PB98-964026
                              EPA541-R98-113
                              December 1998
EPA Superfund
      Record of Decision:
      Paducah Gaseous Diffusion Plant
      (USDOE) OU 15
      Paducah, KY
      8/10/1998

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                                  DOE/OR/06-1527&D2
                                    Primary Document
       Record of Decision for Remedial Action
at Solid Waste Management Unit 91 of Waste Area Group
      27 at the Paducah Gaseous Diffusion Plant
                Paducah, Kentucky
                    July 1998
         Cleared for Public Release

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                                     Department of Energy
                                         Oak Ridge Operations
                                          Paducah Site Office
                                            P.O. Box 1410
                                          Paducah. KY 42001

-i                                              September 22, 1998

          Mr. Robert H. Daniell, Director
          (Division of Waste Management
          Kentucky Department for Environmental Protection
          14 Reilly Road, Frankfort Office Park
~|         Frankfort,  Kentucky 40601

          Mr. Carl R Froede Jr., P. G.
 J         United States Environmental Protection Agency
-*         Region IV
          DOE Remedial Section
 I         Federal Facilities Branch
          Waste Management Division
-,         61 Forsyth Street
 J         Atlanta, Georgia 30303

-i         Dear Mr. Daniell and Mr. Froede:

          RECORD OF DECISION FOR REMEDIAL ACTION AT SOLID WASTE
          MANAGEMENT UNIT 91 OF WASTE AREA GROUPING 27 AT THE PADUCAH
J         GASEOUS DIFFUSION PLANT, PADUCAH, KENTUCKY DOE/OR/06-1527&D2
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          Enclosed for your information is the final Record of Decision (ROD) for Solid Waste
          Management Unit 91 of Waste Area Grouping 27 at the Paducah Gaseous Diffusion Plant The
          ROD was signed by the Department of Energy (DOE) July 8,1998, and by the United States
          Environmental Protection Agency August 10,1998. The Kentucky Department for
          Environmental Protection (KDEP) gave conditional approval of the Dl version of the ROD on
          June 9, 1998, pending minor modification, which DOE incorporated. Based on conversations
          with representatives of KDEP on September 21, 1998,  the June 9,1998, letter serves as their
          concurrence for the ROD.

          If you have any questions or require additional information, please call Myrna E. Redfield at
          (502)441-6815.

                                                Sincerely,
                                               Jimmie C. Hodges, Site Manager
                                               Paducah Site Office

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         Mr. Daniell and Mr. Froede                 2                       September 22 1998

1.

-i        Enclosure

         cc w/o enclosure:
 1        R. H. Blumenfeld, CC- 1 0
 I        P. A. Gourieux, Bechtel Jacobs Company/Kevil
         J. C. Massey, Bechtel Jacobs Company/Kevil
1        B. E. Phillips, JEG/Kevil
 '        R. C. Sleeman, EM-91
         T. Taylor, UKFFOU/Frankfort




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                                             CERTIFICATION

           Document Identification:   Record of Decision for Remedial Action at Solid Waste
                                      Management Unit 91 of Waste Area Group 27 at the Paducah
                                      Gaseous Diffusion Plant, Paducah, Kentucky (DOE/OR/06-
                                      1527&D2 Primary Document)
            I certify under penalty of law that this document and all attachments were prepared under my
            direction or supervision in accordance with a system designed to assure that qualified personnel
            properly gather and evaluate the information submitted. Based on my inquiry of the person or
            persons directly responsible for gathering the information, the information submitted is to the
            best of my knowledge and belief, true, accurate, and complete. I am aware that there are
            significant penalties for submitting false information, including the possibility of fine and
            imprisonment for knowing violations.

            U.S. Department of Energy (DOE)
            Owner and Operator
                       C.
            JimmieC. Hodges, Paducah Site Manager                              Date Signed
            I certify under penalty of law that this document and all attachments were prepared under my
            direction or supervision in accordance with a system designed to assure that qualified personnel
            properly gather and evaluate the information submitted. Based on my inquiry of the person or
            persons directly responsible for gathering the information, the information submitted is to the
            best of my knowledge and belief, true, accurate, and complete. I am aware that there are
            significant penalties for submitting false information, including the possibility of fine and
            imprisonment for knowing violations.

            Bechtel Jacobs Company LLC
            Co-Operator
                                      Manager of Projects                       Date Signed

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 I                                                                DOE/OR/06-1527&D2
                                                                   Primary Document
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           Record of Decision for Remedial Action
at Solid Waste Management Unit 91 of Waste Area Group 27
          at the Paducah Gaseous Diffusion Plant,
                     Paducah, Kentucky
                                            July 1998
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                          Prepared by
                         Jacobs EM Team
                        175 Freedom Blvd.
                       Kevil, Kentucky 42053

                         Prepared for the
                     U.S. Department of Energy
                 Office of Environmental Management

              Environmental Management Activities at the
                  Paducah Gaseous Diffusion Plant
                      Paducah, Kentucky 42001
                          managed by
                    Bechtel Jacobs Company LLC
                             for the
                     U.S. Department of Energy
                 tinder contract DE-AC05-98OR22700

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                                 PREFACE

This Record of Decision for Remedial Action at Solid Waste Management Unit 91 of Waste
Area Group 27 at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/06-
1527&D2, was  prepared in accordance with requirements under the Comprehensive
Environmental Response, Compensation, and Liability Act, the Resource Conservation
and Recovery Act, and  Kentucky Revised Statues Chapter 224,  Subchapter 46.  This
work was performed under Work Breakdown Structure 1.4.12.7.1.11.07.05  (Activity
Data Sheet 5311). This document follows the outline for records of decision contained in
the Federal Facility Agreement For The Paducah  Gaseous Diffusion  Plant, DOE/OR/07-
1707,  and the Guidance on  Preparing Superfund Decision Documents: The Proposed Plan,
The Record of Decision,  Explanation  of Significant Differences, The  Record  of Decision
Amendment, EPA/540/G-89/007.  Publication of  this document meets  a  primary
document deliverable milestone for the United States Department of Energy's (DOE's)
Remediation Management Group at the Paducah Gaseous Diffusion Plant  This
document provides the record of information and rationale that the United States
Environmental  Protection  Agency,  the  Kentucky  Department for  Environmental
Protection, and the DOE utilized in the selection of  a preferred remedial action, 'or
corrective measure, at Solid  Waste Management Unit 91 of Waste  Area Group 27.
Information provided in this document forms the  basis for the development of the
remedial design report for this project.

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                              CONTENTS

PREFACE	ii
TABLES	v
FIGURES	v
ACRONYMS AND ABBREVIATIONS	vi

PART 1.  DECLARATION
          SITE NAME AND LOCATION
          STATEMENT OF BASIS AND PURPOSE
          ASSESSMENT OF THE SITE
          DESCRIPTION OF SELECTED REMEDY
          STATUTORY DETERMINATIONS

PART 2.  DECISION SUMMARY
          2.1    Site Name, Location, and Description	1
          2.2    Site History and Enforcement Activities	1
          2.3    Highlights of Community Participation	:..4
          2.4    Scope and Role of Operable Unit	.-...4
          2.5    Response Action and the Site Management Strategy	4
          2.6    Summary of Site Characteristics	5
                2.6.1  Hydrogeologic Characteristics of the
                      Paducah Gaseous Diffusion Plant Area	.5
                      2.6.1.1  Regional surface-water hydrology	5
                      2.6.1.2  Regional geology	5
                      2.6.1.3  Regional ground-water hydrology	8
                2.6.2  Hydrogeologic Characteristics of Solid Waste
                      Management Unit 91	9
                      2.6.2.1  Surface features and surface water at Solid Waste
                              Management Unit 91	9
                       2.6.2.2  Geology and hydrogeology of Solid Waste
                              Management Unit 91	9
                2.6.3   Operable Unit Characteristics	12
                2.6.4   Summary of Actions Taken to Date	13
                2.6.5   Contaminant Characteristics	14
          2.7   Summary of Site Risks	14
                2.7.1   Human Health Risk Assessment	14
                2.7.2   Ecological Risk Assessment	18
                2.7.3   Conclusions of the Risk Assessment	19
                2.7.4   Remedial Action Objectives	19
          2.8   Description of Alternatives	19
                2.8.1   Alternative 1 — No Action	19
                2.8.2   Alternative 2 — In Situ Remediation (Lasagna™)	19
                 2.8.3   Alternatives — In Situ Enhanced Soil Mixing	21
          2.9    Summary of the Comparative Analysis of Alternatives	21
                 2.9.1   Overall Protection of Human Health and the Environment....23
                 2.9.2  Compliance with Applicable or Relevant and Appropriate
                       Requirements	23
                 2.9.3  Long-term Effectiveness and Permanence	24
                 2.9.4  Reduction  of Contaminant Toxicity, Mobility, or Volume
                       through Treatment	24
                 2.9.5  Short-term Effectiveness	24
                 2.9.6  Implementability	24
                                                    111

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                2.9.7  Costs	24
                2.9.8  State Acceptance	25
                2.9.9  Community Acceptance	25
         2.10  Selected Remedy	25
         2.11  Statutory Determinations	26
                2.11.1 Overall Protection of Human Health and the Environment. ...27
                2.11.2 Applicable or Relevant and Appropriate Requirements	27
                      2.11.2.1 Chemical-specific applicable or relevant
                              and appropriate requirements	29
                      2.11.2.2 Location-specific applicable or relevant
                              and appropriate requirements	29
                      2.11.2.3 Action-specific applicable or relevant
                              and appropriate requirements	30
                2.11.3 Cost Effectiveness	31
                2.11.4 Utilization of Permanent Solutions and Alternative
                      Treatment Technologies	31
                2.11.5 Preference for Treatment as a Principal Element	34
         2.12  Documentation of Significant Changes	34

PART 3.  RESPONSIVENESS SUMMARY
         3.1    Responsiveness Summary Introduction	„	36
         3.2    Community Preferences/Integration of Comments	36

APPENDIX      Remedial Design Schedule for Solid Waste Management Unit 91
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                                                    IV

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                                 TABLES

Table 2-1.   Cost Estimates	25
Table 2-2.   Applicable or Relevant and Appropriate Requirements and To Be
           Considered Information for the Remedial Action (Lasagna™ with In Situ
           Enhanced Soil Mixing Contingency)	32

                                FIGURES

Figure 2-1.  Paducah Gaseous Diffusion Plant Vicinity Map	2
Figure 2-2.  Location of Solid Waste Management Unit 91, Cylinder Drop Test Area....3
Figure 2-3.  Surface-Water Features in the Vicinity of the Paducah Gaseous
           Diffusion Plant	6
Figure 2-4.  Schematic of Stratigraphic and Structural Relationships near the
           Paducah Gaseous Diffusion Plant	7
Figure 2-5.  Location of Cross Section A-A'	10
Figure 2-6.  Cross Section A-A' at Solid Waste Management Unit 91, Cylinder
           Drop Test Area	11
Figure 2-7.  Approximate Extent of Soil Contamination and Area to be Remediated...15
Figure 2-8.  Conceptual Site Model for Solid Waste Management Unit 91,
           Cylinder Drop Test Site	16
Figure 2-9.  Conceptual Schematic of Lasagne1*	.20
Figure 2-10. In Situ Enhanced Soil Mixing Schematic	22
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                 ACRONYMS AND ABBREVIATIONS

The following list of acronyms and abbreviations is provided to assist in the review of
this document.

**Tc          technetium-99
AGO        Administrative Order by Consent
amsl         above mean sea level
AR          administrative record
ARAR       applicable or relevant and appropriate requirement
AT123D     Analytical Transient 1-, 2-, 3-Dimensional Model
BHHRA      baseline human health risk assessment
bis          below land surface
CERCLA     Comprehensive Environmental Response, Compensation, and
             Liability Act
C.F.R.        Code of Federal Regulations
ds-l,2-DCE  cis-l^-dichloroethene
on          centimeter(s)
COC        chemical of concern
CPF         cancer potency factor
DNAPL      dense nonaqueous phase liquid
DOE        United States Department of Energy
ELCR        excess lifetime cancer risk
EPA         United States Environmental Protection Agency
Fed. Reg.     Federal Register
FFA         Federal Facility Agreement
ft           foot (feet)
ft2           square foot (feet)
ft3           cubic foot (feet)
gal          gallon(s)
HSWA       Hazardous and Solid Waste Amendments
HU         hydrogeologic unit
K.A.R.       Kentucky Administrative Regulations
KDEP       Kentucky Department for Environmental Protection
kg           kilogram(s)
km          kilometer(s)
KPDES      Kentucky Pollutant Discharge Elimination System
1            liter(s)
m           meter(s)
ms          cubic meter(s)
MCL        maximum contaminant level
xrg          milligram(s)
NCP        National Oil and Hazardous Substances Pollution Contingency Plan
NPL        National Priorities List
O&M        operation and maintenance
pCi         picocurie(s)
PGDP       Paducah Gaseous Diffusion Plant
ppm        parts per million
POE        point of exposure
PORTS      Portsmouth Gaseous Diffusion Plant
PRAP       proposed remedial action plan
PRP         potentially responsible parties
RAO        remedial action objective
                                                   VI

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RCRA        Resource Conservation and Recovery Act
RGA         Regional Gravel Aquifer
ROD         record of decision
SARA        Superfund Amendments and Reauthorization Act
sec          second(s)
SESOIL      Seasonal Soil Compartment Model
SWMU      solid waste management unit
TBC         to be considered
TCE         trichloroethene
TVA         Tennessee Valley Authority
U.S.C.A.     United States Code Annotated
UCRS        Upper Continental Recharge System
USEC        United States Enrichment Corporation
WAG        waste area group
yds          cubic yard(s)
yr           year(s)
UFC          uranium hexafluoride
jig           microgram(s)
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products. This decision was based on several documents that comprise the AR for this
remedial action  (e.g., the Preliminary  Site Characterization/Baseline Risk Assessment/
Lasagna™ Technology Demonstration At Solid Waste Management Unit 91 of the Paducah
Gaseous Diffusion Plant, Paducah,  Kentucky, KY/EM-128;  the Feasibility Evaluation for
Trichloroethene-Contaminated Soil at Solid Waste Management Unit  91 at the Paducah
Gaseous Diffusion Plant, Paducah,  Kentucky, DOE/OR/06-1557&D3; and the Proposed
Remedial Action Plan for Solid Waste Management Unit 91, Paducah Gaseous Diffusion Plant,
Paducah, Kentucky, DOE/OR/06-1499&D3). The AR includes detailed documentation
of the rationale for undertaking this remedial  action at SWMU 91 of WAG 27.  The
remedial action will be initiated pursuant to the PGDP's RCRA permits and this Record
of Decision (ROD). Values corresponding to  the 1994 DOE  Policy on the  National
Environmental Policy  Act  also were incorporated   in  the  documentation.  The
Commonwealth of Kentucky concurs with the DOE and  the EPA  on the selected
remedial action. The scope of this action warrants  the  incorporation of the selected
remedy into the Hazardous Waste Permit KY8-890-008-982. This ROD will serve as the
primary document for the modification to the permit. This action will address the
chemical of concern (COC) in the soil [i.e., trichloroethene (TCE)] at SWMU 91 of WAG
27 and will serve as a step toward comprehensively addressing PGDP site problems. '

ASSESSMENT OF THE SITE

Actual or threatened releases of  hazardous substances  from SWMU 91 of WAG 27
currently do not present an imminent and substantial danger to public health, welfare, or
me  environment  according  to   the  Preliminary  Site  Characterization/Baseline  Risk
Assessment/Lasagna™ Technology Demonstration at Solid Waste Management Unit 91 of the
Paducah Gaseous Diffusion Plant, Paducah, Kentucky, KY/EM-128. However, leachate and
transport computer modeling [e.g., Seasonal  Soil Compartment Model (SESOIL)] as
presented  in  the Preliminary  Site  Characterization/Baseline Risk Assessment/Lasagna™
Technology  Demonstration at Solid Waste Management Unit  91 of the Paducah Gaseous
Diffusion Plant, Paducah, Kentucky, KY/EM-128, indicates that the COC (TCE) present
in the soil could contaminate the Regional Gravel Aquifer at the point of exposure (POE)
at levels that could exceed the EPA maximum contaminant levels.

DESCRIPTION OF SELECTED REMEDY

The primary objective of this remedial action is to reduce the level of TCE-contaminated
soil thereby reducing the potential future concentrations in ground water that could  pose
a threat to human health and the environment at  the POE  (i.e.,  the DOE property
boundary). The potential for migration of the contaminant from the soil to the off-site
aquifer is the concern associated with this SWMU. The soil at this SWMU contains TCE
with an average concentration of 84 mg/kg (ppm) that may migrate to the nearest POE
at unacceptable levels. Ground-water modeling indicates that reducing the concentration
of TCE in soil at SWMU 91 to less than 5.6 mg/kg will result in ground water that is less
than 5 Hg/1 at the PGDP's security fence. The selected remedial action reduces the
potential ground-water risk to human health and the environment by remediating the
TCE-contaminated soil to below 5.6 mg/kg.

Alternative 2 — In Situ Remediation (Lasagna™) is the selected remedy. The Lasagna™
technology was developed by an  industrial consortium (Monsanto, DuPont, and General
Electric), in cooperation with the DOE  Office  of Environmental Management, Office of
Science and Technology (EM-50)  and the EPA Office of Research and Development.

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The  Lasagna™ technology was  developed to  remediate  soils  and  ground  water
contaminated with TCE and is especially suited to sites with low-permeability soils. The
process uses electroosmosis to move soil contaminants by  flushing  multiple  pore
volumes of water through treatment zones where the TCE can be captured or chemically
altered to non-toxic products.

The success of the technology's initial demonstration (Phase I) that  began January 3,
1995, and ran for  120 days  at SWMU  91, led  to a  full scale  Phase IIA  field
demonstration that was conducted at SWMU 91  from August 1996 through July 1997.
The Phase HA demonstration was executed on an area of approximately 6 m x 9 m (20
ft x 30 ft)  and approximately 14  m (45 ft) deep.  The demonstration used a mixture of
kaolin clay  and  iron particles as the treatment zone medium. The treatment  zone
material was installed using a hollow mandrel. Iron filings were mixed with wet kaolin
clay to form a slurry that was poured down the 14 m (45 ft) mandrel. As a treatment
medium, iron has been shown to reduce TCE chemically to non-toxic end products.

The components of Alternative 2 — In Situ Remediation (Lasagna™) include these.

       •  Electrodes energized by  direct  current that  cause soluble  contaminants
          (i.e., TCE) to be transported into or through the treatment layers and heat the
          soil. The contaminated water in the pore volumes will flow from the anode
          through treatment zones toward me cathode.

       •  Treatment zones containing reagents that either can decompose the TCE to
          non-toxic products or can adsorb the TCE contaminants for immobilization,
          depending on the medium design.

       •  A water management system that recycles  and  returns the water that
          accumulates at the cathode back  to the anode for acid-base neutralization.

If SWMU 91 has not reached the regulatory approved risk assessment cleanup level (i.e.,
soil levels) of 5.6 mg/kg within two years, the operation may be continued until cleanup
levels are reached. However, if the technology is not successful, even  after an extended
operating  time, the DOE, in agreement with the EPA and the KDEP, may proceed to
remediate the unit with Alternative 3, In Situ Enhanced Soil Mixing.

The components of Alternative 3 — In Situ Enhanced Soil Mixing include the following:

       •  A crane or other mechanical mixing unit;

       •  An agent delivery system (e.g., hot air, steam, or hydrogen peroxide); and

       •  An off-gas collection /treatment  system (e.g.,  activated carbon that will be
          regenerated or stored onsite).

The EPA  and the KDEP have participated in the development of this ROD, including
review and comment on the content of the document.

 STATUTORY DETERMINATIONS

 Both remedial technologies [In Situ Remediation (Lasagna™) and In  Situ Enhanced Soil
 Mixing] are protective  of human health and the environment and comply with federal
 and state applicable or relevant and appropriate requirements. The remedial actions
 also are cost effective and follow the statutory mandate for permanent solutions and

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alternative treatment technologies to the maximum extent practicable. Additionally, they
meet the statutory preference for remedies that employ treatments that reduce toxicity,
mobility, or volume through treatment as a principal element. If unrestricted use and
unlimited exposure remain at the unit after the operational period, a five-year review
evaluating whether the remedy continues to provide adequate protection for  human
health and the environment will be required.
Rodney R. Nelson
Assistant Manager for Environmental Management
United States Department of Energy
                                                               Date   7-
                                                  Date
 Richard Green
•Acting. Director, Waste Management Division
 United States Environmental Protection Agency, Region
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                         DECISION SUMMARY

2.1    Site Name, Location, and Description

The  Paducah  Gaseous  Diffusion Plant (PGDP)  is  located in western  Kentucky,
approximately 16 km (10 miles) west of Paducah and about 6 km (4 miles) south of the
Ohio River (Figure 2-1).  This plant is  an uranium enrichment facility owned by the
United States Department of Energy (DOE). The PGDP, which has been in operation
since 1952, supplies fuel for commercial reactors.

The Energy Policy Act of 1992 transferred operation of the DOE's uranium enrichment
facilities to the United States Enrichment Corporation  (USEC). Effective July  1, 1993,
Martin Marietta Utility  Services, Inc., (now Lockheed Martin Utility Services,  Inc.)
contracted with the USEC to provide operation and maintenance (O&M) services. The
DOE  continues  to  perform  environmental  restoration,  decontamination  and
decommissioning,  and  waste  management  activities  at  the  PGDP   under  its
Environmental Management Program contracted to Bechtel Jacobs Company LLC.

Under the DOE's Environmental Management Program, cleanup activities currently are
being conducted at the PGDP to address contamination that resulted from past waste-
handling and disposal practices. These cleanup activities comply with  the requirements
of the Commonwealth of Kentucky, the United States Environmental Protection Agency
(EPA), and the DOE.

This Record of Decision (ROD) addresses one of the solid waste  management  units
(SWMUs), the Cylinder Drop Test Area (SWMU 91), identified at the PGDP (Rgure
2-2). This SWMU is grouped in Waste Area Group (WAG) 27 as a potential source of
trichloroethene (TCE),  a  dense  nonaqueous  phase  liquid (DNAPL)  that  has
contaminated the ground water of the Regional Gravel Aquifer (RGA).  While the action
described  in  this  ROD  will  remediate  mis  suspected  source of ground-water
contamination, any risks to human health or the environment present at the site due to
contaminated  ground water will be addressed as part of the ground-water integrator
operable unit evaluation (WAG 26).

2.2    Site History and Enforcement Activities

The Cylinder  Drop Test Area (SWMU 91) encompasses approximately 0.7  hectares
(1.7 acres) and is located in the extreme west-central area of the plant on the southern
edge of the C-745-B Cylinder Yard (Figure 2-2). Drop tests were conducted at the PGDP
from late 1964 until early 1965 and  in February 1979 to demonstrate the structural
integrity of the steel cylinders used to store and transport uranium hexafluoride (UF«).
Prior to structural testing, the cylinders went through thermal conditioning by immersing
them in a concrete pit containing dry ice and TCE. During the tests, a crane lifted  the
cylinders to a specified height  and dropped them onto a concrete and steel pad to
simulate worst-case transportation accidents.

In the first test period, a brine-ice bath was used to chill one cylinder prior to its drop
test. The 1979 test used  a TCE-  and dry-ice bath to chill one of the steel cylinders. The
concrete in-ground pit that held the TCE refrigerant for cylinder immersion leaked and
resulted in contamination of the surrounding shallow soil and ground water.  Although
one corner of the pit was located, the exact location of the entire pit is unknown. The pit
is approximately 9 m (30 ft) from the drop pad.
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                                                              LEGEND
                                                                    WMWe Management ATM
                                                                    Paducah Ga«eou«DffiiiilonPtant(PGDP)
                                                                    D«partm*nt ol Energy (DOE) RaswvaOon
                                                                    Municipality
                                                                    TvnnMM* Valtay Authority (TVA)
                                                                            Paducah Qaseous Diffusion Plant
                                                                                 Paducah, Kentucky
                                                                                         BJMObt EM Twrn. 1(M
Figure 2-1. Paducah Gaseous Diffusion Plant Vicinity Map

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                         SWMU 91
                         CyfflfMtor Drop T««t AIM
                 SWMU   Solid Waste
                         Management Unit
                         Paducah Gaseous
                         Diffusion Plant Fence
       Appteanwto So*H (It)
                                                                           BJacobs EM T*am. 1996
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Figure 2-2.. Location of Solid Waste Management Unit 91, Cylinder Drop Test Area

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The amount of TCE released at the drop test site can be estimated based on the size of
the cylinders. The cylinders are 3.7 m (12.2 ft) long and 1.2 m (4 ft) in diameter with a
15.2-cm (6-inch) stiffening ring/lifting lug offset on each side, yielding a minimum tank
width of 1.5 m (5 ft). The likely maximum quantity lost  to  the surrounding soil is
approximately   1,627.5   liters  (430   gals)  as  presented  in the  Preliminary  Site
Characterization/Baseline Risk Assessment/Lasagna™  Technology  Demonstration  at  Solid
Waste Management Unit 91 of the Paducah Gaseous Diffusion Plant,  Paducah,  Kentucky,
KY/EM-128.

2.3    Highlights of Community Participation

A Notice of Availability was published in The Paducah Sun, a regional newspaper,
February 22,1998, announcing the beginning of the 45-day public review period for the
Proposed Remedial Action Plan for Waste Area Group 91  at  the Paducah Gaseous Diffusion
Plant, Paducah, Kentucky, DOE/OR/06-1499&D3.  The public  comment period began
February 23, 1998, and ended April 8, 1998. Specific groups that  received individual
copies of the Proposed Remedial Action Plan (PRAP) include the Natural  Resource
Trustees and the Site Specific Advisory Board.  There were no requests  for a  public
meeting or hearing; therefore, the tentatively scheduled public  meeting and the hearing
on March 24,1997, were canceled.

2.4    Scope and Role of Operable Unit

Contamination levels mat could pose a threat to human health and the environment are
present in the soil at SWMU 91. The Lasagna™ field demonstration previously treated  a
portion of the TCE contamination in the soil and shallow ground water at this SWMU.
Trichloroethene is present in the subsurface soil at this unit at concentrations indicative
of possible DNAPL pockets in the saturated soil.  These  DNAPL pockets could allow
long-term releases into the ground water. The shallow ground  water beneath this unit
also contains elevated concentrations of dissolved TCE. This ground water is not used
for drinking water purposes, but it is hydraulically connected to the RGA and  is the
pathway of concern.

The DOE proposes the in situ treatment of soil containing chemicals of concern (COCs)
mat exceed remediation levels at SWMU 91 using the Lasagna™ process. The purpose
of the  selected response action is to destroy or break down TCE  in  situ reducing
contaminant levels below remediation levels. This response action will mitigate  future
migration of dissolved TCE through ground water to the RGA and keep off-site releases
from mis unit below regulatory limits.

2.5     Response Action and the Site Management Strategy

The PGDP  presents  unusually complex  problems  in terms of hazardous  waste
management and environmental releases. The DOE's proposed strategy is to divide the
site into operable units grouped by source areas  and ground-  and  surface-water
integrator operable units. Discrete response actions will be selected and implemented for
each source area operable unit, as well as the integrator operable units that are impacted
by  commingled releases  from the   source area  operable  units.  Prioritization for
 investigation and possible remedial action have been  assigned to each of the integrator
 operable units and  source  area  operable units depending on  their  potential for
 contributing to off-site contamination. As a suspected source  of off-site ground-water
 contamination, SWMU 91 is a high priority for remediation.

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              The DOE  already has begun to address  the ground-water integrator operable units
              through remedial actions on the Northwest and Northeast Plumes. By  addressing this
              future source of off-site ground-water contamination, the DOE is following the cleanup
              strategy for the PGDP as outlined in the Site Management Plan, Paducah Gaseous Diffusion
              Plant, Paducah, Kentucky, DOE/OR/07-1207&D3.

              2.6     Summary of Site Characteristics

              This section briefly  describes the hydrogeology of the PGDP and  discusses  the local
              hydrogeologic and contaminant characteristics of SWMU 91. It also presents an overview
              of the actions conducted to date at the site.

              2.6.1   Hydrogeologic Characteristics of the Faducah Gaseous Diffusion Plant Area

              Unless otherwise noted,  the information presented in this section is derived from the
              Report of the Paducah Gaseous Diffusion Plant Groundwater Investigation Phase Iff, KY/EM-
              150,  and  the Preliminary Site  Characterization/Baseline  Risk  Assessment/Lasagna1*
              Technology Demonstration at Solid  Waste Management Unit 91  of the Paducah Gaseous
              Diffusion Plant, Paducah, Kentucky, KY/EM-128.

              2.6.1.1 Regional surface-water hydrology

              The PGDP is located in the western portion of the Ohio River Basin (Figure 2-3). A local
              drainage divide causes  the  plant's surface-water flow either to be to the east and
              northeast toward Little Bayou Creek or to the west and northwest toward Bayou Creek.
              Bayou Creek and Little Bayou Creek are perennial streams mat eventually discharge into
              the Ohio River.
              Bayou Creek flows generally northward along the western boundary of the plant from
 I             approximately 4 km (2.5 miles) south of the plant to the Ohio River. Little Bayou Creek
J             originates within the West Kentucky Wildlife Management Area and flows northward
              along the eastern boundary of the plant. Little Bayou Creek joins Bayou Creek in a
              marsh located approximately 4.8 km (3 miles) north of the PGDP. Other surface-water
              bodies located  in the area surrounding the PGDP include the Ohio River, Metropolis
              Lake, Crawford Lake, numerous small ponds, gravel pits, and settling basins.
              At the PGDP, man-made drainage ditches receive storm water and effluent from the
              plant These waters are routed through outfalls and eventually discharge into Bayou and
              Little Bayou Creeks. The majority of the flow in these creeks can be attributed to effluent
              water from the plant. The Kentucky Pollutant Discharge Elimination System (KPDES)
              permitted outfalls have a combined average daily flow of 18.5 million liters per day
              (4.88 million gallons per day) and are monitored by PGDP personnel.

              2.6.1.2 Regional geology

              The PGDP is located in the Jackson Purchase Region of western Kentucky,  at  the
              northern tip of the Mississippi Embayment. The stratigraphic sequence at the  PGDP
              consists of a sequence of unconsolidated sediments unconformably overlying Paleozoic
              limestone bedrock at a depth of approximately 104 m (340 ft). The sediments overlying
              the bedrock consist  of the following  strata,  in order  of  decreasing  depth:  the
              Mississippian rubble zone, the McNairy Formation, the Porters Creek Clay, the Eocene
              Sands, the continental deposits, and surficial loess and/or alluvium. Figure 2-4 presents
              a schematic diagram illustrating the relationships between the geologic horizons present
              at the PGDP.

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                                                          Plant
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   P«ducah Qacaous
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                                                                                                 DJteota EM TMID, 1996
                                      Figure 2-3. Surface-Water Features in the Vicinity
                                           of the Paducah Gaseous Diffusion Plant
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SOUTH
                                                                    NORTH
                                              UPFBI CONTMOfTAL MPOMTS
                                             LOWER CONTM0ITM. DEPOSIT*
                                                McNAIRY FORMATION
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     Figure 2-4. Schematic of Stratigraphic and Structural Relationships near the Paducah Gaseous Diffusion Plant

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                                  Potential Surface
                                  Runoff Pathways
	Dltch/Plpline
      Wetland
      100-Year Rood Plain
      Monitoring Well
  O  Soil Boring
                           ..170.— Topographic
                                  Contour Internal «
                                 *' C-745B Cylinder Yard
                                                                   SWMU 91
                                                           UFg Cylinder Drop Test Area
''•*• '*^-:E^ 370 ...^•ri-^y
                                        (     Virginia Avenue

                                                                                  •Jwob* EM TMm. ItM
        Figure 2-5. Location of Cross Section A-A1

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     A
   WEST
            MW158      H003  MW159
             TD110'       TD78'    TD70'
             GL37V     GL 371.6 esf  GL 372'

            0
                                             TCE             8 u,p/k9
                                             CERCLA Phase II Soil Data
                                             TCE            8 u-9/kg
                                             CERCLA Phase II Soil Data
                                         -?n  jTCE           41
                                              CERCLA Phase II Soil Data
TCE
Ground Wat*r-S*mpte
                                                       120|ig/l
                                                    Water Sample
                                                                                     Aoproidrnaw Honxomtl Sett* (A)
                                                                                      Vine*) Exagotntion 1 3X
                      Ground-Water Sample
                                                                             A'
                                                                            EAST

                                                  Concrete                ELEVATION
                                                Drop Test Pad     n
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and overlying loess and has been divided into the following hydrogeologic units (HUs):
day to clayey silt (HU 1), sand and gravel (HU 2), and clay or silty clay  (HU 3).  A
pump test in the area measured the hydrologic properties of HU 2, a 3-m (10-ft) thick
layer of sand and gravel encountered at a depth of 6 to 9 m (20 to 30 ft) bis. Resulting
hydraulic conductivities values ranged from 3.70 x 10* to 3.97 x 10"5 cm/sec  (1 x 10'2 to
1.12 x 10° ft/day) and storage coefficients ranged from 7.43 x 10'3 to 5.9 x  10'2. Water
level measurements taken in MW 160, which is screened in HU 2, indicate that the depth
to the water table is approximately 2 m (7 ft) bis at SWMU 91. The clay aquitard at the
base of the UCRS (HU 3) is approximately 4.6 m (15  ft)  thick and  occurs between
approximately 9 to 15 m (30 to 50 ft) bis. Flow within the UCRS is  predominantly
downward into the uppermost aquifer, the RGA.

The RGA consists of a 4.6- to 6.1-m (15- to 20-ft) thick sand unit (HU 4) overlying 14 to
15 m (45 to 50 ft)  of sandy, pebble- to cobble-sized chert  gravel (HU 5) and sand
(upper McNairy Formation). Two monitoring wells have been completed in  the RGA at
SWMU 91: MW 159, which is screened in the upper RGA at 19 to 21 m (63 to 68  ft) bis,
and MW 158, which is screened in the lower RGA at 31 to 32.9 m (102 to  108  ft) bis.
The depth to water in MW 158 was approximately 11 m (37 ft)  bis [102  m (334  ft)
axnsl] in May 1994. Water levels in upper RGA MW 159 typically are slightly  higher than
those measured in MW 158,  indicating predominantly horizontal flow with a small
downward component of flow within the RGA. The top of the McNairy Formation is
encountered at 33 m (108 ft) bis in MW 158.

2.6.3   Operable Unit Characteristics

Results of the investigations conducted at SWMU 91 indicate that organic contaminants
are present in both soil and ground water at the unit The COC is TCE with maximum
levels of 1,523 mg/kg (ppm) and 943 mg/1 detected in subsurface soil and shallow
ground-water samples, respectively. The concentration of TCE  detected  in shallow
(UCRS)   ground-water   samples  approaches  the   solubility  limit  for   TCE
(1,100 mg/1), strongly suggesting the presence of DNAPL at the site. The concentrations
of TCE in the RGA ground-water samples at the unit are much lower, ranging from 8 to
120 ug/1, indicating that DNAPL likely is confined to the shallow (UCRS)  soils at  the
site. The areal extent of TCE-impacted soils at  SWMU 91 has been estimated as
approximately 558 m2 (6,000 ft2),  with TCE concentrations in this  area  averaging
84 mg/kg. The sampling results indicate that TCE has migrated below the  water table
into the UCRS but has not fully penetrated through the HU 3  aquitard  at the unit.
Residual contamination is present in the subsurface soils to  an approximate depth of
14 m (45 ft) bis.

Other organic compounds have been detected, at low concentrations, in shallow (UCRS)
and deep  (RGA) ground water at  this unit. Those detected in UCRS ground-water
samples include the following: 1,1,1-trichloroethane;  cis-l,2-dichloroethene  (cis-1,2-
DCE);   tetrachloroethylene;  carbon  tetrachloride;  acetone;  bromodichloromethane;
chloroform; and bis(2-ethylhexyl)phthalate. With the exception of the TCE  degradation
product cis-l,2-DCE, these organic contaminants were detected only once  and at
concentrations  less  than  20  UgA  Cis-l,2-dichloroethene  and   two   likely  lab
contaminants, bis(2-ethylhexyl)phthalate and carbon disulfide, have been detected at
low levels in RGA ground-water samples at  the unit. Several organic  compounds also
were  detected  at  low  levels   in  soil  samples  at  the  site,  including  bis(2-
ethylhexyl)phthalate,  fluoranthene, phenanthrene, pyrene,  acetone,   and  memylene
 chloride. However, the only organic compound detected  at  high levels in  soil samples
 from the unit is TCE.
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Six metals (aluminum, antimony, cadmium, chromium, iron, and manganese) have been
detected at elevated concentrations in unfiltered ground-water samples from the unit. Of
these metals, three (aluminum, iron, and manganese) were detected above regulatory
limits [maximum contaminant level (MCL) or secondary maximum contaminant levels]
in filtered UCRS ground-water samples. One, manganese, was detected above regulatory
limits in filtered RGA ground-water samples. Two metals,  cobalt (15 mg/kg) and
aluminum (12,700  mg/kg),  were detected  at levels slightly exceeding  the PGDP
background  values (13.3  mg/kg and  12,000  mg/kg, respectively) in subsurface soil
samples collected from H003. This limited occurrence of metals in the ground water and
soils at the  unit indicates that SWMU 91 likely is not a significant  source of metals
contamination.

One radionuclide, technetium-99 (Tc), has been detected in UCRS and RGA ground-
water samples from SWMU 91. With the exception of one reported value of 336 pCi/1
from MW 160,  the levels of **Tc detected at  the unit generally are near the analytical
quantification limit of 25  pCi/1. The low activities detected in ground water and the
absence of "Tc  from soil samples at the unit indicate its presence likely is related- to
more general plant activities rather than to specific past activities at this SWMU.

2.6.4  Summary of Actions Taken to Date

In 1993, SWMU 91 was selected as the site of an innovative technology demonstration.
The technology, known as Lasagna™, was  developed by a consortium  (Monsanto,
DuPont, and General Electric) with the support of the DOE  and the EPA.  The
Lasagna™ technology is  an in situ technology that  uses electrical  voltage to move
shallow ground water and contaminants in fine-grained or clayey soils. Contaminants
are treated by passing contaminated ground water through in-ground treatment cells.

For Phase I of the  technology demonstration, corrugated metal sheet piles  were driven
into the subsurface at SWMU 91 to act as electrodes on the east and  west sides of the
designated treatment area. The Phase I treatment area encompassed  an area of 3.0 x
4.6 m (10 x 15 ft) and extended to a depth of 4.6 m (15 ft). The water treatment zones
consisted of activated carbon strips that adsorbed contaminants from the ground water,
including the target compounds (i.e., TCE and TCE  degradation products). Sampling
and analytical results documenting the Phase I study are reported in the Preliminary Site
Characterization/Baseline Risk Assessment/Lasagna™  Technology Demonstration  at Solid
Waste Management Unit 91 of the Paducah Gaseous  Diffusion Plant, Paducah, Kentucky,
KY/EM-128. The  Phase I demonstration was conducted over a four-month  period
ending in May  1995 and resulted in a 98.4% reduction of TCE levels in soils within the
treatment area.

The success of  the Phase I demonstration led to implementation, in August 1996,  of a
large-scale demonstration (Phase HA). The Phase HA demonstration was carried out on
an area approximately 6.4 m x 9.1 m (21 x 30 ft) and approximately 14 m (45  ft) deep.
The ground-water  treatment zones consisted of a mixture of clay and iron particles that
were expected to degrade TCE chemically in situ to nontoxic end products. Post-test soil
sampling conducted  for  the Phase  HA  demonstration  indicated  that   cleanup
effectiveness of TCE ranged from 50% to 140%. As anticipated, TCE did not appear to
have been converted to higher concentrations of intermediate chlorinated  compounds,
such as cis-l,2-DCE or vinyl chloride, but it was  degraded to the end products ethane,
ethylene, and acetylene. The initial average TCE concentrations in soil were 18,  42, 52,
34,  and 34  mg/kg at sampling locations 2A-01, 2A-02,  2A-03, 2A-04,  and  2A-05,
respectively. After a  treatment period  of  11  months,  the  average  concentrations
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had  dropped  to 0.87  (2A-01),  24 (2A-02),  0.16 (2A-03), 11  (2A-04),  and 9.2
(2A-05) mg/kg. The cleanup objectives were achieved at locations 2A-01 and 2A-03,
and significant reductions occurred at the remaining locations (Figure 2-7).

2.6.5  Contaminant Characteristics

The conceptual site model (Figure 2-8)  illustrates primary and secondary contaminated
media, transport pathways, exposure pathways, and receptors that may be affected by
releases. This model identifies contaminant leaching from soil to ground water as the
probable migration pathway from SWMU 91.  The selected remedy presented in this
ROD is intended to address the source of contamination, thereby decreasing migration
from the unit and risks to potential receptors. It must be noted that potential receptors
listed in the conceptual site model currently are protected by the PGDP's water policy,
which  offers an alternative water source to  plant  personnel  and the surrounding
community. Potential impacts to human health and the environment-addressed-by the
selected remedy are discussed in Section 2.7.

2.7    Summary of Site Risks

The  Preliminary Site Characterization/Baseline  Risk Assessment/Lasagna™  Technology
Demonstration at Solid Waste Management Unit 91 of the Paducah Gaseous Diffusion Plant,
Paducah, Kentucky, KY/EM-128, contains the baseline human health risk assessment
(BHHRA) and an  evaluation of potential ecological risks at the Cylinder  Drop  Test
Area. This assessment employed state  and federal  guidance to evaluate risks resulting
from exposure to ground water and soil contaminated with TCE and  its breakdown
products at SWMU 91. Environmental transport of TCE to ground water below SWMU
91, to the PGDP security fence, to the DOE property boundary, and to  the Ohio River
was considered in  the baseline risk assessment using computer  modeling  programs:
RISKPRO™, SESOIL, and AT123D.

Specific information regarding the results of the  human health and preliminary ecological
risk assessments are presented in the  following sections. Those elements that are the
focus of the remedial action decision are discussed as appropriate.

2.7.1   Human Health Risk Assessment

Data  from soil and ground-water  samples  collected during  the SWMU  91 site
characterization were evaluated and  used in the BHHRA. In  addition to the  data
evaluation, the BHHRA included an exposure assessment, a toxicity  assessment, a risk
characterization, and a discussion of associated uncertainties.

The potential  for human contact  with contaminants is  evaluated in the exposure
assessment. As illustrated in Figure 2-8, soil and ground water are the  primary media
through which exposure may occur. The  only receptor evaluated  for potential soil
exposure in the BHHRA is a future excavation worker (assumed  to  be exposed to
contaminants in the top 3 m (10  ft)  of soil  20 days/year for one year]. Receptors
evaluated for potential ground-water exposure  in  the  BHHRA  include: a  future
 industrial worker (assumed to come into direct contact with contaminated ground water
 250 days/year for 25 years); and a rural resident [including both an  adult (assumed to
 come into direct contact with contaminated ground water 350 days/year for 34 years)
 and a  child (assumed to  come into  direct contact with contaminated ground water
 350 days/year for 6 years)). Upon completion of  the exposure assessment, doses  for
 each chemical of potential concern (COPC) are calculated  for integration with  toxicity
 assessment information.
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                                                                     Cylinder
                                                                      Storage
                        Cylinder
                        Storage
                                                                           Buried Culvert
                                   Area of Soil Contamination   S
                                        (approximate)
               (Mon.Mo.lW7)
                                                                                         BJ»oota EM TMIK.
                  Figure 2-7. Approximate Extent of Soil Contamination and Area to be Remediated

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Potential       Primary Release        Primary      Secondary Release     Secondary          Exposure        Potential
Sources          Mechanism     Transport/Exposure     Mechanism     Transport/Exposure       Routes         Receptor
                                  Mechanism                           Mechanism

Spills




Infiltration/
percolation




Soil







Infiltration/
Percolation
DNAPL










Ground Water









Inhalation

Dermal
Contact

Ingestion
Inhalation

Dermal
Contact

Ingestion








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Excavation]

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[Excavation
         Figure 2-8. Conceptual Site Model for Solid Waste Management Unit 91, Cylinder Drop Test Site

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The  toxicity  assessment evaluates adverse effects to human health resulting from
exposure to all COPCs; however, the only COC at SWMU 91 is TCE. Consequently, the
toxicity assessment for this document focuses on TCE. During the development of the
Preliminary   Site   Characterization/Baseline   Risk  Assessment/Lasagna™   Technology
Demonstration at Solid Waste Management Unit 91 of the Paducah Gaseous Diffusion Plant,
Paducah, Kentucky, KY/EM-128, TCE was still  classified as a B2 chemical, which  may
cause cancer in humans through  prolonged exposure. Since the development of this
document, the classification  of TCE now is considered a Class C (possible carcinogen)
to B2 (probable) chemical, meaning there still is scientific uncertainty about whether TCE
will cause cancer in humans through prolonged exposure. To estimate excess lifetime
cancer risks (ELCRs) associated  with prolonged exposure to potentially carcinogenic
materials, the EPA's Carcinogenic Assessment Group developed cancer potency factors
(CPFs)  (also referred to as cancer slope factors). The Guidance on Preparing Superfund
Decision Documents: The Proposed Plan, The Record of Decision, Explanation of Significant
Differences, and The Record of Decision Amendment, EPA/540/G-89/007, outlines the use
of CPF as follows:

       CPFs,  which  are expressed in units of (mg/kg-day)'1, are  multiplied by the
       estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-
       bound estimate of the ELCR associated with exposure at that intake level. The
       term "upper-bound"  reflects the conservative estimate of the risks  calculated
       from the CPFs. This  approach makes underestimation of the actual  cancer risk
       highly unlikely.

The cancer potency factors for TCE used in the BHHRA assume TCE is a B2 carcinogen;
they are  as  follows: for the oral pathway,  0.011 (mg/kg-day)"1;  for  the inhalation
pathway,  0.006 (mg/kg-day)"1;  and  for  the  dermal  absorption  pathway,  0.073
(mg/kg-day)"1. After assessing the toxicity of the contaminants, the results are combined
with the exposure assessment and used to develop the risk characterization.

The risk characterization indicates that  currently  there are no unacceptable risks to
human health at SWMU 91   and  that risks to future workers are considered minimal.
This is partially due to the fact that the unit is covered with approximately 1.2 m (4 ft)
of soil and rock that eliminate the potential for direct contact with contaminated surface
soil. This eliminates surface  soil as a pathway of concern for current and future workers.
The total cancer risk (i.e., ELCR)  for exposure to subsurface soil  by an  excavation
worker is 1  x  10"7,  which  is well below Kentucky Department  for Environmental
Protection's  (KDEP's)  allowable de  minimus risk level of  1 x  10"*;  therefore, the
subsurface soil is not a pathway of concern. To  protect ground-water users, the  DOE
provides an alternate water source to the PGDP  and the surrounding community.  Since
the alternate water source  used  by the  plant will continue to be used  in  the future,
ground water is not  a  pathway  of concern for current and future industrial workers.
 Currently, the alternate water supply is used  by all residents in the surrounding area
whose wells are contaminated;  consequently, ground water can be eliminated  as  a
pathway of concern  for current residents.  However, transport modeling indicates that
 the levels of TCE present in  the soil at SWMU 91 will migrate to ground water below the
 unit and eventually may reach the nearest point of exposure (POE) above the regulatory
 level of 5 Hg/1 (i.e., the MCL), which may present a risk to future potential ground-water
 users.

 The maximum concentration of TCE predicted  to reach the PGDP  northern security
 fence  is  200 ug/1,  which corresponds  to a  1  x  10"5  ELCR.  Consequently,  a future
 potential off-site  ground-water user may come  into direct contact with unacceptable
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DOE will take an action that will lower the concentration of TCE in soil at the unit,
which  will  reduce the potential for  contaminant migration to the nearest POE  at
unacceptable levels. Ground-water modeling indicates that reducing the concentration of
TCE in soil at SWMU 91 to less than 5.6 mg/kg will result in a concentration in ground
water that is less than 5 ug/1 at the PGDP's security fence, which reduces the ELCR to a
future potential ground-water user by an order of magnitude to approximately 3 x 10"7,
thus protecting human health at the nearest POE, the DOE property boundary. Current
ground-water  contamination below  the  unit (i.e., RGA)  will be  evaluated  more
thoroughly, relative to cumulative impacts, in the WAG 27 investigation and the ground-
water integrator operable unit investigation.

Uncertainties that could affect the results of the risk assessment and the  ground-water
modeling are detailed in Appendix G of the Preliminary Site Characterization/Baseline Risk
Assessment/Lasagne™Technology Demonstration  at Solid Waste Management Unit 91 of the
Paducah Gaseous Diffusion Plant, Paducah, Kentucky, KY/EM-128, and are summarized as
follows:

       •  Trichloroethene and its breakdown products were singled out for much of the
          sampling efforts at SWMU 91; therefore, contributions  to total risk from
          other contaminants that may be present are not considered;

       •  Frequencies of contact were used in the risk assessment that exceed  current
          rates and may exceed expected future rates, resulting in overestimated risks;

       •  Uncertainties in  toxiciry values related to their derivation  generally are
          addressed by  applying  factors   that  lower  the values   resulting  in
          overestimated risks; and

       •  Uncertainties  associated   with  the  ground-water  modeling  performed;
          specifically that the modeling did  not consider attenuation of TCE, which
          may result in lower concentrations at the nearest POE.

2.7.2  Ecological Risk Assessment

Potential ecological  effects  and whether SWMU 91 poses  an immediate  threat  are
qualitatively evaluated in the preliminary ecological  risk assessment. The ecological
evaluation concluded that currently there are no factors that pose a threat to ecological
receptors. In addition, no factors indicate  the possibility of future exposure to ecological
receptors at SWMU 91, and  it  is likely  mere will be no exposure along contaminant
migratory pathways. These conclusions are based primarily upon SWMU 91's location
within the  facility boundaries inside the PGDP security fence. No critical habitats,
populations of, or potential habitats for federally listed, proposed, or candidate species
exist within the PGDP security fence. No waterfowl or fish are present  in the ditches
surrounding the SWMU.  The plant communities exist  mostly in  mowed grass  and
channeled ditches. Therefore, assessing direct toxic effects on wildlife populations at
SWMU  91  is inappropriate due to the industrial  nature and  small scale of the unit.
 Furthermore, the cumulative effects of contamination of small areas of terrestrial habitat
 and contaminant migration from multiple source units to receiving areas  (e.g., streams)
 will be assessed in the PGDP baseline ecological risk assessment for  the surface-water
 integrator operable unit.

 Based on the findings of the ecological risk evaluation, only the results of the BHHRA
 were used to evaluate the need  for action at SWMU  91 and to develop the remedial
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concerns will  improve conditions in the  ecosystem  by  accelerating  the natural
attenuation process.

2.7.3   Conclusions of the Risk Assessment

While the impacts of these uncertainties to the risk assessment results and ground-water
modeling vary, data conclusively shows that TCE is distributed throughout the soil
within SWMU 91. In addition, underlying ground water in the UCRS appears to have
been  impacted as  a  result of  TCE migration. In consideration  of  all  available
information, TCE is  identified as a human health COC, which is the primary emphasis
for remedial decisions at SWMU 91.

2.7.4   Remedial Action Objective

Results of the human health risk assessment  indicate that the concentration of TCE  in
the soil at SWMU  91  is not at levels that -are  associated  with unacceptable risk.
However, modeling indicates that TCE may migrate to the ground water and eventually
to the nearest POE at concentrations exceeding the MCL of 5 Jig/I. The RAO is intended
to prevent rural residents from exposure to  the only COC, TCE. Thus, the RAO for
SWMU 91  is to mitigate  migration of TCE beyond the SWMU boundary through the
ground water by the soil  leaching pathway.  The Lasagna™ technology demonstration
has  been shown to  meet effectively the  RAO for SWMU 91  by  treating TCE
contaminated soils present in SWMU 91 to less than 5.6 mg/kg. Remediating TCE levels
in soil below 5.6 mg/kg will reduce TCE concentrations below MCLs (less than 5 ug/1),
thereby protecting human health at the nearest POE in ground water.

2.8    Description of Alternatives

Twenty-one technologies were evaluated and screened in the Feasibility Evaluation for
Trichloroethene-Contaminated Soil at Solid Waste Management  Unit  91 at the Paducah
Gaseous Diffusion Plant, Paducah,  Kentucky, DOE/OR/06-1557&D3. Three alternatives
were retained for detailed evaluation. The following paragraphs present a description of
the three detailed alternatives evaluated for SWMU 91.

2.8.1  Alternative 1 — No Action

Pursuant to 40 C.F.R. §  300.430(e) of the  National Oil and Hazardous Substances
Pollution Contingency Plan (NCP),  the  DOE is required to consider a  no action
alternative. This alternative serves as a baseline to which the other alternatives  will  be
compared. Under this alternative, no further  action would be taken at SWMU 91.

Under this alternative, the DOE would take no action to address soil and future ground-
water contamination problems or to minimize further contaminant releases from SWMU
91. The alternative would not reduce future risk. No additional costs are associated
with this alternative.

 2.8.2  Alternative  2 — In Situ Remediation (Lasagna™)

 Alternative 2  consists of in situ soil treatment for TCE. The in-place soil treatment
 proposed is a new, yet demonstrated, technology at the PGDP that is provided under
 the trademark Lasagna™. The Lasagna™ process uses electroosmosis (electrical fields)
 to drive pore volumes of water containing TCE to treatment zones that also are  located
 in the ground (Figure 2-9). The volume of soil proposed  for treatment at SWMU 91  is
 estimated to be 32  m (105 ft) long by 18 m  (60 ft) wide by 14 m (45 ft) deep, which


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Note: Electro-Osmotic Flow is Reversed
    Upon SwHcNng Electrical Polarity.
                                                                                             •Jacob* EM T**m. 1M6
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                 Figure 2-9. Conceptual Schematic of Lasagna™

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equates to  approximately 7,645 m3 (270,000 ft3 or 10,000 yd3). The treatment zones
(approximately 20) are estimated  to be 18 m (60 ft) long by 14 m (45 ft) deep and
approximately 5 cm (2 inches) thick. The media used for treatment may consist of a
variety of products such as iron,  kaolin clay, and water with the specific treatment
medium being determined during design. Electrodes will be placed at the ends of the
area and most likely at evenly spaced intervals between treatment zones to supply the
electrical current for treatment.

2.8.3  Alternative 3 — In Situ Enhanced Soil Mixing

Alternative 3 consists of stripping volatile organics using a crane-mounted auger (Kgure
2-10). The diameter of the soil auger ranges from 0.9 to 3.6 m (3 to 12 ft). Steam, hot air,
or hydrogen peroxide is injected through the auger to assist in stripping volatile organics
(i.e., TCE)  from the soils. Soil vapors, contaminated with volatile organic compounds,
are collected under a surface shroud and transported to an off-gas treatment system
(e.g., activated carbon that would be regenerated or stored onsite). Treatment zones are
overlapped to address the entire contaminated area.                              ;

This technology is particularly suited to shallow applications  [i.e., effective at depths
down to 12 m (40 ft)] above the water table, but it can be used at greater depths [some
commercial vendors have successfully operated this process at depths to 305 m (100 ft)
with the smaller diameter augers)]. This technology appears to be applicable to all types
of soils (i.e.,  sandy, silty, or clayey). This technology may require an off-gas treatment
system  if  the  expected  contaminant  concentrations  exceed emission  standards;
therefore,  the  cost  presented in  the  following text  includes off-gas treatment.
Application of this technology at the Portsmouth Gaseous  Diffusion Plant (PORTS) site
indicated that removal efficiencies decreased as depths increased; however, none of the
depths conducted at PORTS exceeded  the 7-m (22-ft)  depth  interval.  Removal
efficiencies also increased with operation times.

2.9    Summary of the Comparative Analysis of Alternatives

This section  provides the basis for determining which  alternative does the following:
(1)  meets  the threshold criteria  for  overall protection  of  human health  and the
environment, and complies with applicable or relevant and appropriate  requirements
(ARARs); (2) provides the best balance between effectiveness and reduction of toxicity,
mobility, or  volume through  treatment, implementability, and cost;  (3) satisfies  both
state and  community acceptance; and (4) is consistent with the  Hazardous Waste
Permit

Nine criteria are required by  the CERCLA for evaluating  the expected performance of
remedial actions.  The remedial alternatives have been evaluated based on  the nine
criteria that are identified as follows.

       (1)     Overall protection of human health  and the environment. This  threshold
              criterion requires that the remedial alternative adequately protects human
              health and the environment, in both the short and long term. Protection
              must be demonstrated  by the  elimination,  reduction, or control  of
              unacceptable risks.

        (2)    Compliance with ARARs.  This threshold  criterion  requires  that the
              alternatives be assessed  to determine if they attain  compliance with
              ARARs of both state and federal law.
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                    Note: Treatment agents (e.g., hot air or steam) are delivered through the mixing
                          blade with emissions captured in the shroud covering the mixed region.
              Sourer. MoOfied from Mutch and Ash. 1993
                                                                                      BJ*oab* EM T««m. ims
                              Figure 2-10. In Situ Enhanced Soil Mixing Schematic

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                     (3)     Long-term effectiveness and permanence. This primary balancing criterion
                            focuses on the magnitude of residual risk and the adequacy and reliability
                            of the controls used to manage remaining waste (untreated waste and
. j                          treatment residuals) over the long term (i.e., after remedial objectives are
                            met). Remedial  actions that provide the  highest  degree of  long-term
-*                          effectiveness and permanence are those that leave little or no waste at the
 1                          site,  make  long-term  maintenance and monitoring  unnecessary,  and
                            minimize the need for institutional controls.
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                     (4)     Reduction of contaminant toxicity,  mobility, or volume through  treatment.
                            This primary balancing criterion is used to evaluate the degree to which
                            the alternative employs recycling or treatment to reduce the toxicity,
                            mobility, or volume of the contamination.

                     (5)     Short-term  effectiveness. This primary  balancing  criterion  is  used  to
                            evaluate the effect of implementing the alternative relative to the potential
                            risks  to the  general public, potential  threat  to  workers, potential
                            environmental impacts,  and the time required  for  protection to  be
                            achieved.

                     (6)     Implementability. This primary balancing criterion is  used to evaluate
                            potential difficulties  associated with implementing the alternative. This
                            may include  technical feasibility,  administrative feasibility, and the
                            availability of services and materials.

                     (7)     Cost. This primary balancing criterion is used to evaluate the estimated
                            costs  of the alternatives. Expenditures include the capital  cost, annual
                            O&M, and the combined total present value of capital and O&M costs.

                     (8)     State  acceptance. This modifying criterion  requires  consideration and
                            incorporation of any comments on the ROD from the Commonwealth of
                            Kentucky.

                     (9)    Community   Acceptance.   This  modifying  criterion   provides   for
                            consideration of any formal comments from the community  concerning
                            thePRAP.

               2.9.1  Overall Protection of Human Health and the Environment

               An alternative must meet this threshold criterion to be eligible for selection. Alternative 2
               would meet this criterion because it remediates the contaminated soil and reduces  the
               future potential for contaminants to migrate to the aquifer and offsite. Alternative 3 also
               meets this criterion because it remediates the contaminated soil and reduces the future
               potential for contaminants to migrate to the aquifer.  Alternative 1 does not meet this
               criterion since it does  not address the remediation of contaminants in the soil and  the
               potential of the contaminant to migrate to the ground water and potentially off site.

               2.9.2   Compliance with Applicable or Relevant and Appropriate Requirements

               An alternative must meet this threshold criterion to be eligible for selection. The chosen
               remedial action will provide compliance with ARARs. Both Alternatives 2  and 3 would
               meet ARARs. A  detailed description of ARARs  is presented in  Section 2.11 of this
               ROD. Alternative 1 would not comply with ARARs.
                                                      23

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              2.9.3  Long-term Effectiveness and Permanence

              Alternative 2 would reduce potential long-term impacts to the aquifer by treating the
              contaminated soil (i.e., destroy TCE). However, untreated TCE in the soil may remain
              and could  require minor maintenance and some monitoring. The specific  needs for
              maintenance and  monitoring, if any, will be determined after the operational period.
              Also, Alternative 3 would reduce potential long-term impacts to the aquifer by treating
              the contaminated soil. Untreated TCE soil contamination may remain  that could require
              minor maintenance and some monitoring. Reliability for Alternative 1 is not applicable,
              since no remedial action is taken.

              2.9.4  Reduction of Contaminant Toxicity, Mobility, or Volume through Treatment

              Alternative 2 will reduce toxicity, mobility, and volume through the treatment of TCE-
              contaminated soil. This alternative will be designed to treat the soil to an average level
              below 5.6 mg/kg by the Lasagna™ process, which uses electroosmosis (electrical fields)
              to drive pore volumes  of water  to treatment zones. The Lasagna™  technology-is
              predicted  to remediate the contaminated soil to cleanup levels within two years. If the
              unit has not reached cleanup levels after approximately two years, the process may be
              allowed to continue for an extended time. However, if the process is not successful at
              achieving cleanup levels, DOE, in agreement with the EPA  and KDEP, may use another
              technology (e.g., Alternative 3). Alternative  3 will also reduce toxicity,  mobility,  and
              volume  through the  treatment of TCE-contaminated  soil.  Alternative 3  would be
              designed to treat the soil to an average level below 5.6 mg/kg by conducting in situ soil
              mixing  combined with vapor extraction  (e.g.,  hot  air  injection)  and  off-gas
              collection/treatment. Alternative 1 will not reduce toxicity, mobility or volume through
              treatment.

              2.9.5  Short-term Effectiveness

              Short-term effectiveness is not applicable for Alternative 1. No negative impacts on the
              community or environment are anticipated for Alternative 2 or Alternative 3. Risk to
              workers by volatile emission will be controlled by engineering methods and is within
              acceptable limits for Alternative 3.

              2.9.6  Implementability

              Alternative 1 would be  technically and administratively feasible to implement since no
              action is  involved.  Availability of services  and materials  is not applicable  since
              construction would not take place.

              Alternative 2  would  be technically  and   administratively  feasible  to  implement.
              Construction and operation of the technology on a smaller scale have been proved at
              the PGDP.

              Alternative 3 would be technically and administratively feasible to implement. Materials
              and  services are available  and  the technology  has been  demonstrated  at  other
              DOE facilities.

 .             2.9.7   Costs

-*             Estimated present worth, escalated capital costs, and 30-year O&M costs for each
              alternative are presented in Table 2-1. The total present worth cost and O&M costs for
 I             each alternative also are presented in the Table 2-1.


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                           Table 2-1. Cost Estimates
Criteria
Cost
Total escalated
capital cost
Total present
worth capital cost
Annual O&M cost
Present worth
O&M costs
Total present
worth cost
Alternative 1 -
No Action

$0
$0
$0
$0
$0
Alternative 2 - In Situ
Remediation
(Lasagna™)

$1,924,000
$1,849,000
$7,000
$99,000
$1,948,000
Alternative 3 - In Situ
Enhanced Soil Mixing

$2,879,000
$2,762,000
$7,000
$102,000 .-
$2,864,000
2.9.8  State Acceptance

This remedial action will be initiated pursuant to provisions of the PGDP's Kentucky
Hazardous  Waste Maragement Permit  KY8-890-008-982.  The   Preliminary  Site
Characterization/Baseline Risk  Assessment/Lasagne™ Technology Demonstration at Solid
Waste Management Unit  91 of the Paducah Gaseous Diffusion  Plant, Paducah, Kentucky,
KY/EM-128, was issued to the KDEP and the EPA for review. The Feasibility Evaluation
for Trichloroethene-Contaminated Soil at Solid Waste Management Unit 91 at the Paducah
Gaseous Diffusion  Plant,  Paducah, Kentucky, DOE/OR/06-1557&D3  and the Proposed
Remedial Action Plan for Solid Waste Management Unit 91, Paducah Gaseous Diffusion Plant,
Paducah, Kentucky, DOE/OR/06-1499&D3 have been approved by the KDEP and EPA.

2.9.9  Community Acceptance

As previously discussed in Section 2.3 and later in the Responsiveness Summary, which
is Section 3 of this ROD, the public has been provided the opportunity to comment on
the selected remedial action. No member of the public stated opposition to the selected
remedial action or any other aspect of the proposed plan.

2.10   Selected Remedy

Based upon the evaluation of the alternatives utilizing the nine CERCLA criteria, the
remedy that best meets  the threshold, balancing, and  modifying  criteria  for the scope
and objectives of this remedial action is Alternative 2.
                                      25

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 '             The selected remedy will, at a minimum, consist of the following elements.

"J                    •  In situ soil treatment for TCE (Lasagna™).

                     •  The Lasagna™  process uses electroosmosis (electrical fields)  to drive pore
<«                       volumes of water containing TCE to treatment zones located in the ground.

                     •  The volume  of saturated soil proposed for treatment  at  SWMU 91 is
                        estimated to be 32 m (105 ft) long by 18 m (60 ft) wide by 14 m (45 ft) deep,
 j                       which equates approximately  to 7,645 m3 (270,000 ft3 or 10,000 yd3).
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      •   The treatment zones (approximately 20) will be nearly 18 m (60 ft) long by
          14 m (45 ft) deep and approximately 5 cm (2 inches) thick.

      •   The media used for treatment may consist of products such as iron, kaolin
          clay, and water with the exact composition being determined during design,

      •   Electrodes will be placed at the ends of the area to be remediated and, most
          likely, at evenly spaced intervals between the treatment zone boundaries to
          supply the electrical current needed for treatment.

The DOE will prepare a detailed design for this remedial action in accordance with the
requirements specified in the  Declaration of this ROD. During remedial design and
remedial construction activities, some changes may be made.

This action is  expected to  provide overall protection  of human  health and  the
environment It also can be implemented  in compliance with ARARs. This action will
serve as a remedial action for the soil at SWMU 91 of WAG 27.  Contaminant mobility
to the underlying aquifer will be reduced as a result of the treatment. This alternative
will provide short-term effectiveness and may be readily implemented. As shown in
Table 2-1, the total present worth estimated cost for Alternative 2 is $1,948,000.

The Lasagna1** process  is an innovative technology. If the unit has not reached cleanup
levels within two years, the process may be allowed to continue operation until cleanup
is achieved. However, if the process is not successful at achieving cleanup levels, the
DOE may use  another technology, Alternative 3 — In Situ Enhanced Soil  Mixing, to
remediate the unit. This technology consists of the following elements:

       •  A crane or other mechanical mixing unit;

       •  An agent delivery system (e.g., hot air, steam, or hydrogen peroxide); and

       •  An off-gas collection/treatment system (e.g., activated carbon that will  be
          regenerated  or stored onsite).

2.11   Statutory Determinations

This remedial action is protective of human health and the environment and complies
with both federal and state ARARs. This remedial action is cost-effective, and it follows
the statutory mandate for permanent solutions and alternative treatment technologies  to
the maximum extent practicable. Additionally, this action meets the statutory preference
for remedies that employ treatments that  reduce toxiciry, mobility,  or volume as a
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 '             principal element. Since  contaminants  may  remain at  the unit, a  five-year  review
              evaluating whether the remedy's cleanup levels provide adequate protection for  human
              health and the environment may be required.

              2.11.1 Overall Protection of Human Health and the Environment
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             The selected action contributes to protection of human health for PGDP employees and
             the public through treatment, which will limit the potential  for direct exposure and
             mitigate migration of contaminants from the SWMU.  The remedy provides effective
             sampling and management of all residual wastes generated during implementation of the
             action, if unlimited use and unrestricted exposure remain after remediation.

             2.11.2 Applicable or Relevant and Appropriate Requirements

             The United States Congress specified in CERCLA § 121 (42  U.S.C.A. § 9621)  that
             remedial actions  for the  cleanup of hazardous substances  must  comply with the
             requirements, criteria, standards, or limitations under federal or  more stringent state
             environmental laws that are legally  applicable or relevant  and  appropriate to the
             hazardous substances or circumstances at a site. The EPA categorizes ARARs as being
             either "applicable" or "relevant and appropriate" to a site. The terms and conditions
             pertinent to these categories are discussed as follows.
                    3*  Applicable requirements are "those cleanup standards, standards of control,
                       and other substantive requirements, criteria, or limitations promulgated under
                       federal environmental or state environmental or facility  siting laws  that
«.                     specifically address a hazardous substance, pollutant, contaminant, remedial
 »                     action, location, or other circumstance found at a CERCLA site" (40 C.F.R. §
                       300.5).

 1                  •  Relevant and appropriate requirements are "those cleanup standards, standards
 J                     of  control,  and  other substantive  requirements,  criteria,  or limitations
                       promulgated under federal environmental or state environmental or facility
~l                     siting laws that, while not applicable to  a hazardous substance, pollutant,
_J                     contaminant, remedial action, location, or other circumstance at a CERCLA
                       site, address problems or situations sufficiently similar to those encountered
                       at  the CERCLA  site that their use  is well suited to the particular  site"
                       (40 C.F.R. § 3005).
              Requirements under federal or state law  may be either applicable or relevant and
              appropriate  to CERCLA cleanup  actions,  but  not both.  If  a requirement is  not
              applicable, then it must be both relevant and appropriate in order for it to be an ARAR.
              In cases where both a federal and a state ARAR are available, or where two potential
              ARARs address the same issue, the more stringent regulation must be selected. However,
              in cases where  the implementation of a  federal  environmental  program has  been
              delegated by the EPA  to  a state, typically,  the analogous state regulations would be
              used as ARARs.

              Other information that does not meet the definition of an ARAR may be necessary to
              determine what is  protective or may be useful in  developing  CERCLA remedies. In
              addition, ARARs do not exist for every chemical or circumstance likely to be found at a
              CERCLA site. Therefore, the EPA believes that it may be necessary, when determining
              cleanup requirements or designing a remedy, to consult reliable information that would
              not otherwise be considered a potential ARAR. Criteria or guidance developed by the
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             EPA, other federal agencies, or states may assist  in determining, for example, health-
             based cleanup levels for  a particular  contaminant or the appropriate  method  for
             conducting an action for  which no ARARs exist. This other information is to be
             considered (TBC) information and may be used when developing CERCLA remedies.
             The TBC  information  generally falls  within  three categories: (1)  health effects
             information,  (2) technical information on  performing or evaluating investigations or
             response actions, and (3)  policy. A possible  fourth category  of TBC information is
             proposed regulations, if the proposed regulation is non-controversial and likely to be
             promulgated as drafted.

             The EPA  further categorizes  ARARs  based  on  whether  they are specific to  the
             chemical(s) present at the site (chemical-specific), the remedial action being evaluated
             (action-specific),  or the location of the site (location-specific). Terms  and conditions
             relevant to this categorization include the following.

                    •   Chemical-specific ARARs usually are "health- or risk-based numerical values
                        or methodologies which, when applied  to site-specific conditions, result-in
                        the establishment of  numerical values"  [53 Fed.  Reg. 51437 (December 21,
                        1988)]. These values establish the acceptable amount or concentration of a
                        chemical mat may remain in, or be discharged to, the ambient environment.

                    •   Action-specific ARARs usually are "technology- or activity-based requirements
                        or limitations placed on actions taken with respect to hazardous wastes, or
                        requirements to conduct certain actions to address particular circumstances
                        at a site" [53 Fed. Reg. 51437 (December 21,1988)]. Selection of a particular
                        remedial  action at  a site will  trigger action-specific  ARARs that specify
                        appropriate technologies and performance standards.

                    •   Location-specific  ARARs  "generally  are  restrictions  placed   upon  the
                        concentration of hazardous  substances or the conduct of  activities  solely
                        because they are in  special  locations"  [53 Fed.  Reg. 51437 (December 21,
                        1988)]. Some examples of special  locations include floodplains, wetlands,
-i                      historic places, and sensitive ecosystems or habitats.

              The EPA designated these categories to assist  in the identification of ARARs; however,
              they are not necessarily precise [53 Fed. Reg. 51437 (December 21,1988)]. Some ARARs
 J            may fit into more than one category, while others  may not  fit definitively into any one
-*            category.
              According to the preamble to the NCP at 53 Fed. Reg. 51443 (December 21, 1988),
              potentially responsible parties  (PRPs)  conducting remedial actions,  or  portions of
              remedial actions entirely onsite as denned in 40 C.F.R. § 300.5, must comply with the
              substantive portions of ARARs, but not the procedural or administrative requirements.
              Substantive requirements pertain directly to the actions or conditions at a site, while
              administrative requirements (e.g., permit applications  and procedural requirements)
              facilitate remedial action implementation. Also, CERCLA § 121(d)(4)  [42 U.S.C.A. §
              9621(d)(4)] provides several ARAR waiver options that may be invoked, provided that
              human health and the environment are protected. Moreover, under CERCLA § 121(e)
              [42 U.S.C.A. § 9621(e)], PRPs are not required to obtain federal, state, or local  permits
              in order to conduct on-site response actions.

              In the NCP at 40 C.F.R. § 300.150, the EPA has addressed the relationship of ARARs to
              worker protection standards. The EPA  states that  CERCLA response actions must
              comply with the worker protection standards and requirements of  the Occupational


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Safety and Health Act of 1970 (29 U.S.C.A §§ 651 through 678) and analogous state
laws; however, the standards and requirements are not ARARs  [55 Fed. Reg. 8680
(March 8, 1990)].

The DOE,  in  Order 5480.4,  Environmental  Safety and Health  Standards, establishes
general requirements for environmental protection, safety, and health standards for all
DOE and contractor operations. The Order is an internal standard, and, consistent with
40 C.F.R. § 300.150, is not an ARAR. Nonetheless, DOE Order 5480.4 must be followed
during the design, construction, operation, modification (if any), and decommissioning
phases of the remedial action.

Lastly, while  CERCLA  requires that  the RCRA and  other environmental laws be
evaluated as ARARs [42 U.S.C.A. § 9621(d)(2)(A) and 40 C.F.R. § 300.420(f)(l)(i)(A)],
this in no way limits, takes away, or negates the KDEP's RCRA authority at the PGDP.

Chemical-, location-, and action-specific ARARs and TBC information that exist for
remedial action at SWMU 91 are described in the following sections.  These ARARs
apply both to the preferred Lasagna™ technology and to the contingency remedy, In Situ
Enhanced Soil Mixing, unless otherwise noted.

2.11.2.1  Chemical-specific applicable or relevant and appropriate requirements

Ground-water contamination.

The Kentucky Administrative Regulations at 401 K.A.R. 8:250-420  may be relevant and
appropriate for contaminated ground water at SWMU 91. The MCLs defined in these
regulations are legally applicable to water "at the tap" but are not applicable to the
cleanup of ground water. However, they may be considered as relevant and appropriate
in situations where ground water may be used for drinking water. The MCL for TCE is
0.005 mg/1 (401 K.A.R. 8:420  § 3). This ARAR is relevant and appropriate to both the
preferred and contingency remedy. Either  technology is  expected to reduce the soil
contamination to a level that would no longer contribute to ground-water contamination.

2.11.2.2  Location-specific applicable or relevant and appropriate requirements

Wetlands and floodplains.

No adverse impacts to  floodplains or wetlands  in the vicinity of SWMU 91  are
anticipated. Consequently, although all ARARs discussed in this section are applicable,
those referring to floodplains  and wetlands will be met by avoidance of the resource.
However, if impacts become apparent, due to construction or other plan modifications,
additional requirements (compliance with the substantive requirements of Nationwide
Permit (NWP) 38, 33 C.F.R. § 330) will need to be addressed and/or initiated during
the remedial design and/or remedial action phase to comply  with the ARARs.  The
requirements discussed in this section will apply to both remedial technologies.

Wetlands, and a small portion of the 100-year floodplain of Bayou Creek, have been
 identified in a drainage ditch  approximately 100 feet south of SWMU 91.  Construction
 activities must avoid or minimize adverse impacts to wetlands and act to preserve and
 enhance their natural and beneficial values [Executive Order  11990;  40 C.F.R.  §
 6.302(a); 40 C.F.R. § 6, Appendix A; and 10 C.F.R. § 1022]. In addition, construction
 activities must minimize potential harm to  the 100-year floodplain (Executive Order
 11988 and 10 C.F.R. § 1022).
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The DOE will avoid, to the extent practicable, the long- and short-term adverse impacts
to floodplains and wetlands [10 C.F.R. § 1022.3(a)]. The DOE will undertake a  careful
evaluation of the potential effects of any DOE action taken in a floodplain [10 C.F.R. §
1022.3(c)J.

Construction in wetlands will be avoided unless there are no practicable alternatives [40
C.F.R. § 6.302(a)]. Degradation or destruction of wetlands will be avoided to the extent
possible  [40 C.F.R.  § 230.10  and  33 U.S.C.  §  1344(b)(l)].  Considerations about
protection of wetlands  will be incorporated into planning, regulating,  and decision
making [10 C.F.R. § 1022.3(b)]. Any action involving the discharge of dredged or fill
material into wetlands will be avoided to  the extent possible (13  U.S.C.  § 1344,  40
C.F.R. § 230, and 33 C.F.R. §§ 320 to 330).

2.11.2.3 Action-specific applicable or relevant and appropriate requirements

Solid waste management unit cleanup.

The regulations that apply to the cleanup of SWMUs are applicable to Lasagne™ and In
Situ Enhanced Soil Mixing. These applicable regulations do not contain specific cleanup
standards, but instead they require corrective action measures  that will result in  the
protection of human health and the environment (40 C.F.R. § 264.101  and 401  K.A.R.
34.-060 § 12). Either technology would comply with this ARAR

Site preparation activities.

Although fugitive dust associated with the implementation  of  either remedial action
would be minimal, on-site construction activities may produce airborne pollutants. The
Kentucky Air Quality standards found in 401  K.A.R.  63:010 §§ 3-4 contain general
standards of performance governing fugitive dust emissions.  The standards require the
use of water or chemicals, if possible, and /or placement of asphalt or concrete on roads
and material stockpiles  to control dust [401 K.A.R. 63:010  § 3(l)(b)]. The standards
also require that visible dust generated from implementation  of the remedial alternative
not be discharged beyond the property line of the PGDP [401 K.A.R. 63:010  § 3(2)].
Additionally, all open-bodied  trucks that operate outside the property boundary and
that may emit materials that could become airborne must be covered [401 K.A.R. 63:010
§ 4(1)]. These requirements are applicable.

Toxic air emissions.

No TCE  emissions are anticipated with the Lasagna™ technology.  However, if the
contingency remedy, In Situ Enhanced Soil Mixing, is implemented, the potential exists
for TCE emissions to occur. The DOE must first determine if  the regulations at  401
K.A.R. 63:022 apply by calculating the significant emission level for the specific toxic air
pollutant (as specified in Appendix B of 401 K.A.R. 63:022).  If it is determined  that the
toxic air regulations apply, normally, a permit would be  required. However, because this
is a CERCLA  action, only the substantive provisions must be followed. The regulation
 specifies that no source is to exceed the allowable emission limit specified in Appendix
 A of 401 K.A.R. 63:022. If the emission limit cannot be met, even after the application of
best available  control technology, then best available control technology must  be  used
 (401 K.A.R. 63:022  § 3). Appropriate measures would be taken, if the contingency
 remedy were implemented, to comply with this ARAR.
                                       30

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 I
 '            Surface-water control for construction activities.

             Storm-water discharges from construction activities onsite at the PGDP are regulated by
 j            the KPDES Permit (KY0004049) established pursuant to 401 K.A.R. 5:055. The PGDP's
             KPDES Permit  specifies that  best  management practices and sediment and  erosion
-»            controls be implemented at a site to  control storm-water runoff. These requirements are
 j            applicable during the construction of either remedy identified in this ROD.

             Hazardous waste determination.

             During construction of the  remedial  action, either Lasagna™ or In Situ Enhanced Soil
             Mixing, a minimal amount of soil will be generated. The soil must undergo a hazardous
-l            waste determination pursuant to 40 C.F.R. § 262.11  and 401  K.A.R. 32:010 § 2. If the
 j            waste is determined to be hazardous,  RCRA Subtitle C  requirements would be
             applicable (40 C.F.R. § 262.34, 401 K.A.R. 34:030 § 5). Any waste generated during
—            implementation of the remedial action will be characterized appropriately.

*-*            Radioactive waste determination.

I             Any waste generated with the remedial action must be characterized with sufficient
             accuracy to permit proper segregation, treatment, storage, and disposal [DOE Order
             5820.2A, m.3.d(l)]. The DOE Order 5820.2A is TBC information to the disposition of
             Jany radioactive waste associated with this action. Waste characterization data must be
             recorded on a waste manifest and must include the following: the physical and chemical
             characteristics  of  the waste; volume of the waste; weight of  the waste; major
             radionuclides and  their concentrations; and packaging date, package weight,  and
 I            external volume. Again, during the  implementation of Lasagna™ or In Situ Enhanced
             Soil Mixing, appropriate characterization will occur.

             Table 2-2 lists the chemical-, location-, and action-specific ARARs for remedial action at
             SWMU91.

-i            2.11.3 Cost Effectiveness

             The preferred remedy provides overall effectiveness to remove and  treat contaminants
             and to reduce potential risk while being proportional to its cost. The preferred remedy
 1            represents the least expensive remedial alternative that employs innovative treatment.

             2.11.4 Utilization of Permanent Solutions and Alternative Treatment Technologies

             The selected remedy (Lasagna™) meets the statutory requirement to utilize permanent
             solutions and treatment technologies to the maximum extent practicable. The selected
             remedy  also satisfies the five primary balancing  criteria.  It  provides long-term
              effectiveness and permanence; it provides the greatest reduction of toxicity, mobility,
              and volume through treatment; it provides short-term effectiveness; it is administratively
              and  technically feasible to implement; and it is  the  most  cost-effective remedial
              alternative evaluated.
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      Table 2-2. Applicable or Relevant and Appropriate Requirements and To Be Considered Information for the Remedial Action
                                  (Lasagna™ with In Situ Enhanced Soil Mixing Contingency)
Regulatory Triggers
Requirements
Prerequisites
Federal Citation
K.A.R.
Citation
CHEMICAL-SPECIFIC
Protection of drinking
water
Treatment to MCLs: TCE 0.005 mg/1.
Contaminants that have leached
into potential sources of drinking
water — Relevant and
appropriate to ground-water
remediation, applicable at the
"tap."
40 C.F.R. §
141.60
401 K.A.R. 8:420 § 3
LOCATION-SPECIFIC
Protection of
wetlands
Protection of
floodplains
Avoid or minimize adverse impacts
to wetlands to preserve and enhance
their natural and beneficial values.
Avoid degradation or destruction of
wetlands to the extent possible.
Incorporate considerations about
protection of wetlands into
regulating and decision making.
Follow substantive requirements of
general Nationwide Permit
conditions.
Avoid siting or construction in any
100-year floodplains.
Any federal action that will
have an impact on wetlands
— Applicable if avoidance is not
achieved.
Any action involving discharge of
dredged or fill material into
wetlands — Applicable if
avoidance is not achieved.
Any federal action that will
have an impact on wetlands
— Applicable if avoidance is not
achieved.
Any federal action within a 100-
year floodplain — Applicable if
avoidance is not achieved.
10CF.R,§1022
and Executive
Order 11990
40CF.R.§
230.10 and 13
U.S.C. §
1022.3(b)
10 C.F.R. §
1022.3(b)and33
C.F.R. § 330
10 C.F.R. § 1022
and Executive
Order 11988




NJ

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       Table 2-2, Applicable or Relevant and Appropriate Requirements and To Be Considered Information for the Remedial Action
                                 (Lasagna™ with In Situ Enhanced Soil Mixing Contingency) (Continued)
       Regulatory Triggers
          Requirements
         Prerequisite
Federal Citation
 K.A.R.
Citation
                                                            ACTION-SPECIFIC
      Site preparation and
      construction
      activities
OJ
CO
Reasonable precaution must be taken
to prevent particulate matter from
becoming airborne. Such precautions
may include the following:
  •   Use water or chemicals to
      control dust from construction
      activities and/or place
      asphalt, oil, water, or
      suitable chemicals on roads
      and material stockpiles to
      control dust;
  •   Ensure  that no visible
      fugitive dust is emitted
      beyond the property line; and
  •   Ensure  that all open-bodied
      trucks are covered if any
      materials in the truck could
      become airborne.
Handling, processing,
construction, road-grading, and
land-clearing activities
— Applicable.
                 401 K.A.R. 63:010 § 3
                                                                                                              401 K.A.R. 63:010 §
                                                                                                              401 K.A.R. 63:010 § 3(2)
                                                                                                              401 K.A.R. 63:010 § 4(1)

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1
 1
1
3
3
 i
3
 1
3
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 J
3
2.11.5 Preference for Treatment as a Principal Element

The selected remedy meets the statutory preference for treatment as a principal element.
This is accomplished by the Lasagna™ technology that remediates soils by driving the
TCE-«>ntaminated pore volume  water through  treatment zones.  The process uses
electroosmosis to move contaminants in the soil pore water into treatment zones where
the contaminants can be captured or decomposed.

2.12  Documentation of Significant Changes

The Proposed Remedial Action Plan for Solid Waste Management Unit 91 at the Paducah
Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/06-1499&D3, was made available
for a 45-day  public review and comment period that began February 23,  1998, and
ended on April 8,1998. No meeting was requested for the proposed plan nor were any
comments received  from the public; therefore,  the DOE has  determined  that  no
significant changes to the remedy are necessary.
                                       34

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                              PARTS

                     RESPONSIVENESS SUMMARY
                                35

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1

1

1
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1

3
                    RESPONSIVENESS SUMMARY

3.1   Responsiveness Summary Introduction

The responsiveness summary has been prepared to meet the requirements of sections
113(k)(2)(b)(iv)  and  117(b)  of  the  CERCLA, as  amended  by  the Superfund
Amendments and Reauthorization Act (SARA) of 1986, that requires DOE as "lead
agency" to respond ". . . to each of the significant comments, criticisms, and new data
submitted in written or oral presentations" on  the SWMU 91  of WAG 27 Proposed
Remedial Action Plan.

The DOE has gathered information on the types and  extent of contamination found,
evaluated remedial measures, and recommended a remedial action that will reduce the
potential migration of contaminants from the soil to the aquifer (i.e.,  off-site ground
water to the FOE). As part of the remedial action process, a notice of availability
regarding the PRAP was published in The Paducah Sun, a major regional newspaper of
general circulation. The Proposed Remedial Action Plan for Solid Waste Management Unit. 91
at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/06-1499&D3, was
released to the general public February 23, 1998. This document was made available to
the public at the Environmental Information Center in the West Kentucky Technology
Park in Kevil, Kentucky, and at the Paducah Public Library. A 45-day public comment
period began February 23, 1998, and continued through April 8, 1998. The PRAP also
contained information that provided the opportunity for a public meeting to be held, if
requested. No request for the meeting was made by the public, so no meeting was held.
Specific groups that received individual copies of  the  PRAP included  the Natural
Resource Trustees and the Site Specific Advisory Board.

Public participation in the CERCLA process is required by  the SARA. Comments
received from the public are considered in the selection of the remedial action for the
site. The responsiveness summary serves two purposes:  (1)  to provide the DOE with
information about the community preferences  and concerns  regarding  the  remedial
alternatives, and (2) to show members of the  community how their  comments were
incorporated into   the decision-making  process- However,  there were no  public
comments.

3.2    Community Preferences/Integration of Comments

No comments, written or oral, were received from the  public; therefore, this document
does not address public comments, except to  the extent that it is assumed that the
proposed plan is satisfactory to the public.
                                      36

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                                Remedial Design Schedule for
                               Solid Waste Management Unit 91
ID
1
2
3
4
S
6
7
8
9
10
11
12
13
14
15
16
17
10
19
20
21
Task Name | Duration | Start
PRAP/ROD 1700 2/23/98
Public Comment on PRAP 45d 2/23/98
End Public Comment Period Od 4/8/98
ROD Development 126d 4/8/98
EPA ROD Signature ; Od 8/11/98
Procurement 141d; 5/13/98
[
SOW, RFP, Proposal. Negotiate 140d > 5/13/98
Award Id 9/30/98
Remedial Design (RD) 262d 10/1/98
Draft Initial RD 30d 10/1/98
30% Onboard Review Od 10V30VB8
develop 60% package 70d 10/31/98
60% Onboard Review I Od 1/8/99
Develop 01 (90%) Package 70d 1/9/99
Issue 01 Remedial Design Od 3/19/99
EPA/KDEP Review of D1RD 33d 3/20V99
EPA/KDEP Issue Comments Od 4/21/99
Revise D1 Remedial Design 30d 4/22/99
Issue 02 Remedial Design ' Od 5/21/99 j
EPA/KDEP Rnal Review 29d 5/22/99!
CFC ' Od 	 6/19/99!
( Finish
8/11/98
4/B/98
i 	 4/8/98
| 8/11/98
8/11/98
9/30/M
:
9/29/98
9/30/98
6/19/99
10/30/98
10/30/98
" 	 1/8/99"
1/8/99
3/19/99
3/19/99
4/21/99
4/21/99
5/21/99
5/21/99
6/19/99
6/19/99
2nd Quarter

^^^^^
r^^


3rd Quarter

•*7I
J
«>4/8
^•s^^^-v:vs

•^^•••••IIIBBBM

4th Quarter 1st Quarter) 2nd Quarter) 3rd Quarter


spa
• 8/11
^KH^^BBp
I
•^••^•••^B^^ ^
• 10/30
^•^pspyva
• 1/8
hv.v.v.v.v.y.v.v.v.v.w.l
• 3/19
• 4/21
• 5/21
•
Protect: Lasagne
Schedule based on calendar days
Date: 4/29/98
Task

Progress

Milestone
3  Summary
   Rolled Up Task
                                                                   Rolled Up Progress

                                            Rolled Up Milestone O

                                                Page 1

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                The distribution sheet that is included in this signed Record of Decision has become
            obsolete since the signing of this Record of Decision. We have included this current revised
                                   version by which we now distribute documents.


                                                 DISTRIBUTION
1


J

1
J
J

J
U.S. DEPARTMENT OF ENERGY
Myma Redfield
US. Department of Energy
P.O. Box 1410
Paducah, KY 42001

Nancy Cames, CC-10
(Letter only)
US. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

Gary Hartman
(Letter only)
US. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

Jimmie C Hodges (3 copies)
US. Department of Energy
P.O. Box 1410
Paducah, KY 42001

K. Kates, AD-424
(Letter only)
US. Department of Energy
Chirtn IBuilding
167 Mitchell Road
Oak Ridge, TN 37830

Robert L-Nace
(Letter only)
EM-423 Quince Orchard
US. Department of Energy
19901 Germantown Road
Germantown, MD 20874-1290

Robert C Sleeman, EW-91
 (Letter only)
US. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

Don Williams
 EM-42/Cloverleaf Building
 US. Department of Energy
 19901 Germantown Road
 Germantown, MD  20874-1290

 U.S.gStVIRpNMENTAL
 PROTEJ^i'l^N AGENCY
 Carl R. Froede, Jr. (3 copies)
 US. EPA, Region 4
 61 Forsyth Street
 Atlanta, GA 30303

 JACOBS  ENGINEERING
 GRblJP
 Bruce E. Phillips
 Jacobs Engineering Group Inc.
 175 Freedom Boulevard
 Kevil, KY 42053
SYSTEMATIC MANAGEMENT
SYSTEMS
W. F. Redfield
US. Department of Energy Site Office
5600 Hobbs Road
West Paducah, KY 42086

KENTUCKY DEPARTMENT  OF
FISH AND WILDLIFE
Wayne Davis
Environmental Section Chief
KY Department of Fish and Wildlife
Resources
f 1 Game Farm Road
Frankfort, KY 40601

BECHTEL 1ACOBS
COMPANYTTg
Patricia A. Gourieux
(Letter only)
Bechtel Jacobs Company LLC
761 Veterans Avenue
Kevil, KY 42053

Jimmy C Massey
(Letter only)
Bechtel Jacobs Company LLC
761 Veterans Avenue
Kevil, KY 42053

NATURAL  RESOURCE
TRUSTEES
Alex Barber
Commissioner's Office
KY Dept for Environmental
Protection
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Abraham Loudermilk
Tennessee Valley Authority
400 W. Summit Hill Drive
 Knoxville, TN 37902

 Andrea B. Perkins
 US. Department of Energy
 Federal Office Building
 200 Administration Road
 Oak Ridge, TN 37830

 Allen Robison
 US. Department of Interior
 Fish and Wildlife Service
 446 Neal Street
 Cookville, TN 38501

 STATE OF  KENTUCKY
 Robert H. Daniell, Director
 Division of Waste Management
 KY Dept for Environmental
 Protection
 14 Reilly Road
 Frankfort Office Park
 Frankfort, KY 40601
Steve Hampson
Cabinet for Human Resources
Radiation Control Laboratory
100 Sower Boulevard
Suite 108
Frankfort, KY 40601

Todd Mullins
KY Division of Waste Management
US. Department of Energy Ste Office
5600 Hobbs Road
West Paducah, KY 42086

Tuss Taylor (3 copies)
UK/KDEP
18 Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Dr. John A. Volpe
Radiation Control Branch
Cabinet for Human Resources
275 East Main Street
Mail Stop HS2E-D
Frankfort, KY 40621

TVA
TecTWhitaker
(Letter only)
Plant Manager
Shawnee Fossil Plant
7900 Metropolis Lake Road
West Paducah, KY 42086

 U.S. ENRICHMENT
 CORPORATION
T. Michael Taimi
 (Letter only)
 US. Enrichment Corporation
 2 Democracy Center
 6903 Rockledge Drive
 Bethesda, MD 20817

 U.S. GEOLOGICAL SURVEY
 TomMesko
 US. Geological Survey
 9818 Bluegrass Parkway
. Louisville, KY 40299-1906

 WEST  KY WILDLIFE
 MANAGEMENT AREA
 W. D. Hendricks
 West Kentucky Wildlife
 Management Area
 Kentucky Department of Fish
 and Wildlife
 10535 Ogden Landing Road
 Kevil, KY 42053

 SITE SPECIFIC ADVISORY
 BOARD
 Site Specific Advisory Board
 Information Age Park Resource Center
 2000 McCracken Boulevard
 Paducah, KY 42001
J
             JEG.0197.27

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                                      DISTRIBUTION
US. DEPARTMENT OF ENERGY
Nancy Games, CC-10
US. Department of Energy
FedetafOffice Building
200 Administration Road
Oak Ridge, TN 37830

Gary Hartman
US. Department of Energy
FederafOffice BuildingEM-923
200 Administration Road
Oak Ridge, TN 37830

Jimmie C. Hodges (3 copies)
US. Department of Energy
P.O. Box 1410
Paducah,KY 42001

K. Kates, AD-421
US. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

R.P. Molenaar
US. Department of Energy
Maxima Building
107 Union Valley Road
Oak Ridge, TN 37830

Robert C Sleeman, EW-91
US. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

Don Williams
EM-42/Cloverleaf Building
US. Department of Energy
19901 Germantown Road
Germantown, MD 20874-1290

EPA
OurlR- Fioede, Jr. (5 copies)
US. EPA, Region 4
61 Forsyth Street
Atlanta, GA 30303

JACOBS ENGINEERING TEAM
IRC
Bruce E. Phillips (2 copies)
Jacobs Engineering Group Inc.
175 Freedom Blvd.
Kevil, KY 42053

Don J. Wilkes (2 copies)
Jacobs Engineering Group Inc.
125 Broadway
Oak Ridge, TN 37830

 SYSTEMATIC MANAGEMENT
 SYSTEMS
W. F. Redfield
US. Department of Energy Site Office
 5600 Hobbs Road
 West Paducah, KY 42086
KENTUCKY DEPARTMENT OF
FISH AND WILDLIFE
Wayne Davis
Environmental Section Chief
KY Department of Fish and Wildlife
Resources
#1 Game Farm Road
Frankfort,  KY 40601

BECHTEL JACOBS COMPANY
rce
Patricia A.  Gourieux (3 copies)
Bechtel Jacobs Company LLC
761 Veterans Ave.
Kevil, KY 42053

Jimmy C. Massey
Bechtel Jacobs Company LLC
761 Veterans Ave.
Kevil, KY 42053

K. L. Holt (2 copies)
Bechtel Jacobs Company LLC
761 Veterans Ave.
Kevil, KY  42053

NATURAL RESOURCE
TRUSTEEJ
Alex Barber
Commissioner's Office
KY Dept for Environmental
Protection
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Abraham Loudermilk
Tennessee Valley Authority
400 W. Summit Hill Drive
Knoxville, TN 37902

Andrea B. Perkins
US. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

Allen Rob ison
US. Department of Interior
Fish and Wildlife Service
446 Neal Street
Cookville, TN 38501

 STATE OF KENTUCKY
 Robert H. Daniell, Director
 Division of Waste Management
 KY Dept. for Environmental
 Protection
 14 Reilly Road
 Frankfort Office Park
 Frankfort, KY 40601

 Steve Hampson
 Cabinet for Human Resources
 Radiation Control Laboratory
 100 Sower Boulevard
 Suite 108
 Frankfort, KY 40601
Todd Mullins
KY Division of Waste Management
US. Department of Energy Site Office
5600 Hobbs Road
West Paducah, KY 42086

Tuss Taylor (4 copies)
UK/KDEP
18 Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Dr. John A. Volpe
Radiation Control Branch
Cabinet for Human Resources
275 East Main Street
Mail Stop HS2E-D
Frankfort, KY 40621

TVA
Barry Walton
Office of General Council WT-10A
400 W. Summit Hill Drive   '
Knoxville, TN 37902

Janet Watts
Manager of Environmental Affairs
5D Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801

Ted Whitaker
Plant Manager
Shawnee Fossil Plant
7900 Metropolis Lake Road
West Paducah, KY 42086

U.S. ENRICHMENT
CORPORATION
T. Michael Taimi
US.EC.
2 Democracy Center
6903 Rockledge Drive
Bethesda, MD 20817

U.S. GEOLOGICAL  SURVEY
TomMesEo
US. Geological Survey
9818 Bluegrass Parkway
Louisville, KY 40299-1906

WEST KY WILDLIFE
 MANAGEMENT AREA
LeeBolrdy
West Kentucky Wildlife
 Management Area
 Kentucky Department of Fish
 and Wildlife
 10535 Ogden Landing Road
 Kevil, KY 42053
 JEG.OJ97.27/DlfcD2
                                                            6/26/98

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