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J U H- 2 9- 9 q4 W E D 1 2: 5 9 P. 0 2 <br />~ • <br />Carl Mount <br />Jurie 29, 1994 <br />Page 2 <br />betweE:n the operable units and an undisturbed background condition. <br />Distux•bance of the area prior to full characterization may render <br />a background determination invalid, complicating eontamination- <br />relate:d studies in other parts of the site. <br />Future Bite use <br />Over 'the last several months, DOE has convened the surrounding <br />communities to work with DOE to determine the future uses of the <br />Rocky Flats site, including the buPPer Zone. A decision on the use <br />of a significant portion of the buffer zone outside of the context <br />of th:Ls group appears to undermine the purpose of the group, and <br />DOE's support for the planning activity. <br />In a Yelated manner, DOE has recently promoted the Site Wide EIS as <br />the centralized planning tool for near term land use decisions nat <br />addressed by the Future Site Uses Working Group. While the <br />relat:Lonship between these two planning efforts remains hazy, to <br />say tk~e least, it would seem that one or the other activity, if not <br />both, would need to be a part of the decision on buffer zone use, <br />as presented in the western Aggregates proposal. <br />Prelilainary studies in the area indicate considerable ecological <br />value in the Rock Creek drainage, but the ecological <br />characterization of the area is not completed. It is our <br />understanding that DOE would need to determine the impact oP use of <br />the area on this ecosystem under the National Environmental Policy <br />Act before a decision could be made regarding the acceptability of <br />the activities. <br />Public Aocess Impacts <br />The v;31ue of the buffer zone to the DOE lies in providing a margin <br />of safety between the hazards inherent in the industrial area of <br />the plant and the public. Recently DOE has initiated several <br />studi,as relating the risks of plant activities to the public, <br />through the Plutonium Vulnerability Assessment, the updating of <br />building-specific Safety Analysis Reports (SAR), and the re- <br />evaluation o! the Emergency Planning Zone (EPZ). Each of these <br />studies, and others related to air permitting, is keyed to the <br />distance at which the public could become exposed to emissions from <br />plant activities or incidents. <br />Allowing expanded access to the buffer zone may change the basis of <br />calculation for the exposure assessment contained in these <br />documents, and possibly others. A decision to reduce this margin of <br />safety without re-evaluating the results of these studies seems <br />inappropriate. <br />