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<br />Carl 1Kount <br />June 29, 1994 <br />Page 2 <br />betwe~=_n the operable units and an undisturbed background condition. <br />Disturbance of the area prior to full characterization may render <br />a background determination invalid, complicating contamination- <br />related studies in other parts of the site. <br />Future Site 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 buffer zone. A decision on the use <br />of a :significant portion of the buffer zone outside of the context <br />of this group appears to undermine the purpose of the group, and <br />DOE's support for the planning activity. <br />In a related manner, DOE has recently promoted the Site Wide EIS as <br />the centralized planning tool for near term land use decisions not <br />addre:;sed by the Future Site Uses Working Group. While the <br />relationship between these two planning efforts remains hazy, to <br />say tYie 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 />Preliriinary 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 />under;;tanding that DOE would need to determine the impact of 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: Access Impacts <br />The value of the buffer zone to the DOE lies in providing a margin <br />of sai°ety between the hazards inherent in the industrial area of <br />the plant and the public. Recently DOE has initiated several <br />studies relating the risks of plant activities to the public, <br />throucrh the Plutonium Vulnerability Assessment, the updating of <br />building-specific Safety Analysis Reports (SAR), and the re- <br />evaluation of the Emergency Planning Zone (EPZ). Each of these <br />studies, and others related to air permitting, is keyed to the <br />distar.~ce 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 />