usual standard.7 MR. ABRAMS: Another thing you have to keep in mind,8 Sheldon, is you might have some of these radioisotopes that

9 are naturally-occurring background concentrations .10 MR. PLOTKIN : That's something you can't do anything11 about?._ ._.12 MR. ABRAMS Exactly .13 MR. PLOTKIN : In the meantime, you have .01 as acceptable14 picocuries per gram . If you take your cesium 137, You've go t15 the background, you know, going all the way from wherever it16 is .2 -- .2 up to 3 .5 . which the order of magnitude is over17 what's accepted . So you're saying the natural background is18 maybe -- I don't know -- 350 times the EPA standards ?19 MR. LUPO: Yes .20 MR. PLOTKIN That means 350 people out of a million can21 get cancer, and that's acceptable ?22 MR. LUPO: It's what's in the background.23 MR. HIRSCH : That background means it came from a nuclear24 fallout . So what you're seeing is cesium. strontium have th e25 residual contamination above EPA's permissible numbers . But

PAGE 9 6

1 soil size , so .46 is wrong . Even if it's right -- let' s

2 assume it's right Look at the top of the range that you'r e3 getting at Boeing 's data .567 . So you are having a number of

4 samples in the Rocketdyne measurements that are above5 anything seen in the background, which you're calling6 "background," and they are well in excess of EPA CERCLA7 limit of the background. So even from your own data, th e8 measurements found in the bum pit is higher than anything

9 seen in the local background and above the EPA's cleanup .

10 Take a look for a moment at plutonium in your own

11 chart. You,-say that the average from the Boeing data of two12 figures is .27, and that the average from local background is13 .02 : in other words . ten times higher than the average14 background you're seeing in plutonium 238 .15 If you go to cesium 137 . at the top of the Boeing16 data is .569 . The top figure seen anywhere in the local17 background from your own chart is .13 . Those measurements18 are four times higher in the bum pit than seen anywhere else19 in the background. Your own datas show the soils found in20 the burn pit is contaminated with radioactivity in excess of21 radiated background .

22 I'd like to read a letter that Your office just sen t23 to DTSC . It stated the soil at this site doesn't need to be24 remediated. and they're calling it off the chart because the25 soil concentrations at the burn pit are similar to those o f

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what's flaky is you're using the national background .Shouldn't you be using the local background'' Secondly .

ou're using the national background from reports publishedin 1987 I presume that data goes back well before that .And I'm sure you know the concentrations from the fallouthave diminished dramatically since the atmospheric testing

stopped because of the weather . So the national backgroun dfigure is inappropriate to use . But what's intriguing is .06

') is wrong right where you have the cesium range. underIli McLaren-Hart . .03 to .06 . That should be in the .2 range .I I MR. LUPO : I'll have to go back and --12 MR. HIRSCH : You have it on your chart correct : right?13 1 have it with me . The actual for cesium is -- the14 top of the range is .19 from the 1993 study . And the top of15 the range is .21 from the -- if you want the '95 percentile .16 its .21 .17 MR. LUPO : Maybe I should premise something .18 On the bottom of the page has the data for th e19 McLaren-Hart study looked at . and we took the selected sites20 that had similar geologic structures and soils . clays --21 MR. HIRCH : So you didn't even use the McLaren-Hart's22 data: you manipulated that and --23 MR. LUPO: We used the samples that had similar soil24 types .25 MR. HIRSCH : They didn't -- they obviously chose a larger

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background soils . Therefore . the soil from the burn pit doesnot need to be licensed for radioactive materials and may bedisposed as appropriated for hazardous materials . Yourletter says none of it is above background . but your ownchart says it's way over background .

f) Let me read one last thing to you which is what

Boeing reported, which you reviewed . They said that thecesium 137 levels were in some instances greater than loca l

9 background concentrations due to a local fallout from the-10 nuclear weapon testing . The concentration of strontium 9 0

11 was somewhat higher than the local background or the12 concentration source --13 MR. HSU : Roger . if I may respond. Can ] ?14 First of all . I want to emphasize what we said in15 that letter is that it's similar to the background range .16 The background range -- if you read that letter . that letter17 says "similar." It does not say within the background range .18 MR. HIRSCH : Four times higher than the background --19 MR. HSU: Let me finish .20 The result basically showed only four to six dat a21 points from those composite samples had that kind of level .22 But the other data points were basically below the MDA level,23 okay? So what I'm getting at is this : Four out of 7 824 samples showed that number . Also there was a larg e25 uncertainty associated with them . And then if you look at

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1 the national level again -- well, were talking about 12 backgrounds . You cannot -- 23 Have we decided what is an acceptable background? 34 Are we going to use the McLaren-Hart data, or are we going to 45 use a new set of background data for Area IV? 56 MR. HIRSCH : If you re going to use the highest 67 concentration level of the United States as background -- 78 MR. HSU: I'm not using that . 89 MR. HIRSCH : That is what you're using . 9

10 MR. HSU: No, were not. 1 011 MR..HIRSCH: The citation you just gave us_ the .1987 1 112 NCRPM "Exposure of the Population in the United States and 1 213 Canada from Natural Background Radiation," that's from a 1 314 fallout decades ago throughout the whole country . You know 1 415 you cannot use as background something that's not -- 1 516 MR. HSU: We're not using it.. we are referencing it . You 1 617 take a look at that table, it shows for comparison purposes. 1 718 and we showed you the graph for comparison reasons . 1 819 MR. HIRSCH: You are using it -- 1 92(1 Na- HSU : We are using it for comparison . 2021 MR. HIRSCH : Right . Exactly . 2 122 MR. HSU: We're not using it to determine things . The 2223 criteria we use is the sitewide release concentration 2 324 criteria which we have proved . 2 425 MR. HIRSCH : Oh. no . 2 5

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people. And we have had discussions on this issue that hav enot been totally resolved yet, okay? And we hope to resolv ethat in the near future .

And secondly, I said earlier the c rite ria we used inreleasing a facility for unrestricted use, again, is referredto 15 millirems, those equivalent limits . Under tha tpremise, even though the soil left on site was less thanthose concentrations, it can be even left on site as residua l

activity based on the decommissioning criteria . However, Idid say earlier people should apply a letter of philosoph yand try to get them down as low as possible . And I believe

Rocketdyne has done that in their process .The third thing you said earlier about the

background . we never said anything that is below backgroun dor was in the background range is not radioactive . Intheory, radioactivity doesn't decay to zero . There's alway sgoing to be some radioactivity . If you go by the explan atio nof half-life rule- you never get zero out of it to star twith . And then we try to use these background data to sho wpeople how the soil concentrations compared to what i sconsidered background in terms of ranges .

When you look at those data for radiochemica lanalysis of strontium. please refer to that table. thatparticular table that Rocketdvne submitted . In there, yo uwill see only four out of 78 samples show that number . the

PAGE 10 0

higher number .4 something .Also look at the uncertainty and look at all the

uncertainty of these numbers used in that table . They areplus or minus almost 100 -percent error -- I mean . onuncertainty . Basically . when you get gown to the MDA level .it cannot be distinguished from background . so you want to --

I MR. HSU : Oh. yes .2 MR. HIRSCH : Let me ask you this then : The letter is not3 accurate then ?4 MR. HSU I'm not saving it's not accurate . It's similar

to it. You can go through all the graphs, first . Look a t6 the graphs first .7 M . HIRSCH : Steve . I want to go back to what you said8 earlier today . that the sitewide criteria which is 100 time s9 more relaxed to EPA-CERCLA requirements . that your release

10 criteria are only to determine whether that the soils ca nI I stay in place . I've asked you repeatedly . What are your12 standards for determining the waste is not radioactive an d13 can go to unlicensed facilities'? The answers appears to come14 back is, if it's not above background . it can go a s15 nonradioactive . It is clearly way over background .16 MR. HSU: Okay . Can I respond now ?̀17 MR. HIRSCH : Please .18 MR. HSU: First to answer that. Column 1 . DOE actually19 should be Rocketdyne, but DOE approved Rocketdyne' s20 proposal . That number -- that column and the next column .21 they were based on different models and different default22 values as the parameter . I want people to understand that .23 That is the risk model EPA came up with, and the number we24 came up with was using the DOE RESRAD -- capitalized ..25 R-E-S-R-A-D -- that's the first thing I want to point out to

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7 you want to be able to understand the fluctuation and look at8 the overall picture of the strontium analysis result . An d9 based on our confirmatory sample result and our review of

,10 their submitted information, we made a determination that theI I soil concentration in this upper pond and this area is wel l12 within the release criteria . That is the final -- that is13 the basis that we used to make that determination .14 I believe -- I believe I've answered that, question15 unless you have further questions .16 MR. HIRSCH : I just think you've got it absolutel y17 wrong . And I think we have to do something before that stuff

18 goes out .19 MR. HSU: I'm wrong in what?20 MR. HIRSCH : I have the strontium data in front of me .21 and there are far more samples than four over the top --22 MR. HSU: I said four to six .23 MR. HIRSCH: You're still wrong about that . Its way24 over that . It's way over that .25 Secondly, this is done through a rigorous

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SHEET 14 FAGE lc 'I statistical method, which you're not using . You're supposed2 to take 95 percent -- even that is much larger than yo u3 should use -- but you're way over 95 percentile on many of4 these samples .5 Lastly, you're mixing up the questions . And you re6 supposed to work with EPA because the law requires this7 facility to be cleaned up to the CERCLA standards .8 MR. HSU: I do not believe that's the case at thi s9 point . I believe that DHS maintains the jurisdiction for

10 that release until a decision is made .11 MR. HIRSCH : The decision is made by whom?12 MR. HSU: Either through the CERCLA legal review or13 maybe -- it may be some other process . I don't know . What14 I'm telling you now is that we do maintain tha t15 jurisdiction . And even DOE. they have to ask us for16 concurrence not -- they have their jurisdiction . but they17 have to ask us for our concurrence . We try very hard to make18 sure things don't get out of there . and we don't releas e19 sites that don't meet any criteria .20 MR. HIRSCH : You do?21 MR. HSU: We do not release any sites that don't meet the22 criteria .23 MR. HIRSCH : Let me just summarize it again what you just24 told us because were going around in a circle . And I'd ask25 the legislative people and other agencies because you're like

to have an illegal act

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1 end of this week or the beginning of next week . CERCLA does2 not define what is radioactive waste and what is not3 radioactive . That's a decision these guys make . Fro m4 background up to 15 millirems , they can release it. from what5 1 heard Steve to say .6 MR. HSU : I'm absolutely not -- I w ant to make sure you7 underst an d I'm not saying that . I am saying if the residual8 activity is less th an the concentration that corresponds t o9 15 millirems . you can even leave it on site without cleaning

10 it up.11 MR. HI RSCH : But you can' t ship it to Buttonwillow or12 Kettleman CAN, --13 MR. HSU : I w ant to address that issue you raised14 earlier .

15 The Department of Health Serv ices has neve r16 authorized any such shipment of radioactive shipment from17 New York State to Buttonwillow . The Buttonwillow case is18 still under investigation . I do not w ant to discuss that.19 and I'm not privileged to discuss that because there are20 legal reasons behind it . And again. DHS has never . ever21 autho rized that . And there is a DTSC license . whic h22 basically autho ri zed up to a cert ain qu antity of know n23 material, at Buttonwillow or Buttonwillow site . But were24 not here to discuss Buttonwillow . If you want me to cite the25 letter that we wrote to whatever the company is to tell the m

1 02

2 There was a big scandal erupted when your agencypermitted radioactive waste from a facility . the DOE facility

4 in Ne" York State. to be shipped to the Button;pillow facilityhere in California . which is not licensed to take radioactiv e

0 waste. Your agency . a day after the shipment came in .realized it was illegal -- the stuff never should have gone

8 there .

9 We're about to have a large amount of radioactiv e10 waste from the burn pit . from chemicals illegally burned forI I a ]on() time . shipped to a sister facility at Kettleman Cit y12 which is not licensed to take radioactive waste . You've just13 shown us through your own data -- and I have in front of me14 the Rocketdvne data -- that demonstrates that soil isI5 contaminated well in excess of the background level . both the16 top range of the background of 95 percentile . And it is i n17 fact also clear from the data that you have released th e18 site, despite the fact the contamination is above EPA CERCL A19 guidance . which CERCLA is expressly clear on the law DOE must20 meet . So we've got two sets of problems .21 MR. HSU: Is that settled'' I don't understand that .22 MR. KELLY : Let me add my two cents' worth on that .23 The CERCLA standards apply to what DOE could leave24 behind at the site . The CERCLA levels -- and I can clarify25 this for you in a letter . I can get the letter to you by the

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I that they have done an illegal shipment of the waste . there2 is a letter . It's a public record .3 M. HIRSCH : You're about to permit an illegal shipment

to Kettleman City .MR. HSU Here I also want to respond to that question

There is no national standard at this point in timeto say basically what's di minimus . what's below th e

8 regulatory concern . There's no national standards at thi s9 point right now . And I hope EPA or NRC or someone comes up

'10 with one . But what I'm getting here is. the concentration w eII have here is similar to that of the background and much less12 than the sitewide release crite ri a . okay? If we go by th e13 sitewide release crite ri a . then that' s the basis fo r- your --14 for a determination .15 Again. I don't want to drag on with this, but I want16 to mention to you there is something that is calle d17 negligeable individual dose . I believe in Rocketdvne's18 proposal . they have provided those assessments which19 basically indicated that the resulting dose will b e20 somewhere -- somewhat equivalent to I millirem . okay? That's21 my recollection. I cannot guarantee whether my recollection22 is 100 percent correct. But if you can go back to tha t23 particular document, you can see that . So what I'm getting24 here is if you use th e modeling that was used to develop the25 25-millirem rule, and you plug in those numbers. the

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PAGE 10 61 concentrations that we see in the soil, you probably would2 get your answer. That is probably close to a I-millire m3 range .4 So what I'm trying to get at is there is no nationa l5 standard for determining what can be regarded as -- can be6 regarded as nonradioactive. But there is a critical point7 here that if it does not impose a significant health hazard,8 then a decision should be made -- I use the word "should,"9 okay? We hope were not subjecting people and th e

10 environment to this unnecessary dose, and we hav e11 demonstrated that's the case . So I hope EPA comes up with

12 that number . There is no such number in any regulation .13 MR. HIRSCH : Let me just summarize what you just told

14 us.15 You're saying there's no legal authority for you t o16 permit waste you know to be contaminated but you believe to17 be di minimus to go to unlicensed landfills?18 MR. HSU: We have legal authority .19 MR . HIRSCH: But there is no BRC di minimus?2)) MR. HSU: Nationally . but --21 MR. HIRSCH : Not in the state?22 MR. HSU: But based on our analysis . we have made a23 determination .24 MR. HIRSCH : That the stuff can be left in place -- if I25 understand what you're telling me . you're using that standard

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10 6

to determine what c an go to a - -

MR. HSU : I'm not telling you that . I'm telling you it' s

3 negligeable . ho-v\ insignificant . 1 3MR. HIRSCH : To you . it's insignificant : to the person 4

6who may get cancer . its not .

My point is . you have no legal authority to permit t ,7 materials above background to go off site You kno\y that to8 be true'?

8

9 MR. HSU : I don't know . I will get back to you . I will 9I)) go back and confer with the legal staff and come back and 10I I tell you whether we have that authority or not . But I'm not l I12 sure . I'm not in licensing . I don't do -- 1 2

13 MR . HI RSCH: The shipment is about to go out . but you 1 3

14 don't know what the standard is . and you don' t know what's 1 4

15 legal . and you don' t know the ship is about to leave? 1 5

16 MR. HSU : I believe DHS has the authority granted by the 1 6

17 Health and Safety Code to control the radioactive waste so 17

18 that they would not be hazardous to the public health and 1 8

19 environment . We do have that authority . 1 920 MR . HI RSCH : You don't have autho ri ty to permit 20

21 radioactive material to go to an unlicensed facility : 2 122 correct? 2223 MR . HSU : No. we don't . We never do that. 2324 MR. HI RSCH : You're about to . 2425 MR . HSU: I'm not sure . I don't believe so . 25

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PAGE 1081 MR. PLOTKIN : Just a quick comment .2 You said there aren t standards and so forth for You3 to go by, et cetera . And let's suppose that, in the end,4 it's decided that EPA really has a proper view of things, and5 the one-in-a-million risk is the proper standard to abide

6 by. And if that is the case, then all the material out of7 that bum pit is radioactive by that standard : isn't that8 so?9 MR. HSU: No. Our regulations don't define what's

10 radioactive material and what's not.11 MR. PLOTKIN : You have a risk factor of one in a12 million ?13 MR. HSU: Uh-huh .14 MR. PLOTKIN : Given the risk factor of one in a million .15 it allows you to have .01 picocuries per gram of cesium 137 .

16 If you go over to see what the material is in the bum pit .17 it's well in excess of that . Consequently . if your -- if EPA18 standards are or the things that eventually prevail . thi s19 thing . then Steve . by any criteria, cannot allow that21) material to be moved off the site : isn't that so?21 MR. HSU: The EPA standards supersede if there is one .22 MR. PLOTKIN : But you say those standards --23 MR. HSU: You're still missing the risk range . and it' s

24 probably not emphasized enough . And its risk range runs from

25 ten to minus six up to ten to minus four for the upper end .

That's intended to -- for materials intended to stay on

site . And before materials get shipped off site . they do

need to comply with the rules. and I believe that. in fact .

is the law that DHS operates under .

MR . 1-HRSCH : Let's me be clear about this . We have their

measurements of contamination which showed that the soil isabove our cleanup standards and . therefore . cannot -- need s

to be remediated . So you've got contamination outside of theburn pit at these levels . It violates the CERCLA guidance atpresent . That's the terms of remediation on site .

The second issue is they're about to move a lot ofsoil to an unlicensed facility . If you accept theargument and you accept the risk analysis, You can ship themto an unlicensed facility . which you're not saying but youthought that's what the rule was . If what he's saying i scorrect, what happened at Buttonwillow would have been legalbecause the Army Corps cleaned up the facility to their sitecleanup standard . and they shipped it off to an unlicensed

facility . His agency says that' s illegal .

MR. PLOTKIN : Can we look at the numbers we got for

local background for cesium 137? The local background forcesium you're using is .I 1 --

MR. HIRSCH : That's wrong . McLaren-Hart, there's your

range . There's Your 95 percentile .The same thing here . These are wrong . And that' s

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I the source he gets --

2 MR. HSU : Roger. didn't you explain that there was a3 review --4 MR. PLOTKIN : You gave me only two minutes to review it .5 If I had more time, we could have had pinned you further.6 MR. HSU : Roger, did you say earlier that there was a7 determination of those background locations because of soil8 types?9 MR. HI RSCH : I have a larger number of soil samples .

10 You're using the smaller subset . The range can't get11 larger . . The .12 and . 21 -- .16, .it' s a typo . If the highest12 is .21 . you can't get -- this is as twice as high .l3 MR. LUPO : I'll have to -- the . 16 is from the Boeing14 report . And I don' t know where all those numbers came from .15 1 know where all the McLaren-Hart numbers came from. We do16 have some other numbers that c an factor in but nowhere near17 the numbers Boeing used in their --18 MR. HIRSCH : The highest we have is . 2 from McLaren-Hart19 from all of the locations . Take a look at the measurement20 from Boeing --21 MR. LUDO : We used cesium or --22 MR. HIRSCH : Let's use cesium . .229 . that' s above-. .567 .23 that' s above : . 209 . that's right at the top : that's outside24 of one of the areas . .016 . .097 above. . 297 above . all of25 those are above or top of the range and above the

PAGE 11 2I signific ant topic .2 What is the will of the group at this point' ?3 UNIDENTIFIED SPEAKER : We can't wait till the crap goes4 off the mountain for you guys to come back --

5 MR. CAIN : I'm speaking to the workgroup , please .

6 MR. HIRSCH : Clearly, there has to be a message from this

7 workgroup . We're strongly recommending that the government8 agencies take cogniz ance of the fact that they may be on th e

9 verge of doing something grossly illegal, an d its going to10 come back on them until proper st andards are agreed to and

. 11 further evaluation takes place .12 MS. BATARSEH : I think what we heard tonight is . D an . is13 saying these levels are way above background , and Steve said14 these levels are similar to background . the risk i s15 insignificant . There are really two messages being sent16 tonight . I think , as regulatory agencies . we really should17 go back and look at this . look at the risk and really decide18 what needs to be done . But one point I w ant to make is . as19 we are going back and making sure we 're looking carefully at20 the Boeing numbers because we don't have any problem with DHS21 numbers in the background .22 As we go back and take another look . I think it s23 impo rtant to remember that the reason why this measure was24 implemented was because we found there is a threat to the25 public health and environment from this impoundment . It' s

11 0

I vu-percentile range . The stuff is radioactive . Your agency2 can't permit it to move . And if you weren't concerned about3 it . you wouldn't have sent a letter two weeks ago asking i f4 it's radioactive --

MR . LUPO At the risk of being boo'd off the podium --r MR. HIRSCH Hold on .

All right . Roger . DHS went out and collectedS confirmations . You guys vent out and collected your own9 data. right ?

10 MR. LUDO : Right .I 1 MR. HIRSCH : You went to these areas . you looked at the12 data -- we already talked about the strontium data -- Stev e13 mentioned the MDA levels were fairly high . the uncertainty14 was as much as 100 percent for the Boeing data . You guys15 event out and collected your own data . For strontium 90 . you16 got an average of .04 .17 MR. LUDO : Seven samples in seven locations -- six or18 seven locations .19 MR. HIRSCH : What is the risk from .04?211 MR. LUPO : Four times -- four times the CERCLA guidance .21 MR. HIRSCH : If you use that .04 to -- '22 MR. ABRAMS : .04 compares to --23 MR. LUPO : There's four times -- four times minus six .24 MR. CAIN : At this point, I'm going to interject. The25 meeting is over the scheduled time. This is clearly a very

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I really hard to go back . and think of what Gerard said about2 PCB's . dioxins. mercuries in this impoundment . They need to3 move this to a licensed facility . I don't want to do4 anything illegal . We don't want to do that . so we do have to

check into this . But as we do this . I think it's importan t

6 to remember. as Dawn said . she lives down this hill . and we7 do have concerns about not moving forward with this. and wr

want to do it legally, and we want do the right thing . So I

9 guess that's where we need to leave it .10 MR. HIRSCH : I'm not suggesting not being moved off the11 site. but I think it should go to a licensed facility .

12 Kettleman is not licensed to take mixed waste .

13 1 want to make a formal suggestion . I think that14 your agency . just from the standpoint of politics of this .I 5 would like to avoid a repetition of Buttonwillow where the16 stuff went and afterwards you determined that it shouldn't

17 have . I, therefore . would suggest that there'd be a18 conference call established in the very near future befor e19 any of this can move with Ed Bailey, the head of DHS . who's20 deeply involved in the Buttonwillow matter and has bee n21 involved in this issue here . and with Ed Lowery [phonetic] .22 the head of your department who has also been involved in the

23 Buttonwillow fiasco and this issue . Senator Boxer's involved24 in that matter . Any other legislative offices that want to25 get involved. EPA. if you will join us . Let's get a

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1 conference call . and let's get this thing resolved before I

2 this soil moves off to where it should not go . 2

3 What is the legal standard that determines what is 34 mixed waste or not or whether it c an go to a facility it can 4

5 take radioactive waste or not. and you aren't sure -- 5

6 MR . HSU : I'm what? 67 MR . HI RSCH : You're not sure ; you told us that . 7

8 MR . HSU : I told you what decisions we have made an d the 89 reasons why we made those decisions . 9

10 And also I will mention that if the analysis 1 011 indicates there is insignific ant dose -- 1 1

12 MR. HI RSCH : That' s not your stan dard. 1 2

13 What my suggestion is to have a conference call . We 1 3

14 aren 't going to resolve it here . I think we have to do it 1 415 soon because it's going to blow up in everyone's face 1 516 otherwise . 1 6

17 MR. KELLY : If we actually do a conference call in a 1 7

18 relatively short time frame -- definitely there ' s things,1 8

19 that are unresolved here . We need time to set it up now . Is1 9

20 the easiest way to do it -- we have to see when Lowery an d2 0

21 Bailey are available .2 1

22 Bailey is currently out of the countr yHSU : Mr an dMR .. . 2 223 he won 't be back until May 29th . or the first day he will be

2 324 He's attending the ERPA meetin gback is May 29th ..

2 425 HIRSCH : And can you arrange to have him be on aMR. 2 5

11 4

conference call . Or do you have to wait till the 29th tofind out when he's available? '?

4

MR . HSU : I can certainly to to see if the person acting

in his position during his absence . what suggestion she would 4provide . I cannot answer that question at this time .

MR . HIRSCH : Is Laura still here'' 6

8

M. HSU : Definitely . we want to be a pan ol'thatconference call . 8

9 MR . HI RSCH : Steve. could you call his secretary to find 9

110 out about his availability . I'm trying to find out if he's 1 0I I available on the 30th or as soon as it can be a fterwards . I I12 MR . HSU : Right . He will be back in the office on the 1 2

13 30th . 1 3

14 MR . HI RSCH : It'd be more expeditious if you'd contact 1 415 the appointment secretary beforehand and try to get a 1 516 tentative date on his calendar . 1 617 MR . HSU : I will certainly in, . 1 718 MR . KELLY : ETSC will do the same for Mr . Lowery . 1 819 MR . HIRSCH : Any chance any of this will move before that 1 920 time? I see the lovely smile on your face . Gerard. can any 20

21 of this stuff move before the conference call`? - 2 1

22 MR . ABRAMS : I'm not sure . 22

23 MR . HI RSCH : I would strongly suggest that none of it 23

24 moves before any of this gets resolved . 2425 What' s this panel all about? All the people from 25

PAGE 11 6

the community is here, and yotire saying you can't be sureyou can stop it-from moving? I don't understand, you know,what's the problem . All you have to do is to tell the trucksnot to come in wherever the trucks come from hauling it off.This shouldn't be a big problem .

MS . JOHNSON : Errors have been made in the past . I'd

urge you to error on the side of caution . This is putting

the community at risk .MR . CAIN: ]'think Anna has clearly articulated some

concerns about the removal of the soil from FSDS . A

conference call will be made . I'm quite confident DTSC is

very familiar with your concerns . And we'll be in contact

with Mr. Hirsch on any scheduling changes to the removal of

the soil .MR. HI RSCH : Let me just say that I'm going to act on the

assumption what you just said nothing is going to move before

we have this conference call . If you discover that's the not

going to be the case . I want to know immediately because I

think we need not wait for Ed to come back . but I'd ask

Senator Boxer's office to be involved . Director of DHS to be

on that call . I don't think we can wait until it's too

late . If there's enough time for us to wait for Mr . Bailey

to return, fine . If there's not enough time . we'll go over

his head to the director of the department . okay? We have

the director --

1 1 6

MR. HSU I will definitely bring the message back and

see what kind of arrangement we can make with the -- what's

the name' 'MR. CAIN I am out of the office for next week . but

if --MR . KELLY : Who should we --

MR . CAIN: We'll start contacting tomorroN\ .I'm calling the meeting closed . I'm sure the

community members would like to ask several questions on this

topic . If you'd like to fill out one of the three-by-fiv e

cards . we will make sure you get an answer from the public

agency .Just as a reminder. our next official meeting is on

September 13th . and you'll all be sent notifications of the

meeting through the mail .

I want to thank you very much for attending and hop eto see you at our next meeting . Thank you .

(Proceedings concluded at 10 :20 p .m . )

11 5

Atkinson -Baker,Inc

11 7

1-800 -288-3376

HDMSPOOI34604

00 - a rt iculated

0 250 (111 :2227 12193 :6 96 :12

00 [3) 10 :3 31 :16,16 297 111110 :2 401 [5131 :21 32 :3 93 :20 94 :13 108 : 29th 131114 :23,24 116 : 1

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330 [111 :2 2I350 12194 :18,20

1 15110 :3 31 :23 37 :22 99 :18 105 : 365 [1165 :1 120 399 [1154 : 11,500 [1] 62 : 91-millirem [ 7] 106 :210,000 [1180 :2410:00 (212 :25 3 :110:20 111117 :1 9100 13199 : 8 105 :22 111 :14100-percent [ 7] 101 :410981 [211 :13,2410th [ 7168 :911 111109 :2211th [317 :5,5,712 15132 : 14,19 45 :17 76 :19 110 :11120 [1145 : 413 (2157 :18 96 :1 7137 16193 :20 94 : 14 96 :15 97 :8 108 :15 109 :2 113th (317 :9,12 117 :1415 [17] 7 :20 20 :20,22,24,25 21 :2 50 :25 56 :25 68 :18 73 :24 74 :19 85 :16,24 87 :18 100 :6 104 :4,915-millirem [ 7] 34 :1 616 [411 :122:1 110 :11,1316th [712 :1 318 [1] 76 :1919 [1195 :141959 [ 1161 :11960s [ 1 ) 59 :181964 [1157 :231969 (2159 :9,131977 [2] 86 :19,201987 [2195 :4 98 :11198811159 : 61990 (4156 :23 57 :3,5,1 51991 (3( 61 :3 63 :14 80 :2 31992 (2156 :23 57 : 51993 (3159 :6 86 :12 95 :1 41995 [1159 : 71997 (3116 :7 34 :24 68 : 91999 (2131 :18 56 :1 91st 13114 :11 31 :18 58 :22

22 16137 :23,23 94 :16,16 95 :10 110 :

1 820 (3) 81 : 13 90 :8,920-minute [7] 3 :232000 [3] 1 :12 2 :1,132001 [2132 :15,19209 (11110 :2 321 15193 :8 96 :15,16 110 :11,1222 [1173 :1 6229 [1] 110 :2223 [2190 :8, 9230 [3187 : 23,25 88 :5232 [2187 :15,23237 [1187 :1 5238 [4188 : 1,2,4 96 :1424 [2112 : 7 65 :1 125 13120 :24 51 :6 53 :525-millirem 12153 :15 105 :2525-millirems -per-year [ 1151 :5

9A032F 1

4 [11101 : 140 11117 : 20 88 :9,18,20,25 89 :14 90 :13,22 91 :18 92 :4,8

4059 [1] 10 :1645 [1184 :2546 11196 :147-millimeter [1139 :1 74th [117 :4

55 12187 :13 93 :9551-7300 [111 :23567 12196 :3 110 :22569 ]1196 :1 659 19110 :19,22 25 :22 31 :20 32 :236 :7,8 ,10 44 :5

86 11157 :2 36 :30 1311 :12 2 :2,25

77 [3166 :1 57 :24 74 :1977 [1] 86 :2 278 13187 : 13 97:23 100 :25

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97 11186 :219a032f1 [111 :25

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abnormality ( 1) 51 :2 1above [24130 :7 34 :15 , 15 57 :4 61 :15 80 :19 81 :3,13 82 :9 94 :25 96 :4,9 97 :4 99 :14 103 : 18 107 : 7 109 :7110 :22,23,24,24,25,25 112 :13

abrams [45] 5 :20 , 20 7 :2 20 :16 21 :10 42 :14 , 19 60 :16 72 :18 73 : 11,15,20,23 74 :1,4,10 , 13,18 , 23 75 :1,6,15,20 76 : 11,16 77 :2 , 9 78 :1,3,1980 :22 81 :8,16 83 :18,20 84:9,16,21 88 :19 90 :1 91 : 2 94 :7 , 12 111 :22 115 :2 2

absence [ 7] 115 :4absolute [ 1140 : 7

Atkinson -Baker,Inc

absolutely 121101 : 16 104 :6absorbed 1 1129 :2 ,

accept 14123 :5,6 109 :12,13acceptable [12122 :9 23 :7,7 29 :650 :25 51 :10 93 :21 94 :1,4,13,2198 : 3

accepted [7194 :17access [7124 :18accident [1l 14 :13accomplished (7136 :1 3according [2157 :13,15accurate 13117 :19 99 :3,4acknowledge 11149 :22across (1160 :3act 15167 :23,24,25 103 :1 116 :15acting [212 :15 115 :3action 1916 :16 10 : 12 30 :21 47 :11,14,18 50 :2 55:7 61 : 3

actions (213 :13 44 :1 7activities [5] 12 :6 62 :11 88 :2,3 89 :

1 2activity (9) 40 :25 52 :1 62 :19 63 :1467 :21 80 :23 89 :15 100 :9 104 :8actual ( 1195 :1 3actually (9] 11 :1 68 :6 78 :3 81 :2083 :20,21 84 : 21 99 :18 114 :17

add 1 3114 : 4 43 :24 103 :22added [218 :1 75 : 8addition [2] 24 :2,7additional [718 :12,14,23 79 :7,1480 :2,3

additions [ 716 :1 3address [7) 35 :8 37:4,20 66 :23 68 :3,11 104 :1 3

adequate 13116 :21 18 :13 69 :14adhere [2] 47 :4 54 :2 5adjust [117 :13administrative (1( 3 :11adopbd [7167 :21adulthood [1159 :21advance [2] 31 :2 44 :17affect [ 2143 :9 79 :21affiliated [1)5 :13affiliation [2158 :3, 3afterwards [3168 :4 113 : 16 115 :11agencies 1817 :19 15 :15 34 :6 53 :883 :13 102 :25 112 :8,1 6

agency 11813 :17 5 :14 42 : 9 55 :1056 :14,18 57 :13 59 : 11 60 :14 70 :1472 :15 80 : 13 103 :2,6 109 : 19 111 :1113 :14 117 :1 2

agency 's [1177 :4agenda [2012 :23 3 :4,9,13,13,15,156 :11,12,13 7 :18 22 :12 30 :24 37 :22 47 :16 49 :20 54 : 9 55 :16 56 :160 :1 3

aggressive [2150 :17 52 :18ago 19110 :7 15 :22 25 :6 27 :1 62 :887 :2,7 98 :14 111 : 3

agree [2] 11 :10 41 : 1agreed 1513 :6,6 16 :15 27 :18 112 :

1 0agreement ( 8110 :13 17 :23 35 :143 :3 53 :17,18 79 : 11 80 :4

agricultural (2159 :10,1 9ahead 1515 :4 12 : 18 19 :13 72 :1 80 :8

airborne 11140 :17alamos [2115 :1 55 :22allotted [217 :20 60 :12allow [71108 :19allowed (2115 :10 43 :11allows ( 11108 :1 5almost [3121 :9 90 :9 101 :4already [10131 :12 35 : 18 44 :13 45 :

11 46 :548:1858:18 62 :1673:12111 :1 2

already -written [1156 :23although [1)4 :16ambitious [213 :10,15amidst [1110 : 6among [413 :18 56 :15 57 :7 58 :17amount 15149 :2 53 :2 60 :6 65 :12103 : 9

amy 1211 :13,24analogy 12113 :10 15 :19analysis [9139 :6 85 :8,17,22 100 :23 101 :8 106 :22 109 :13 114 :10

analyze [1189 :1 0and/or (1)15 :10antlers [7] 49 :24angeles 13114 :25 58 :13 67 :6animal [2138 :3,1 8anna [7)116 :9announcements [212 :19 3 :12another [15] 8 :25 11 :3 45 :25 54 :555 :10 64 :8,20 66 :17 69 :6 71 :9 73 :5 83 :11 86 :9 94 :7 112:22answer 19130 :16 35 :9 42 :3 90 :2192:12 99 : 18 106 :2 115 :5 117 :11answered 13130 :19,20 101 :14answers [ 21 56 :11 99 :13antinuclear (1( 53 : 7anybody [417 :6 13 :6 21 :21 55 :7anybody's [1167 :1 6anyhow [1) 43 :22anyway [2154 :2 83 :17apart (1) 43 :15apologize 13131 :7,13f9apparatus (7139 :21apparently [2125 :7 82 :7appears [1199:13apple [1147 :9applicability [1143 :4applied [1] 71 :6applies [1]49 :1 4apply [3149 :19 100 :10 103:23appointment (1) 115 :15appreciate [712 :22 23 :23 26 :2030 :12,16 46 :2 54 :11

appreciated [413 :25 4 :2,22 55 :1approach [7150 :17appropriate [7122 :11appropriated [7197 :3approval [513 :13 6 :12,14 46 :10,24

approve [7146 :1 1approved (3110 :12 63 :22 99 :19approximately [2) 4 :10 32 :19april [1163 :2 5area [29115 :9 18 :11,24 24 :22 25 :327 :25 39 :2,15 40 :2,14 41 :5,5 43 :1251:1452 :21 56 :2257 :1861 :20,25 62 :19,24 63 :19 64 :4 79 :14 80 :25 86 :11 88 :18 98 :5 101 :11

areas (11119 :11 27 :15 29 :12 45 :763 :4,5,12 86 :10 88 :16 110 :24 111 :1 1

aren 't [6] 74 :14,16 83 :13 108.2114 :5,1 4

argument [3171 :12 90 :7 109 :13arid 11183 :22army 12156 :9 109 :1 7around 11017 :24 16 :4 18 :6 63 :1964 :5 69 :24 89 :4,24 91 :20 102 :24

arrange 12117 :5 114 :25arranged [213:2 16 :16arrangement [11117 :2a rticles [1158 :1 9articulated [7] 116 : 9

1-800-288-3376

HDMSPOO134605

asbestos - ches t

asbestos (10124 :15 42 :7,12,19,21,23 43 :14 48 :7,20,21assembly [1) 5 :10asse rt ing (1) 82: 8assessment [13] 10 :24 13 :2,20,2122,25 15 :16 25 :15,24 26 :12 30 :955 :17,20assessments [11105 :18assessments /cis [1) 12 :14assist [1] 3 : 1associated [3111 :17 42 :24 97 :25association [1) 5 :23assume 14128 :19 41 :5 50 :23 96 :2assumed (1192 : 4assumes [1] 32 :4assuming [1]40 :21assumption [3128 :18 41 :7 116 :1 6assure 1112 :18atkinson-baker (1)1 :21atmospheric [1195 :6atomic (1191 :1 1atsdr [2)57 :16 59 :3attacks [114 :23attend [1159 :2 5attending [21114 :24 117 :16attention [1] 56 :12attorneys [1149 :25audience [1413 :21,24,25 4 :20 5 :627 :4 54 :12 55 :1 70 :5 82 :15 84 :1285 :11 91 :16 92 :2 0august 1816 :20 .24 7 :1 .9 32 :5 62 :22 63 :8,20authority [71106 :15 .18 107 :6,11 .16,19,20

authorized [31104 :16,21,22availability 1217 :14 115 :10available [1314 :10,11 9 :18 10 :1719:9 33 :23,25 36 :19 87 :16,25 114 :21 115 :2,1 1average [6190 :7 .9 96 :11 .12,13111 :1 6

avoid [2137 :7 113 :15awake [1 ] 58 :1 5aware 15116:16 25 :21 27 :4 59 :1 .8away [4) 14 :25 38 :24 39 :2 61 :21aye 1117 :10

3b-e-t-h [1)47 :9b-o -e -i-n -g [ 1) 34 : 1back [45) 15 :8 16 :7,18 21 :5 34 :2135 :5,12 37 :3 43 :20 45 : 11 60 :2 65 :20 71 :14 72 :3,5,18 73 :2,11 75 :576 :2,3 77 :10 85 :24 87 :24 91 :1393 :14 95 :4,11 99 :7,14 105 :22 107 :9,10,10 112 :4,10,17,19,22 113 :1114 :23, 24 115 : 12 116 :19 117 :1

back -down [1] 70 :1 4backfill [14 ] 63 :9,20,22 64 :17,19,25 65 :13 66 : 2,20 68 :17,22 69 :1,11 73 :1 7

background [ 107] 29 : 4 30 :8 38 :5,14,20,23 39 :9,11,23 40 :1,6,7,7, 10,11 41 :4,5,9,9,10,13, 21,22 42 :1 58 :4 60 :17 80 :19,22 81 :3,13 82 :9 87 :11,12,23 88 :7,10 ,11,17,23 89 :3,22,23 90 :3,5,6,9,10,12,13,17,18,19,23 93 :5,5,12 94:9,15,17,22,23 95 :1,2,3,7 96 :5,6,7,9,12,14,17,19,2197 :1,4,5,9,1 .1,15,16,17,18 98 :3,5,7,13,15 99 :14,15 100 :14,14,15,19,21 101 : 6 103 :15,16 104 : 4 105 :11107 :7 109 :21,21 110 :7 112 :13,14,2 1

backgrounds [ 1) 98 :2

9A032F1backing [1] 71 :1 8bailey [4] 113 :19 114 : 21,22 116 :22

balance [ 1] 12 :1 6barbara 1416 :22 14 :13 22:24 70 :8barometers [1) 21 : 3barrier [ 1l 66 :19base (2161 :15 66 : 4based 11517 :14 14 :2 19 :8 21 :1 49 :13 58 :2 62 :11 68:6 85 :8,13 86 :599 :21 100 : 9 101 :9 106 :22

basically 1 14127 :5 38 :5 ,13,19 71 :372 :1 86 :16,21 97 :20,22 101 :5 104 :22 105 :7,1 9basis 13153 :13 101 :13 105 :13batarseh (5) 5 :16 .16 6 :23 79 :6112 :1 2

became [1147 :15become [1170 :1 9bedrock 122162 :15 63 :1, 4 ,10,10,15 64 :5 , 6 67 :2 68 :13,16 69 :8,1570 :22 72:6,25 77 :12,16, 18 79 :18,21 86 :1 7

bedrooms [1] 13 :7befo rehand [ 1] 115 :15began (2131 :18 62 : 6begin 1812 :4,17 3 :11 11 :13,20 12 :3 31 :14 62 :22beginning [ 41 15 :6 , 12 62 :18 104 :1begins (3131 :17,23 83 :25behind [4161 :10 78 :10 103 :24104 :20

behold [1115 :2 3believe (2718 :13 13 :10 27 :19 28 :1,2 29 :25 34:3 35 :21 38 :24 45 :2149 :1 51 :25 71 :6 77 :3 80 :9 86 :13,25 100 :11 101 :14,14 102 :8,9 105 :17 106 : 16 107 :16,25 109 :3

below 16129 :4 85 :20 93 :9 97 :22100 :14 106 : 7

beneath [2165 :4 69 : 8best [ 5) 2 :12 46 : 6 70 :13 78 :20 84 :

1 6beta [ 2179 :9 91 :14beth [1147 : 6better [ 6) 18 :19 48 :19 61 :23 74 :2479:23 84 :1 9between [5113 :12 21 :8 .19 22 :2 53:

1 6big 1517 :2 12 :25 36 :20 103 :2 116 :5

biggest [1] 79 :19bill (1) 56 :15bins (2127 :9,10bio-accumulation [1] 93 : 2bit 18115 :9 21 :16 27 :1 51 :11 61 :2366 :2 71 :13 72 :1 3

blackhawk ( 1)60 :2blank [3139 :4,5,20blended 12157 :24 59 :14blocks [U 24 : 1blow [1] 114 :15blue [1] 88 :1 3board 1513 :24 66 :11 67 :7 68 :2076 : 2boeing,[ 20] 16 :10 27 :22 34 :1,4 36 :23 44 :8 51 :1 63 :24 71 : 6 78 :11 83 :11 87 :12 96 :11,15 97 :7 110 :13,17,20 111 :14 112:20

boeing 's [1196 :3boeing-rocketdyne [3] 1 :2 2 :145 : 3bold [1] 30 :23boo'd [1)111 :5book [1) 92 :13

books [1) 92 :1 7borrowed [3174 :4 75 :1 84 :3both 12125 :19 103 :15bottom [3113 :8 57 :1 95 :18boulevard [2] 1 :22 60 :1box [1] 58 :25boxer (1) 70 : 8boxer ' s 121113 :23 116 :20bradley 12123 :14 24:25branch [4] 6 :3,6 34 :14 37 :25brand (1) 1 :22brc [1] 106 :1 9break 1512 :21 3 :22 23 :22 54 :10,16bridge 11) 5 :1 8briefly [1144 : 2bring 1816 :16,20 56 :2,3,12 86 :3 92 :17 117 : 1broad 13112 :15 46 :3 47 :14broke [1) 43 :1 3broken [1121 :12brought [1] 55 :7brush (1) 12 :15buck [1183 :14budgeta ry (1] 12 :1 2building 15117 :18 8 :15,25 9 :9 10 :16,16,19, 22 12 :7 13 :6 19 :17 25 :22 31 :20 32 :2,14,19 33 :22,24 34:1,2,7,11,16 35 :13,17,25 36 :1,5,6,7,8,9,10,17,22,25 37 :5,7 38 :8,25 40 :18 41 :6,12 42 :23 43 :24 44 :5,6 45 :1749 :1451:2359 :1 7

buildings [3419 :10 19 :3,14,24 20 :4,5,5 21 :12,14 22 : 6,19 25 :17 28 :23 32 :10,18,21 33 : 5 36 :4 38 :1 42 :20 44 :3,9,12,13 46 :2,6,10,13,19,21,2246 :548:449 :1 3bulldog [2152 :21 53 :2bunch 12119 :16 71 :22buried [1) 46 : 9burn [26110 :8 29 :17,24 54 :10 60 :14,17 61 :9,18 66 :25 70 :15,16 78 :4 80 :10 82 :24 86:10 88 :15 90 :2596 :8,18 ,20,25 97 :1 103 :10 108 :7 .16 109: 9

burned [2170 :18 103 :10bu rt [1] 59 : 4business [1] 16 :24buffo nwi l low 1 111 103 :4 104 :11,17,17,23,23,24109 :16 113 :15,20,2 3

buy [1175 :17buyer [1] 42 :22bypassed [ 1] 82 : 8

C

Atkinson-Baker,Inc

cain [6212 :4,5 5 :5,12,24,24 .6 :11 7 :4,7,18 8 :6,19,21,23 9 :3,8,24 12 :19,21 17 : 9 19 :19 21 :15 22 :14 30 :19,21 36 :1237 :12,1441 :1743:2346 :23 47 :16,20,22 50 :9 52 :23 53 :14 54 :7,15 55 :23 56 :1,5 60 :11 70 :1,9 75 :19 80 :6 82 : 14,19 83 :19 84 :12,19,23 85 :6 92 :16,18,22 111 :24112 :5 116 :9 117 :4, 7

calculated (1] 51 :6calendar [1] 115 :16calendars [1] 6 :2 0california 11711 :12 2 :1 5 :5,24 34 :12,19 35 : 14 53 :19 56 :20 57 :4 66 :13 67 :8 ,25 76 : 1 83 :4,22 103 :5

call 1 1817 :25 15:4 35 :8 46 :13 81 :4,16,17 113 : 18 114 :1,13,17 115 :1,8,9,21 116 :11,17,2 1

called 15114 :24 27 : 6 29 :3 83 :24105 :1 6

callegus [1159 :16

calling [3196:5 ,24 117 :8calls (2] 3 :5 8 : 2came 112134:23 59 :12,14 60 :3 75 :11 92 :3 94 :23 99 :23,24 103 :6 110 :14,1 5

canada [ 1198 :1 3cancer [3] 93 :18 94 :21 107 :5cancers [1157 : 7cannot 18190 :17 98 :2,15 101 :6105 :21 108 :19 109 :7 115 :5

canyon 12158 :25 67 :1 0cap C2] 69 :11 71 :2,3,10 72 :12 73 :13 77 :5

capitalized 1 1199 :24caps [1171 :22cards (1) 117 :11care [1) 3 : 2careful 11173 :25carefully [2166 :9 112 :19car ry (1171 : 5case [9 164 :1071 :1672:1592 :5102 :8 104:17 106:11 108 :6 116 :1 8

cast [1111 :8catch [2151 :18,22catholic [1)58 :20caught [1] 56 :24caus [1) 55 : 5caution 13123 :5 50 : 8 116 :7celebrities [2] 5 :6,7census [2157 :15,15center [1168 :1 8cents ' [1)103 :22ceqa [ 1155 :1 2cercla [14143 :4,6 49 :17 81 : 18 96 :6102 :7,12 103 :18,19,23,24 104 :1109 :9 111 :2 0

cercla's [1] 55 :20ce rtain [3116 :2 58:19 104 :22ce rtainly [8] 14 :4 43 :10 45 :1646 :6 52 :1 81 :25 115 :3,1 7

cesium 115192 :23 93 :4,11,20 94 :14,24 95 :9,13 96 : 15 97 :8 108 :15109 :21,22 110 :21,22

cetera 15116 :21 16 :6,14 58 :5 108 :3

chair [1] 92 :20challenge [1179 :1 8chance [3137 :8 78 :13 115 :19change 16118 :6 19 :9 21 :24 64:17,22 91 :1 1

changed [2110 :23 50 :14changes 1516 :13 64 :14,22 69 :23116 :1 3

channel [4]62 :2,3,4,14channels [6161 :21 62 :4,7,7,12 86 :

1 2characterization [11]15 :21 16 :8,12,20 17 :22,25 69 :7 72 :25 77 :12,13 79 : 9

characterize [ 1169 :8characterized [2] 15 :9 16 :23characterizing [1115 :1 2cha rt ( 14132 :11,14 33 : 22 35 :2-1 87 :16 93 :6,10 ,16,17 95 :12 96 :11,17,24 97 : 5

chatswo rth (2] 58 :25 62 :1cheaper (1176 :2 3check [3]44 :18 51 :15 113 :5checked [ 1) 36 :18checking [3] 53 :3,4,12chemical [3123 :16 26 :6 61 :6chemicals [7133 :15 70 :16,17,1780 :12 81 :9 103 :1 0

chest [1153 :6

1-800-2S8-3376

HDMSPOO134606

chicken - debate

chicken [1] 15 :17child 0132childhood (1] 59 :21children [1(50 .6chlorinated 0161 :9choice [1128 :15chose [ 1195 :25chosen [1)66 .9christ (1160 :4christian [2] 58 :14 60 :4church ( 1) 60 : 4cif 11187 :13circle [ 1(102:24citatiorr 11] 98 :11cite [1] 104 :24cited [1] 25 : 6city [5 ] 80 :17,20 103 :11 104 :12

105 : 4civil [3157 :23,24 58 :16clara (2)19 :19 23 :18clarification (2147 :19,25clarify (4120 :6 21 :23 39 :12 103 :24cla rion [ 1159 : 5clarita [2] 23 :20 59 :12classified []74 :1U,1381 :882 :3clay []64:1266:16,18 73 :16 74 :1,5,6,7,8,9,11,13,20,21,22,2575 :21276 :9 ,13,15,16 77 :5 82 :24,2583 :2,2484 :2,3,111519,21,22

clayey [1] 74 :1 2clays [ 3176 :21 83 :20 95 :2 0clean [5] 19:5 23 :8 66 :20 72 :11 77 :6

cleaned [2) 102 :7 109 :17cleaning [6)18 :1,1 19 :13 23 :1,2

104 : 9cleanup [2215 :22 12 :9,24 14 :8 15 :12,20 18 :1221 :11,19 22 :2 , 5,8 32 :

i 22,25 34 :845 :7 47 :22 61 :15 78 :496 :9 109 :7,1 8

cleanups (1192 : 7clear [14] 21 :21 26 :23 29 :10 30 :1633 :1443 :946 :21 49 :21 70 :23 79 :493:1103 :17,19 109 : 5

i clearance [ 1 ] 63 : 6clearly [7] 33 :3 47 :3 77 :24 99 :15111 :25112 :6116:9

close 1]8 :440 :12,25 62 : 10 83 :184 :24 106 : 2closed [(76 :1 78 :10 117 :8closely [1] 3 : 9cluster [1] 69 :20clusters [116410coalition [1] 5 :23code [1] 107 :17coefficient [ 1) 84 :6cognizance [1) 112 :8collect [ 1166 : 5collected [ 10166 :6 67 :10 86 :16 87 :11,13 89 :8 ,9 111 :7,8,15

collecting [1] 79 : 9collects [1] 64 :24color [1] 58 : 2column 119 :13 87 :18 88 :4,5 99 :18,20,20

columns [218 :12,14combust [1] 60 :2 2come (32)7 :15 12 :13 15 :16 17:818 :3 25 :932 :1939 :543 :344 :1247 :2 48 :21 51 :9 53 :21 54 :24 71 :1372:1074 :6,21,2575 :584 :1389 :3 93 :14,23 99 :13 107 :10 112 :4,10 116 :4,4,1 9

comes 1]48 :1372 :474 :15,16 75 :1 83 :6,8 105 :9 106 :11

9A032F1commencing 011 :12comment [24] 47:12 50 :5 51 :3,352 :23 53 :21,23 54 :20,23 60 :11,1366 :7 67 :1 68 :4 ,6 69 :14 78 :9 79 :1980 :6,7 82 :15,16 94 :4 108 :1

commented [ 1 ] 53 :9comments [9] 7 :10 12 :22 44 :1646 :25 53 :21 55 :2468 :5,1083 :19commerce [1] 29 :7commercial [1] 19 :20commission (2134 :23 94 :2commitment [4144 :23 45 :3,8 46 :3

commi tted [5] 13 :2 20 :22 31:2534 :20 44 :22

committee [3] 5 :18 53 :7 54:11commi tt ing [1] 54 :12common [3158 :9,9 93 :19community 112(4 :10 7 :22 16 :3 54 :1957 :2 58 :23 ,24 59 :1094:4 116 :1,8 117 : 9

community's (4] 16 :24 18 :13,1719 :2 2

community -accepted [1] 18 :2compacted []64:11 75 :7,9,10 76 :17

company (4] 24 :16 48 :20 71 :19104 :2 5

compare [7 ] 20 :9 39 :11,2340 :541 :4,11 90 :1 7

compared [6(41 :22 67 :15 75 :2388 :7 90 :14 100 :2 0

compares [1) 111 :22comparing [1]41 :21comparison [ 8] 85 :7 87 :10,22 93 :10,17 98 :17,18,2 0

compatible [2] 351 53 :19compilation (1157 :14compiled [1] 86 :2 3complete (919 :4,6 12 :2 .5 .10 35 :2147:2270 :1478 :4

completed [4] 13 :3 25 :24 28 :1232 : 4

completely [2) 53 :9 76 :8completion [2] 10 :1825 :15compliance [3] 34 :8 55 :9 57 :23complicated ( 1] 20 :2 1comply [ 2] 31 :21 109 :3component [%] 10 :4,19 64 :2,8 65 :2469:681 :2 2

components [ 8] 60 :19 , 20 61 :2,463 :21 65 :666 :15,19

composite [1 ] 97 :21concentration [ 14138 : 14 85 :18,19,25,25 86 :3 87 :19 97 :10,12 98 :7,23 101 :11104 :8 105 :10

concentrations [8121 :2 94 :9 95 :5 96 :25 97 :9 100 :8,20 106 :1

concern 1129 :3 53 :11 56 :22 57 :22 58 :21 66 : 25 105 :8

concerned 0145 :10 50 :7 51 :1172 :7 82 :23 83 : 5 111 :2

concerns [] 16 :21 53 :16 66 :7 83 :6 113 : 7 116 :10,1 2

conclude [1)21 :16concluded (11117 :19concludes [ 1] 69 :25concluding [1] 85 :2 3concrete [4] 11 :8 20 :14 21 :11 24 :

1concurrence (2] 102 :16,17condition [1] 37 :25conduct [4]4 :16,18 , 20 16 :15conducted [ 3] 56 :20 57 :2 67 :17confer [ 1] 107 :1 0

Atkinson -Baker,inc

conference ]12[3 :5 8 :2 15 :4 113 :18114 :1,13,17115 :1,8,21116 :11 ,1 7

confidence (1) 41 :24confident [1 ] 116 :11confirmation [2(63 :6 86 :1 5confirmations [1l 111 :8confirmatory (1] 101 :9confirmed [1] 37 :25confused [3] 25 :25 27 :13 76 :13consequently [11108 :17conse rvation [4127 :2,6 46 :9,12conse rvative [1] 42 :2considerably] 49 :18consideration [2) 21 :25 51 :7considered [ 6) 29 :21 53 :22 80 :1581 :23,24 100 :2 1consist [1166 :16consistent [2] 21 :7 34 :25constituents (1142 :9constitutes [1] 82 :7constitutional [1158 :15constraints [1] 12 :12construction [1] 42 :22consumer [1)29 :1contact [2] 115 :14 116 :12contacted (]43 :1656:1766 :10contacting [2164:6 117 :7contacts [1] 51 :24contained [2) 42 :7 61 :12contaminants 0148 :22 61 :1271 :577 :6,16,1978 :16

contaminate [1170 :25contaminated [ 11] 26 :10 30 :1341 :10 63 :17 65 :4 69 :4 70 :15,2096 :20 103 :15 106 :16

contamination [34] 11 :23 20 :12 .1921 :9,13,2022 :2,629 :2030:733 :6,17 34 :3,18, 21 40 :4,9,24,2541 :250 :2251 : 8,859 :1661 :670 :2271 :1679:21 80 :12 83 :7 94 :25103 :18 109 :6, 8

content [ 10164 :13,17,22 65 :13 .17,22 74 :7 75 :8 83 :24 84:4continuation [2] 12 :1,6continue [5111 :22 36 :15 67 :370 :25 72 : 6continuous [1] 68 :15contracting [1) 42 :25contractor [3] 38 :1242:2444 : 7control [1112 :7 5 :17,21,25 39 :5,2060 :15 66 : 11 67:6 92:20 107 :17

controversial (1129 :8conversation [2(2 :9 92 :18convert [1] 91 : 8convinced [1] 83 :9coolant [1] 89 :17cooling [1) 49 :1coop [1] 15 :17cooper [1] 59 : 4copy [5]4 :13 14 :10,12,13,14corps 12 156 :9 109 :1 7correct [14]4 :7 13 :11 28 :5 45 :948 :7 88 :22 89 :25 90 :11 91 :24 93 :2295 :12 105 :22 107 :22 109 :16

corrections (1) 4 : 8corrective [3] 11 :11 78 :6,19correctness [1)4 :6correspond [1)21 :2correspondence [3144 :2046 :11,

1 4corresponds [2] 50 :25 104 :8cosmogenic [2] 91 :22 92 :9cosmogenically [1] 91 :20couldn 't [6] 14 :23 15 :1,3 19 :2 23 :

7 92 : 2counter 0 139 :20counties' [1(43 :1 9count ry [6] 58 :16 89 :24 90 :4,2498 :14 114 :22

county [ 2) 25 :5 42 :1 4couple [9] 19 :20 56 :4,11 62 :7 63 :18,21 66 :9,1267 :7

courageous [ 1] 70 :1 3court [12] 4:4,12 9:14 10 : 9 41 :15,17,1947 :3,7 54:25 57 : 9 75 :18

cover (32111 :17 63 :9, 21 65 :22 66 :2,4,12,15, 18,23 67 :1,17,18,23,23,24 68 :14,17,23,25 69 :12 72 :19,2373 :7,15 75 :23 ,24 76 :20 77 :11,15,20 83 :2 1

coverage [ 1132 :20covered P]31 :1248 :1 86 :13covering (1)63 :1 6covers ( 1133 :13coyote (1(67 :10cracks [ 2) 63 :2 83 :4crap (1] 112 :3creates [1) 57 :25creed [1] 58 :2crews [1] 62 : 6criteria (22] 20 :23 34 :17 68 :6 85 :15,15,19 86 :2,6 87 : 17 94:1 98 :23,2499 :8,10 100 :4,9 101 :12 102 :19,22105 :12,13 108 :1 9

critical [1 ] 106 :6criticism [2115 :24,25criticized [1) 18 :23csr [2] 1 :13,2 4cur rent (6] 20 :4 25 :21 37 : 11 50:1962 :11,2 3cur rently [41 19 :9 52 :5 65 :3 114 :2 2cut [2(17 :14 59 :24cutting [ 2143 :15 .16cx [1] 9 :21

ud8d [10] 7 :18 11 :22 12 :1,2,5,8 26 :1032 :743 :2446 :14

damn [ 1183 :1 6dan [9114 :10,12 43 :24 55 :10 74 :179 :22 80 :2 87 : 1 112 :1 2

dan's [1] 47 :25dandy [11597dangerous [2191 :1 93 :2daniel [ 1 ] 5 :1 8data (31] 19 :9 27 :23,24 57 :5,14 65 :10 67 :11 73 :11 76 :2,577 :1078 :2579:986 :12,15,23 87 :8,9,11,12,13,16,17, 18 88 :7,13,23 89 :1 90 :2495:4,18,2296 :3,7,11,1697 :20,2298 :4,5 100 :19,22 101 :20 103 :13,14,17 111 :9 ,12,12,14,15

datas [1] 96 :1 9date [813 :146 :197 :1314:11 32 :1533 :2444:7115:16

dated [2] 14 :11 56 :1 9dates [2[8:15,17 _daughter [ 2] 88 :1, 3dawn [3182 :21 83 :18 113 :6day [417 :465:11103 :6 114 :23day-today [1 ] 53 :1 3days [[4 :1053 :4 65 :11days' [1145 : 4daze [1144 :15de [2160 :1,1dea [2132 :9,9deal [1(78 :16dealers [1] 25 :10debate ]]23: 1

1-800 -288-3376

HDMSP00134607

debris - exist

debris 1 19120 :14 21 :21 22 :19 24 :21 27 :5,8,9,15 28 :3,7,10,12,16,2231 :22 46 :9,11 62 :15 63 : 1

decades 0198 :14decay [1] 100 :16decays (1] 91 :1 8december [3156 :19 59 :5 63 :23decide [2] 83 :14 112 :17decided [2198 :3 108 :4decision [12110 :24 27 :25 29 :1 931 :2277 :479:2485 :1386 :4102 :10,11 104 : 3 106 : 8

decisions 13178 :11 114 :8,9decommissioning [ 1] 100:9 __decontamination [3111 :13,21 12:3

deeper [1165 :21deeply [11113 :20default [1] 99 :21define [21104:2 108 :9defined [ 1] 82 : 2definitely [5] 37 :6 43 :5 114 :18115 :7 117 : 1

definitive [1] 43 :2delegated [2181 :19,21demolish 1519 :12 24 :19 48 :16,1949: 8

demolished [7122 :7 34 :9 38 :8 48 :11,13,14,1 5

demolishing [1110 :6demolition [918 :15 10 :17 11 :13,21,21 25 :16 32:15 33 :24 45 :2

demonstrated [1 ] 106 :11demonstrates [ 11 103 :14demonstration [3) 67 :18,22 68 :2 1

dempsey [31 13 :25 14 :3 30 :23demsey [1192 : 1department [2812 :7 5 :16,20,24 6 :2,5,8,934 :1343 :344 : 350:1254 :

1 1 56 :20 57 :4 60 :15 61 :5 68:5,1 170 :25 71 :7,8,25 72 :1 73 :22 104 :15 113 :22 116 :24

depends [2190 :15 .18depth ( 1 ) 65 :21depths [ 1] 64 :11derive [1] 21 :1derogato ry [114 :23described [1) 57 :4description [1117 :1 8design [22163 :9 66 :1,2 ,8,10,15,2267 :5,7,11,23 68 :14 69 :13 72 :22,23 73 :1,5,18,20,23 74 :24 83 :22

designed [1169 :1 1designs [5166 :9 ,12 67 :19,24 68 :2 0

despite [11103 :18detail [2124 :18 33 :1 7details [4] 10 :14 22 :12 24 :17 33 :

1 0detectable [1141 :23detection [1151 :17determination [5] 101 :10,13 105 :14 106 :23 110 : 7

determine (4143 :11 98 :22 99 :10107 : 1

determined (1) 113 :16determines [1] 114 :3determining [3181 :21 99 :12 106 :5

develop [1] 105 :24device [1152 :12devices [1151 :2 0dhs [42] 7 :19 20 :1 21 :6,8,17,23 27 :17,23 34:24 35 :2,15,16 36 :10,18

9A032F137 :15,22,24 38 :10,21 49 :14 80 :1381 :4,16 ,19,22,25 83 :15,15 85 :2,11 87 :13,25 88 : 14 89 :12 102 :9104 :20 107 :16 109 :4 111 :7 112 :20 113 :19 116 :20

dhs-approved [1] 86 :5di [3] 105 :7 106 :17,19difference [1120 :19differences 14113 :16 89:5,6,6different [9138 :4 43 :8 66 :2 67 :18,25 87 :8 90 :20 99 :21,2 1

dig [2128 :17 78 :15diminished (1)96 :6dioxins 13161 :10,14 113 :2di rect [1]4 : 1di rectly [1]54 :1 7director [5] 49 :24 56 :15 116 :20,24,2 5

dirt [6171 :9,11 72 :2,13 73 :10 80 :1 0

disagreement [2179 :11 81 :2disagrees [1) 80 :2discover [1] 116 :17disc rete [ 1]64:11discrimination [1) 58 : 1discuss (6)12 :21 22 :11 29 :25 104:18,19,24

discussed [2] 8 :2 56 :16discussion [1417 :21 21 :18,22 32 :6 33 :1,2,12 36 :15 43 :7 53 : 1 54:6,11 70 :10 85 : 3

discussions 1313 :18 21 :4 100 :1diseases [1156 :1 4diseases ' [1) 56 :18disgusted [ 1183 :12dismant led [1] 28 :23disposal [9] 10 :11 11 :15,16 19 :2127:11 58 : 8 60 :18 61 :7 85 :12

disposals [ 1) 81 : 5disposed [1197 :3distance [2] 62 :3,9distinction [21 21 :19 22 :2distinguished [11101 :6divide [119 :5divided [218 :16 10 :2division (1149 :24document [3] 16 :5 86 :15 105 :23documentation [1126 :22doe [3717 :19 8 :7 13 :12,15,17 15 :10 16 :24 17 :10 20 :18 21 :4,7,8,2423 :8 25 :10 27 :17 29 :5 34:2,3 44 :16 47 :23 49:19 50 :5 55 :18,20,2183 :15,16 87 :17 93 :17 99 :18,19,24102 :15 103 :3,19,23

doe's (4112 :24 20 :7 21 :16 23 :2doe-rocketdyne [1] 38 :12doea [1] 31 :24doing [2212 :18 9 :11 13 :2,21 14 :8,9,20 17 :13,19 19 :1 33 :4,16,18,18,19 38 :12 46 :6 72 :16 73 :12 83 :1392 :14 112 : 9

dollars [1) 32 :2 4done [2917 :11 12 :19 15 :11,25 16 :131 :23 38 :21 42 :21,22 51 :13 55 :18,19 63 :13 68 :14 70 :23 72:7 75 :1079 :7,8 85 :8,22 86 :19,19 90 :20,20100 :12 101 :25 105 :1 112 :18

donna [1) 6 : 7doors [1178 :10dormitory [1) 87 :1 4dose [5151 :6 105 :17,19 106 :10114 :1 1

dosimeters [1151 :19double [ 1190 :9double -check [2133 :11 46 :21

down [33110 :25 19 :3 20 :2 21 :1222 :20 24 :21 37 :2,5,7 41 :25 43 :1344:5,14 46 :15 49 :16 57 :9 62:9 63 :1 64 :25 66 :5 71 :5,13,18 72 :4 74 :15,15,16 76 :17 83 :6 86 :17 93 :6100 :11 113 : 6

downhill [1 ] 83 :5dozen [1] 92 :3draft [6 14 :11 56 :19,19 57 : 1 58 :1159 : 4

drag (1)105 :15drainage [2] 61 :21 86 :11dramatically [1195 :6dries [1] 83:2 -drifted [1121 :1 6drill [1] 73 :2drive [1159 :25driveway [1] 52 :21dropped [1] 32 :1 3dry [3176:22 82 :25 83 :25dsre [ 1160 :25dtld [2151 :20 52 : 9dtsc [14110 :12 11 :3 27 :5,17 49 :1968 :7 81 :19,21,25 82:10 83 :14 96 :23 104 :21 116 :1 1

due 13124 :14 89 :15 97 :9during [1412:21 3:5 4 :23 26 :11 29 :2030:8,1833 : 1954:1661:465 :15,17 68 :4 115 : 4

duties [1] 14 :25duty [ 1181 :18

E

Atkinson-BakerInc

e-mail [4135 :8,8,11 37 :2 0ea 16128 :12 29 :20 30 :8,9 ,18 31 :2332 :4, 5

each [713 :16 4 :21 31 :5 33 :5 38 :253 :7 75 :1 9

ear [1) 8 : 1earlier 111128 :22 37 :17 40 :14 68:6,8 99:8 100 :4 ,10,13 104 :14 110 :6

early [1159 :1 8easier [1] 71 :19easiest [2118 :18 114 :20east [1162 : 1ed [3] 113 :19,21 116 :19effect [1165 :19effectiveness [1] 66 :8effo rt [1144 :15effo rts 13362 :2,2 70 :13eight [3167 :14,15 86 :1 4either [4121 :7 50 :22 74 :22 102 :12elastic [1184 : 4elasticity [1184:17element [1] 64 :20elements [2164 :1 86 :18elevated [1161 :14elsewhere [3174 :2 78 :14,23emergency [1) 44 :3emphasize 12179 :6 97 :14emphasized [1] 108 :24emplacement [1] 63 :8encapsulate [1177 :20encompassed [1129 :18encompassing [1148 :2encounter [1] 64 :15encountered (1) 61 :4end [16131 :15 37 :1,11,12,13 39 :2244 :9 52 :21 55 :25 57 :11 77 :24 80 :3 93 :7 104 :1 108 :3,25

endangered [1149 : 5ending [1)3 :1ends [1116 :4energy 1316 :8,9 43 :3engineered [5163 :9,20 68 :16 76 :16,18

engineers [1) 56 :9england [2183 :2, 3enough [9] 17 :6 26 :23 41 :25 44 :159 :19 79 :2 108 :24 116 :22,23

entered [1177 : 3entire [2] 59 :9,1 0environment [7134 :10 49 :16 79 :25 83 :22 106 :10 107 :19 112 :25

environmental [7110 :24 12 :13 25 :15,24 26 :12 30 :9 55 :1 7

epa [5312 :20 5 :1,2 7 :19 10 :13,1711 :1,1 13 :2,3,13,15 16:15,24 20 :11 21 :4,7,17 22 :7 23 :3 27 :17,2333 :11 36 :18 44 :4,11 45 :1 46 :11,20 48 :1 49 :17 53 :8,16,16 82 :1 83 :16,16 87 :18,21 93 :17,19,21 94:1896 :6 99 :23 102:6 103 :18 105 :9106 :11 108 :4,17,21 113 :25

epa's [1118 :14 12 :24 20:7,10,2421 :25 23 :8 46 :10 49 :12 94 :25 96 :9

epa-cercla [ 1]99 : 9equal 13172 :14 75 :25 85 :23equilibrium ( 1 ) 88 :4equivalent [4121 :9 53 :6 100 :6105 :20

erpa [1l 114 :24errata [1)4 : 8error 17123 :4,4 30 :1 31 :8 50 :8 101 :4 116 : 7

errors [1] 116 :6erupted [1] 103 : 2essentially [3145 :9 68 :24 82 :2established [3140:6 68 :8 113 :18establishing [1147 :2 3et 15115 :21 16 :6 ,13 58 :4 108 :3etsc (1)115 :1 8evaluation [3] 14 :9 15 :23 112 :11evapotranspiration [3165 :19 67 :5 75 :2 4

even [15120 :11 25 :19 37 :5 52 :9 69 :22 72 :15,15 95 :21 96 :1,7 100 :7 .8102 :2,15 104 : 9

evening [212 :4 4 :12event [1165 :17events [1164 :16eventually [11108 :18everybody [716 :25 22 :12 57 :1258 :23 59 :7 60 :16 61 :23

everyone [812 :11,17 4 :18 6 :20 8 :1022:454 :1583 :13

everyone 's [1] 114 :15everything [6116 :6 19 :4 36 :3 40 :16 46 :22 78 : 7

everywhere [1) 88 :10evidence [2180 :13 81 :12 -exact [1] 23 :2 1exactly [6139 :1 43 :9 59 :22 74:2394 :12 98 :21

examine [1l 15 :17examined [1119 :1 5example [5110 :20 32 :14 33 :12 57 :22 65 :2 5

examples (1)67 :9 -excavation [4127 :10 62 :18,19,24excavator [1163 :1 1exceeds [1140 :8excellent [1) 67 :1 2excess [4196 :6,20 103 :15 108 :17exchange (1)8 : 4excluded [1145 :7excuse 13119 :8 32 :5 86 :21exercising [1158 :15exhausted [1160 :12exist [1] 63 :1 9

1-800 -288-3376

HDMSPOO134608

existing - hirsch

existing [5] 12 :6 22 :1 34:19 54 :369 :23

expand [1176 :2 2expect [4162 :21 65 :15,17,21expected-way [1] 37 :1expeditious [11115 :14experience [1] 16 :23explain [5] 18 :19 28 :21 85 :7 87 :15110 : 2

explanation [1] 100 :17exposed [615923 62 :15 63 :3,10,1585 :1 7

exposure [3] 94 :1,5 98 :12expressed [3153 :16 66 :7,25expressly [11103 :19extraction [4165 :2 69 :3,21 78 :21extractions [1]771 6extreme [1] 57 :22extremely [2] 71 :24 72 :6eye [1] 56 :24

Ff-e-r-k-i-n -e-s [1156 :8face [3] 70:14 114 :15 115 :20facil itator I2] 2 :8,1 5facilities [1618 :15 12 :16 13 :1 24 :23,2426 :6,8,1427 :11 30 :14 38 :151 :24 55 :21 81 :14 82 :11 99 :13facility [46] 8 :10 10 :5,5,6,11 11 :12,20,22 12 :2,827 :1628:829 :21,2332 :7,11,15 42 :1743:11,17 50 :20,20 55 :18,21 57 :17 60 :18 65 :5 72 :1081 :1585:1286:4,10 100 :5 102 :7103 :3,3,411107 :21109 :12,14,17,19 113 :3,11 114 : 4

fact [12] 13 :14 19:1449 :12 56 :1757 :16 59 :8 82 :24 85 :13 103 :17,18109 :3 112 : 8

factor [3[ 108 :11 .14 110 :16factors [1] 7 :1 5fading t1] 10 :21fair [2157 :25 65 :1 2

j fairly [4136 :20 65 :22 66 :9 111 :13fallout [4] 94 :24 95 :5 97 :9 98 :14familiar [11 116 :1 2famous [ 1192 : 1far [3119 :15 30 :21 101 :21fat [1) 83 :24fed [2] 59 :9,11federal [1] 51 :4feel [1] 16 : 2feeling [2] 10 :21 46 : 7feet (]62 :9 66 :16,17 68 :18 73 :16,2474 :1 9

fellish [11441 5ferkines (4156 :4,7,7 57 :10fernando [5123 :15 24 :25 25 :1 59 :12,1 3

few [9] 11 :5 27 :1 31 :12,23 32 :6 53 :478:1582 :588 :24

few-and -far-in - between [1 ] 59 :2 3

fiasco [1] 113 :23fiberglass (2)39 :17,1 9field 1412 :14 56 :22 60 :9 89 :13fifteen -minute [1] 3 :2 2figure [)43 :7 55 :11 95 :8 96 :16figures [1] 96 :1 2file [1] 1 :25filed [1]4 : 9fill [5] 18 :25 64 :6 73 :16 78 :14 117 :1 0

filter [3) 39 :4,17,1 9final [1614 :5,14 14 :16 17 :21 20 :222 :8 27 :18 72 :20,22 77 :14,22,2378 :2 79 :12,24 101 :12

9A032F1finalized [ 114 :1 7finally (1) 17 :7 _finance [ 1] 54 : 1find [10115 : 18 16 :1 17 :2,8 22 :2561 :13 86 : 18 115 : 2,9,10

finding [2) 64 :4 85 :2 4fine [4 ] 17 :18 59 :7 83 :25 116 :23finish [6] 37 :16 40:13 62 :12,23 93 :1497 :1 9

finished [ 2137:21 87 :4fire [3] 14 :25 59 : 19 61 :8firm [1124 :1 1first [3113 :11 6 :18,23 7 : 18 9 :9,25

14:18 15 :9 17 : 5 23 :12 30 :25 36 :1440:342 :54.8 :13 59 :1368 :1070:18 71 : 17 72 :18,19 77 :9 80 :2392:20 93 :16 97 : 14 99 :5 , 6,18,25114 :2 3

fiscal [ 11] 10 : 2,3 11 : 19 31 :6 , 14,16,16,21,23 32 :2,25

fission (2] 89 :1493 : 1five [6] 46 :4,8 48 :3 54 :23 67 :10 76 :

2fix [1] 18 :25flag [1] 83 :12flaky [2] 72 :3 95 :1flexible (2) 6 :22 8 :3floor [ 3] 13 :8,8 50: 6flow [3172 :24 73 : 13 82 :24flowing [2164 :5 83 :8fluctuation [ 1 ] 101 :7flux [1] 72 : 4fly-by -night [1 ] 59 :23flyers [1160: 7focus []90 :22 92 :18,23foliage (2) 76 :14,1 5folks [5128 :2,4 51 :18 52 :19 85 :2follow [3] 3 :9 4 :3 18 :6follow-up [1 ] 57 : 2followed [1 ] 3 :22following [3] 3 :19 26 :2 33 :4fo re [1) 67 :1 3forever [1177 :20forget I1] 79 :13forgot [1] 22 :2 2form [3) 9 :16 50 :22 54 :1formal [1)113 :1 3former [10 ] 10 :11 24 :24 26 :14 27 :1645 :2 60 :17 .1861:22 85 :11 86 :9

fo rth [6] 13 :7 16 :25 18 :11 39 :1076 :7 108 : 2

forward [6) 14 :6 28 :19 36 :15 72 :23 73 : 1 113 : 7

found [ 13] 14 : 22,24 27 :6,15 61 :1567 :12,22 85 :25 88 :12 90 :25 96 :8,19112 :2 4

four [17] 60 : 4 62 :21 64 : 3 65 :11 90 :2496 :1897:18,20,23 100 :25 101 :21,22 108 : 25 111 :20,20,23,23

fox [11151 7fractured (2) 63 :5 69 :15fractures [7] 70 :21,22 , 24 76 :22,2377 :7 78 :1 6

frame [ 1] 114 :18frames [1) 7 :24francisco [1] 56 :15friends (1] 56 :1 1front [4139 :1 47 : 4 101:20 103 :13frustrating [1) 32 :23fsdf [ 5] 60 :25 64 :9 65 : 2 66 :24 84 :2fsds [ 1 ] 116 :1 0full (2)9 :3 16 :13full-time [ 1 ] 53 :2functioning [ 1 ] 39 :22

Atkinson- Baker, Enc

fu rther [3] 101 :15 110 :5 112 :11future [4] 14 :5 , 8 100 :3 113 :18fy04 [ 1] 12 : 1fy05 [1] 12 :5

Ggamma [2138 :13 91 :14gap [1] 5 :1 9gaps [1144 :21gases [1182 :24gathe red (1) 65 :1 2gave [5] 22 :18 30 :25 74 :7 98 :11110 : 4

general (2) 3 :23 87:22generated [2] 87 :20 91 :20generations [2]59 :21,22gentlemen [1) 4115geologic [1195 :20geology [1] 63 :5geotechnical [1] 75 : 7gerard [915 :20 11 :9 27 :5 70 :13 77 :21 80 :9 82 :23 113 :1 115 :20

gets [6] 15 :24 36 :2447 :1682 :2110 :1 115 :2 4

getting [1612 :19 36 :9 37 :6,17 42 :243 :20 55 :8 67 :13 84 :20 85 :3 87 :193 :18 96 :3 97 :23 105 :10,23

gigantic [1] 90 :1 3give (26] 9 :10,20 25 :1226:21 32 :6,17,20 33 :17 35 :7 37 :2 41 :23 43 :144:22 45 :3,12 60 :5 61 :17 62 :5 64 :12,18 73 :14 80 :22 83 :16 87 :20,2588 : 1

given [9123 :24,25 42 :4,7 43 :1446 :1351 :3 53 :11 108 :1 4

gives [1] 12 :1 5giving [3] 33 :3 79 :3 92 :12glad (1) 29 :1 3glance [1) 46 :10goods (2)29 :1, 2got [3118 :1 10 :413 :23 14 :7,10,21

15 :22,23 16 :21 17 :740 :11 46 :1050 :12 51 :11 53 :3 69 :18 ,21 72 :16,2073 :5,23 76:2 79:19 89 :22 90 :1294 :14101 :16 103 :20 109 :8,20111 :1 6

gotten [1] 38 :1 3government [3] 15 :15 31 :14 112 :7

gown [11101 :5graded [1186 :10grafts [1] 59 : 6gram [5189 :25 90 :6 93 :21 94 :14

108 :1 5grand [2] 1 :11 84 :7granted [1] 107 :1 6graph [419 :17 23 :13 90 :23 98 :18graphical [ 1188 : 6graphite (1] 33 :23graphs [4] 57 :16 88 :8 99 :5,6gravity [1172 : 5grayer [1(43 :12great [1172 :10greater (1) 97 : 8greg [19] 13 :22,23 14:3,7,16,19,23,2315:14,2216:5,1917:2,4,19 18 :3,8,19 30 :23

greg 's [1] 19 :12grossly [1)112 : 9ground [514 :3,15,17,1988 :10grounded (1)16 :22groundwater [16133 :13 65 :2,4 67 :469 :3,4,18,21 70 :19,25 71 :5,15,1772:2479 :22 83 : 7

group [9] 4 :22 6 :17 18 :1 35 :23 47 :155 :658:185:10112 :2

groups (2)53 :8 58 :16grow [2) 71 :11 76 :15growing 0172 :3guarantee [11105 :2 1guess ]1]7 :1 1 8 :9 9 :19 21 :5 28 :611,13,1435 :441 :1445:1351 :1360 :24 113 : 9

guidance (4)49 :18 103 :19 109 :9111 :20

guide [1] 81 :23guideline [1154 :4guilty [1] 58 : 7guys (18 :7 104 :3 111 :8,14 112 : 4

Hh-u-s-h [2] 47 :10 55 : 4half ([63:6 62 :13 89 :24 90 :1half-life (11100:1 8halfway (2)3 :21 54 :8halls [1) 60 :4handed (1] 60 :7handle [1143 :11handling (2111 :12 58:8handout 14l 8 :9 9 :18 22 :17 86 :24hands [3115 :24 41 :1943:19hanford [1)55 .1 8hannibal [1) 50 :5hanover (2155 :8,1 3happen ]]42 :10 43 :22 44 :8 46 :7happened [5] 13 :21 24:9 50 :15 55 :15109:1 6

happening (4)16 :3 66 :24 79 :18,23

happens [2] 76 :6 91 : 4hard (5] 31 :2 70 :3 79 :14 102 :17113 : 1

hassle [2) 12 :25 16 :4hassling [1115 :5hauled [1) 19 :17hauling [11116 :4hazard (1] 106 : 7hazardous [7124 :1442:6 43 :17 .1867 :1997:3107:18

head [3] 113 :19,22 116 :24headqua rters [1150: 1health [20) 62,5 23 :3 34 :14,14 37 :2550 :13 52 :17,20 53 :10 56 :21 57 :2,4 61 :15 79 :24 104 :15 106 :7 107 :17,18 112 :25

hear (8) 29 :13,14 33 :1 47 :21 56 :657 :12 58 :9 60 :1 6

heard [7115 :258:661 :1 77 :22 94 :3104:5112 :1 2

hearing [2123 :6 51 :4hearings [1] 58 :7heat [1] 83 :3heating (1149 :1heck [1] 73 3held 1 616 :21 28 :4,12 51 :2,4 67 :3hello [1] 5 : 2help [2) 7 :2 41 :17helpful [1] 33 :1 0high [3119 :11 110 :12 111 :13higher [14] 23 :2 41 :11 50 :24-59 :1790 :3,6,18,2596 :8,13,18 97 :11,18101 : 1

highest [[23 :5 71 :7 98 :6 110 :11,1 8

hill [11 113 : 6hills [3) 19 :18 23 :15 83 :8hirch [1] 95 :2 1hire [1142 :24hired [1124 :1 1hirsch [16915 :18,18 13 :25 21 :1822 :15,23 23 :19,23 24 :2,7,13,20,2525 :5,14,19,25 26 :2,8,16,19,2 3

1-800-288-3376

HDMSP00134609

hirsch - level

27 :3 28 : 9,14,16 29 :23,25 30 :4,12,19,20,25 31 :5,10,20 32 :8,14,2133 :10,15,22 34 :2,6 35 :17,20 36 :2,16 37 :940 :16,20,2241 :3842:4,13,1743 :1344:1,11 45 :5,19,2346 :2,6,2048 :2,13,16,23,25 52 :2453 :23 55 :12 70 :11 73 :9,12,19,22,25 74 :2,6,12 76 :21 77 :3,21 78 :2,1079:280 :9 81 : 6,9,18 82 :6 85 :487 :2,5 ,8 88 :23 89 :3,8,11,17,2090 :3,22 91 :4,8,13,16,18,22,25 92 :10,2393 :1,8,10,1494 :2395:12,2597 :18 98 :6,9,11,19,21,25 99 :2,7,17101 :16,20,23102 :11,20,23104 :11 105 : 3 106 :13,19,21,24107 :4,13,20,24 109 :5 ,23 110 :9,18,22 111 :6,11,19,21 112 :6 113 :10114 :7,12,25 115 :6 ,9,14,19,23 116 :13,1 5hispanic (1157 :19hispanics [1] 57 :8historically [ 1125 :9hit [1] 74:22hold [2137 :11 111 :6holds (1162:23hole [1] 18 :25holes [1] 73 :4homework (1 ) 92 :15homogeneous [1] 576honest [1] 92 :1 2hope [9111 :11 72 :2 78 :17 79 :3100 :2 105 :9 106 :9 ,11 117 :16

hopefully [618 :4 10 :25 26 :8 44 :877 :18,1 9

hoping (2)4 :17 12 :2hospital (1157 :7hot['[ 83 :1 3hotel [211 :11 59 :5hour [1136 :13hours ( 2) 65 :1 1 .11house [11 13 :6housing [1] 57 :2 5however [4] 4 :12 15 :10 38 :2 100 :9howlering [3115 :11 .14 16 :17hsu (83 ) 6 :4,420:2,8,11,1821 :1,13

34 :11 35 :19,21 36 :3,8 37 :16 38 :2439:7,1240 :1,13,18,21,2341:7,14,20 42 :11,1550 :1951 :1952:6 .11,15 53 :15,2454 :7 85 :7 90 :15

92 :9,11,17,20 97 :13,1998 :8,10,16,20,22 99 :1,4,16,18 101 :19,22102 :8 ,12,21 103 :21 104 :6,13 105 :5 106 :18,20,22 107 :2,9,16,23,25108 :9 ,13,21,23 110 :2,6 114:6,8,22115 :3,7,12,17 117 : 1

huge [3] 83 :4,12 90 :12hugo-neu [2)23 :1725 :11hundred [3132:17 71 :13 74 :10hundred-percent [1] 32 :20hundreds [1132 :24hung [1177 : 7hush [14]47 :5,6,9,18,21 48 :5,1049 :3,5,8 ;11 55 :3,4,13hygienist [1159 : 5

Iias (1158 :10Ic [1157 : 7idea [5166 :3 69 :1783:10,10,11identification [114 : 7identified [5] 22 :18 36 :17,23 45 :6,2 0

identify [2163 :4, 6illegal [9] 19 :24 58 :8 103 :1,7 105 :1,3 109 :19 112 :9 113 :4

9A032F 1illegally [11103:10illness [112 :11imagine [1136 :24immediately [11116 :18impact [3]43 :5,5 67 : 3impacted [9]39 :2,1440 :14,16,19,2141 :651 :785 :16

imperfections [1] 75 :21impermeable [2171 :10 74 :21implementation [2] 12 :3,10implemented [4166 :12 67 :7,24112 :2 4

impo rtant ( 11] 15 :2 21 :19,22 28 :21 40 :11 56 :16 63 :21 64 :2 88 :20112 :23 113 : 5

impo rted [ 1159 :15impose [2] 50 :24106 :7impoundment [17161 :19,20 62 :4,10,19,24,25 63 :17,1964:465:568 :1869 :9,24 78 :21 112 :25 113:2

impoundments [4] 61 :7,11,22 69 :4

improved [1] 69 :12inappropriate [1] 95 :8inc [211 :21 38:3incentive [1172 :10inches (2)76 :19,19include [2158 :18,25included [2121 :3 51 :7includes [2] 57 :25 88 :2including [2]57 :6 67 :19incorporated [2134 :19 86 :6incorrect [1193 :8increased [3151 :25 52 :1,2indeed [1178 :1 7indefin ite [1147 :15indefinitely [1171 :23independent [4115 :15,15 16 :1944 :1 2independently [1]53 :12indicated [8135 :238:4 .1944:580 :9,11 86 :16 105 :1 9indicates (11114 :11indication [2160 :5 64:18individual ( 4158 :1 85 :17 88 :13105 :1 7

individuals [3158 :2,16 .17industrial [1159 :5infiltration [11163 :24 64 :1,20 65 :767 :2 68 :25 69 :12 73 :7,9 79 :7,15

information [18] 2 :20 4 :6 8 :3,11,13,23 9 :4,6 14 :2 27 :20 60 :9 64 :1365 :9,10 ,12,14 68 :21 101 :10

informed [1] 24 : 7initial [2] 58 :7 61 :3inside [2136 :25 39 :15insignificant [41107 :3,4 112 :15114 :1 1insist [1] 13 :18inspect [1] 51 :23inspection [218 :14 51 :2 2inspections [1151 :24inspector [2] 52 :6,7install (1] 73 : 1installation [4] 10 :4,19 64 :3,8instance (1185 :20instances (1)97 : 8instant [2] 51 :21 52 :11instead [1171 :24instrument [2140 :3,7insure [1119 :1 2intend [4127 :8 32 :17 49 :8 68 :12intended [21109 :1, 1intending [1127 :12intent [1145 :25

interagency [1] 10 :13interest (1154 :2 2interested [4] 14 :4 33 :16 37:17 64 :4interim [17110 :12 54:9 60 :13 62 :6,1763 :23 66 :23 67 :21 68 :11 72 :20,2177 :1,2579 :12,2080:184:9interject [2] 36 :12 111 :24interrupt [1121 :1 5intriguing [1195 :8introduce [414 :25 5 :9,13 70 :6introductions (2)3 :12 5 :4invasive [1157 :7investigate [1117 :13investigation (5] 18 :24 28 :2 57 :3,5 104 :1 8investigations ['128 :19invitation [1160 :8invited [1] 60 : 8involved [11114 :5,8,17 19 :6 38 :15113 :20,21,22,23,25 116 :2 0isn't [9113 :9 17 :8 25 :20 37 :1443:2 76 :9 93 :9 108 :7,20isotope (2] 87 :25 88 :2isotopes [3] 86 :23 87 :23 88 :7issue [12)20 :1842 :2343:21 46 :452:3 68 :3 82 :8 100 :1 104 :13 109 :11113 :21,2 3issued [1] 53 :25issues [7111 :7,24 12 :13 30 :17 43 :845 :164.8 :1 7

it'd [2] 54 :25 115 :1 4item (1816 :16,18 7 :18 10 :23 11 :3,533 :5 47 :11,14,1850 :251 :1555 :7,1666 :1 59 :3 60 :13 84 :2 4

items (9) 3 :24 22 :15 30 :21 32 :2550 :16 54 :17,20 55 :2 58 :19itself ( 4) 9 :1640 :1843:18 71 :25iv [2124 :22 98 : 5

janua ry [3135 :2 37 :24 82 :12jeopardy [1123 : 3job [2] 19 :12 25 :23johanna [1170 : 7johnson [715 :22,2214:1523 :1 .1276 :13 116 : 6

join [2] 62 :4 113 :25judgment (1) 39 :24julie [1] 49 :2 4june [4162 :18,20,22 79 :10jurisdiction (4(42 :11 102 :9,15,1 6

Atkinson-Baker,Inc

K

kmex (1158 :12knocked (1137 :7knolls (2)5 :23 58 :25knowledge ])25 :12 58 :9,10known (2)42 :6 104 :22knows [2] 22 :12 42 :23kowalski [3182 :18,21,21kuehl's [1151 1

k-o-w-a-I-s-k-i [1] 82 :22kaiser [2186 :13 87 :13keep [413 :25 8 :4 23 :6 94 : 7Kelly [34] 4 :25 5 :2,26 :1,10,22 7:6,12,23 8 :7,20,22 13 :19 19 :23 20 :1,14,17,21 26 :22 28 :6,10 36 :22 43 :1 45 :9,18 46 :4 49 :22 81 :20 85 :287 :20 103 :22 114 :17 115 :18 117 :6

kettleman [ 9] 19 :18 23 :15 80 :16,2081 :4 103 :11104 :12 105 :4 113 :1 2

key [2133 :8 72 :8kicks [1165 :18kids [1]84 : 7kind [17112 :23 15 :23 16 :2 19 :6,632 :22 39 :8,23 41 :3 42 :10 51 :1660 :6 82 :19 84:16 89 :17 97 :21 117 :2

kinds [2(1525 59 :1kingdom (1160 :4kits (1)58 :10

CI -e-u-s-s - i -e-r 1 1150 :11I-i-s [1147 : 9I-i-s-a [1147 : 6lab .[7] 5 :3 15 :1 56 :22 60 :9 75 :7 87 :2589 :1 3

labor [1] 7 4laboratory (8)2 :14 39 :4,5,6,10 40 :6 84 :5 89 : 9

labs []67 :17 68 :21 75 :22lack [1157 :2 0laid [2] 76 :17 86 :24land (3171 :20,21 83 : 1landfill [11123 : 14,15 28 :25 67 :9,9,10,13,1469 :876 :18,18

landfills [9] 19 :20 26 :10 33 :6 49 :1767 :8,20,2076 :1106:17

language [1]423large ]]44:21 90 :16 97 :24 103 :9larger (5190 :24 95 :25 102 :2 110 :9,

1 1largest (1 ) 58 :1 2last (21 ) 7 :1,25 11 :5,19 17 :24 32 :11 35 :6,10,18 37 :24 38 :22 47 :18,20,22 48 :5 51 :1556:6 02 :20 68 :369 :14 97 : 6

lastly [4] 12 :9 64 :20 69 :6 102 :5

lasts [1] 31 :24late [4] 6 :19 14 :22 87 :1 116 :22later [5] 9 :25 13 :24 46 :1 62 :22 75 :5

lateral [5166 :24 72 :24 73 :13 79 :1682 :2 4laterally [1] 74 :16laura (215 :10 115 : 6law [3[ 102 : 6 103 :19 109 :4laws (2) 19 :1657 :25layer (2] 75 :4 76 :16layered [1] 86 :1 7lead (5)3 :16,177 :1942:860 :14leaking [1125 : 8leaner [1184 : 3learned 13)28 :21 80 :18 82 :12least [3] 16 :22 22 :18 67 :23leave [8] 30 :8 50 :2 77 :18 78 :23103 :23 104 :9 107 :15 113:9

led [1] 48 :2 4left [10]45 :13 56 :24 61 :10,11 84 :25 85 :1,21 100 :7,8 106 :24legal [9] 102:12 104 :20 106 :15,18107 :6,10,15 109 :16 114 :3

legally [11113 : 8legislative [4] 5 :7 70 :4 102 :2 5113 :24

lend [1] 9 :16length (1 ) 65 :9less [9] 72 :1485:14,18,23 86 :1,2100 :7 104 :8 105 :1 1

letter [32126 :21,24 27 :1,2,4,19 30 :22 36 :2345:1,3,5,23 46 :1,2,18 47 :19,2348 :1,1,4 96 :22 97 :4,15,16,1699 :2 100 : 10 103 :25,25 104 :25105 :2 111 :3

letters [1178 :1 2leussier [7] 50 :11,11 51 :11 52 :4,8,14,1 6

level [28] 9 :22,23 12 :24 19 :17 29 :5 ,

1-800-288-3376

HDMSP00134610

level - nea r

633 :1338:6,1339 :1341 :1124,2550 :2123 53 :17 55 :19 80:19 81 :382 :9 97 :21,22 98 :1,7 101 :5 103 :1 5

levels (»119 :12 21 :20 22 :3,5,8 23 :738 :1951:961:1471 :788:897 :8103 :24 109 :9 111 :13 112 :13,14license [7134 :12,20,2235 :1480 :20 86 :7 104 :2 1licensed (11130 :1442:24 51 :2381 :1482:1397:2103:5,12113 :3,11,1 2

licensing (11107 :12light (U70 : 3limit [6(34 :18,21 40:9,25 54:22 96 :7limited [ 1 ] 88 :1 8limits [7] 3 :6,7,9 8 :5 21 :9,14 100 :6line [3) 66 :18 93 :9,20liner (3166 :4,16 69 :11lisa [2) 47 :6 55 : 4list (618 :25 9 :9 35 :9 37 :15,17 47 :

1 6listed [2(2 :2435 :13listen [1122 :4literature [1] 87 :1 2little [11] 15 :8 27 :13 52 :17 60 :7,1761 :23 66 :2 71 :13 72 :13,14 80 :22live [1 ] 83 : 5lived [2] 59 20 83 :1livermore [ 1) 55 :19lives [2]25 :3 113 :6living [1) 57 :1 8to [1] 15 :2 3local [22) 42 :17 59 :2484 :11 88 :11,17,23 89 :3 90 :3,5,8,12,17 93 :5 95 :296:9,12,1697 :8,9,11 109 :21 .21

locally [1) 90 :1 3located [ 1] 65 :4location [3123 :21 24 :4 .6locations [7122 :1924 :20 86 :16110 :7,19 111 :17,1 8

logger [1] 65 :10long 12)44:1 103 :11longer [[24 :13 91 :7,11,12look [36)7 :3,4,5,8 25 :2,13 27 :21,24 28 :17 30 :1037:844:446 :1 63 :1268 :1978:691 :2592:1 86 :1788 :6 91 : 15 92 :11 96 :2,10 97 :2598 :17 99 : 5 100 :22 101 :2,2,7 109 :20 110 :19 112 :17,17,22

looked [4]66 :9 67 :18 95 :19 111 :1 1

looking [5] 7 :12 10 :18 58 :21 66 :22112 :1 9loose [4] 16 :4 50 :3 62 :15 63 :1lopez [83] 6 :9,9 7 :3 8 :9,25 9 :7,9,1510 :1,1112 :2013:1,10,1514 :2,1915 :7 16 :10 17 :16,18 18 :3,8,15,18,23 19 :8,11,2522 :22,2423 :9,13,20 24 :1,5,9,17,23 25 :1,12,18,2026 :1,5,14,17,21 27 :2,1428 :11,1529 :21,24 30 :2,10 31 :4,7,18 32 :2,13,1733 :8,12,21 34 :1,344 :245 :1,17,21,25 46 :17 47 :25 48 :8,11,15,17,2449 :1,4,7,10,12

los [5] 14 :25 15 :1 55 :22 58 :13 67 :6losing [1] 91 :1 6lost [1) 73 : 8lot [12] 11 :17,24 15 :24 16 :8 19 :1438 :9 48 :17 50 :13,1652:283 :3109 :1 1

lovely [1] 115 :2 0low [4) 42 :2 51 :9 66:21 100 :11low-permeability [1168 :16

9A032F 1low-shrinkage [1) 84 : 6lower (8] 61 :3,19,24 62 :7,14 63 :1580 :24 86 :1 1

lowery (31113 :21 114 :20 115 :18lowest [1123 :6luis [1)42 :16luminescent (1151 :1 9lupo [38] 6 :2,2 86 :9,21 87 :4,7,9 88 :2289 :2,6,9,14,1990 :11 91 :3,6,10,14,20,24 92 :25 93 :4,9,11,23 94 :2,19,2295 :11,17,23 110:13 ,21 111 :5,10,17,20,23

lysimeter [3) 64:23 65 :25 66 :1lysimeters (1) 64 :2 1

Mm-a-d-e-I-i-n-e [1] 56 :7m-a-s-o -n [1] 50 :4m-i-I-I-i-k-e-n [1167 :1 2made [22)4 :891421 :21 27 :25 33 :1457 :364:2368:569:1070:1372 :19 78 :11 101 :10 102 :10,11106 :8,22 114 :8,9 116 :6,11

madeline [2) 56 :5, 7magnitude (4)13 :14,14 86 :2 94:

1 6mail [11117 :15mailed (1)37 :18main [2) 62 :19,24maintain [2) 53 :18 102 :14maintained [1] 71 :23maintains (2) 83 :24 102 :9major [1] 12 :1 6manage [1) 70:20management [2) 23 :16 33 :13manager [1] 5:2manipulated [1] 95 :22manufactu rers [1] 24 :10many (41 13 :14 36 :4 83 :2 102 :3map [2] 25 :2 63 : 5mapping [1] 63 :4market [1)44 :16marks [1111 :6ma rvelous [1152 :25mary [1] 50 :4mason [2] 50 :4, 4mass ]]67:3 77 :17,18 78 :22,23material [37) 11 :18 23 :14,18,2425 :8,9,23 30 :6 31 :4 .9,10 61 :10 63 :1,2,16 64 :7,12,18,25 75 :9 76 :19 80 :2481 :13,5,10,11 .2282:286 :789 :22 104 :23 107 : 21 108 :6,10,16,20materials [24] 11 :12 24 :24 25 :10,1626:5,1029 :3,6,1930 :14,15,2534 :12,20 47 :24 48 :2 51 :23 70 :16,1797 :2,3 107 :7 109 :1, 2

mathematically [1] 57:19matter (316 :15 113 :20,24matters [1] 93 :1 9matthew [1] 50 :11maximum []85 :17 93 :5,21mclaren -hart ]]87 :11 88 :7,12 95 :10,19 98 :4 109 :23 110 :15,18

mclaren -ha rt 's [1] 95 :2 1mda ]]97 :22 101 :5 111 :13mean [8) 9 :21 15 :16 51 :15 78 :2491 :12 101 : 4

meaningful [1] 47 :1 3means [61 13 :6 51 :7 53 :5 57 :19 94 :20,23meant (1)11 :17meantime (1) 94 :13measurable [3) 29 :4 30 :6,7measure [14]41 :25 66 :23 67 :2171 :25 77 :1,25 79 :12,20 80 :1 84 :4,992 :1,6 112 :2 3

Atkinson-Baker,Inc

measured [2184 :5 92 :5measurement [2141 :24 110 :19measurements []39:10 96 :4,8,17109: 6measures [12111 : 11 54 :9 60 :1462 :6,18 63 :23 68 :11 72 :21,22 78 :6,20 79 :1 4meat [116 :15media [1] 58 :1 0meet [(59:19 102 :19 ,21 103 :20meeting [28)2 :5131625 3 :14,214:4,11,246 :197 :14 14 :24 15 :3 35 :2,10 36 :13 37 :24 54 :8 55 : 6 58 :22

'59 :2584:25111 :25 114 :24 117 :8,13,15,1 7

meetings ()4 :16 6 :21 58 :10member [4]5 :10 6 :16 35 :22 80 :7members (25)3 :51920234 :1 6,,19,20,21 5:12 7 :16,23 9 :3 12 :2 122 :14 32 :23 50 :9 54 :12,12, 1-9 61 :1670 :272 : 884:12117 :9

memo [7114 :717 :2,2368 :9,10,1169 :1 0

memorandum (1171 :1mention (6)44:251 :1 64:2 85 :10105 :16 114 :1 0

mentioned [8] 35 :6 46 :18 48 :4 51 :11 65 :6 70 :19 71 :1 111 :13

mentioning [1] 63 :2 2mercuries (1)113 : 2mercu ry [(48 :21 23,24,25 61 :15message [21 112 :6 117 :1messages [1 ] 112 :1 5met [2] 20 :3 32 : 9metal [10123 :17 25 :5 ,11 26 :11 27 :8,9 28 :3,25 60 :20,2 2metals (2] 28:25 29 :1method (1] 102 :1methods (1 ) 89 :1 0microphone [6(4 :3 10 :10 47 :2 54 :2482:1584 :1 3

might [16] 6 :25 11 :9 36 :22 37 :6 41 :944:245 :746:1951 :1856:2565 :15,16 66 :23 67 :2 86 :18 94:8

migrated [1(77 :1 9migration [3] 68 :12 ,15 79:16mike []6 :9 13 :19 16 :12,20 19 :228 :1 46 :25 47 : 4

mile [2) 57 :17 62 :10milestones [1] 33 :8milliken [2] 67 :9,1 2million [5] 93 :25 94 :5,20 108 :12,

1 4millions [1] 32 :24millirem [2] 51 :6 105 :20millirems [11)20 :20,22 21 :2 50 :2553 :5 85 :16,24 87 : 18 100 :6 104 :4,9

mind [3] 19 :13 84:18 94 :7minds [2] 22 :4 54 :20minimize [1] 68 :24minimum [3141 :23,23 55 :19minimus ]]105 :7 106 :17,19minor [1)8 :1 1minus [9) 67 :14,15 75 :11 87 :20 93 :24101 :4108:25,25 111 :23

minute [ 2] 15 :8 21 :1 5minutes [9)7 :20,20,21 54 :12,2381 :13 84 :25 87 :2 110 :4

missed [117 :25missing [2] 32 :10 108 :23mistake [1] 51 :1 7mixed (11(80 :15,2081 :6,8,10,11,16,24 83 :15 113 :12 114 :4

mixing (1)102 :5

model (2(72 :11 99 :23modeling [4] 21 :4 68 :19 85 :22105 :2 4models [1] 99 :21modify (1)3 :8moisture [24( 649,10,12,13,16,17,22,23,24 65 :7,13,17,20,21 66 :568 :12,15,24 69 :20 75 :8,8 76 :7,983 :2 4

moment [8] 2 :17 29 :25 30 :4 36 :1270 :12,23 92 :16 96 :1 0

money [3117 :6,7 71 :19monitor [6] 51 :20 58 :1469 :1,2276 :11,1 2monitored [1142 : 5monitoring (15142 :6 50 :17 63 :18,2464 :1,21 65 :7,24 69 :1,15,16,2276:3 77 :10 79 : 8monitors (1(51 :14monolithic [1) 66 :1 2month [6] 27 :12 32 :1 44 :8 49 :1062:20 75 : 5months [8] 25 :6 31 :23 32 :6 44:952 :13,14 64 :15 80 :11

moratorium (1(5918morning [3] 14:12 56 :13 87 :4most [4156 :16 57 :2262 :884 :17mostly [1(45 :1 0mountain (1) 112 : 4move [19] 24 : 11 28 :1936:1543 :854 :9,18 60 :13 73 :1 76 :21,24 82:10 84 :24 109 :11 111 :2 113 :3,19115 :19,21 116 :1 6

moved ]]46:948 :2 .18 108 :20113 :1 0

movement [1169 :1 8moves []46:22 114 :2 115 :24moving (8119 :3 30 :18 50 :14,16,1880 :10 113 :7 116 :2

ms ]32)51O,1€,22 6 :7,23 9 :22 14 :1523 :1,1247 :5,9,18,21 48 :5,1049 :3,5,8,11 50 :4 55 :3,13 56 :4,757 :10 70 :776 :13 79 :6 82 :18,21112 :12 116 : 6

much [2512 :22 17 :1 30 :1 31 :1933 :1 43 :23 46 :23 54 :25 55 :9 59 :1760 :11 62 :8 63 :12 68 :24 69:25 70 :1,971:2085 :1486 :1 87 :3 102 :2105 :11 111 :14117 :1 6

multiple [1] 59 :2 1municipal [5] 26 :10 28 :25 49 :1767 :8,20municipalities [1)67 :25must [5] 31 :1 36 :9 49 :19 68 :11103 :1 9mutual [11591 1

n-e-p-a (1(9 :15na [ 1 ] 87 :1 5name [1412 :6 25 :13 35 :7 37 :19 47 :2,6,7 54 :24 55 : 10 56 :5 82 :19,20,21117 : 3

national [22(53 :1758:4 67:17 68 :21 75 :22 87 :12 88 :8,10 89 :22 90 :6,10,14, 18,19 93 : 13 95 :1,3,7 98 :1105 :6,8 106 : 4

nationally (1) 106 :2 0natural (6161 :21 87 :23,23 92 :1094 :17 98 :1 3

naturally (2] 88 :24 91 :3naturally -occurring (1) 94 :9nay [117 :1 0nays 11)7 :12ncrpm [1198 :1 2near [6)49:5 65 :16,18 1003 110 :

1-800-288-3376

HDMSP00134611

near - Plotki n

16 113 :1 8necessarily 12140 :18 94 : 2need [3216 :18,22 21 :5 30 :10 44 :7,18 46 :17 52 :20,20 53 : 17 54 :2 56 :11 72 :25 76 :8,21 77 :11 78 :3,5,19,2579 :2381 :2592 :11,13,1496:2397 :2 109 :3 113 :2,9 114 :19 116 :19needed (1127 :21needs m 29 :8 46:21 59 :19 67 :182 :10 109 :7 112 :18negligeable 121105 :17 107 :3negligent (1] 57 :21negotiations [1] 78 :10nelson (1156 :1 5nepa [2] 9 :13 55 :9network (1165 :7neutrons [3] 91 :5,6,1 1never (9] 59 :2 60 :6 84 : 18 100:14,18 103 :7 104 :15,20 107 :23

new 15134 : 23 68 : 1 98 :5 103 :4 104 :1 7

newspapers (2] 58 :17 59 :24next [28] 3 :13,14 6 :19 9 :19 10 :16,25 11 :19 12 :12 27 :16 32 :1 33 :4,18 37 :15 44:8 49 : 10 53 :1 56 :3 62 :1380 :11 81 :12 84 :24 85 :1 93 :499 :20 104 :1 117 :4,13,1 7nice [1] 18 :5nine [119 :8non-hispanics (1157 :10nonagenda [313 :24 54 :17 55 :2none [4] 71 :14 72 :5 97 :4 115 :23nonimpacted (1141 :5nonradioactive [2199 :15 106 :6nonsense [1172 :1 8normal [1165 :15normally [3141 :20 88 :3,20north [311 :22 25 :1 62 : 1note [4144 :20 56 :25 70 :3 88 :20noted [2130:20 42 :2 1nothing [5] 28 :16 52 :22 68 :1 76 :10 116 :1 6

notice [8] 35 :5 44 :17,22 45 :4,1246:21 53 :24 70 : 3notification [4] 37 :2 45 :2 57 :2058 : 6notifications [11 117 :14notified (4110 :17 44 :24 59 :2,22notify 11 ) 56 :1 0nowhere (11 110 :1 6me 116] 20 :16 ,17,20,23 21 :8,23 34 :23,25 35 :1 51 : 1 53 :15 ,17 81 :2282:1 94 : 2 105 : 9

nrc's (1 ) 22 : 1nuclear [2] 94 :23 97 :1 0number (2513 :4 7 :14 11 :7-,16 35 :737:1940 :844 :3,1367 : 18,2585 :21 87 :19 89 :8,9 91 : 11 96 :3 97 :2499:20,23 100 :25 101 :1 106:12,12110 : 9

numbers 116187 :22 88 :1,4 93 :12,12,23 94 :25 101 :3 105 :25 109 :20110 :14,15,16,17 112 :20,2 1

0

o'bispo 11142 :16oakridge [ 1155 :18oal (1 ) 35 : 4object (1154 :5obliquely [1171 :1observed [ 1138:1 0obviously [ 6] 19 :9 31 :24 39 :13 43 :13 52 :2 95 :25

occasionally (2) 3 :8 7 :15occur 12176 :22 91 :2occurred 12161 :1 63 :14

9A032F 1occurring 13188 :21 ,24 91 :3october 14110 :3 31 :17,18 68 :9off-site 12143 :4 47 :23office 1816 : 11 43 :15 50 : 1 56 :14 96 :22 115 :12 116 :20 117 : 4

offices (2152 :19 113 :24official (3]4 :5,14117 :13oils [1] 61 :1 1okay [3415 :5 6 :18,25 8 :6 9 :6 10 :123 :13 30 :18 32 :3,17 36 :3 39 :24,25 40 :3,19,20,22 41 :3 42 :3 46 :2549 :22 53 :5 54 :18 60 :16 85 :6,7 93 :11 97 :23 99 :16 100 :2 105 :12,20106 :9 116:24

old [2127 :6 33 :5older 11142 :19on-site [2175 :1 84 :1 5once 1512 :15 4 :14 54 :23 63 :9 81 :24

one (4618 :8 10:23 11 :5,7 14 :12 18 :2327 : 1534 :436 :241 :1547 :18,20,22 51 :12 52 : 8 56 :16 57 :17,1958 :22 59 :3 64 : 2 65 :6 66 :14,22 68 :372:874 :1475 :1880:583 :6,10,21 85 :1,20 92 :16 93 :4,25 94 :5 97 :6 105 : 10 108 :11,14,21 110 :24112 :18 117 :1 0

one-in-a-mil lion 12193 :18 108:5one-third [1136 :1 3ones [4118 :3 26 :9 45 :11,15ongoing [1] 62 :1 7only [2217 :12 14 :16 24 :20,23 31 :11,2434 :1735:2436;1341 :1949 :14 51 :12,12 54 :12 58 :19 ,20 81 :985 :20 97 :20 99 :10 100 :25 110:4

cops [ 1110 : 1open [4146 :24 65:5 70 :10 82 :14opened [1( 3 :1 8operated [1123 :16operates [11 109 :4operating (2168 :2 69 :21operation (2 ) 65 :5 69 :3opinion [1] 80 :4oppo rtunities 11178 :8oppo rtunity 13117 :14 54 :19 55 :3opposed [1155 :20opposing [1170 :11option [1173 :6options [2] 78 :7,24order 15116 :12 56 :10 71 :18,19 94 :1 6

orders [3113 :13,14 86 :1oregon [1] 58 :20organic [1] 33 :23organization [3] 5 :14 6 :4 55 :4orientation [1161 :17oriented [1] 61 :2 3origin [1158 :4original [214 :9 24:10originally [2110 :20,22other (4114 :21 7 :15 8 :11 9 :9,9 12 :12 22 :14,15 25 :11 31 :8 38 :21 44 :9 45 :7 48 :22 50 :9,16 55 :18,21,2456 :11 59 :3 65 :24 66:22 67 :5 68 :6,1969:1071 :21 74 :1575:1977 :1778 :22 8 0 :6 83 : 19 85 :18 96 :13 97-22 102 :13,25 110 :16 113 :24

otherwise [2192 :6 114 :16ourselves [1] 54 :1 1out [84] 2 :20 6 :20 10 :14,21 11 :1614 :21,22,24 15 :18 16 :1,4 17 :8,1424 :17 25 :8 26 :25 27:24 28 :5 29 :731 :7 33 :11 34 :9,23 35 :24 43 :7 44 :7,745:13,1647 :11,1549 :1751 :17 52 :21,22 53 :2,4,13 56 :24 57 :

16,19 60 :7,9 64:4 65 :1,20 66 :2468 :1 69 :21 70 :24 72 :21 73 :2,4,675 :11 76 :22 78 :16 80 :10 82 :13,2583 :2 84 : 1,21 86 :3,15 88 :24 94 :2097 :23 99 :25 100 :18,25 101 :18102 :18 107 :13 108 :6 111 :7,8,15114 :22 115 :2,10,10 117 :4,10

outlined 12162 :9 68 : 9outside 14141 :6 54:6 109 :8 110 :23

over 121111 :16 17 :13 56 :17 66 :1771 :3,1075 :1981:283 :884 :1 94 :4,16 97 :5 99 :15 101 :21,24,24 102 :3108 :16 111 :25116 :23

overall [2] 32 :22 101 :8overheads [1132 :16overlain [1166 :16owensmouth [ 1160 : 2own (131. 16 :15 20 :8 58 :17 70 :2577 :4 96 :7,10,17,19 97 :4 103 :13111 :8,1 5

owner 12135 :13 42 :2 3

P

Atkinson-Baker,Inc

P .m 1511 :12 2 :2,25 3 :1 117 :19package 1419 :4 35 :3 87 :7,8packaging [ 2111 :23,25packet [ 1111 :1 0page 13132 :11 56 :25 95 :18paint [1148 :24pan 14164 :21,23 65 :25 66 :1panel 14170 :2 , 10 85 :10 115 :25paper [2139:17,19paragraph (1157 :1parameter (1) 99 :22parameters [1] 84 :4pa rt [12116 : 25 24 :14 27 : 16 37 :21,22 46 :19 62 : 14,22 63 :16 64 :6 85 :3 115 : 7partially [2136 :5,1 0particular [414 :19 68:22 100 :24105 :23parts [ 1142 :8pass [216 :1 39 :24passed 11160 :3passes (1165 :18passing ( 1) 83 :14past [11116 :6pathways [2151:7 85 :17pathyway (1) 85 :22Pauline 1.115 :16

-pauline ' s (1147 :12pcb's [ 3161 :12,14 113 :2pedro [1] 23 :17pendency [1] 33 :20pending [1]25 :1 5people 12413 :1 9 :17,18,20 35 :2350 :12 51 : 3 52 :18 53 :21 54 :4 56 :24 58 :19 59 :1 60 :6,7 91 :25 94 :2099 :22 100 :1,10 ,20 102 :25 106 :9115 :25people's [1123 : 3per 110120:20,22 21 :2 51 : 1 85 :1689 :24 90 :6 93 :21 94 :14 108 :15percent 19132 :18 41 :24 57 :18 71 :13 74 :10 75 :9 102 : 2 105 :22 111 :1 4percentage [ 1] 74 : 8percentile (4195 :15 102 :3 103 :16109 :24

pe rform [4168 :23,23 76 :6 84 :6pe rformance 113164 :18 67 :11,15,22 68 :19 69 :1,20 73 : 6 75 :23,24,25 76 :12 77 :1 0

pe rformed [1] 38 :10performing [3166 :22 69 :2 76 :4

pe rforms (1] 68 :22perhaps (1) 25 : 3period 1913 :20,23 30 :18 52 :12 54 :17 60 :12 66 :8 67 :1 68 :4

periods [1] 51 :3permanent 12152:4,6permeability ( 4166 :21 67 :13 75 :10,1 1

permeable [2171 :2 83 :25permissible [1] 94 :25permission (1) 84 :23permit 151105 :3 106 :16 107 :6,20111 :2

permitted 12130 :8 103 :3permitting [1182 :1 1person (6135 :7 41 :8 43 :15 52 :4107 :4115 : 3

person 's 11137 :19personal 1114:23personally [1116 :2personnel 11171 :7persons [1] 57 :20petition (1] 54 :5phase [31 12 :4,10 78 :6Phelan [3] 67 :9,13,14Phil [1137 :1 9Philip [1( 37 :19philosophy ( 11100 :10phone [2136 :7 37 :1 9phonetic [5] 44 :16 55 :8 58 :13 83 :1 113 :2 1

pick [3152:9,9,12picks 11140 : 5picocuries (5189 :24 90 :5 93 :2194:14 108:1 5picture [3122 :3 33 :7 101 :8piece [2171 :3 75 :13piezometers 13164 :3 69 :17,18pinned [11110 : 5pipeline [ 1159 :12pipelines [1159 :9pit [26110 :8 29 :17,24 54 :10 60 :14,1861 :1866 :2570:15,15,1678 :580 :10 82 :24 86 : 10 88 :16 90 :25 96 :8,18,20,25 97 :1 103 :10 108 :7,16109 : 9

pits (1) 71 :22place (14115 :9 24 :8 49 :15 63 :2065 :2,19 70 :18 71 :9,17 76 :19 88 :24 99 :11 106 :24 112 :1 1

placed 15127 :9,10 61 :2 75 :8 88 : 5places 14119 :21 24 :8 82 :13 90 :2 0

( 1] 68 1 6l iac :p n gplan [141 9 :11 11 :8 ,20 27 :20 46 :1 762 :9 63 :23,24 64 :2,21 69 :7 79 : 980 :3 86 :1 3planned [3133 :25 45 :15 65 :23plans [4116 :13 17 :24 31 :5 48 :11plant [1] 78 :1 4planted (1176 :20planting (1176 :1 4plastic 110171 :3,22 73 :13,17,19,2 174 :21 75 :13,15 77 :5play [1] 7 :25plea [1] 58 : 7please [2012 :21 5 :14 9 :6 , 14 10 :941 :15,18 47 :3,4,7 56 :5 57 :9 73 :2575 :18 , 19 84 :13 92 :16 99 :17 100 :23 112 : 5plenty (2178 :8,2 4Plotkin 15 71 5 :10 , 10 12 :22 13 :4,12,17,21 14 :7,16 15 :5,8 16 : 11 17 :9,11,17,20 18 : 5,10,16 , 21 19 :1 ,10,13,20 20 :7,9,13 21 : 6,13 30 :23 38 :2339 :6,8,21 40 :10 74:14,19,25 75 :3 ,

1-800-288-3376

HDMSPOO134612

plotkin - regulatio n

13,17 76 :6 89 :21 90 :5,12 93 :16,2594 :3,10,13,20108 :1,11,14,22109 :20 110 : 4

plotted [1] 65 :14plug (1] 105 :25plumes 11159 :6plus [11101 :4plutonium [2] 96 :10,14podium [11111 : 5point [30] 14 :6 22 :10 26 :18 34 :451 :25 52 :17 54:8,19 57 :16,20 60 :3 62 :24 63 :3,5 69 :10 70 :11 79 :680 :4 82:1787 :13 92 :12 99 :25 102 :9 105 :6,9 106 :6 107 :6 111 :24-112 :2,1 8pointed [1] 72 :21pointing [1] 65 : 1points [4] 88 :13 90 :25 97 :21,22poking [1] 73 :4policies [1] 50 :1 9political [3] 58 :3 72 :14 76 :24politics [2177:3 113 :1 4pond [9] 61 :3,19,24,24 63 :15 80 :24,25 86 :11 101 :1 1

pool-bath [1160 :21poor [1(28 :15population [2] 57 :7 98 :12portion [1(35 :2 4position [4130 :2 34 :24 49 :12 115 :4

possibility [2112 :11 19 :1possible [413 :9 26 :19 92 :3 100 :

1 1possibly [1] 92 :2post [1(43 :16postcleanup [1] 14 :9posted [114 : 3potassium 114188 :9,15,18,20,2589:14 90 :13,22 91 :2 .10 .12 .18 92:4, 8potato [1(83 :1 3potential [4128 :8,9 43 :5 44 :17potentially [1164 : 6practice (8125 :14,16 26 :9 27 :1229 :8,13,14 30 :1 3

precisely [1129 :11preclude [1169 :12predict [2] 77 :5 78 :2prediction [1] 76 :25prejudgment (1] 32 :8preliminary ([27 :20 38 :13 56 :18,1957 :1 58 :11 59 : 3

premise [2] 95 :17 100 :7prepare [2] 11 :1 54 :10prepared [1188 : 8present [4] 5 :7 8 :23 70 :11 109 :10presentation [17 :20 9 :1,24 12 :1921 :1769 :2580 :17

presentations [2] 3 :16,17presented [2] 22 :21 33 : 9press [2158 :20 59 :24pressure [2152 :19 71 :6presume [1195 :4pretty [9115 :18 16 :22 62 :8 67 :1568 :2,22,23,24 69 :2 5

prevail [1] 108 :18prevent [1] 67 :1previous [1] 10 :7primarily [1160 :19printed [1] 58 :20prior [2] 20 :22 87 :6private [1] 26 :11privileged [11104 :19privy [1] 60 : 6probably [1116 :1944:954 :1 55 :

9A032F 11062 :12,2065 :1 76 :11 106 :1,2108 :2 4

probe [ 1] 65 : 8probes [8] 64 :9,10 , 12,16 65 : 7,8,1669 :20

problem [9] 7 :6 16 : 7 37 :4 60 :2573 :1375:15 112 : 20 116 :3,5

problems [5] 15 :13 74 :14,17 83 :21103 :2 0

procedure [2151 :17 52 :16procedures [2] 50 :15,19proceed [1] 28 : 1proceedings [2] 1 :10 117 :19process (16) 18 : 20 26 : 7 45 :14 51 :2,5 53 :20,25 54 :5 72 :13 78 :3,8,12,20 84 :10 100 :12 102 :1 3

produce [2155 :14,15produced [1191 :22produces [ 1 ] 92 :8product [1] 89 :15products [ 1193 : 1profile [ 4 ] 24 :9 , 15 38 :3,18program [2151 :23 81 :20prog ress [1] 82 :14prohibit [1149 :13prohibited [1180 :1 5project [8(5 :29 :1,2,20 12 :15,1767 :22 68 :22

projecting ]110 :13 11 :10 32 :4projection [2] 31 :8 32 :2projections [ 1119 :8promulgated [2151 :5 53 :15promulgation [ 1 ] 20 :2 3proper ['7117 :6 18 :2,11 27 :11 108 :4,5 112 :1 0

properly [3] 16 :23 19 :15,22prope rties (1126 :1 1property []48 :3 71 :9 72 :7 78 :14prophenal [ 1161 :11proport ionally [1(52 :1proposal [4120 :24 27 :21 99 :20105 :1 8

proposals [ 1] 66 :14proposed [ 3135 :6 37 :18 53 :24proposing [ 1(72 :23protect [1] 70 :14protected [ 1172 :15protection [ 1 ] 66 :2 0protective [7 (68 :7,8 71 :25 72 :2473 :3,5 79 :2 4protocol [ 1] 28 :5prove [2] 77 :7,8proved [2] 73 :12 98 :24provide [514 :13 31 :1 66 :19 85 :23

115 : 5provided [614 :7 8 : 10,12 14 :-3 25 :10105 :1 8

provision [2169 :11,14prowler [2] 23 :17 25 :11pscott@dhs . ca .com [1] 37 :20public [25132 : 24 46 :25 50 :13 51 :452 :17,18,20 53 :23 54 :23 55 :24 60 :1266:772 :973 :2578 :8,11,1279 :4,24 80 : 6 83 :19 105 :2 107 :18 112 :25 117 :1 1

public 's ['[53 :10public -comment [1] 54 :17publications [ 1 ] 58 :20publish [ 1(58 :17published [1195 :3puddle [1 ] 75 : 4pulled [1165 :20pump [ 2] 11 :20 12 :2pumping [1165 :3pure [1174 :8

Atkinson -Baker,Inc

purpose [ 1 ] 38 : 9purposes [3 ] 32 :6 71 :21 98 :17put [2619 :17 13 :7,8 17 :3 19 :2 22 :11 23 :18 29 : 1 34 :939 :4,1944 :351 :14,17 52 :19 60 :21 70 :13 71 :3,9,10 72 :2,12,13 75 :4 87 :16 90 :23putting [3135 :3 71 :24 116 : 7

Qqualified [1]48 :20quality [4166 :11 67 :669 :23,23quantified [1] 66 : 6quantify [2] 64 :24 69 :19quantity (1] 104 :22qua rter [2] 38 :22 62:1 0question [23] 8 :16,20 11 :5 16 :9 17 :9 21 :5 22 :24 23 :11 28 :7,7 30 :1945:650 :1251 :1455:1680:581 :2,1089 :21 90 :21 101 :14 105 :5 115 :5

question-and-answer [2] 3 :20,23

questions [18] 3 :18 4:2 7 :21 8 :229 :19,25 22 :21 31 :3,12 35 :10,1037 :10 56 :10 70 :2 87 :6 101 :15 102 :5 117 :9

quick [[31:1247:5 52 :24 84 :14108 : 1

quickly [312 :23 22 :16 32:16quite [5] 17 :19 43 :7 84 :3 88 :16116 :1 1

quote [3]34 :18 57 :7,1 1

Rre-s-r-a-d [1] 99 :25race [ 1158 :2rad [2] 45 :2 81 :5radiate [3191 :4,6,10radiated [ 1 ] 96 :2 1radiation [13] 38 :6 39 :3,1348 :7,850 :24 51 :21 52 :11 53 :11 60 :24 61 :494 :5 98 :1 3

radio [1] 58 :1 2radioactive [50] 10 :5 11 :12 25 :6,7,8,17 28 :22 29 :4,22 30 :7,14 32 :1533 :16 34 :12,19 51 :23 58 :8 70 :15,1780 :12,1881 :10,11,21,2382 :1,3,5,7,12,13 85 :5 86 :7 97 :2 99 :12100 :15 103 :3,5,9,12 104 :2,3,16107 :17,21 108 :7,10 111 :1,4 114 :5

radioactively [1] 30 :1 3radioactivity [16] 19 :16 29 :7,1830 :740:1742:550 :21,23 80 :14,1881 :1382:985 :1496 :20100 :16,1 7

radiochemical [1] 100 :22radioisotope [2185 :20 86 :1radioisotopes [1] 94:8radiological [1616 :3,5 8 :10 11 :13,2312 :713:116 :824:2426:1427 :16,22 28 :8 34 :1437:2485 :12

radionuclides [2] 5917 87 :18radiosodium [1133 :23rain [4] 64 :16 65 :17 71 :4 72 :4rainfall [11691 2rains [2]71 :4,1 2raised [5(45 :646:449 :23,23 104 :1 3

ranch [4] 23 :18,19,24,25ranchers [1149 :1 7range [25138 :5 67 :1488 :11,23 90 :117,18 93 :1395:9,10,14,1596 :297 :15,16,17 100 :15 103 :16 106 :3108 :23,24 109 :24 110 :10,25 111 :1

ranges [4168 :17 89 :393 :5 100 :21

rate [1162 :1 1rather [2123 :5 40 :1 2rcra [14] 12 :9 66 :15 67 :19,20,23,2372 :9,19 73 :15,17,20 75 :23 81 :2083 :2 1re-analysis [1] 38 :15re-analyzed [1157 :6re-look [1] 87 :9react [2160 :22,22reactive [ 1160 :19reactor [1] 60 :25reactors [2136 :21 89 :1 8read [7 132 :11 45 :5,2358 :1996:2297 :6,1 6

reading [13138 :639 :14,14,15,2340 :2,341 :3,11 52 :11 60 :5 90 :10,1 1

readings [1] 38 :4ready [2187 25 :21real [2158 :21 84 :14realized [1] 103 : 7really [2117 :23 8 :5 15 :13 16:21 21 :21 22 :10 26 :20 28 :17 42 :2,2 52 :20,20 79 :15,17 80 :3 81 :4 108 :4112 :15,16,17 113 : 1

reason [7] 14:21,21 26 :24 36 :2461 :13 91 :25 112 :2 3

reasons [3198 :18 104 :20 114 :9recall [2] 23 :21 36 : 3receive [1] 87 :5received [7114 :11 22 :19 24 :20,2442:18 43 :18 45 : 1receives [1178 :12receiving [1] 79 :8recently [1151 :13recess [1] 54 :14recharacterization [2] 18 :10,2 1recipient [1143 :19recognize [1155 :8recoNaction [21105 :21,2 1recommendation [2172 :19 77 :4recommendations [1] 57 :3recommended (3]71 :2 72 :1,16recommending [1] 112 :7reconditioned [1] 28 :23record [2149 :20 105 :2recorded [1]4 :4records [1] 25 :10rectangular [1166 :3recycler [3]23 :17 25 :5 28 :4recyclers [3] 25 :11 26 :11 29 :1recycling [1127 :9red [2] 83 :12 88 :11reduced [1] 20 :24refer [2] 16 :5 100 :23reference ][90:1992:13,1 7referencing [1] 98 :1 6referred []61 :1862:2 64 :21 66 :15100 : 5referring [2124 :6 35 :17refining [114 :15reflect [1] 46 : 3refuge [ 1] 48 :6regarded [2] 106 :5,6regarding [12] 2 :2035 :11 48 :1,558 :11,24 59 :3 69 :10 71 :1 79 :12,15,1 9regional [2 ] 56 :14 66 :11register [1] 51 :20registry (3)56 :14,18 57 :14regular (1] 89 :23regulate (2)81 :5,6regulated [1181 :25regulating (1)42 :12regulation (2135 :3 106 :1 2

1-800 -288-3376

HDMSP00134613

regulations - site-wid e

regulations (]53 :19 81 :22,23108 : 9

regulatory [7] 5 :1419 :23 34 :6,2453:8 105 :8 112:1 6related (2)11 :24 14:25relatively [3115 :2 82 :4 114 :18relaxed (2)68 :5 99 :9release [29120 :421:1434:13,13,1635 :12,15,2444 :1949:1350:20,2085 :15,15,1986 :2,4,6 87 :17 89 :1298 :23 99 :9 101 :12 102 :10,18,21104:4105 :12,1 3

released [12)34 :936 :5,10,11,1738:1 45 :11 46 :5 49:15 85 :11 91 :14103 :1 7

releases [1159 :24releasing [1] 100 :5religion [1158 :3remain [1165 :22remaining [1] 63 :18remedial [1)79 :7

remediated [2] 96 :24 109 :8rernediation [2] 14 :5 109 :10remedy [8) 72 :20,21 77 :14,15,22,23 78 :20 79 :1 3remember [4136 :24 92 :1 112 :23113 : 6

reminder [1] 117 :13removable [4] 40 :4,24,24 41 :1removal [9] 10:1246:11 48 :21,2161 :3 63 :14 80 :23 116 :10,13

remove [8] 27 :8 62 :25 63 :2,11 69 :377 :16,1778 :22

removed [134 :448 :12,13,14,1562 :8,16 63 :10 80 :2 3

removing [7161 :6,1362 :6,12,14,15 65 : 3

repaired [1] 15 :1 8repeat (]9 :1443 :18 47 :14repea sdly [ 1 ] 99:11repetition [1] 113 :1 5repo rt [7] 11 :4 16 :5 38 :25 43 :2055 :9 56 :24 110 :1 4

repo rted [2] 1 :24 97 :7reporter [12] 4 :4,139 :1410 :941 :15,17,19 47 :3,7 54 :25 57 :9 75 :18

reports [2] 56 :23 95 :3represent [2] 55 :5 58 :23representative [3] 2 :6 56 :9 70 :8representatives I1] 5 : 8reps [1]70 : 4request [3130 :21 34 :13 35 :15requested [3]8 :11,1354:16requesting 11145 : 1require [2] 77 :6 80 :3required [3 ] 35 :1 55 :15 63 :23requirements (4) 34 :7 68 :7,8 99 :9requires (2) 52 :18 102 :6research [1) 60 :1 9researching [1] 59 :15residences [1] 71 :21resident [1152 :7residents [1] 57 :1 8residual 111129 :3,6,18 50 :21,2361 :1079 :2085:1494:25 100 :8104 : 7

resolve [4] 18 :18 43 :21 100 :2 114 :1 4

resolved [4] 11 :7 100 :2 114 :1 115 :24resolves [118 :16resolving [1113 :16resounding [1) 6 :14respect (2] 37 4 :21respectability [1] 55 :14

9A032F 1respond [3] 97 :13 99 :16 105 :5responded [1]45 :3response [7)30 :12 52 :24 57 :3responsibility [7)16 :281 :7,12responsible [1142 :1 0resrad [1199 :24rest [1] 62 :17restrict [1) 37 : 6restricted [5) 38 :1 45 :22,24 46 :848 :3

restrictions [1 ] 85 :1 3result [5) 3 :418 :24 97 :20 101 :8,9resulted [1] 89 :1 2resulting [2]40 :8105 :19results [3]20 :3 38 :19 67 :12resu rvey [3) 17 :4,22,25retreated [1] 68 : 7return [11116 :23reversal (2)71 :8 72 :4reverse [1] 77 4review [14) 2 :23 27 :23 46 :17 52 :1655 :19,20 56 :20 ,22 57 :16 85 :8 101 :9102 :12 110 :3, 4reviewed [4] 4 :6 29 :9 86 :1497:7rfi [8] 11 :3,1112 :3,1028 :2 33 :12,15 85 : 1

rights [3] 57 :23,24 58 :16rigorous [1] 101 :2 5risk [18) 50 :24,25 51 :10 87 :19 93 :1894:599 :23108 :5,11,14,23,24109 :13 111 :5,19 112 :14,17 116 :8

rmhf [5] 11 :12,22 12 :3,9 45 :17road [2) 37 :2, 5rock [ 2) 89:5, 6rocketdyne [21] 5 :22 15 :10,10,1620 :22 26 :25 27 :1,5 34 :11 35 :12,13,22,23 44 :16 58 :7 89 :16 96 :499 :19 100 :12,24103 :1 4

rocketdyne's [6] 15 :21 18 :16 34 :786 :696:19106:17

rocketdyne-santa [1] 56 :21rocks [1) 71 :1 5roger[7]6 :285 :788 :19 97 :13 110 :2,6 111 : 7

role (1[21 :25roll-off [1) 271 0room [5] 1 :11 7 :14 25 :3 58 :23 59 :8rooms [1 ] 60 :5rough [1)4 :1 1roughly [2] 62 :20 68 :17routine [1] 51 :22rule [7134 :23 43 :9 53 :15 87 :5 100 :18 105 :25 109 :1 5

rulemaking [9 ] 35 :6 37 :18 51 :2,553 :8,20,24 54 :4, 6rules [1514 :3,15,17,1943 :4,1047 :4 49 :12 54 :25 82 :3,4,5,6 94 :2 109 :3run [212 :25 75 :7rundown [1)62 :5runs [2161 :21 108 :2 4

Ss-h-a-n-d -o-n [1138 :8safety, [11107 :17sake [1) 90 : 8sam [1147: 9same [ 11] 6 :4 39 : 18 40 :2 41 :12,1866:4 74 :21 75 :25 87 :9 109 : 25 115 :18

sample [6] 24 :22 74:7 88:13 90 :1693 :4 101 : 9samples [24) 38 :7,11,24 63 :7 75 :686 :14 87 :13,14 88 : 14 89 :4,8,9,10,11 90 :1695:2396 :497 :21,24 100 :

25 101 :21 102 : 4 110 :9 111 :17sampling [)27 :7 38 :10 , 11 86 :13san [8)23 :15,1724 :2525 :1 42 :1656 :15 59 :12,1 3sandia [)67 :17 68 :21 75 :22sanitation [ 1) 39 : 3santa [912 :13,20 5 :23 19 :19 23 :18,2057 :1759:1260 :8satisfaction [2] 18 :16,17satisfacto ry [1] 18 :1 3save [1]7119saving [1) 54 :2 2saw []27 :19 31 :11 43 :15 58 :1075:22,24 -saying [17114:7 17 :2 30 :3 37 :1645 :3 46 :20 72 :1 75 :25 94 :17 99 :4104 :7, 7 106 :15 109 :14,15 112 :13116 : 1

says [ 18] 26 :3 27 :5 32:14 33 :22,23,2435 :20 36 :19 57 :1 60 :7 72 :1183 :14,15 ,16 97 :4, 5,17 109 :19

scan (1) 38 :1 3scandal [1 ] 103 :2schedule [813 :1010 :2317:632 :9,2247 :2262:17,23scheduled [5]2 :25 10 :22 11 :1012 :16 111 :25

scheduling [1] 116:13school [ 6] 38:3 ,8,9,11,16 86 :21schools [5) 24 :3,1342 :6,7 43 :14science (2)58 :1460 :5scotched [1] 14 : 1scoff [113719scrap [2] 25 :10 27 :8scrape [1 ] 63 :11scti [1] 10 :4seasonal [1 ] 64:1 3second [6113 :8 50 :6 57 :1 59 :1488 :19 109 :1 1

second -floor [ 1 ] 13 :10secondly [195 :2 100 :4 101 :25secreta ry [2] 115 :9,15sections [1 ] 9 : 5sediments [1 ] 89 : 7see E718 :3 9 :18 11 :15 12 :1,11 16 :2018 :5,11 29 :15 31 :3 32 :16,2533 :6,10 39 :21 40 :23 53 :1 55 :7 58 :12,13,14,14 63 :8,15,1865 :15,17,21 73 :5,8 78 :17 86 :18 88 :4,16,2593 :3,6,11100 :25 105 :23 106 :1108 :16 114 :20 115 :3,20 117 :2,17

seeing [2) 94 :24 96 :14seek [1] 35 :14seem [2] 23 :4 68 :1seems [2) 44 :21 92 : 5seen [9144 :21 75 :25 83 : 2 87 :2 89 :2396 :5,9,16,1 8

select [3) 77 :13,22,23selected [419 :12 66 :10 73 :23 95 :19

sell [1] 71 :20semones [1)2 . 5senator [3) 70 :8 113 :23 116 :20send [5) 15 :2,17 31 :8 80 :16 81 :4sending [2129 :7 30 :1 3sends [3] 2 :11 83 :1289:12senior (1] 71 :6sense [1] 48 :19sensible [1) 87 :6sensitive [2) 41 :25 54 :15sensors [2] 65 :9 76 : 7sent [17] 2 :20 4 :5 14 :12,13,21 26 :2527 :1,4,11 28 :3,24 49 :16 75 :696 :22 111 :3 112 :15 117 :14

separate [2) 24 :5 74 :17

separated [1 ] 81 :1september [616 :247 :9,12 10 :332 :3 117 :1 4series [2] 86 :23 88 :8serious (1] 16 :2 1serv ices [6] 6 :3,5 34 :1456 :21 57 :4104 :1 5

set m6 :1818:1961 : 864:11 66 :498 :5 114 :1 9

sets [1) 103 :20sett ing [2)3 :13,14sett led [11103 :2 1seven [8] 57 :19 60 :3 68 :17 84 :2586:14111 :17,17,18several [8116 :18 17 :24 22 :1548 :1959 :21 80 :11 90 :5117 : 9

sex [2) 57 :11 58 :3shall [1) 7 :5shandon [4138 :2,7,11,16share [1) 53 :1 1she'll [1)4 :1 .3she's [1184 :19sheet [1) 9 :17sheila [1] 5 :11sheldon [ 1] 94:8shining [1] 70 4ship [6 ] 26 :5 29 :19 31 :22 104 :11107 :15 109 :1 3

shipment [7153 :12 103 :6 104 :16,16105 :1,3107 :13

shipped [ 5128 :24 103 :4,11 109 :2,1 8

shipping [1)81 :14shoot [1) 73 :3short [1] 114:18shot [ 1] 86 : 9shouldn't [6146 :8 79 :13 90 :22 95 :

2 113 :16 116 : 5show [ 5] 25 :10 55 :9 96 : 19 100 :1925

showed [5138 :13 97 :20,2498 :18109 : 6

showing [218610 88 :11shown [3 ) 59 :4,6 103 :13shows [2] 23 :13 98 :17shrink [3176 :22 83 :20 84 : 1side [5] 23 :5 50 :8 64 :3 74 :16 116 :7

sideways [1] 74 :22sign [1) 2 :18sign-in ]1[ .35

signed [219 :10 35 :17significant [2] 106 :7 112 :1signing [1110 :1 3simi [6)1 :11 2 :1 58 :25 59:11 60 :283 : 7

simi-conejo [1] 1 :1 1similar [ 13] 38 :14,19 65 :25 68 :2093 :12 95 :20,23 96 :25 97 :15,17 99 :4105 :11 112 :14simple [1) 55 :1 6simply [3) 66 :19 71 :8 76 :23since [ 5] 15 :6 23 :1037:24 49 :1 695 :6sir [1110 :9sister [1 ] 103 :1 1site [42) 1 :2 2 :15 10 :25 14 :20 18:922 :9 24 :14 28 :3,4,12,24 30 :8 31 :22 35 :15 38 :25 41 :21 50 :14 51 :152 :6 53 :3 58 :11 74 :3,4 84 :20 85 :18,21 86 :14 90 :25 96 :23 100 :7,8103 :18,24 104 :9,23 107 :7 108 :20109 :2,2,10,17 113 :1 1

site-specific (1)21 :3site-wide [1) 34 :1 6

Atkinson-Bakerjnc 1-800 -288-3376

HDMSP00134614

sites - torn

sites [8119 :24 26 :10 42 :9 51 :2066 :13 95 :19 102 :19,21

sitewide [10)85 :15,15,19 86 :2,587 :17 98 :23 99 :8 105 :12,13

si tt ing [1) 52 :2 1situation [2137 :7 92 : 1six 110167 :10 75 :11 87 :20 88 :1693 :24 97 :20 101 :22 108 :25 111 :17,23

size [2190 :16 96 :1skeptical [1) 78 :18slade 1211 :13,24sleep [ 1150 :6slide [1161 :18slides 59 :4slippage (1112 :11Slow 46 :15 57 :9slowed [1126 :2 5small 16 :25 49 :2 88 :17small -•r (1) 110 :1 0smile. 11115 :20so -c ied [1)72:1 9soc ' conomic [1) 58 : 4sod ,n [22110 :4,5,11,19 11 :20 12 :2 29 ,21 54 :9 60 :14,17,18,20,22 6 18 78 :4 82 :23 85 : 11 86 :989 :' 91 :7,1 2

sods n-potassium [1] 89 :20soil 14 : 5 20 :18 21 :2,11,20,2022 : : 27:7 29 :24 30 :6 33 :2,6 34 :15, 3:7,10,10,15,24 50 :22 62 :8,15 , :9 64 : 8,10 66 :17,20 69 :1870:2 71:14 72 :19 74 :2,7,12 75 :11 7 1977 :580 :14,2482 : 985:4,14,2 25 87 :19 96 :23 96 :1,23,2597:' 00 :7,20 101 : 11 103 :14 106 :1 10') :6 .12 110 :7,9 114:2 116 :10,1 4

soils 15160 :25 61 :5,5,6,13,13 62 :6 .12 ` 4,16,21 63:17 78 :14 86 :1895 :20 96 :19 97 :1 99 :1 0

sold :2] 42 :20 71 :20solid ?133 :13 74 :20solvents (3) 61 :8,8, 9

i somebody [4115 :14,14 25 :2,3somehow [4132 :21 72 :4,13,16someone [4143 :15,21 53 :12 105 :9

som time [2110 :7 31 :25Sometimes 1217 :13 13 :14somewhat [3132 :23 97 :11 105 :2 0somewhere 0123 :20 26 :3,16,1738 :25 84 :19 105 :20

soon (21114 :15 115 :1 1sorry (9) 8 :20 9 :15,20 21 :10 23 :2125 :1 28 :15 78 :1 87 : 1

sort [3] 13 :25 39 :24 60 :21Soto [ 2160 :1, 1sounds (1] 30 :23source (5151 :8 75 :1 84:3 97 :12110 : 1

sources [1) 92 : 3southern 1615 :5 66 :13 67 :8,25 76 :1 83 :2 2

speaker 12017 :17 9 :21,23 36 :1,737 :10,13 50 :10 54 :25 55 :22,2580 :5 84 :7,11,14,18 86 :20 91 :17 92 :14 112 : 3

speakers 1114 :8speaking [1) 112 :5special ( 1) 60 :8species [1] 49 : 5specific 014 :1 29 :16 36 :24 46 :5specifically 13145 :5 50 :2 56 :23specified [1)15 :21

spell [2147 :7 82 :20spent [2] 32 :24 56 :13spikes [ 7189 :4spirit [114 :1 8Split [1138 :1 1spoke 13128 :2 50 :6 67 :6spokesperson 1113 :17spread [1)11 :1 6sptf [2111 :20 12 :5ss fl [31 1 :1 2 :4 24 :12stable [2] 48 :18 65 :22staff [1) 107 :10stage (1) 72 :22staging [1125 :22stained [2]63 :4,1 1standard [14120 :20 53 :9 93 :19,2594 :6 105 : 6 106 :5,25 107 :14 108 :5,7 109 :18 114 :3,1 2

standards (53)12 :23,24,25 13 :5,5,12,12,13,18,18 16 :25 18 :2,11 19 :5 20 :4 ,7,7,8,9,12,13,16,17,19,1921 :6,23 22 :1 23 :2,2,5,6,8 34 :8 49 :14,18 50 :7 53 :4 67 :16 68 :5 93 :17,17 94 :18 99:12 102 :7 103 :23 105 :8 108 :2,18,21,22 109 :7 112 :10

standpoint [5116 :24 18 :14 19 :22,23 113 :1 4

sta rt [14] 8 :7,9 10 :16 12 :8 17 :1225 :23 31 :20 32 :7 46 :14,18 62 :1880 :10 100 :18 117 : 7

sta rted [ 3110 :6 25 :8 44 :6sta rt ing [1131 :2 5sta rts (1) 6 :2 4State [9] 5 :14 47 :2 5317 54:24 56 :5 82 :19 103 :4 104 :17 106 :21

stated [2155 :13 96 :23statement [ 4126 :2,15 29 : 10 30 :11States [3157 :15 98 :7,1 2station 0124:3,12,15,18 38 :3,1858 :1 2

statistical [ 1] 102 : 1status 11518 :11,14 9 :1,2,11,13 14 :17 16 :6 17 :21 30 :22 32 :16 44 :2053 :11,18 58 : 4stay 1 4148 :10 49 :15 99 :11 109 :1staying (1) 50 :2 3steel [1120 :1 4step 1819 :19 35 :5 77 :11,12 78 :4,5,

19,25steps [1127 :1 8Steve [13] 2 :6 5 :24 6 :4,23 7 :24 21 :10 92 :8 99 :7 104 : 5 108 :19 111 :12112 :13 115 : 9

still 1 19118 : 8 29 :4 30 :18 33 :15 38 :1544:2448:663 :1767:370 :2272 :21,25 82 :23 84 :10 86 :21 101 :23 104 :18 108 :23 115 :6stop [12117 : 12 26 :11 29 :13,14,1433 :7 68 :12,15 80 : 19 81 :14 88 :19116 : 2

stopped 15125 :14 26 :3,4 27 :13 95 :7

stopping [1133 :19stops [1172 :5storm ( 1) 65 :18stp [1] 66 :4straight [1) 74 :15strategy [1169 :11stratified (1) 57 :11stream [2183 :6,8stretches [1175 :16stricter [1149 :18strongly [21112 :7 115 :23strontium 0194 :24 97 :10 100 :23101 :8 ,20 111 :12,15

9A032F1

Atkinson-Baker,Inc

structures 15119 :17 24:21 38 :3,18 95 :20

structuring (1( 3 :16stuck [7) 84 :8studies [1188 :1 2study (18111 :11 16 :8,11,12,20 17 :23 56 :21 57 :2, 5,6 58 :11 75 :22 78 :6,20 87 :11 90 :20 95 :14,1 9

Stuff [ 14119 :4 21 :11 22 :18 31 :3 43 :20 70 :24 75 :4 80 :16 101 :17 103 :7106 :24 111 :1 113 :16 115 :21

style [3173 :15,17 76 :23subjecting [1)106 :9submission [1)11 :3' -submit [3127 :22 63 :24,24submitted 15135 :4 69 :7 79 :10 100 :24 101 :1 0subset (11110 :1 0substances 1812 :7 5:17,21,25 43 :656 :1857:1460:15substituting [1) 2 : 8subtitle [2167 :19,20subtract [2140 :8 42 :1suction [1) 65 :19sufficient [1126 :22suggest 13177 :9 113 :17 115 :23Suggested [2118:3 32:8suggesting (11113 :10suggestion (4152 :25 113 :13 114 :13 115 :4

suggests [1) 77 :23suite (1)1 :2 2summarize [21102 :23 106:13summer [3144 :4,10 83 :3supersede [ 11106 :21suppose [1] 108 : 3supposed 0114 :10 16 :12 31 :1 70 :18 87 :5 102 :1, 6

supposedly [1] 29 : 5surface [19120 :11,13 21 :9,13 22 :2,525 :1934 :17,17,2038:1739:940 :9,25 41 :1 50 :22 51 :8 65 :16,18surfaces [3138 :17 39 :16,18surplus [2) 29 :2, 2surprised [1126 :24survey [23110 :14 11 :1 13 :2,3,4 14 :20 16 :7,16 20 :3 27 :23 33 :24,2535 :24 36 :19 37:3 38 :2,4 .6 39 :2 42 :21 51 :12 61 :4 63 :3

surveyed [1136 :20surveying [1110 :1 8surveys 14139 :13 44 :12 86 :15,16susana 0] 2 :14,20 5 :23 56 :21 57 :17 58 :25 60 : 8

Sutherland [316 :7,7 9 :22sweep [1162 :25swimming 11160 :21swing (1) 16 :1 3synthetic [3171 :2,10 72 :12system 16149 :2 65 :20,24 76 :3 78 :22,2 2

systematically [1) 79 : 1

T--table 1912 :18 36 :18 78 :7 86 :24 87 :10 98 :17 100 :23,24 101 : 3

tag (1) 36 :20talked 1617 :24 8 :5 12 :6 14 :12 28 : 6

111 :12tarp [1163 :16team [115 :12tearing (2119 :3 44 :5technical (1( 83 :23techn iques 12118 :12 19 :6technology [7177 :17telephone (1) 56 :13

ten [13] 3 :22 7 :21 54 :12 67 :14,1575 :11 87 :2,20 90 :7 93 :23 96 :13108 :25,25

ten-feet-by-ten-feet [1166 :3ten-minute [213 :20 54 :10tentative (217 :13 115 :1 6terms 110155 :14 64 :5,17 66 :20 69 :17,19,20 93 :2 100 :21 109 :10

test [3)11 :20 12:2 75 :1 0tested 12148 :9 75 : 3testing 16110 :4,19 36 :24 37 :1 95 :697 :1 0

tests [2117 :7 26 :6thanks (1) 83 :18themselves [314 :18,21 5 :1 3theory [3172 :3,11 100 :16there 'd [1l 113 :1 7there's [6615 :5 7 :19 8 :20 11 :7,24

15:25 16 :3 17 :1 22 :17 23 :1,14,15,16,17 25 :3,5 26 :24 29 :2 32 :10 36 :25 37 :3 39 :21 40 :23,24 41 :1,3 42 :19,21 44 :15 48 :6,7,8 50 :13 51 :1752 :11 53 :7 54 :1 63 :17,21 64 :9 65 :2 66 :17,18 69 :2 70 :22 73 :13 75 :5,21 78 :13,24 79 :11 80 :13 82 :8 84 :19 86 :20 90 :1 92 :4 100 :16 105 :8106 :15 109 :23,24 111 :23 114 :18116 :22,23

the refo re [3197 :1 109 :7 113 :17thermal [1151 :1 9they'll 19142 :24 62 :11,13,18,25 63 :3,4,11,20

they've 110115 :20 42 :5 j3 :16 46 :548:18 59 :22 62 :8,16 67 :21 76 :2thick [1) 71 : 3thickness [2164 :11 68 :17thinking [2146 :19 77 :24third 14] 24 :4,6 50 :10 100 :13tho rium (2187 :14,23tho rough [1)19 :12tho roughly [1129 :8though [2139 :6 100 :7thoughts [1) 79 :3thousand-feet [1162 :3th reat (1) 112 :24three 19145 :19 52 :13,14 60 :4 62 :20 67 :9 76 :1 89 :4,11

three-by-five Ill 117:10throughout [3159 :20 72 :7 98 :14tied (2134 :18,2 1till 15137 :11,12 89 :23 112 :3 115 :1timetable [1] 19 : 2title [3157 :23,24,24tld 12152 :9,1 2today [712 :8,9 5 :6 15 :3 37 :6 77 :799 : 8today's [114 :1 1together 13135 :3 57 :24 75 :20tom 11014 :25 5 :2 18 :8 20 :13 26 :2128 :1 36 :17 46 :13,15 87 :20

tomorrow [213 :2 117 : 7tonight [1212 :10,12,24,25 3 :1,1021 :23 22 :4,11 84 :25 112 :12,16

took 18131 :19 38 :7,11,17 60 :1-87 :14 90 :16 95 :1 9

top [18171 :4,11 72 :2,13 73 :17 76 :14,15 93 :7,20 95 :14,14 96 :2,15,16 101 :21 103 :16 110 :23,25

topanga [1160 : 2topic 11113 :16 21 :16 36 :14 37 :11,12,23 44 :1 80 :7 84 :24 112 :1 117 :10

topics 1612 :24 3 :4,6,11 56 :16 85 :1torn 15119 :14 22 :20 24 :21 44 :1449 :1 6

1-800-288-3376

HDMSPOO134615

total - zon e

total [1154 :2 3totally [4] 35:21 76 :8,13 100 :2tougher [1171 :20towards [4144 :9 62 :1,22 63 :8tower (1158 :1 5toxic [912 :7 5 :17,20,25 56 :14,1857 :13 60 :15 71 :2 2

toxicity [2158 :24 93 :2toxins [1159 :22track [213 :25 64 :22traditionally [216 :21 7 :8trailer [3139 :18 48 :6 51 :13trailers [14] 24 :2,10,11,13,19 38 :2,1842 :443:1448 :6,9,1850 :1552 :8

transcript 1411 :10 4 :5,9,14transfer (1) 9 :13transferred [2] 42 :15 81 :18translated [1165 :9transmitted [1) 65 :10transparencies [2131 :1,5transportation 12111 :25 62 :21transported 11147 :24transuranium [2111 :6,15t reat 12160 :18,20t reating [1165 :3t reatment [2169 :3 78 :22t ribal [1158 : 2tried (1(43 :2triennium [3192 :2 .3,24troubled [1) 71 :24troubling [1130 :1 5tru [5)11 :6,15,23,24 12:13trucks 13152 :22 116 :3,4true [3126 :15 79 :22 107 : 8try [13] 3 :7,8 15 :3 18 :18 37 :7 43 :150 :1 100 :11,19 102 :17 115 :3,15,1 7

trying 111] 16 :19 17 :5 18 :25 24 :1727:7 29:10 32 :18,20 54 :3 106 :4115 :1 0

tuesday [3] 1 :12 2 :1 7 :17turnout [1158 :2 1turns [1184 :2 1twice (2182 :10 110 :1 2two [31] 8 :13 11 :12 15 :22 24 :7 30 :21 31 :2 32 :25 36 :20 41 :19 44 :953 :6 62 :4 65 :2 66 :16,17 69 :21 74 :14,17 86 :1,11 87 :6,7 88 :3 89 :2490 :1 96 :11 103:20,22 110 :4 111 :3112 :1 5

type [10165 :8,25 66 :22 67 :7,11 68 :24 73 :20 88 :25 89 :5, 6

types [5128 :18 67 :24 68 :20 95 :24110 : 8

typical [2139 :3,16typically [1) 61 :9typo [1] 110 :11

0U .S [412 :20 5 :1 6:7 70 :8uncertainties [2] 11 :17 29 :12unce rtainty [6]44 :24 97 :25 101 :2,3,5 111 :1 3under [8134 :11 35 :13 50 :19 56 :195 :9 100 :6 104 : 18 109 :4underflow [1]66 :24underlying [1] 69 :15underneath [3166 :19 69 :4 75 :5understand [2113 :7 30 :2 31 :1032 :12 44 : 15 61 :1,10 79 :15,17,2380 :12,14 81 :1,18 86 :4 99 : 22 101 :7 103 : 21 104 : 7 106 :25 116 :2understanding [1179 :3understood [2117 :3 53 :25unidentified [1817 :17 9 :21,23 36 :

9A032F11,7 37 : 10,13 55 :22,25 80 :5 84 :7,11, 14,18 86 :20 91 :17 92 :14 112 :3united [3157 :15 98 :7,1 2universal [1144 :23univision [1158 :13unknown [114:7unless [316 :24 85 :3 101 :15unlicensed [8181 :15 82 :11 99 :13106 :17 107 :21 109 :12,14,18

unlikely [1] 32 : 9unnatural [ 1] 92:4unnecessa ry 12176 :8 106 :10unprotected [1]53 :10unprotective [1153 :9unquote [ 1) 34 :18unresolved [2135 :10 114 :19unrestricted [6] 35 :15 44 :13 50 :21 85 :12 86 :5 100 : 5untaken [ 1] 55 : 3until [15114 :22 15 :2 25 :7 ,23 28 :4,12,16 31 : 22 52:12 59 :8 , 14 102 :10112 :10 114 :23 116 :21

up 17013 :2,18 7 : 15 10 : 2 12 :13 18 :119 19 :2 , 5,13 23 :1,2,8 25 :2,13 26 :25 28 : 17 40 :5 46:25 51 :9,12 52 :9,10,12 55 : 7 56 :2,3 59 :8 60 :2 62 :4,1265 :14 , 1867 :371 :1472 :5,10,12,18 73 :11,16 76 :3 ,3 77:6,7,1082 :14 83 :12 89 : 4 90 :8 , 23 91 :1592 :3 93 :5,20,23 94 :16 99 :23,24102 :5,7 104:4,10,22 105 :9 106 :11108 :25 109 :17 114 :15,1 9updates [1] 6 :16 'Mupgradient [1] 69 :16uphill [1164 : 3upper [ 10] 61 :19,24 62 :10,25 63 :

17 76 :19 80 :25 86 :11 101 :11 108 :25

Upset [1] 17 :17uranium [2188 :1,2urge ( 1) 116 :7uses [2121 :7 93 :2 0using [26112 :23,24 13 :13,18 19 :721 :24 29 :5 38 : 23 49 :14,19 50:784 :21 95 : 1,2,3 98 :8,9,16,19,20,2299 :24 102 :1 106 :25 109 :22 110 :1 0

usual [2183 :12 94 : 6

Vvacation [1) 6 :24vaccine [ 1] 89 :14vague [ 1122 : 3valley [911 :11 2 :1 23 : 15 24 :25 25 :

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