United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R04-93/138
October 1992
SEPA Superfund
Record of Decision:
USDOE Oak Ridge Reservation
(Operable Unit 8), TN
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50272-101
REPORT DOCUMENTATION 11. REPORT NO. . 2. 3. Reclplenr. Acc88810n No.
PAGE EPA/ROD/R04-93/138
4. Thle and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 10/06/92
USDOE Oak Ridge Reservation (Operable Unit 8), TN 6.
Sixth Remedial Action
7. Author(a) 8. Performing Organization Rept. No.
9. Performing Organization Name and Address 10 Project Task/Work Unh No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Add- 13. Type of Report & Period Coverlld
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 ' 14.
15. Supplementary Notes
PB94-964022
16. Abstract (Limit: 200 words)
The 30-acre USDOE Oak Ridge Reservation (Operable Unit 8) site is a former waste
storage area located in the McNew Hollow area, Roane County, Tennessee. Formerly known
as the White Wing Scrap Yard, WAG 11 is partially wooded and thickly vegetated. The
site lies within the Bear Creek drainage basin near the junction of Bear Creek and East
Fork Poplar Creek. Historically, WAG 11 was u&eq as a storage area for.
radi~actively-contaminated scrap and debris from the Oak Ridge National Laboratory
(ORNL), the Y-12 plant, and the K-25 plant (formerly the Oak Ridge Gaseous Diffusion
Plant). Various types of materials, inclu~ing steel tanks, metal, glass, concrete, and
miscellaneous industrial waste with alpha, beta, and gamma contamination were stored at
the Wh~te Wing Scrap Yard beginning in the early 1950s; however, precise dates of
operation are uncertain. In 1966, efforts began to clean up the site in preparation
for the proposed relocation of the adjacent White Wing Road. Most of the larger surface
scrap was removed and buried in ORNL's solid waste storage area 5. Onsite clean up
efforts by USDOE continued, and in 1970, approximately 6,000 yd3 of contaminated soil
were removed off site. Several sampling efforts conducted by ORNL from 1987 to 1991
identified onsite threats posed by the radiologically-contaminated scrap and debris,
which exceeded regulatory levels. Previous 1991 and 1992 RODs addressed the United
(See Attached Page)
17. Document Analysis .. Descriptors
Record of Decision - USDOE Oak Ridge Reservation (Operable Unit 8), TN
Sixth Remedial Action
Contaminated Medium: debris
Key Contaminants: metals (lead), inorganics (asbestos), radioactive compounds
b. IdentifierslOpen-End8cl Terms
c. COSATI FlelcllGroup
18. Availability Statemant 19. Sacurhy Class (This Report) 21. No.ofPagas
None 26
20. Securhy Class (This Page) 22. Price
None
(See ANSI-Z39.18)
See Instructions on Rev81S8
OPTIONAL FORM m (4-77)
(Formerty NTIS-35)
Department of Commerce
I
[
I .
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EPA/ROD/R04-93/138
USDOE Oak Ridge Reservation
Sixth Remedial Action
Abstract (Continued)
(Operable Unit 8), TN
Nuclear Corporation disposal site, sediment at the Y-12 Plant, sludge at the K-25 Plant,
surface water at the K-25 Plant, and soil at the Y-12 Plant, as OUs 2, 3, 4, 6, and 18,
respectively. This ROD provides an interim action and addresses the contaminated surface
debris remaining at the site. Subsequent RODs will address additional onsite threats,
including those posed by soil, ground water, and surface water. The primary contaminants
of concern affecting the debris are metals, including lead; other inorganics, including
asbestos; and radioactive materials.
The selected remedial action for this site includes manually collecting and segregating
approximately 10,000 ft3 of surface debris from WAG 11, based on detectable radioactivity,
and transporting these to the WAG 6 Consolidation Area for disposal; separating lead
bricks and any vessels containing liquids; decontaminating or reusing the bricks under an
existing waste management system, or if reuse is not feasible, managing these under RCRA;
and disposing of the surface vessels containing free liquids at a waste management
facility. The estimated present worth cost for this remedial action is $160,000.
PERFORMANCE STANDARDS OR GOALS:
Not provided.
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. ... '. "..' . -. .-.' _." ...
-_..~ --_.- ...-.--- - - ----_. H_- - .., .
.. ..- ,. '.--'"
r-
Interim Record of Decision
for Oak Ridge National Laboratory
Waste Area Grouping 11 '.
Surface Debris, . ," ,
Oak Ridge, Tennessee
September 1992
DOE/OR-10SS&D4
" o. (J. 8
.-.--
. .
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DOElOR-10SSIcD4
92-225-161~
Interim Record or Decision
for Oak Ridge National Laboratory
Waste Area Grouping 11
Surface Debris,
Oak Ridge, Tennessee
September 1992
Prepared for
U.S. Department of Energy
Office of Environmental Restoration
and Waste Management
Prepared by
Radian Corporation
120 South Jefferson Circle
Oak Ridge, Tennessee 37830
under ContraCt No. DE-AC05-900R21851
Doc. IF920818.SJMSl
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TABLE OF CONTENTS
ACRONYMS AND INlTIALISMS
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
PART 1. DECLARATION...................................
. SITE NAME AND LOCATION. . . . . . . . . . . . . . . . . . . . . . . . . .
STATEMENT OF BASIS AND PURPOSE. . . . . . . . . . . . . . . . . . .
ASSESSMENT OF THE SITE . . . . . . . . . . . . ... . . . . . . . . . . . . .
DESCRIPTION OF SELECTED REMEDY. . . . . . . . . . . . . . . . . .
STAiUTORY DETERMINATION. . . . . . . . . . . . . . . . . . . . . . . .
APPROVALS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
PART 2. DECISION SUM~Y ..............................
SITE NAME. LOCATION. AND DESCRIPTION. . . . . . . . . . . . . .
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . .
HIGHLIGHTS OF COMMUNITY PARTICIPATION. . . . . . . . . . . .
SCOPE AND ROLE OF THE RESPONSE ACTION. . . . . . . . . . . . .
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . .
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . .
DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . .
Alternative I-No Action. . . . . . . . . . . . . . . . . . ... . . . . . . .
Alternative 2-Stage All Debris On-Site. . . . . . . . . . . . . . . . . .
Alternative 3-Decontaminate Metal Debris and Stage
Remaining Debris On-Site. . . . . .. . . . . . . . . . . . . . . . . .
Alternative 4-Disposal of Debris in WAG 6 ........ . . . . . . .
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. .
Overall Protection of Human Health and the Environment. . . . . . .
Compliance with ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . .
Long-Term Effectiveness and Permanence. . . . . . . . . . . . . . . .
Reduction of Toxicity. Mobility. or Volume Through Treatment. .
Shon-Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . .
Implementability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Swe Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . .
The Selected Remedy. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
STAiUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . . . .
Protection of Human Health and the Environment. . . . . . . . . . .
Compliance with ARARs . . . ... . . . . . . . . . .'. . . . . . . . . . . .
Cost Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Use of Permanent Solutions and Treatment Technologies. . . . . . .
Preference for Treatment. . . . . . . . . . . . . . . . . . . . . . . . . . .
F9D1'~1
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iv
1-1
1-2
1-2
1-2
1-2
1-3
1-4
2-1
2-2
2-2
2-5
2~
2~
2~
2-7
2-7
2-7
2-8
2-8
2-9
2-9
2-10
2-10
2-10
2-10
2-10
2-10
2-12
2-12
2-12
2-14
2-14
2-14
2-14
2-14
2-15
IIM1211P2
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PART 3.
TABLE OF CO~'TENTS (continued)
EXPLANATION OF SIGNIFICANT CHANGES. . . . . . . . . . . . . . .
BIBLIOORAPHY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
RESPONSIVENESS SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . .
Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Background on C -::nunity Involvement. . . . . . . . . . . . . . . . .
SUIJUDary of Com.:::~nts Received and Agency Responses. . . . . . .
R.emaining Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Appendix A. MEETING MINUTES AND LEITER OF RESPONSE
f9'Dl I.IDoU 1
iii
2-15
2-15
3-1
3-2
3-2
3-2
3-3
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ACM
ALARA
ARARs
CERCLA
CFR
DOE
Energy
Systems
EPA
J:S
IROD
O&M
ORNL
ORR
RCRA
RI
TBC
TCA
TDEC
WAG
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ACRONYMS AND INITIALISMS
asbestOs-a>ntaining material
as low as reasonably achievable
applicable or relevant and appropriate requirements .
Comprehensive Environmental Response, Compensation, and Liability Act
Code of Federal Regulations
U.S. Department of Energy
Mar,tin Marietta Energy Systems, Inc.
U.S. Environmental Protection Agency
feasibility study
Interim Record of Decision
operation and maintenance
Oak Ridge National Laboratory
Oak Ridge Reservation
Resource Conservation and Recovery Act .
remedial investigation
to be considered
Tennessee Code Annotated
Tennessee Depanment of Environment and Conservation
Waste Area Grouping
iv
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PART 1. DECLARATION
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SITE NAME AND LOCATION
Waste Area Grouping (WAG) 11
Oak Ridge National Laboratory (ORNL)
Oak Ridge Reservation (ORR)
Oak Ridge. Tennessee
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim r~edial action for ORNL WAG 11
~urface debris. This aCtion was chosen in accordance with the Comprehensive Environmental
Response. Compensation and Liability Act (CERCLA) of 1980 as amended by the Superfund
Amendments and Reauthorization Act. and. to the extent praCticable. the National Oil and
Hazardous Substance Contingency Plan. This decision is based on the administrative record for
this site.
The SweofTennessee and the U.S. Environmental Protection Agency (EPA) concur with
this interim action for the WAG 11 remediation.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site. if DOt addressed by
implementing the response action selected in this Interim Record of Decision (lROD). may
present a current or potential threat to public health. welfare. or the environment.
DESCRIPI'ION OF SELECTED REMEDY
This interim aCtion is intended to reduce the threats to human health and the environment
posed by a variety of radiological and physical hazards located within the bounds of WAG 11.
1be major components of this interim action are:
. collection and segregation of all surface debris at WAG 11 and
. transportation and disposal of debris in WAG 6.
This interim action is DOt the final aCtion planned for the site. but will provide a significant
reduCtion in the threats to human health and the environment by isolating the waste from the
environment. After the contaminated surface debris is addressed. a Remedial Investigation
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(RI)1F~ibility Study (FS) is planned that could result in more remedial actions or a decision to
take DO further action. Interim remedial action on WAG 11 prior to ,.:mpletion of the RIIFS will
provide additional benefits consistent with the goals of CERCLA, i;;;;udini:
. a reduction in further degradation of the environment by e1iminming surface
debris as a source of further environmental coDt2mination;
. a reduction in the difficulty, expense, and possible pbysiw harm associated
with site surveillance, maintenance activities, and future remedial actions by
e1imift2tini debris that interferes with mowing, clearini, and characterizing the
site; and
. an increased likelihood of success for future subsurface investigations by
eliminating surface debris that interferes with most subsurface investigative
methods.
STAtUrORY DETERMINATION
The selected remedy is protective of human health and the environment, complies with
federal and state requirementS that are applicable or relevant and appropriate to the remedial
action and is cost-effective. This remedy utilizes permanent solutions and alternative treatment
teehnologies to the maximum extent practicable for this site. However, because this is an interim
action, remedies employing treatment that reduces tOxicity, mobility, or volume as a principal
element of the remedial action will be addressed by the final response action. Subsequent actions
are planned to address fully the principal threatS posed by the site. Review of this site and of this
remedy will be continuing as part of the development of the final remedy for the site. Because
this remedy will result in hazardous substances remaining on the site, a review will be conducted
within five years after commencement of the remedial action as final remedial alternatives are
developed.
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APPROVALS
a :;r~
,
Manager
U .$. Depanment of Energy (DOE)
Oak Ridge Field Office
/0- ;2 -~
Date
, ~() Q.,~~ ~:>
DiredOr. DOE Oversight Div' -
State of Tennessee
~~=\\on
U.S. Environmental Protection Agency, Region IV
/~ - :1 - 9:;;.
Date
\~ ~ C\~
Date .
Pll'DII.moCSl
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PART 2. DECISION SUMMARY -
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SITE NAME, LOCATION, AND DESCRIPI'ION
WAG 11 is 1 mile east of the intersection of Highways 58 and 95 in the McNew Hollow
area just nonh of Pine Ridge. The site occupies approximately 30 acres in Roane County,
Tennessee, and is within the boundaries of the DOE ORR. WAG 11 is appro1l:im!ltf1y 3 miles
from the western edge of the city of Oak Ridge, the closest population ccmer. FilW'e 1 shows
the geographic location of the site.
Formerly known as White Wing Scrap Yard, WAG 11 is panially wooded and thickly
vegetated. A forest of small pine trees covers about 30~ of the site, while the r~JftJljnj"'g area
is covered by mixed grass, brush, and young hardwoods. The site lies within the Bar Creek
drainage basin neat the junction of Bear Creek and East Fort Poplar Creek. AU surface water
flow within the WAG is to Bear Creek along two unnamed tributaries. Hot Yard Road bisects
the site, and East Fork Ridge Road generally parallels the nonhern boundary. A site map
depicting significant geographical and topographical information about WAG 11 is presented in
Fig. 2.
SITE IUSTORY AND ENFORCEMENT ACTIVITIES
WAG 11 was a storage area for radioactively contaminated scrap and debris from the Oak
Ridge National Laboratory (ORNL), the Y-12 Plant (Y-12) and the K-25 Plant (formerly the Oak
Ridge Gaseous Diffusion Plant). Material (steel tanks, metal, glass, concrete, and miscellaneous
industrial trash) with alpha, beta, and gamma contamination was first stored at the White Wing
Scrap Yard in the early 19505; however, precise dates of operation are uncertain. During active
use, the area of the scrap yard nonh of Hot Yard Road was enclosed with a chain lint fence, and
the area south of the road was fenced with barbed wire..
In 1966, effons began to clean up the site in preparation for the proposed relocation of
White Wing Road. Most of the larger surface scrap was removed and buried in ORNL's Solid
Waste Storage Area 5. Site cleanup continued into October 1970 with the removal of
approximately 6000 yd' of contaminJted soil from the site. All fences were removed during these
activities. .
ORNL conducted a limited sampling effort in 1987 and 1988 for the purposes of gaining
information on the geology, hydrology, soils, and geochemistry of WAG 11, as well as
information on releases and inventory of hazardous materials in WAG 11, for use in the design
of a Resource Conservation and Recovery Act (RCRA) Facility Investigation (ORNL April 1988).
ORNL sampled and analyzed groundwater, surface water, mud, gravel, and soil.
1'92II1'~1
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2-3
T -- - -
.. ... - ...
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-.
I
J.mIIC
- --............ .. ~
D(~:r)
- ---.......-"
- .-....11....... . -
RADIAN
WAG 11 ana SurTound,n; O'~O
Sou'e.: Radian
Col. 1992
~ ..mil: '1-
r"voro"rne"IOI Resto'ol'~" P'OIl'O"'"
roll '
-
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.
o
..
~
.
~
.
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I
890
I
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000 1)000 -. '(DR
---
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- CGI,...,
((U'''- It ru, ~ '"',
COIIIIIIJI II1IJIYIIt . ""
RADIAN
Sourer' 0IINt.
Dolr. 1991
[n.i.onmcntol Rrsh"otion Proq'Qm
WAG t t Sitr loIoJ)
~ -." Ulc.- " ..,,- liliA'
N
J.
,
fiQ 1
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On November 10, 1989, the site was roped and placarded with .Controlled Aru. signs
at 5O-ft interVals and Tennessee Wildlife Resources Agency safety zone signs at l00-ft intervals
to exclude deer I::..uJters and other intruders from the site.
A s~ radiological scoping survey of acc~:jle areas at WAG 11 was conducted
intermittently from December 1989 through July 1991 by ORNL (ORNL September 1991). The
purpose of this investigation was to provide an updated cont3.min2tion swus of the site and a
basis for the formulation of interim corrective actions that will limit human exposures to
radioactivity and minimi~ the potential for CODt3.min~nt dispersion.
On December 21, 1989, the ORR was placed on CERCLA's National Priorities List,
which mandates specific requirements that environmental restoration activities must follow.
An Interim Remedial Measures Study (Radian July 1992) was completed in July 1992 to
determine the best alternative for reducing the potential health threat posed by contaminated
surface debris on WAG 11.
IDGIU..IGHTS OF COMMUNITY PARTICIPATION
The Proposed Plan for the ORNL WAG 11 Interim Remedial Action was released to the
public in July 1992 by inclusion in the administrative record mainL1i:1ed at the Information
Resource Center in Oak Ridge, Tennessee. Notice of availability of the proposed plan was
published in the Oak Ridger on July 10, 12, and 15, 1992; in the Knorville N~-Senri1U!I on July
10, 12, and 15, 1992; and in the R(}(lM County News on July 13, 15, and 17, 1992.
A public comment period was held from July 14 through August 12, 1992. A public
meeting was not scheduled, but opportunity for a meeting was offered in the published notice of
availabil ity.
A response to the comments received during the comment period is included in the
Responsiveness Summary, which is part 3 of this IROD. This decision document presents the
selected interim remedial action for the ORNL WAG 11 surface debris. This selection was made
in accordance with CERCLA, as amended by the Superfund Amendments and Reauthorization
Act of 1986, and to the extent feasible, the National Contingency Plan.
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SCOPE AND ROLE OF THE RESPONSE AcrION
The purpose of this interim remedial action is to reduce the powWal threat to human
health and the environment from the radiologically contaminated scrap and debris lying on the
surface of WAG 11. This interim action will reduce the poteDtial threat to human health posed
by physical hazards to an inadvenent intruder and the possible spread of radioactive
cont2min2tion by that intruder. Collec:tion and disposal of the cont2mift2ted debris will provide
a significant reduction in the threat to human health and the environmeat by isolatin& the waste
from the environment. Subsequent actions under CERCLA are planned to fully address the
threats posed by the rp-m2ining exposure pathways at the site. These may iDdude. but are not
limited to, the soils, groundwater. and surface water. The site will be evaluated during the
RIIFS, as mandated in CERCLA.
This interim action is consistent with planned future activities at the site. In particular,
this interim remedial action will provide a reduction in the difficulty, expense, and possible future
harm associated with site surveillance, maintenance activities, and future remedial activities by
eliminating debris that interferes with mowing, clearing, and characterizing the site. This
remedial action will also increase the likelihood of success of future subsurface investigations by
elimin2ting surface debris that interferes with most subsurface investigative med1ods.
SUMMARY OF SITE CHARACTERISTICS
Cont2min2ted surface debris that litters much of the surface of WAG 11 is a result of the
intentional storage on the site of contaminated scrap, debris, and industrial waste. A cleanup of
the site was conducted by DOE in the late 19605 and 19705; however. some large pieces and a
large quantity of smaller contaminated debris still remain scattered throughout the site.
Measurement surveys of alpha, beta, and gamma radiation have revealed that contaminants are
present on some of the debris in levels high enough to be of concern. Swipe sample analytical
results have shown elevaled concentrations of au, mes, and other isotopes. Results of
radiological surveys on the debris range from O.S mradlb to 21 mradlb. Physical hazards include
sharp pieces of metal and broken glass on the ground surface.
SUMMARY OF SITE RISKS
WAG 11 is covered with contaminated debris. including pieces of metal. glass, graphite,
concrete, plastic, wood. and composite materials. Visual inspections and radiation measurements
made on the surface of the debris have identified a variety of radiological and physical hazards.
f92D8IUIMSI
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Radiololical hazards at the site can present both internal and external exposures to those
accessin& it. Physical hazards include sharp pieces of metal and broken Jlass lyinl on the ground
that may cause accident or injury. A person who trips or falls could be seriously injured by
bein& cut or punctured. Injury from contaminated material could poteDtially cause radiololical
CODt2min.:ants to eater :be bloodstr~ resulting in internal exposure. Material at the lite could
also be picked up and carried on by wildlife or someone unaware of the cont2min.:ation,
inadvenemJy exposing others to radiation and spreading the CODt2min.:ation off-site. AsbestOs-
contJlining materials (ACM) are also present on the surface and are a potential threat.
CoDt2minJited debris at WAG 11 also presents an ecological risk. Wildlife is exposed
to the same types of hazards as those associated with human health risk, includin& the possibility
of puncture wounds and exposure to ionizing radiation. Additionally, contaminated vegetation
is probable on the site, and consequently, the potential exists for radionuclide transfer to higher
levels in the ecological food chain.
DESCRIPTION OF ALTERNATIVES
This section provides a description of how each alternative will address the contaminated
surface debris found at WAG 11. Four alternatives are presented. These alternatives are not
intended to r~mediate the entire WAG 11 site; instead, they are intended to reduce the risks
associated with cont::amin2ted surface debris. Remediation of the entire site would be addressed
in future CERCLA aCtions.
Alternative I-No Action
CERCLA requires that the -no-action- alternative be evaluated to serve as the baseline
for comparison at every site. Under this alternative, no further action will be taken to reduce the
potential threat to human health and the environment caused by contaminated scrap and debris
on the surface of WAG 11. This alternative will cost nothing to implement.
Alternative 2-Stage All Debris On-Site
This alternative consists of collecting all surface debris and pi acini it in an on-site staging
facility. ACtivities include clearini vegetation from inaccessible areas, collection of light and
heavy surface debris and ACM, containerization of debris, and construCtion of an on-site staging
facility. Containerized debris will then be placed in the staging facility until a final remedial
action is chosen. Implementation of this alternative will considerably reduce physical hazards for
persoMel involved in future investigations, the final remedial solution, and routine maintenance
of WAG 11. Since the debris has been a source of contamination in the soil and other media at
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WAG 11, implementing this temporary measure will help stabilize the site IDd prevem further
deeradation to the environment.
Implementation of this alternative will take approximately 10 months. The presem worth
cost for this alternative, including implementation or capital cost (includin& qineering design
aDd construction) and operation aDd maintenance (O&M) cost, is esti"nlt~ to be 5348,000.
Alternative 3-Decontaminate Mdal Debris and Stage Remaining Debris Oo-Site
This alternative consists of collecting all surface debris, decollt2miftllti,,& meW debris,
containerization of DOn-meW debris and ACM, and construction of an on-sUe Itaiin& facility for
the storage of DOn-metal debris. Vegetation clearing activities identical to tbose for Alternative
2 will be required. Metal debris will be decontaminated using both physical and chemical
processes to remove contamination in successive layers from the debris' surface. Decontaminated
metal debris will be released to an operational DOE scrap metal facility for final disposition.
Implementation of this alternative will considerably reduce physical hazards for personnel
involved in future investigations, the final remedial solution, and routine maintenance of
WAG 11. Since the debris has been a source of cont2min2tion for the soil and other media at
WAG 11, implementing this temporary measure will aid in stabilizing the site and preventing
funber degradation to the environment. In addition, the amount of debris to be staged will be
minimized by decontaminating and removing the meW from the site.
Implementation of this alternative will take approximately 12 months. The present worth
cost for this alternative, including implementation or capital cost (including engineering design
and construction) and O&M cost, is estimated to be S529,000.
Alternative 4-Disposal of Debris In WAG 6
This alternative consists of collecting all surface debris and removing it from the site.
Activities include clearing surface vegetation, collecting surface debris, aDd transporting and
placing the debris in the WAG 6 waste consolidation area. Lead bricks and any vessels
containing liquids will be segregated from other debris. Lead bricks will be decont2mifuated and
reused or disposed of under an existing Martin Marietta Energy Systems, Inc., (Energy Systems)
waste management program. If reuse is DOt feasible, the decont3min:ated lead will be managed
under Energy Systems RCRA programs. Surface vessels containing free liquids will be flagged
for characterization and disposal in an operational waste management facility radler than in
WAG 6. .
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All othu surface debris will be collected, segregated based on surface radiological
measurements, and placed in covered dump trucks and/or boxes and transponed to the WAG 6
Waste Consolidation Area for disposal. The design and operation of these facilities emphasize
isolation of the wastes from groundwater, surface water, and infiltration, as well as void space
contrOl to minimi7..e futUre settling. By placing the ... ~ri::: ~eneat:". 1D engineered covu system,
the potential for contmtin2nts to enter the environment decreases.
Implementation of this alternative will take a!>proximately 4 mentha. The present worth
COSt for this alternative is estimated to be SI6O,OOO. :De disposal teehniques for this alternative
have been modified as noted in the section titled Explanation of Significant Ow1ges (page 2-15).
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section provides a basis for determining which alternative provides the .best balance
of tradeoffs. with respect to nine evaluation criteria. These criteria are:
. overall protection of human health and the environment;
. compliance with applicable or relevant and appropriate requirements (ARARs);
. long-term effectiveness and permanence;
. reduction of toxicity, mobility, or volume through treatment;
. shon-term effectiveness;
. implementability;
. cost;
. regulatory agency acceptance; and
. community acceptance.
Overall Protection or Human Health and the Environment
Alternative 1, No ACtion, is DOt protective of and offers DO reduction in risk to human
health and the environment. Alternatives 2,3, and 4 will equally reduce the risk associated with
surface debris and offer a moderate degree of protection. However, Alternative 4 offers the
greatest degree of overall protection of human health and the environment. Disposini of the
debris in WAG 6 results in reduced handling and processing of the waste and provides for its
long-term disposition.
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--_. ... ...~~._...__..,...._._---, ---...-....
.--.. .,. .
Compliance with ARARs
Table 1 provides a summary of ARARs for the remedial action. Altematives 2, 3, aDd
4 wUl comply with all listed ARARs.
Long-Term Eft'ectiveness and Permanence
AltcmaUve 1 provides DO long-term effectiveness. Alternatives 2, 3, aad 4 provide high
long-term effectiveness in preventing surface debris from funher degradiDa the environment.
Alternative 4 also provides for long-term disposition of all surface debris; therefore, Alternative 4
has the highest degree of long-term effectiveness and permanence.
Reduction or Toxicity, Mobility, or Volume Through Treatment
Alternative I, No Action, does nothing to reduce toxicity, mobility, or volume of
WAG 11 surface debris. Alternatives 2 and 4 do not incorporate any treatment techDologies for
reducing cont:amin:al1t toxicity, mobility, or volume. Alternative 3 could increase or decrease the
volume of waste depending on the method used to. dccont:amin:lte the metal debris.
Short-Term Eft'ectiveness
Alternative 1 provides DO short-term effectiveness. Alternatives 2, 3, and 4 wUl take
quick action to protect human health and the environment in the short tenD whUe a finaJ remedial
solution for the entire site is being developed. However, Alternatives 2, 3, and 4 involve
haDdling and processing waste, with Alternative 3 requiring the greatest degree of handling, and
hence, the greatest worker exposure.
Implementability
Alternatives 1, 2, 3, and 4 are all technically and administtatively implementable. Of
the action alternatives, Alternative 4 appears to have the lowest degree of implementation
requirements with respect to design aDd engineering requirements. However, it has I higher
degree of administtative requirements because the material must be transported and disposed of
It another WAG on the ORR.
Cost
Alternative 1 does DOt involve any cost. Alternative 2 costs $348,000. Alternative 3
costs 5529,000. Alternative 4 costs 5160,000.
...II-"MSI
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Table 1. Summary or ARAIls
ARAR category
Locatioa-Specif"ac
Wetlaodi
Adioa-SpeciC'.c
OD-cite
,CDa8tnlctionlexcavation or
baDdling of materials
Surface water controls
Worker pro&ectioo
Public health protection
Tr8DIpOJUtion
Waste Packaemg and
HaDdliDg
Waste I118D&gemeut
Requirement
Must act to avoid adverse impact.
",ini...i7J! poteDtial harm. and
pre8aVe and mbaDce wet1and5 to the
exteDt possible. New CODStnIctioo in
weclaDd5 iboWd be avoided
Precautioas must be taken to prnrm
particulate matter from becomine
airborne. FuJitive dust emissions
must be controlled
Must ensure compliance with the
substantive requirements of the state
permitting process. Implemeut good
&ite plaDDing and best management
practices to control storm water
, discharges
Must adhere to health and safety
standards
Must keep radiation do5C6 for
iDdividuah Al.ARA
Must meet requiremeuts that addre55
preparation of shipping papers,
container marking, labeling. vehicle
placarding. packaging. testini of
packaaes and containers. and
carriqe by public highway
Must adhere to p8Ckaemg and
handling requirments
Must handle aDd dispose of waste in
. maDDer that i5 protective of public
health aDd the enviroDmeut
Citatioas
40 CFR 6 Appeadix A 10
CFR 1022
(Applicable)
40 Cf1l 50.6 and
TCA 1200-3-8-.01
(Applicable)
TCA 69.3.108
TCA 1200-4-3
TCA 12~
TCA 1200-4-1~.05
4OCFRI22
(Applicable)
Radiation protection
1taDdards, 29 CFR 1910.
(Applicable) and
DOE Order 5480.11 (TBC)
DOE Orden 5400.5 and
S820.2A (TBC)
49 CFR 172, 173, 177. and
178 aDd 10 CPR 71
(Applicable)
DOE Order 5480.3 (TBC)
-10 CPR 61.56(a)(1)-(7) and
.S6(b)(2) and (3)
(relevant and appropriate)
DOE Order 5820.2A (TBC)
*While DOE fully plans to comply with the relevant and appropriate requirements of 10 CPR Part 61, it
ia the Department'. position that mc replatioas are m!! applicable to DOE. DOE must meet the
requiremects of DOE Order 5820.2A, which, in this instance, are equivalent technical requirements to
tboee found in the mc replatioDS.
Al.ARA - u low u reasonably achievable
CPR - Code of Feden.l ReplatioDl
DOE - U.S. Department of Eneri)'
TBC - to be considered
TCA ... Tennessee Code Annotated
I'9DII.m.cs1
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1CMZ2192
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~..._-------;,.-_._---_._..._-_.- "_...
S&ate A~ptaDCe
The Swe of Tennessee has reviewed the alternatives proposed for interim action at
WAG 11. IDEC concurs with the selection of Alternative 4.
Community Acceptance
During the public comment period for the Proposed Plan, several comlftP.ntc and questions
were presented about the proposed alternative. In general, the public qreed with the selec:tion
of Alternative 4. The ResponsiveDess Summary of this IROD addressca the questions aDd
comments from the public in deW!.
,
The Selected Remedy
Based on consideration of the requirements of CERCLA, the detailed analysis of
alternatives, and public comments, the most appropriate remedy for the WAG 11 surface debris
is a variation of Alternative 4, Dispose of Debris in WAG 6. The disposal techniques for the
selected remedy bave been modified as noted in the section titled Explanation of Significant
Changes (page 2-15). .
An estimated 10,000 ft3 of debris will be manually collected from the surface of
WAG 11. Lead surface debris (lead bricks) and any vessels containing liquid will be segregated
from the other debris. The rem:aining debris will then be segregated (detedable radioactivity vs
nondectable), collected and placed in covered dump trucks and/or boxes, and transponed to
WAG 6 for disposal. Debris will be placed in the waste consolidation area located in WAG 6~
WAG 6 is scheduled to be closed under a CERCLA remediation in the near future.
The costs of the variation of Alternative 4 presented in Table 2 are based on best
engineering estimates of vegewion cover and debris volume. All costs were developed for
comparison with other alternatives aDd may not represent the actual costs. Changes may be made
to the remedy as pan of the remedial design and construction processes. Such changes, in
geDeral, reftect modifications resulting from the engineering design process.
1'9D1..,'..,1
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ICMI2I92
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Table 2. Cost Summary
lIem
CoR ($)
30,000
145,000
35,000
30,000
Clearing vegetaboa
CollectiDg aDd packaging debris
TramportiDg to WAG 6
n-"..ta",i"8t1"glead
Subtotal
100,000
340,000
CoaItructinglilOl
EDgineeriDg design C 20 ~
Conting=cy at 25 ~
68,000
85,000
T oeal
493,000
AKumptiODS:
5,000 ft3 of debris in existing landfill
5,000 ft3 of debris in silos
Need 86 B-25 boxes C $1,500 each
Need 10 silos C $10,000 each
I'V'DII.sn,c, 1
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100'I12I92
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..- ..~.&.._._-- ---------------.'.'--. .
STAnrI'ORY DETERMINATIONS
UDder its legal authority, the DOE's primary responsibility. CEIlCLA IRes is to
UDdenake remedial actions that achieve adequate protection of human hwth IDd the eDVironm~.
In addition, Sect. 121 of CERCLA establishes several other staIUtOry requiremems and
preferences. These specify that when complete, the selected remedial action for this site must
comply with applicable or relevant aDd appropriate environmental staDdarda established UDder
federal and. state environmental laws unless a statutory waiver is justified. The leIecud remedy
~ also be coSt-eBective and utilize permanent solutions and altemative treaaDeat or resource
recovery technologies to the maximum extent practical. Finally, the StatUte includes a preference
for remedies that employ treatment that permanently and significantly reduce the volume, toxicity,
or mobility of hazardous wastes as their principal element. The following sections discuss how
the selected remedy meets these statutory requirements.
Protection or Human Health and the Environment
The selected remedy provides protection of human health by reducinl the existing threat
posed by physical hazards and the possible spread of radioactive cont:amin2tion to an inadvertent
intruder. The remedy wUl provide similar benefits to animal life in the area. When
implemented, the remedy wUl also reduce further degradation of the environment by eliminating
the debris as a source of environmental contamination.
Comp6ance with AltARs
The selected remedy wUl comply with all the ARARs shown in Table I, aDd a waiver
is DOt requested.
Cost Effectiveness
The remedy wUl permanently remove the Contllmin:ated surface debris from the site and
is, therefore, the most cost-effectivealtemative available.
Use or Permanent Solutions and Treatment Technologies
The selecud remedy provides a permanent solution to the existing and future threats
posed by cont:amin.ated. surface debris at WAG 11. It does DOt utilize a treatment teehnology
because a viable method is DOt available. The selected remedy represents the best balance of
tradeoffs, given the limited scope of the action.
F9Dll.sn.u1
2-14
ll11a2192
-------
Preference ror Treatment
At this time, viable technologies that address radioactive COOt.2miMition are DOt readily
available; containment IDd isolation from the environment while radioactive decay ocaus appears
to be the most desirable method of mitigation. This remedy is DOt the final solution or action for
remediating WAG 11; it is aD interim action ooly. Although this interim action will not
completely remediate the site, it will remove some known sources of cont2min2tion currently in
direct contact with soils. Because of the wide variety and condition of the debris IDd IWUre of
CODt.2minants of concem, treaanent is not a viable option at this time. Treatment will be
addressed in the decision document reftecting the final remedy selection for this site.
EXPLANATION OF SIGNIF1CANT CHANGES
The Proposed Plan for the ORNL WAG 11 Interim Remedial Action was released for
public comment in July 1992. The Plan identified Alternative 4, Disposal of Debris at the
- WAG 6 Waste Consolidation Area, as the preferred alternative. After the Proposed Plan was
released for public review, it was found that the Waste Consolidation Area may not be ready to
receive wastes in time to be used for this interim remedial action. A disposal option consistent
with the intent of the preferred alternative was identified and selected. The new disposal option
provides better confinement of the wastes from the environment than the Waste Consolidation
Area. Debris will be placed in low-level waste silos at WAG 6. Silo disposal is a currently
utilized disposal technoloi)' utilizing an engineered facility within WAG 6, designed and operated
to isolate the waste material from surface water and groundwater, control subsidence and provide
radiation protection. Additional costs as shown in Table 2 for silo disposal are attributed to the
inclusion of silo construction costs. In the original estimate, facility construction costs were
assumed to be included in the WAG 6 remedial action effort.
BIBUOGRAPHY
ORNL (Oak Ridge National Laboratory) April 1988. Envir01V1le1Jlal Dara Package for the White
W"",g Scrap Yard (WAG 11). ORNLIRAP45, Oak Ridge, Tenn.
ORNL September 1991. Surface Radiological Investigations ar White W"",g Scrap Yard,
ORNLIER-52, Oak Ridge, Tenn.
P9D1'~1
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1CW2192
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.0 . . - .. - _... ..-" ....--
. ._4'... -.--...---.--...--.-....-----...--... ,."'._0
Radian (Radian Corporation) July 1992. Inzerim Remedial Measures SnIdy for ORNL WAG II,
DOE/OR-I01SD2, Oak Ridge, Tenn. .
Radian July 9, 1992. Proposed Plan for the GRNL WAG 11 IlJ1erim RDneditIJ Action,
DOE-QR-I017D4, Oak Ridge, Tenn.
I'92IIl'~l
2-16
1Q1Q2/92
-------
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