EPA/ROD/R04-95/235
September 1995
EPA Superfund
Record of Decision:
US DOE Paducah Gas Diffusion Plant,
Solid Waste Management Units 2 & 3
of Waste Area Group 22. KY
8/22/95
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DOFJORl06-1351&Dl
Record of Decision for Interim Remedial Action
at Solid Waste Management Units 2 and 3
of Waste Area Group 22
at the Paducah Gaseous Diffusion Plant
Paducah, Kentucky
July 1995
CL~EARED FOR PUBLIC RELEASE
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CERTIFICA TION
Document Identification:
Record of Decision for Interim Remedial Action at Solid
Waste Management Units 2 and 3 of Waste Area Group 22 at
the Paducah Gaseous Diffusion Plant, Paducah, Kentucky
I certify under penalty of law that I have personally examined and am familiar with the
information submitted in this application and all attachments and that, based on my inquiry of
those persons immediately responsible for obtaining the information contained in the
application, I believe that the information is true, accurate, and complete. I am aware that
there are, significant penalties for submitting false information, including the possibility of fine
and imprisonment.
u. S. Department of Energy
Owner and Operator
Q' ~
~.I~ '~
JImmIe C. Hodges, Paducah SIte Manager
Paducah Site Office
U. S. Department of Energy
;-/.J -7-5"-
Date Signed
The Department of Energy has signed as "owner and operator" and Lockheed Martin Energy
Systems, Inc., has signed as "co-operator" this application for the permitted facility. The
Department has determined that dual signatures best reflect the actual apportionment of
responsibility under which the Department's RCRA responsibilities are for policy,
programmatic, funding, and scheduling decisions, as well as general oversight, and the
contractor's RCRA responsibilities are for day-to-day operations (in accordance with general
directions given by the Department of Energy as part of its general oversight responsibility),
including but not limited to, the following responsibilities: waste analyses and handling,
monitoring, record keeping, reporting, and contingency planning. For purposes of the
certification required by 40 CFR Section 270. l1(d), the Department of Energy's
representatives certify, to the best of their knowledge and belief, the truth accuracy and
completeness of the application for their respective areas of responsibility.
Page 1 of 2
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CERTIFICA TION
Document Identification:
Record of Decision for Interim Remedial Action at Solid
Waste Management Units 2 and 3 of Waste Area Group 22 at
the Paducah Gaseous Diffusion Plant, Paducah, Kentucky
I certify under penalty of law that I have personally examined and am familiar with the
information submitted in this application and all attachments and that, based on my inquiry of
those persons immediately responsible for obtaining the information contained in the
application, I believe that the information is true, accurate, and complete. I am aware that
there are significant penalties for submitting false information, including the possibility of fine
and imprisonment.
Lockheed Martin Energy Systems, Inc.
Co-Operator
1/13/1)
,
ystems, Inc.
Date Signed
The Department of Energy has signed as "owner and operator" and Lockheed Martin Energy
Systems, Inc., has signed as "co-operator" this application for the permitted facility. The
Department has determined that dual signatures best reflect the actual apportionment of
responsibility under which the Department's RCRA responsibilities are for policy,
programmatic, funding, and scheduling decisions, as well as general oversight, and the
contractor's RCRA responsibilities are for day-to-day operations (in accordance with general
directions given by the Department of Energy as part of its general oversight responsibility),
including but not limited to, the following responsibilities: waste analyses and handling,
monitoring, record keeping, reporting, and contingency planning. For purposes of the
certification required by 40 CFR Section 270.11(d), Lockheed Martin Energy Systems, Inc. 's,
representatives certify, to the best of their knowledge and belief, the truth accuracy and
completeness of the application for their respective areas of responsibility.
Page 2 of 2
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DOEIO Rl06-1351&Dl
Record of Decision for Interim Remedial Action
at Solid Waste Management Units 2 and 3
of Waste Area Group 22
at the Paducah Gaseous Diffusion Plant
Paducah, Kentucky
July 1995
Prepared by
Jacobs Engineering Group Inc.
175 Freedom Boulevard. Kevil, KY 42053
Under Contract DE-AC05-930R22028
Prepared for
United States Department of Energy
Environmental Restoration Division
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PREFACE
This Record of Decision for Interim Remedial Action at Solid Waste Managemelzt Units 2 and 3
of Waste Area Group 22 at the Paducah Gaseous Diffusion Plant (DOE/OR/06-1351&D1) was
prepared in accordance with requirements under the Comprehensive Environmental
Response, Compensation and Liability Act, Resource Conservation and Recovery Act,
and K.R.S. 224.46-530 for documenting the selection of a preferred interim remedial
action, or corrective measure, for a solid waste management unit. This Record of
Decision has been prepared in accordance with the "Record of Decision" outline
prescribed in Appendix D of the draft Federal Facility Agreement for the Paducah
Gaseous Diffusion Plant dated December 22, 1993. This work was performed under
Work Breakdown Structure 1.4.12.7.1.02.11.02 (Activity Data Sheet 5302, "Offsite
Groundwater Contamination"). Publication of this document meets a milestone
pursuant to the United States Department of Energy's fiscal year 1995 commitments to
federal and state regulatory agencies. This primary milestone document provides a
record of information to be considered and the rationale which the United States
Environmental Protection Agency and the United States Department of Energy will
utilize in the selection of a preferred remedial action, or corrective measure, at Solid
Waste Management Unit 2, the C-749 Uranium Burial Ground, and will formally record
the decision to implement this interim action. This document also contains a schedule
for conducting remedial design phase activitie8 for this project. Information provided in
this document forms the basis for the development of the Remedial Design Report for
this project.
11
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ACKNOWLEDGMENT
Jacobs Engineering Group Inc. under prime contract to
the United States Department of Energy developed this
document with the assistance of the Jacobs
Environmental Restoration Team members:
Geraghty and Miller, Ine.
Lockwood Greene Technologies, Ine.
P AI Corporation
Solutions To Environmental Problems
United Science Industries
University of Tennessee
Additional support was given to the team by Lockheed
Martin Energy Systems, Ine.
I
,
III
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CONTENTS
PREFACE. ....................... .......... ................... ...... ...... ......" ................ .....".. ......... .... ......................... ii
ACKNOWLEDGMENT[[[ ...,.............................. iii
TABLES[[[ ............. vi
FIGURES .... ....................~................................................ [[[ vi
ACRONYMS AND ABBREVIATIONS ................................................. ........... ..... ..,.......... ...... vii
PART 1.
PART 2.
DECLARATION
SITE NAME AND LOCATION
STATEMENT OF BASIS AND PURPOSE
ASSESSMENT OF THE SITE
DESCRIPTION OF SELECTED REMEDY
STATUTORY DETERMINATIONS
DECISION SUMMARY................ ..........,...... ..... ............,.. .................. ..,........ ........., 1
2.1 Site Name, Location, and Description '"'''''''''''''''''''''''''''''''''''''''''''''''''''' 2
2.2 Site History and Enforcement Activities [[[5
2.3 Highlights of Community Participation [[[ 6
2.4 Scope and Role of Operable Unit '"'''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' 6
2.5 Site Characteristics[[[ ""'''''''''''''''''''''' ........... 7
Hydrogeologic Characteristics[[[ 7
Nature and Extent of Contamination at Solid Waste
Management Unit 2 .......... ..........,.. ........ ...... ................................................. 9
Conceptual Site Model for Transport and Exposure Pathways
at Solid Waste Management Unit 2[[[ 11
Summary of Site Risks [[[ 11
Human Health Risks [[[ 11
Environmental Risks.. ................... "'''''''''''''' ..... '''''''''''''''''' ............... ....... 14
Remedial Action Objectives ......, ......................,............... ...... ................... 14
Description of Alternatives [[[ 15
Alternative I-No Action. ....... .................................,...... ................. ......... 15
Alternative 2-Limited Action """'''''''''''''''''''''''''''''''''''''''''''''''''''''''''- 15
Alternative 3-Excavation, Treatment, and Storage/Disposal........... 16
Alternative 4-Low Permeability, Multilayered Cap,
Dewatering, Additional Monitoring
and Institutional Controls '"'''''''''' ............ ......., ............. ..........~.... ..... ..... - 16
Alternative 5-Low Permeability, Multilayered Cap,
Additional Monitoring, and Institutional Controls............................... 17
Summary of the Comparative Analysis of Alternatives....................... 18
Overall Protection of Human Health and the Environment................ 19
Compliance with Applicable or Relevant and
Appropria te Requirements ................~... ..........,........ ................................ 19
Long-Term Effectiveness and Permanence ............................................ 19
Reduction of Contaminant Toxicity, Mobility, or Volume
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Overall Protection of Human Health and the Environment................ 27
Applicable or Relevant and Appropriate Requirements...................... 28
Chemical-specific applicable or relevant and
appropriate requirements.. ............ .............. ....... .:.............................. 30
Location-specific applicable or relevant and
appropriate requirements .............. .................. .... .................. ... ..... ..... 30
Action-specific applicable or relevant and
appropriate requirements ............................................ .......... ... ...... .... 31
Cost Effectiveness ............ [[[ 34
Utilization of Permanent Solutions and Alternative
Treatment Technologies .............................. ........... ............ ....... ................ 34
Reduction of Toxicity, Mobility, or Volume through Treatment ........ 34
Permanent Remedy......... .......................... ........ ...... ............. ................. ..... 44
Documentation of Significant Changes[[[ 44
Five-Year Review........... ............... ... ................. .......................... ................44
2.11
2.12
PART 3.
RESPONSIVENESS SUMMARY....................... ...................... ....... ....................... 45
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Table 2-1.
Table 2-2.
Table 2-3.
Table 2-4.
Figure 2-1.
Figure 2-2.
Figure 2-3.
Figure 2-4.
Figure 2-5.
TABLES
Summary of Long-Term R~sk at Solid Waste Management Unit 2
under No Action and Interim Action[[[- 13
Comparative Analysis of Altematives[[[ 20
Cost Estimates for Interim Action [[[ 27
Applicable or Relevant and Appropriate Requirements for Remedial
Action: Low Permeability, Multilayered Cap and Monitoring Wells....... 35
FIGURES
Paducah Gaseous Diffusion Plant Vicinity Map ............................................ 3
Location of Solid Waste Management Units
in Waste Area Group 22 [[[ 4
General Subsurface Profile of the Paducah Gaseous Diffusion
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ACRONYMS AND ABBREVIATIONS
The following list of acronyms and abbreviations is provided to assist in the review of
this document.
~c
ARAR
bls
BMP
c.F.R.
CAA
CERCLA
cm
COC
COPC
DNAPL
DOE
EMEF
EPA
Fed. Reg.
FFCA
FS
ft
gal
HSWA
m
J-value
K.A.R.
KDEP
KPDES
I
LDR
LLW
m
~g/l
mrem
MW
NCP
O&M
PCB
pCiI g
pCi/1
PGDP
PPE
PW
RAO
RCRA
RGA
RI
ROD
SARA
SWMU
technetium-99
applicable or relevant and appropriate requirement
below land surface
best management practice
Code of Federal Regulations
Clean Air Act of 1970
Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended
centimeter(s)
chen1icalofconcern
chemical of potential concern
dense nonaqueous phase liquid
United States Department of Energy
Environmental Management and Enrichment Facilities
United States Environmental Protection Agency
Federal Register .
Federal Facility Compliance Agreement
feasibility study
foot (feet)
gallon(s)
Hazardous and Solid Waste Amendments of 1984
inch(es)
qualifier indicating estimated value
Kentucky Administrative Regulations
Kentucky Department for Environmental Protection
Kentucky Pollutant Discharge Elimination System
liter(s)
land disposal restriction
low-level (radioactive) waste
meter(s)
microgram(s) per liter
millirem(s)
monitoring well
National Oil and Hazardous Substances Pollution Contingency Plan
operation and maintenance .
polychlorinated biphenyl
picoCurie(s) per gram
picoCurie(s) per liter
Paducah Gaseous Diffusion Plant
personal protective equipment
Present Worth over 30-year period
remedial action objective
Resource Conservation and Recovery Act, as amended
Regional Gravel Aquifer
remedial investigation
record of decision
Superfund Amendments and Reauthorization Act of 1986
solid waste management unit
vii
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TBC
TCE
U.S.c.A.
UCRS
WAG
WKWMA
yd3
yr
to be considered
trichloroethene
United States Code Annotated
Upper Continental Recharge System
waste area group
West Kentucky Wildlife Management Area
cubic yards
year(s)
Vln
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PARTl
DECLARATION
!)
(
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DECLARATION FOR THE RECORD OF DECISION
FOR INTERIM REMEDIAL ACTION
AT SOLID WASTE MANAGEMENT UNITS 2 AND 3
OF WASTE AREA GROUP 22
SITE NAME AND LOCATION
Solid Waste Management Units 2 and 3 of Waste Area Group 22
Paducah Gaseous Diffusion Plant
Paducah, Kentucky
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action for Solid Waste
Management Units (SWMUs) 2 and 3 of Waste Area Group (WAG) 22 at the Paducah
Gaseous Diffusion Plant (PGDP) near Paducah, Kentucky, chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986, and to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan. This decision is based on the administrative record for this site.
The United States Department of Energy (DOE) entered into an Administrative Order by
Consent pursuant to Sections 104 and 106 of CERCLA, effective November 23, 1988,
with the United States Environmental Protection Agency (EP A). The PGDP was issued a
Kentucky Hazardous Waste Management Permit and an EPA Hazardous and Solid
Waste Amendments (HSWA) Permit July 16, 1991. The PGDP was placed on the
National Priorities List effective June 30, 1994 (59 Federal Register 27989, May 31, 1994).
Currently the DOE, the EP A, and the Kentucky Department for Environmental
Protection (KDEP) are negotiating a Federal Facility Agreement for the PGDP site. On
February 10, 1994, the EPA approved the DOE's January 20, 1994, proposal to issue a
feasibility study report for SWMUs 2 and 3 of WAG 22. The concept of limiting the
feasibility study to these two SWMUs was originally discussed among the EP A, the
KDEP, and the DOE representatives during a June 11, 1992, meeting, and again during a
January 5, 1994, meeting. Since SWMU 3 underwent Resource Conservation and
Recovery Act (RCRA) closure in 1987, it does not require additional remedial or correc-
tive actions at this time. Data gaps exist which prevent development and evaluation of
final remedial actions at SWMU 2. In order to mitigate risks posed to ground water and
the potential for direct contact, the DOE will implement an interim remedial action at
SWMU 2. This interim remedial action will be initiated pursuant to the Interim Measure
provisions of PGDP's Kentucky Hazardous Waste Management Permit issued by the
KDEP and K.R.S. 224.46-530, the HSW A Permit issued by the EP A, and this Record of
Decision (ROD). The Commonwealth of Kentucky concurs with the DOE and the EP A
on the selected interim remedial action. This action will serve as an incremental step
toward comprehensively addressing PGDP site problems.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from SWMU 2, if not addressed
by implementing the response action selected in this ROD for interim remedial action,
may present an imminent and substantial endangerment to public health, welfare, or the
environment in the future.
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I--~-
DESCRIPTION OF SELECTED REMEDY
The primary objective of this interim remedial action, or corrective measure, is to reduce
the infiltration of precipitation into buried wastes and mitigate any leaching of
chemicals of concern from the wastes while the DOE collects additional data to support
evaluation of a final remedial action. The Surface Water Integrator Operable Unit and
the Ground Water Integrator Operable Unit at the PGDP will be addressed
comprehensively in subsequent operable units. Solid Waste Management Units 2 and 3
are identified as source units at the PGDP. This interim remedial action for a source unit
constitutes an incremental step toward comprehensively addressing site-wide problems
at the PGDP. Decisions regarding final remedial actions will be made through the
remedial investigation and remedy selection process after the source units are more fully
understood.
The principal threat associated with SWMU 2 is the potential for transport of
contaminants to the ground water operable unit and subsequent threats associated with
the potential contamination of an aquifer and transport of contaminants beyond DOE
property. The major components of the interim action remedy include:
.
Once a determination has been made regarding possible ground water
interaction with the buried wastes, a low permeability, multilayered cap may be
placed on SWMU 2, the C-749 Uranium Burial Ground, to reduce infiltration of
surface water from precipitation events into and through buried wastes. This wil1
reduce potential leaching of contaminants to ground water. The cap will also
decrease the gamma exposure rate to background levels and further decrease the
likelihood of on-site workers and terrestrial animals coming into direct contact
with the buried wastes.
.
A ground water monitoring program will be implemented in the uppermost
aquifer, the Regional Gravel Aquifer, to detect any release of contaminants from
SWMU 2.
.
Institutional controls wil1 be implemented to prevent transferal of the SWMU 2
property and prevent future intrusive activities at the unit.
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
This interim action is protective of human health and the environment in the short term
and is intended to provide adequate protection until a final ROD is signed for this unit.
This interim action also complies with federal and state applicable or relevant and
appropriate requirements for this limited-scope action, and is cost effective. This interim
remedial action meets Condition IV. E. of the Kentucky Hazardous Waste Management
Permit relating to interim corrective measures. This interim action is not intended to
fully address the statutory mandate for permanent solutions and alternative treatment
technologies to the maximum extent practicable for SWMU 2. Since this action does not
constitute the final remedy for SWMU 2, the statutory preference for remedies which
employ treatment that reduce toxicity, mobility, or volume as a principal element will be
considered during evaluation of a final response action. Subsequent actions are planned
to fully address the principal threats posed by the conditions at SWMU 2. Since this
interim remedy will result in hazardous substances potentially remaining above health-
based levels, a review will be conducted to ensure that the remedy continues to provide
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adequate protection of human health and the environment within five years after
commencement of the interim remedial action. Since this is an Interim Action ROD,
review of this unit and of this remedy will be ongoing, as the DOE continues to develop
final remedial alternatives for S U 2 of WAG 22 at the PGDP.
Date
'i4ftr
,
R ertD. emp ey . -L -
Assistant Manager for Envirorun,Ht~gement
United States Department of Energy
~M7~ M
John H. Hankinson, Jr. 1
Regional Administrator
United States Environmental Protection Agency, Region IV
Date
P-22..q.r-
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PART 2
DECISION SUMMARY
1
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DECISION SUMMARY
2.1
Site Name, Location, and Description
The United States Department of Energy (DOE) is conducting environmental cleanup
activities at the Paducah Gaseous Diffusion Plant (PGDP) under the DOE Environmental
Management and Enrichment Facilities (EMEF) Program. These cleanup efforts are
required to address contamination that has resulted from past waste handling and
disposal practices at the plant. The DOE is conducting the remedial activities in
compliance with the requirements of the Kentucky Department for Environmental
Protection (KDEP) and the United States Environmental Protection Agency (EP A).
The PGDP, located in western Kentucky, is an active uranium enrichment facility owned
by the DOE. Effective July 1, 1993, the DOE leased the plant production operations
facilities to the United States Enrichment Corporation, which in turn contracted with
Lockheed Martin Utility Services, Inc. to provide operations and maintenance services.
Lockheed Martin Energy Systems, Inc. manages EMEF_Program activities for the DOE.
The PGDP is located in McCracken County in western Kentucky, approximately
3.5 miles south of the Ohio River (Figure 2-1). The PGDP facility covers about 540
hectares (1,335 acres), with approximately 300 hectares (740 acres) situated within a
fenced security area; the remaining 240 hectares (59~ acres) are maintained by the DOE
as a buffer zone surrounding the plant. Approximately 850 hectares (2,100 acres) of land
beyond the buffer zone are leased by the DOE to the Commonwealth of Kentucky as
part of the West Kentucky Wildlife Management Area (WKWMA). The WKWMA is
used extensively for recreation, primarily hunting and fishing.
The principal pathway of ground water flow anhe PGDP is the Regional Gravel Aquifer
(RGA), which consists of unconsolidated gravel and sand deposits occurring between 12
and 33 meters (m) [40 and 100 feet (ft)] below land surface (bls). From the PGDP, ground
water within the RGA flows in a northward direction toward the Ohio River, which is
the local base level for the system. Ground water contaminant plumes originating from
the PGDP and extending north and northeast from the plant are located within this
aquifer.
Waste Area Group (WAG) 22 consists of the following solid waste management
units (SWMUs):
.
SWMU 2, the C-749 Uranium Burial Ground;
SWMU 3, the C-404 Low-Level Radioactive/Hazardous Waste Burial Ground;
SWMU 7, the C-747-A Burial Ground; and
SWMU 30, the C-747-A Burn Area.
.
.
.
These four units are situated within the security-fenced area in the northwest portion of
the plant (Figure 2-2). Although SWMUs 7 and 30 are contained in WAG 22, it has been
mutually determined by the DOE, the EP A, and the KDEP that remedy selection at these
two units will not be conducted until further characterization activities have been
completed. Consequently, SWMUs 7 and 30 will not be considered further in this
document. As shown in Figure 2-2, SWMUs 2 and 3 are located near the west-central
portion of the security-fenced area of the PGDP. Both burial grounds have been capped,
SWMU 2 with a 15-centimeter (cm) [6-inch (in)] clay cap and 46-cm (18-in) vegetative
2
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~
Illinois
818
i!~
.!'i
.e!:o
1~f!1
-
p~,q
~
fJ\\Ilm
Wildlife Management Area
Paducah Gaseous Diffusion PIM! (PGDP)
Department 01 Energy (DOE) Reservation
Munlclpalily
Tennessee Valley Authority (TVA)
Municipal Water Supply Wells
(Kevil, KY and Metropolis, IL)
~r~
~~l
Kentucky
--.,,~
VJ
Mississippi River
,6~..,....,....,....
".~.."""'co'
"""'.G.~\\"\.
023
, ,
Approximate Scale (miles)
Paducah Gaseous Diffusion Plant
Paducah, Kentucky
IIDJacobs ER Team, 1995
Figure 2-1. Paducah Gaseous Diffusion Plant Vicinity Map
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\
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/'--'. -.-.- ---. J
:--" '''''~~''\.--(C:-=:-~~~'''' .. '--"---
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8
MaGruder
Villiage
Legend
Departmenl 01 Energy
- Rosentation Boundary
_..- SUI1aceWalor
~;J Swamp or MaIsh
I :x:
I ~
~.. :D
'..... 0
.",
0.
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,
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__I
,--
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--LSWMU 3
404 low-level
:-~~~lill
SWMU2 ~~
c-749 Uranium ;
Burial Ground
.- ------- ~ m
'-
--.
'..
Legend
F'7777/I Solid Waste Management
~ Unit (SWMU)
---- Surface Water
~ Security Fence
0' 500' 1000'
r---------....J.
Approximate Scale (feet)
:>
r
,
.
.J_-
Figure 2-2. Location of Solid Waste Management Units in Waste Area Group 22
-------
.
- -~--~.-
I
I
[":
I; "
, ",
,
cover and SWMU 3 (a regulated unit) with a Resource Conservation and Recovery Act
(RCRA) multilayered clay cap. The surfaces of both burial grounds are primarily grass
covered. Surface elevations vary from about 113 to 119 m (370 to 390 ft) above mean sea
level in the immediate vicinity of the two units. Surface runoff fro~ the SWMUs flows
into the ditches located north, south, and east of the units and discharges through
Kentucky Pollutant Discharge Elimination System (KPDES) Outfall 015 to Big
Bayou Creek.
2.2
Site History and Enforcement Activities
The C-749 Uranium Burial Ground (SWMU 2) is located in the west-central portion of
the plant north of Virginia Avenue and on the western edge of the C-404 Low-Level
Radioactive/Hazardous Waste Burial Ground (Figure 2-2). It encompasses an area of
approximately 2,970 m2 [32,000 sqare feet (fe)] with approximate dimensions of 48.8 by
61.0 m (160 by 200 ft) and is divided into 6.1 by 6.1 m (20 by 20 ft) sections. The C-749
Uranium Burial Ground was used from approximately 1951 to 1977 for the disposal of
uranium and uranium containing wastes. The exact depth of the buried waste is not
known. Wastes were reportedly placed in trenches excavated to a total depth of
approximately 2.1 to 5.2 m (7 to 17 ft) and then covered with 0.61 to 1.2 m (2 to 4 ft) of
soil. Occasionally, fires were reported as a result of oxidation of pyrophoric uranium
metal, but no subsidence was observed resulting from potential volume reductions due
to the fires. In 1982, the C-749 Uranium Burial Ground was covered with a 15-cm (6-in)
clay layer and a 46-cm (18-in) vegetative cover. It has been estimated that 2.44 x 105
kilograms (270 tons) of uranium, 2.23 x HY liters (1) [59,000 gallons (gal)] of oils, and 1.70
x 10" I (450 gal) of trichloroethene (TCE) were buried in SWMU 2. Most of the waste
consisted of pyrophoric uranium metal in the form of machine shop turnings, shavings,
and sawdust. Pyrophoric uranium metal was usually placed in 20-,30-, or 55-gal drums
and petroleum-based or synthetic oils were used to stabilize the waste. It is possible
these oils may have included some polychlorinated biphenyl-(pCB) contaminated oils.
Other forms of uranium, including oxides of uranium (solid and dissolved in aqueous
solutions), uranyl fluoride solutions, uranium-zirconium alloy, slag, and uranium
tetrafluoride were buried in smaller quantities.
There is no documentation of technetium-99 (~c) disposal at SWMU 2, but its presence
is suspected due to its association with operations at the PGDP. Technetium was
produced at the PGDP as a by-product from reprocessing of reactor tailings. A portion
of the uranium-containing wastes disposed in burial grounds at the PGDP likely
contains ~c from this source. In addition, detections of ~c in ground water samples
from nearby monitoring wells indicate that it may be present in SWMU 2.
In August 1984, Area 9 [which is approximately 6.1 by 4.3 m (20 by 14 ft)] and located on
the southern border of SWMU 2) of the C-749 Burial Ground was excavated in response
to concern about the integrity of the drums containing TCE reportedly disposed in this
area. Little documentation is available concerning this activity. During excavation, four
of the fifteen 30-gal drums believed to be in Area 9 were recovered, and three of them
were in such poor condition that their content could not be determined. In addition to
the four 30-gal drums, approximately 36 plastic-lined 55-gal drums were excavated. Five
of the 55-gal drums were of poor integrity. There was no record of the 55-gal drums
having been buried in Area 9.
The C-404 Low-Level Radioactive/Hazardous Waste Burial Ground (SWMU 3) is
located immediately east of the C-749 Burial Ground in the west-central area of the plant
(Figure 2-2). It is approximately 42.7 by 115.8 m (140 by 380 ft) and was originally
constructed in the early 1950s as an aboveground holding pond, with an on-grade
5
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tamped earth floor and 1.8-m (6-ft) high clay dike walls. The burial ground was used
from 1951 to 1957 as a primary disposal area for 99Tc and uranium-contaminated
effluent. In 1957, all free liquids were removed, and disposal of uranium-contaminated
bulk solid wastes began at the unit. In 1976, after the facility was f~lled with bulk solid
waste, it was covered with compacted earth and the weir at the southwest comer was
converted into a leacbate collection sump. From 1977 until closure of the unit in 1986, the
upper portion of SWMU 3 was used for the disposal of bulk and containerized uranium-
contaminated solid waste. A portion of this waste, consisting of approximately 645
drums of precipitation filter cake (end products from the gold dissolver process) was
found to be RCRA hazardous in 1986. Solid Waste Management Unit 3 was
subsequently covered with a RCRA multilayered cap and certified closed in 1987. It is
regulated under RCRA as a land disposal unit and is required to comply with a RCRA
post-closure permit which was issued on September 1992. .
Because SWMU 3 is closed with a RCRA cap and is being addressed by RCRA post-
closure permit requirements, only SWMU 2 will be addressed by the interim remedial
actiQn described in this Record of Decision (ROD). Solid Waste Management Unit 3 will
continue to be regulated under the existing RCRA permit which requires continued
ground water monitoring.
2.3
Highlights of Commu~ity Participation
From May 31 to June 29, 1995, a notice of availability regarding the Proposed Remedial
Action Plan was published in a regional newspaper, The Paducah Sun. The Proposed
Remedial Action Plan for Interim Action at Solid Waste Management Units 2 and 3 of Waste
Area Group 22 (DOE/OR/06-1315&D3) was released to the public May 31, 1995.
Specific groups which received individual copies of the Proposed Remedial Action Plan
include the local PGDP Neighborhood Council, Natural Resource Trustees, and the
PGDP Environmental Advisory Committee. A public meeting was tentatively scheduled
for June 22, 1995, if requested by June 12, 1995. Since no requests were made for a public
meeting, a notice of the meeting's cancellation was published in the Sunday, June 18,
1995/ edition of The Paducah Sun.
2.4
Scope and Role of Operable Unit
Consistent with the DOE strategy, this interim action is intended as an incremental step
toward addressing the source unit, SWMU 2. A potential contamination release into the
RGA has been identified as the primary threat posed by SWMU 2. The objective of this
interim action is to reduce infiltration of leachate through the unsaturated waste and
delay the potential breakthrough of uranium and other chemicals of concern (COCs) to
the RGA. By implementation of this interim action, leaching of contaminants into the
ground water will be reduced while a final remedy for SWMU 2 is being evaluated.
Several data gaps exist which prevent the DOE from evaluating a final remedial action
for SWMU 2. The missing data regarding SWMU 2 relates to the depth of the waste, the
volume of the waste, and the form of the waste. One of the more important data gaps is
whether any of the buried wastes are saturated or in direct contact with ground water. If
the waste is in fact saturated, the effectiveness of the cap is limited and the contaminants
are more likely to migrate within the RGA, thus posing a risk to off-site receptors.
Additional information will be collected to fill data gaps as necessary to evaluate a final
action in three separate manners. Field work associated with implementation of this
action will fill some data gaps. Information collected during the course of other DOE
projects near SWMU 2 will also fill data gaps. In addition, the DOE will prepare a
6
-------
separate sampling plan currently scheduled to be submitted to the EP A and the KDEP in
late 1995. The sampling plan will address those critical data gaps which will not be iillE:J
as a direct result of this interim action or other field projects. This interim action is an
efficient, cost effective means of reducing risks posed by SWMU 2 at an early stage,
while information necessary to evaluate a final action is being collected. Once the proper
information has been collected, the DOE will evaluate and reconunend a final remedial
action for SWMU 2.
2.5
Site Characteristics
Hydrogeologic Characteristics
The subsurface at the PGDP consists of approximately 103.7 m (340 ft) of unconsolidated
sediments overlying Mississippian limestone bedrock. Figure 2-3 presents a general
subsurface profile of the PGDP area. The following discussion focuses on those
lithologies present beneath SWMU 2.
Surficial deposits in the vicinity of SWMU 2 consist of approximately 4.0 to 6.1 m
(13 to 20 ft) of silt loam and silty clay loam. These deposits consist of about 1.8 m (6 ft) of
soil and an underlying 2.1 to 4.3-m (7 to 14-ft) thick layer of wind-deposited, fine-
grained, silty material called loess.
Underlying the surficial deposits are unconsolidated sediments consisting of
interbedded and interlensing gravel, sand, silt, and clay. These deposits, divided into the
Upper and Lower Continental Deposits, were lain down in the region during the late
Tertiary and Quaternary periods. The Upper Continental Deposits consist primarily of
clayey silt, with thin layers of sand and occasional gravel found at a depth of about 4.0
to 6.1 m (13 to 20 ft) bls. They are approximately 12.2 to 15.2 m (40 to 50 ft) thick in the
vicinity of SWMU 2. The loess and the Upper Continental Deposits have been informally
grouped into a ground water flow system referred to as the Upper Continental Recharge
System (UCRS). Water level measurements from a UCRS monitoring well, located at the
northern edge of SWMU 2, Monitoring Well (MW) 154, indicate an area of high ground
water elevations exists at SWMU 2. The ground water flow direction within the UCRS is
ultimately downward through the low permeability clay, silt, or dayey silt layer
separating the Upper and Lower Continental Deposits.
The top of the Lower Continental Deposits is typically found at depths of approximately
18.3 to 21.3 m (60 to 70 ft) bls. The Lower Continental Deposits consist predominantly of
well-rounded chert gravel with sand and are approximately 6.1 to 9.1 m (20 to 30 ft)
thick in the vicinity of SWMU 2. The principal gravel facies of the Lower Continental
Deposits, the RGA, is the uppermost aquifer at the PGDP.
The Continental Deposits are underlain by the McNairy Formation at depths of
approximately 25.9 to 30.5 m (85 to 100 ft) bls. The McNairy Formation in this area of the
plant site has been described as brown to gray, silty, clayey, very fine to fine sand with
dark gray silty clay. The total thickness of the McNairy Formation is approximately 68.6
m (225 ft). Directly underlying the McNairy Formation are the Mississippian rubble zone
and the Cretaceous Tuscaloosa Formation, which consist of a 1.5 to 6.1 m (5 to 20 ft)
thick layer of subangular chert and silicified limestone fragments. Deep borings at the
PGDP have encountered Mississippian limestone bedrock approximately 102 to 107 m
(335 to 350 ft) bls.
7
-------
SOUTH
Terrace
Gravels
NORTH
DOE
PGDP
Loess
I
il!!
~I~
I
I
PORTERS CREEK CLAY
!
McNAIRY FORMATION
NOT TO SCALE
IJI]Jacobs ER Team, 1995
Figure 2-3. General Subsurface Profile of the Paducah Gaseous Diffusion Plant Area
-------
Nature and Extent of Contamination at Solid Waste Management Unit 2
The results of the Phase I and Phase II Site Investigations indicate that organic, metal, and
radio nuclide contamination is present in surface so;ls, subsurface soils, and ground water
in the SWMV 2 area. Sampling locations at SWMU 2 are shown in Figure 2-4. The
possible source of this contamination is the low-level (radioactive) waste (LLW),
primarily uranium and uranium-contaminated material, buried within the unit.
Over 30 chemicals of potential concern (COPCs) were identified in the Remedial
Investigation Addendum for Waste Area Grouping 22, Burial Grounds, Solid Waste Management
Units 2 and 3, at the Paducah Gaseous Diffusion Plant risk assessment. Nineteen of these
COPCs were detennined to pose a potential risk great enough to be considered COCs for
the Feasibility Study for Solid Waste Management Units 2 and 3 of Waste Area Group 22 at the
Paducah Gaseous Diffusion Plant. The criteria used to identify the COPCs and COCs, as
well as the uncertainties associated with the identification process, are presented in the
Remedial Investigation (RI) Addendum and in Appendix A of the Feasibility Study (FS).
The principal organic contaminant detected in the ground water at SWMU 2 is TCE,
found primarily in the VCRS at concentrations varying from about 4 to 1,400 micrograms
per liter (~g/l). Trichloroethene also has been detected in the upper RGA, at levels
ranging from <5 to 98 ~g/l. Trichloroethene is transported as a dissolved phase liquid in
the direction of ground water flow. It also has the potential to migrate in the form of a
dense nonaqueous phase liquid (DNAPL). As the buried waste containers degrade
within SWMU 2, DNAPLs could potentially migrate to subsurface soils and ground
water.
Metals have been detected above Phase IT Site Investigation reference levels in soil and
ground water samples at SWMU 2. Arsenic and silver were detected above reference
levels in soil samples taken from borings located at the perimeter of SWMU 2. The
principal inorganic contaminants in the ground water at SWMV 2 are manganese,
vanadium, and beryllium. Beryllium was detected in total (unfiltered) metals analyses at
levels above allowable drinking water maximum contaminant levels in the UCRS.
Manganese and vanadium were detected at levels above reference values in VCRS wells
located near SWMU 2.
Radiological contamination has been detected in shallow soil samples from borings
located at the perimeter of SWMU 2, primarily at H 221 northwest of SWMV 2 and at
H 262 southwest of SWMU 2. The radionuclides ~c [up to 58 picoCuries per gram
(pCi/g)] and total uranium (up to 89 pCi/g) have been detected in surface soils and in
the ditch southwest of the unit to a depth of approximately 1.8 m (6 ft). The extent of
surface radiological contamination likely extends from H 221 in the swale west of
SWMU 2 and from H 262 in the ditch south of SWMU 2 to Outfall 015.
Ground water sampling indicates radiological contamination is present in the VCRS near
SWMU 2. The principal radiological contaminants are ~c and, at lower levels, uranium.
In ground water samples from the UCRS wells near the unit, ~c was detected at levels
ranging from < 25 to 2,175 picoCuries per liter (pCi/I). Uranium has been detected at
varying levels in VCRS wells; the maximum values (total fraction analysis) detected in
UCRS wells at SWMU 2 were 10 pCi/1 a-value) uranium-234 in MW 49, 1.0 pCi/1
uranium-235 in MW 91, and 27 pCi/1 uranium-238 in MW 154. In general, the
radiological contamination in the VCRS is higher than that found in the RGA. The
principal radiological contaminant detected in the RGA is ~c. Two downgradient wells
in the area, MW 51 and MW 67, have reported ~c values up to 53.2 pCi/1 in the upper
RGA. Uranium has not been detected above reference levels in the RGA in the vicinity of
9
-------
......
o
I
i
I
i
!
I MW-85 H-220 MW-88 MW-91
\ MW-154t?\ 0{ G! -57 . MW-84. ~.IMW-8~..--__..........MW:8.Z._~.---=~~..._._-_.........M.W::9J). ,SJ, . MW-92
11!-'" - - ~......_._~.""......II!,)- - - -I . - - -l1li- - .......~......_.~..!"....!111..-- . ....._-. - - - - - - -,.~.. - - - - - - - - iIIr'-,. - - . .................
~/ ( MW-58 -' @ I .....--"'" 375 MW.55.-..MW-56-"""""''''''''''''''''''''''-'-''''', " II. \
,.1 ,../j'*H-202R1,-4 '"'''''' 371......"""""-""'-"'" MW-74 .1/";1''''''/'' .."..-"'--""'" 380 .......--....--....-...........-....-[[[-......-...... ...... ."--""""""'-"""'''''''''''''''''''''''''''''''''''''''''''', " ", ""'" I ':>\ )1. .
......._---_............-~_..."""" ~
i I ;1 SWMU 2. '/1 ~. ,/ ......,.385'''''''''''''''''''''''--'''''-'''''''''''''''''-'''''''''''''''''''''' ... ,,' \ \\ II MW-751
MW-51 I ""-""""".......' I I ... "'''''''''''''''_'''''''''390'''''''''''' '''''.. \ . ! \
( 'I C-749 ( I : \ ( SW.~U 3"" \ \ \:
1 \. I URANIUM .J : I \ I'. \ \ \ I. I
J, I /'. C-404 I
M~-~Jif BURIAL / : I \ \ LOW-LEVEL \ I j II
\ II GROUND I I \ \ RADIOACTIVElHAZARDOUS WASTE I j \ I
\11 * 11\\ ,I II.
\ I : \. I I \ \. BURIAL GROUND j! I I MW-45
MW-: I "ORI-6 :: \. "",..................... .'ft- ..............-......... 390............................./ ! ! f:
I "" ,.../'\ I \,... """ .I / ! I
.'., i ,.......'''_.tt.~..'''~:::~~~~~i~~:~~~-:::::'.::-::.:=::.::::-;:.. i.: H~008
I ORI-5 * I
I MW-48* MW-49 I
~---------------,
.. 370 .. w'"''''''''''''''''''''''''',.,,'''''''
.
MW-67
H.262 S
~"Y.:.~~~~..~~.:~!. .." 'W"...
H-261 S
.. 370"
"""""""'370 .......................
.....,.....,..,..,..."..",....................,"..............
.................."....... mo'-' 370 '"
... .m...- ""..' ....._._-~.-.-....._....._......_.....
"",-_._,~----_._-,_.W.....h ...,.,."-"" "........ '''''''''''''--'''''''''''''''''''_n__''''''''''''''''''''''''''
VIRGINIA AVENUE
'.:::')"
Legend
.ff~
.~~
In
UJ
a:
I-
en
.£:
-
co
.
o
@
o
S
*
--
RGA Monitoring Well .
Shallow UCRS Monitoring Well
Deep UCRS Monitoring Well
Plugged and Abandoned Well
Soil Boring
Double-Ring Infillrometer Test
SWMU Boundary
11 711
~ r"""""t
AppaDnato - ~..t)
Modified 'rom CH,M Hill Southeesl. 1991
IiOJecobs ER Te8m, 1995
-------
SWMU 2. The RESRAD (Residual Radioactivity) computer code was used for the FS to
model potential leaching of uranium from SWMU 2. Results of this modeling indicate
that uranium may migrate from SWMU 2, although very slowly, taking approximately
1,900 years to migrate to the RGA. .
Two radiation walk-over surveys of SWMU 2 were conducted in August 1994. Detailed
information concerning these surveys can be found in the FS. The survey results indicate
that a generalized, low-level gamma field exists across SWMU 2. The field may be
partially attributable to the large quantities of uranium metal buried in SWMU 2.
Cylinder storage yards located adjacent to SWMU 2 are also likely contributing to the
elevated gamma readings. In addition, during the Phase II Site Investigation, a radiation
walk-over survey of the ditch located south of SWMU 2 was conducted. The results of
this survey indicate that beta and gamma emitters are present at the surface of the ditch
at levels exceeding three times background.
Conceptual Site Model for Transport and Exposure Pathways at Solid Waste
Management Unit 2
The conceptual site model presented in Figure 2-5 identifies the probable and potential
contaminant migration and exposure pathways at SWMU 2. From the source, defined as
the low-level radioactive waste buried within SWMU 2, two probable pathways are
identified: (1) a probable pathway to the adjacent soils; and (2) a probable pathway to
ground water due to leaching and dissolution of contaminants. Consistent with the DOE
strategy, DNAPL is considered a potential source beneath the buried waste since burial
records indicate that TCE, a potential DNAPL compound, was buried at SWMU 2.
However, the presence of DNAPL has not been identified at SWMU 2. Potential
exposure to contamination at SWMU 2 via air is currently limited since SWMU 2 is
covered with a IS-em (6-in) clay cap and a 46-cm (I8-in) vegetative cover. These are the
primary pathways and will be the focus of Section 2.6. The interim action presented in
this document is intended to address the potential transport of contaminants to ground
water via infiltration of precipitation through the buried waste materials at this SWMD.
The risks that are addressed by this interim action are discussed in the following section.
2.6
Summary of Site Risks
The results of the risk assessment suggest there is sufficient potential risk to the public
and environment to warrant action. A summary of the long-term risk is presented in
Table 2-1. The principal goal of the interim remedial action is to implement source
control measures which will diminish infiltration of surface water from precipitation
events the buried waste. This will reduce potential leaching of TCE and uranium into
the ground water. The interim action will also eliminate the present and future potential
for direct contact with the buried waste by both humans and terrestrial animals. A
summary of the risk assessment is presented below.
Human Health Risks
The data from the Site Investigation were evaluated in the human health risk
assessment. To identify contaminants of potential concern, all constituents detected in
the surrounding soils and ground water were evaluated using established guidelines.
From this data, contaminants of potential concern included metals, organic compounds,
and radionuclides. Whether the chemicals detected in the ground water beneath the unit
are associated with SWMU 2 is not known due to a lack of sampling data from the
waste. Since uranium and TCE are two primary waste sources in SWMU 2, source term
11
-------
o. --- -- Volatilization
: and Particulate
: : Suspension :- -.
o 0 0
o . 0
1.1 I
o 0 0
.: I .
: J, Combustion :
: . : -.. ~ (Following Excavation) - - - -
o 0
o 0
o 0
o 0
.:: +. :.u... m.. u........ .uu. u.... um. m u.... u....... u. u......'..'............... uu.... u....... u.DI'"i:~r"~. .. crEE]
o
.
.
o
o
o Erosion and Surface Water
f - . -.. Surface Runoff - - - - - -.. and Sediments
.
.
,
,
.
o
Source
Release
Mechanism
Primary
Contaminated
Media
Exposure
Pathway
Secondary
Contaminated
Media
Migration
Pathway
Air and
Airborne
Particulates
- - - - - -.. Air Movement - -. - - - - - - - - - - - - _. - - - - - - - - - - -.... -...
-Inhalation
Burled
Waste
Receptor
.. ..
'" .~
~ ~
0 ~ iii
~ 'i: c u
1: ",... "6>
~ e'" "'-0 0
::d~ ",.- "0
-0 _III
'" &~ ",,,, u
o u.a: w
.. 0 0 0
E Surface Water
~ ~ ~~: -.... Runoff . ~ ~ ~ ~ ~.. and Sediments
o 0
: : .
o
o 0
. 0
._-~ :
uuu~I~lu1 10 I 0 I : I
.....
IV
o
o 0
o 0
o 0
o 0
o 0
o 0
, 0
y :
I DNAP+.j..
Vadose Zone
Soli
Infiltration
Ingestion
Inhalation
Dermal Absorption
Leaching
I Ground Water I
Dissolution
Ground Water
Ground Water - -
Movement
SWMU2
Soli
Ingestion
Inhalation
Dermal Absorption
Direct Exposure
-... - ---- ---------
Probable Pathway
Potential Pathway
. Probable Receptor
o Potential Receptor
I Pathway of Concern for Interim Action
u1-1 ~gl--'I
. . 0
. ~- . - __0
. . 0
.-------
. . 0
.
.
.
PADUCAH GASEOUS DIFFUSION PLANT
PADUCAH, KENTUCKY
Figure 2-5. Conceptual Site Model of Solid Waste Management Unit 2
-------
Table 2-1. Summary of Long-Term Risk at Solid Waste Management Unit 2
under No Action and Interim Action
I No Action Interim Action
Future Unrestricted Workers
Direct Direct contact with waste Potential for direct contact reduced by
contact with possible; risks from direct physical barrier created by the low
waste contact unacceptable! permeability multilayered cap.
Future Potential Ground Water User
Ingestion of Risk posed by ground water Migration of contaminants reduced
ground water contamination is unacceptable. through reduction of water movement
Contaminant concentrations in through unit by the cap.
ground water expected to
mcrease.
* Unacceptable risk: a potential risk higher than one additional cancer case in a population of one
million people exposed to a certain level of a pollutant during a lifetime.
concentrations were estimated from disposal records as input parameters for the soil
leaching models.
The exposure pathways evaluated in the human health risk assessment are shown in
Figure 2-5. As indicated by this figure, the risk assessments considered SWMU 2 to be an
industrial site both under current and future conditions. However, the future resident
using ground water was also evaluated for the site. For these scenarios, the principal
pathways considered are inhalation potentially associated with the combustion of
pyrophoric uranium, direct contact with the pyrophoric waste, and ingestion of
potentially contaminated ground water. Although the contaminants in the ground water
do not pose a threat at present, the potential for migration of TCE and uranium to off-
site ground water does exist. As the primary contaminant migration pathway, potential
future releases from SWMU 2 to ground water were evaluated using predictive models
to estimate leaching.
Toxicity information used in the risk assessment was taken from approved EP A
documents and data bases. The potential adverse human health effects associated with
the primary contaminants of concern include carcinogenic effects and noncarcinogenic
or systemic effects. Uranium exposure is associated with radiocarcinogenic and chemical
toxic effects. Exposure to TCE through inhalation and ingestion causes cancer and
various adverse effects on human health.
Risk characterization for workers indicated that under current conditions, the risk at the
unit was not unacceptable. However, the risk characterization for workers under future
conditions indicated that the risk at the unit was unacceptable due to potential direct
contact with the buried waste. Also, the risk characterization for use of contaminated
ground water indicated that ground water use could pose significant unacceptable risk
to human health under future conditions. The primary driver of risk was ingestion of
contaminated ground water. The primary contaminants contributing risk were TCE and
uranium for the interim action.
Table 2-1 presents a summary of the-long term risk at SWMU 2 for workers and ground
water users under both the baseline (no action) condition and after the interim action is
in place. As shown in this table, the interim action is effective in reducing risk from
direct contact with the waste and in reducing the risk posed by the pyrophoricity of the
13
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buried uranium. Also, the interim action is effective in reducing risk from ground water
~tse by reducing the rate of contaminant leaching from the buried waste to the
und~rlying aquifer.
Several uncertainties~ or factors that could significantly affect the results of the risk
assessment, were identified in the risk assessment. Primary uncertainties included needs
to estimate the quantity of buried waste at SWMU 2 and the physical and chemical
makeup of the waste. The effect of having to estimate these factors is unknown;
however, .since the risk assessment used estimates of concentrations of uranium and
TCE that were unlikely to underestimate waste volume or mass, the results of the risk
assessment are not likely to be underestimates of risk.
Another uncertainty identified as being important was the fact that rates of exposure
used in the assessment were likely to be overestimates for most parameters. Both
methods for evaluating TCE and uranium in ground water assumed reasonable
maximum leaching. Therefore, concentrations of TCE and uranium under no action may
result in overestimates of risks.
A third uncertainty.that affected the results of the risk assessment is the assumed
pyrophoric nature of the buried uranium. To address this uncertainty, the risk
assessment considered the various conditions that would need to occur for spontaneous
combustion of the buried uranium. These conditions were presented to ensure that .any
remedial alternative selected for SWMU 2 would reduce the risk posed by the
pyrophoricity of the buried uranium.
Environmental Risks
Potential ecological effects were qualitatively evaluated in the ecological risk
assessment. According to the Site Investigation, neither critical habitat nor known
federal or state threatened and endangered species were located inside the PGDP
boundary. Only various soil and sediment dwelling invertebrates (e.g., earthworms,
chironomids), aquatic and terrestrial insects and their larvae, frogs and salamanders,
and small mammals were reported. The principal source of potential adverse impacts to
ecological reSOUrCE$ at SWMU 2 was the possible failure of the buried waste containers
and the subsequent release of COPCs to a subsurface environment.
The major exposure pathways for terrestrial animals include ingestion of contaminated
biota and, to a lesser extent, ingestion and direct contact with contaminated soils.
Ingestion of water and sediment at SWMU 2 is probably a minor pathway of exposure
for terrestrial animals. Exposure to COPCs would likely. have adverse effects to
terrestrial animals and biota.
The risk to terrestrial animal populations and biota populations is small under the
current condition. Potential risks may be associated with ingestion and direct contact
with buried wastes due to possible releases of COPCs to the environment. The interim
action will limit potential risks by reducing the possibility of a release of COPCs to the
environment.
Remedial Action Objectives
Results of the human health risk assessment (Table 2-1) indicate that ingestion of
contaminated ground water and direct contact with the buried waste pose unacceptable
risks in the future. The remedial action objectives for the interim action are to mitigate
migration of uranium and TCE from SWMU 2 to ground water, and to prevent
14
-------
disturbance or contact with the buried waste materials. The interim action will reduce
infiltration of precipitation, which will reduce potential leaching of TCE and uranium.
The interim action will also reduce human health risks estimated for TCE and uranium
exposure through ground water. In addition, the interim action will"provide current and
future protection from direct contact with the buried waste.
2.7
Description of Alternatives
The following paragraphs present a description of the five alternatives evaluated in the
approved Feasibility Study for Solid Waste Management Units 2 and 3 of Waste Area Group
22 at the Paducah Gaseous Diffusion Plant (DOE/OR/06-1246&D2).
Alternative I-No Action
Pursuant to 40 C.F.R. 9 300.430(e)(b) of the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), the DOE is required to consider a no action
alternative. This alternative served as a baseline to which the other alternatives were
compared. Under this alternative, no further action would be taken at SWMU 2.
Since no wastes would be generated, this alternative did not include the use of any
treatment technologies, containment, or storage components. No additional costs were
associated with this alternative. In addition, the dlternative would not provide
compliance with applicable or relevant and appropriate requirements (ARARs), and it
would not reduce risk. A summary of the detailed evaluation of this alternative is
presented in Section 2.8 of this ROD.
Alternative 2-Limited Action
This alternative primarily consisted of institutional controls designed to prevent access
to SWMU 2. The alternative contained three primary components. First, deed
restrictions would be executed to prevent property transfer, inappropriate use of the
property, and any intrusive activities which could expose buried waste materials.
Second, a suitable fence and warning signs would be installed around the unit to
prevent unauthorized entry. Third, the ooE would conduct reviews of the action no less
than once every five years, since contaminants would remain in the unit. Although this
alternative does not include construction of additional piezometers or ground water
monitoring wells, information collected as a result of ground water monitoring activities
at the PGDP would be utilized during the review proceedings.
A minimal volume of wastes would be expected to be generated from implementation of
this alternative. Soils which would potentially be generated during installation of
fencing would not be expected to contain COCs, so the soils would not require any
special handling. However, if the soils were determined to contain a significant
concentration of any COCs following characterization, they would be handled
appropriately and may require treatment, storage, or disposal. Fencing would be erected
to prevent access to an area encompassing approximately 2,973 m2 (32,000 if) or more.
This alternative would not address potential long-term risks to ground water, and
potentially would not comply with ARARs. Estimated costs and a summary of the
detailed evaluation of this alternative are presented in Section 2.8 of this ROD. .
15
-------
Alternative 3-Excavation, Treatment, and StoragelDisposal
This alternative consisted of excavation of the buried wastes, treatment, and
storage/disposal options. The alternative contained three primary components. First,
the buried waste materials and associated contaminated soils would be excavated.
Dewatering, stabilization of pyrophoric uranium, segregation of waste types, and a
temporary storage facility would likely be required. Second, the wastes would require
appropriate treatments to reduce toxicity. Sampling and analysis would be required to
determine if the wastes would be classified as LLW and/or RCRA characteristically
hazardous waste. Any contaminated water collected during dewatering activities would
also require treatment. Third, the wastes would be stored/ disposed in compliance with
regulatory waste management practices. One option ~valuated in this alternative would
include a long-term storage facility at the PGDP. At this time, the PGDP does not have
such a long-term storage facility or the capacity to accept the volume of LLW and/or
RCRA hazardous wastes which would be generated by this alternative. The other
disposal option considered in this alternative would consist of off-site disposal at an
appropriate facility, likely at another DOE facility. .
A significant volume of waste would be generated as a result of this alternative.
Assuming an excavation depth of 5.2 m (17 ft) at SWMU 2 and potentially contaminated
soils which immediately surround the unit, the volume of wastes generated was
estimated to be in excess of 24,000 m3 [31,000 cubic yards (yd3)]. A significant volume of
on-site storage capacity would be required for the wastes expected to be contaminated
with volatile organic compounds and semi-volatile organic compounds, metals,
radionuclides, and possibly PCBs. The wastes could either be treated or disposed at an
appropriate DOE facility. In addition, dewatering would likely be required to conduct
excavation activities. This alternative included construction of a treatment plant onsite to
treat the extracted water. Potential treatment mechanisms included
precipitation/ coagulation, air stripping, ion exchange, and carbon adsorption.
Treatability testing could be required to optimize treatment of wastes and/or extracted
ground water. Appropriate controls would be utilized during the excavation phase to
prevent adverse effects to workers and the surrounding environment. This alternative
would address, or eliminate, long-term risks to the environment and could be conducted
in accordance with ARARs. However, this alternative may not be safe to implement
since it would include excavation of pyrophoric uranium. Estimated costs and a
summary of the detailed evaluation of this alternative are presented in Section 2.8 of this
ROD.
Alternative 4-Low Permeability, Multilayered Cap, Dewatering, Additional
Monitoring and Institutional Controls .
This alternative consisted of construction of a cap, long-term dewatering of the buried
wastes, installation of additional monitoring wells and piezometers, and institutional
controls. The alternative contained four primary components. First, a low permeability,
multilayered cap would be constructed.over SWMU 2 to significantly reduce surface
water infiltration from precipitation events. Three conceptual capping options, which
vary based on the type and number of layers employed, were evaluated in this
alternative. The estimated cost and modeled effectiveness of each of the three capping
options were compared to the estimated cost and modeled effectiveness of a RCRA cap.
Second, a dewatering mechanism would be constructed to provide long-term, or
continuous, dewatering of the buried waste materials. One dewatering option evaluated
in this alternative would consist of approximately sixteen 9.1-m (30-ft) deep extraction
wells/well points placed around the perimeter of SWMU 2. The second dewatering
option evaluated in this alternative would consist of a highly permeable, approximately
16
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I ~
9.1-m (30-ft) deep drainage trench placed around the perimeter of SWMU 2. Since the
drainage trench wnuld be placed under the edges of the cap, construction of the trench
would precede construction of the cap. Treatment of liquids collected by a dewatering
system would require construction of a treatment system. Third, four RGA ground
water monitoring wells and two UCRS piezometers would be installed to monitor
SWMU 2 and the effectiveness of this alternative at mitigating the potential for release of
contaminants by reducing infiltration of precipitation. Fourth, two of the institutional
controls identified in Alternative 2 (deed restrictions and periodic administrative
reviews) would be enacted.
This alternative would generate solid and liquid wastes. A minimal volume of waste
would be generated if well points were installed for long-term dewatering. The volume
of wastes associated with installation of drainage trenches on the north, south, and west
sides of SWMU 2 was estimated to be in excess of 1,350 m3 (1,840 ydJ). The wastes
produced during installation of either dewatering mechanism, piezometers, and ground
water monitoring wells would likely be managed within the operable unit and placed
on SWMU 2 as contour material for a low permeability, multilayered cap. In addition,
dewatering would likely be required during trench construction activities. This
alternative included construction of a treatment plant onsite to treat the extracted water.
Estimates indicated dewatering activities would produce approximately 0.50 liters per
second (7.9 gallons per minute) of potentially contaminated ground water. Potential
treatment mechanisms included precipitation/ coagulation, air stripping, ion exchange,
and carbon adsorption. Treatability testing could be required to optimize treatment of
wastes and/ or extracted ground water. Appropriate controls would be utilized during
the construction phases to prevent adverse effects to workers and the surrounding
environment. This alternative would address long-term risks to ground water and could
be conducted in accordance with ARARs. However, this alternative would require a
significant amount of long-term care in the form of operation and maintenance, and
ground water extraction and treatment. Estimated costs and a summary of the detailed
evaluation of this alternative are presented in Section 2.8 of this ROD.
Alternative 5--Low Permeability, Multilayered Cap, Additional Monitoring, and
Institutional Controls
This alternative consisted of construction of a cap, implementation of a ground water
monitoring program, and institutional controls. The alternative contained three primary
components. First, a low permeability, multilayered cap would be constructed over
SWMU 2 to significantly reduce infiltration of surface water from precipitation events
into the unit. Three conceptual capping options, which vary based on the type and
number of layers employed, were evaluated in this alternative. The estimated cost and
modeled effectiveness of each of the three options were compared to the estimated cost
and modeled effectiveness of a RCRA cap. Second, a ground water monitoring program
would be established in the RGA to detect potential contaminant releases from SWMU 2.
The monitoring program would also evaluate the cap's effect(s) on the shallow ground
water level in the UCRS and fill data gaps. Third, the institutional controls identified in
Alternative 2 (deed restrictions and periodic administrative reviews) would be enacted.
This alternative would generate a relatively minor volume of solid wastes; for ex.ample,
installation of one RGA monitoring well at the PGOP will produce approximately 2.5 mJ
(85 cubic feet) of wastes. These wastes would likely be managed within the operable unit
and placed on SWMU 2 as contour material for a low permeability, multilayered cap.
Appropriate controls would be utilized during the construction phases to prevent
adverse effects to workers and the surrounding environment. This alternative would
reduce risks to ground water and could be conducted in accordance with ARARs.
17
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Estimated costs and a summary of the detailed evaluation of this alternative are
presented in Sectiqn 2.8 of this ROD.
2.8
Summary of the Comparative Analysis of Alternatives
This section provides the basis for determining which alternative: (1) meets the
threshold criteria of overall protection of human health and the environment, and
compliance with ARARs; (2) provides the best balance between effectiveness and
reduction of toxicity, mobility, or volume through treatment, implementability, and cost;
(3) satisfies state and community acceptance; and (4) is consi~tent with the Kentucky
Hazardous Waste Permit. Although the selected remedy is consistent with the permit,
the selection of an interim corrective measure under the permit does" not require the
following comparative analysis of alternatives.
Nine criteria are required by Comprehensive Environmental Response, Compensation
and Liability Act of 1980 (CERCLA) for evaluating the expected performance of
remedial actions. The nine criteria are identified below and the interim action has been
evaluated on the basis of these criteria:
1.
Overall protection of humari 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.
3.
Long-term effectiveness and permanence. This primary balancing criterion
focuses on the magnitude and nature of the risks associated with
untreated waste and/ or treatment residuals remaining at the conclusion
of remedial activities. This criterion includes consideration of the
adequacy and reliability of any associated containment systems and
.institutional controls, such as monitoring and maintenance requirements,
necessary to manage treatment residuals and untreated waste.
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 until protection is
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.
18
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7.
Cost. This primary balancing criterion is used to evaluate the estimated
costs of the alternatives. Expenditures include the capital cost, annual
operation and maintenance (O&M), and the combined net present value
of capital and O&M costs.
8.
State acceptance.
9.
Community Acceptance. This modifying criterion provides for
consideration of any formal comments from the community on the
Proposed Remedial Action Plan.
A summary of the comparative analysis of alternatives is provided in Table 2-2.
Overall Protection of Human Health and the Environment
An alternative must meet this threshold criterion to be eligible for selection. As
discussed in Section 2.6, this interim action is necessary to address risks posed by
SWMU 2. Alternative 1 does not meet this criterion since it does not address the risks at
SWMU 2. Alternative 2 does not meet this criterion because short-term risks associated
with direct contact to contaminants would be mitigated, long-term risks associated with
contamination of ground water would not be addressed. Alternative 3 would meet this
criterion; removal of the contaminants, treatment, and disposal at a secure, permitted
facility would eliminate nearly all risks. Alternative 4 would also meet this criterion;
direct contact would be mitigated, surface water infiltration from precipitation events
would be significantly reduced, and dewatering would ensure the wastes are not in
contact with water in the UCRS and provide protection of the RGA. Similarly,
Alternative 5 would meet this criterion; the cap and institutional controls would
physically and administratively mitigate direct contact, and infiltration of precipitation
would be reduced, while additional data is collected to support evaluation of a final
action.
Compliance with Applicable or Relevant and Appropriate Requirements
An alternative must meet this threshold criterion to be eligible for selection. Alternatives
1 and 2 would not provide compliance with ARARs since risks to ground water would
not be reduced. Alternatives 3, 4, and 5 would provide compliance with ARARs. A
detailed description of ARARs for the selected remedy is presented in Section 2.10 of
this ROD.
Long-Term Effectiveness and Permanence
This criterion is generally not pertinent to measures implemented as interim actions.
However, the selected interim remedial action is expected to prove effective until a final
remedial action is implemented. Alternative 3 would meet this criterion; excavation,
treatment of wastes, and disposal at a secure permitted facility would provide long-term
effectiveness and permanence. Alternative 4 would meet this criterion also; a cap and
continuous dewatering of the unit would provide long-term effectiveness. Alternative 5
also would meet this criterion until a final remedial action is implemented. Based on
leaching model results from the FS, the estimated time it will take for TCE to migrate
from the UCRS to the RGA without the proposed cap is from 35 to 156 years. Placement
of a cap to reduce infiltration into the waste may significantly increase that amount of
time. Uranium would require an even longer period to dissolve and leach to the RGA.
19
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Table 2.2. Comparative Analysis of Alternatives
N
a
Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5
Evaluation Criteria No Action Limited Action Excavation, Treatment, Low permeabili:f; Cap, Low Permeability Cap,
and Storage/Disposal Dewatering, Ad itional Additional Monitoring,
Monitorin~ and and Institutional
Institutional ontrols Controls
Threshold Critena
Overall Protection of No reduction in risk to Short-term, direct All risks mitigated by Direct contact risk Direct contact risk
Human Health and human health or the contact risk mitigated removal of source mitigated by cap and mitigated by cap and
the Environment envirQnment institutional controls institutional controls
Long-term, ground Wastes treated and
water pathway risk not stored/disposed in a Infiltration of Infiltration of into
addressed r.ermitted, secure precipitation into wastes significantly
acility wastes significantly reduced by cap
reduced by cap Risk to ground wate~
Risk to ground water significantly reduce(~
significantly reduced
Dewatering ensures
waste is not in contact
with VCRS water
Comf1.iance with Would not comply with May not comply with Would comply with Would comply with Would comply with
ARA s ARARs ARARs ARARs ARARs ARARs
Prlmarv Balancm2 Criteria
Long-term Source would not be Interim action, however, Source would be Interim action, however, Interim action, however,
Effectiveness and removed or contained; source would not be removed; maximum risk source would not be source would not be
Permanence exist~ng risk will removed or contained; reduction level would removed; some risk removed; some risk
remam existing risk to ground be achieved would remain would remain
water will remain until
final action implemented Wastes would be Source would be Does not address risk
treated and partially contained to posed by wastes which
stored/disposed at reduce some risks until may be In contact with
r,ermitted, secure final action implemented VCRS ground waler
acility(ies) Cap and continuous Source would be
- dewatering would partially contained 10
provide long-term reduce some risks until
effectiveness final action
Some future implemented; limited to
vaaose zone
contaminant migration
would be possiole Ground water
Ground water monitoring program
implemented to detl'Ct
monitoring program anre contaminant
implementea to detect re eases
anre contaminant
re eases
-------
Table 2-2. Comparative Analysis of Alternatives (continued)
N
......
Alternative 1 AlternatIve 2 Alternative 3 Alternative 4 Alternative 5
Evaluation Criteria No Action Limited Action Excavation, Treatment, Low Permeabili:?; Cap, Low Permeability Cap,
and Storage/Disposal Dewatering, Ad itional Additional Monitoring,
Monitorin~ and and Institutional
Institutional ontrols Controls
Pnmary Balancinlt Criteria (continued)
Reduction of Toxicity, No reduction Interim action; no TOXicit~ reduced Mobility reduced as a Some future
Mobility, or Volume reduction throug treahnent result of cap and contaminant migration
through Treatment dewatering would be possilJle
Mobility reduced by
excavation and Toxicity and volume of Interim action, however,
treahnent contaminants in mobility of wastes in
extracted water reduced unsaturated zone
Volume mayor may not through treatment should be reduced to
be reduced through some extent as a result
treahnent of cap
Short-term Short-term risks to Short-term risks to Short-term risks to Short-term risks to Short-term risks to
Effectiveness community, workers, community and community would be community would be community not
-------
Evaluation Criteria
A ternative 1
No Action
f:3
Comparative Analysis of Alternatives (continued)
A ternahve 2 ternahve 3 Alternahve 4
Limited Action Excavation, Treatment, Low Permeability Cap,
and Storage/Disposal Dewatering, Additional
Monitoring, and
Institutional Controls
Table 2-2.
Alternative 5
Low.Permeability Cap,
Additional Monitoring,
and Institutional
Controls
Services are readily
available
Administratively
feasible
Excavation services are
readily available;
treatment services for
some COCs are
available; off-site
disposal is considered
available; on-site
disposal is .
currentl unavailable
Tec nica y easi e
and most services are
readily available;
construction of
drainage trenches (to an
estimated depth of 30
feet) may require
innovative techniques
Administratively
feasible; regulatory
approval required to
deposit excavated soils
ana/or well cuttings on
unit as contour material
for ca
Administratively
feasible; regulatory
approval required to
cfeposit any excavated
soils and / or well
cuttings on unit as
contour material for cap
-------
Table 2-2. Comparative Analysis of Alternatives (continued)
N
W
Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5
Evaluation Criteria No Action Limited Action Excavation, Treatment, Low Permeabili~ Cap, Low Permeability Cap,
and Storage/Disposal Dewatering, Ad itional Additional Monitoring,
Monitorin~ and and Institutional
Institutional on troIs Controls
Primary Balancing Criteria (continued)
Cost No additional costs Capital cost: $215K With on-site disposal With RCRA cap With ReRA cap
1" year O&M: $3,377K Capital cost: $69,579K and well points (for comparison only)
(K = 1,000) Total cost: $5,197K 1" year O&M: $0 Capital cost: $6,319K Capital cost: $3,240K
(Total cost includes 30 1" yearO&M:$1,031K 1" year O&M: $165K
years of 0 & M) PW: $2,591 K Total cost: $508,511 K
(PW = Present Worth PW: $236,650K Total cost: $29,049K Total cost: $8,337K
PW: $16,708K PW: $5,846K
over 30-year period) With off-site disposal
Capital cost: $69,586K With RCRA cap With low permeability
1" year O&M: $0 and drainage trench cap (Cap option 1)
Total cost: $564,311K Capital cost: $4,923K Capital cost: $2,825K
PW: $288,862 K I" year O&M: $1,031 K 1" year O&M: $76K
Total cost: $23,224K Total cost: $5,380K
PW: $13,403K PW: $4,004K
With low permeability With low permeability
cap and drainage trench cap (Cap option 2)
Capital cost: $3,970K Capital cost: $2,946K
1" year O&M: $1,031K 1" year O&M: $7(iK
Total cost: $22,034 K Total cost: $5,531 K
rw: $12,208K rw: $4,114K
With low permeability
cap (Cap option 3)
Capital cost: $2,615K
l"yearO&M: $76K
Total cost: $5,117K
PW: $3,761K
-------
Evaluation Criteria
State Acceptance
Community
Acce tance
tV
tI>-
Alternative 1
No Action
Table 2-2. Comparative Analysis of Alternatives (continued)
A temative 2 A ternahve 3
Limited Action Excavation, Treatment,
and Storage/D,isposal
A ternative 4
Low Permeability Cap,
Dewatering, Additional
Monitoring, and
Institutional Controls
A ternative 5
Low Permeability Cap,
Additional Monitoring,
and Institutional.
Controls
ia action, consistent wit t
-------
!-
This modeling does not account for buried wastes which may potentially be in contact
with water in the UCRS. Alternatives 4 and 5 would allow s~ffi.cient hme to collect
additional data and evaluate a final action. Long-term effectiveness and permanence
will be fully addressed when a final remedial action for SWMU 2 is evaluated and
selected.
Reduction of Contaminant Toxicity, Mobility, or Volume through Treatment
Alternative 3 would meet this criterion; mobility of contaminants would be reduced as a
result of excavation; and toxicity would be reduced through treatment. Alternative 4
would not meet this criterion; although mobility would be significantly reduced as a
result of dewatering. Alternative 5 would not meet this criterion either, although
mobility of contaminants in the unsaturated/vadose zone would be reduced as the cap
reduces infiltration. This criterion will also be addressed when a final action for SWMU
2 is evaluated and selected.
Short-Term Effectiveness
Alternative 3 would not meet this criterion; although appropriate safety measures
would be utilized, excavation of wastes from SWMU 2 (including pyrophoric uranium)
would produce significant risks to workers. Risks to ground water, surface water, and
the environment would also be increased during implementation of Alternative 3.
Alternative 4 would likely meet this criterion; utilization of appropriate safety measures
during trench and cap installation should prevent significant risks to workers and the
environment. Alternative 5 would meet this criterion; utilization of appropriate safety
measures and best management practices (BMPs) would mitigate risks to workers and
the environment during construction of the cap and installation of the monitoring wells
and piezometers. None of the five alternatives would present significant risks to a
nearby community.
Implementability
Alternative 3 would be implementable; although it is technically and administratively
feasible, significant health and safety concerns exist. Alternative 4 would be feasible;
innovation would be required to efficiently construct the drainage trenches to the
proposed depth of 9.2 m (30 ft). Alternative 5 is readily implementable; it is technically
and administratively feasible and the services required for implementation are readily
available from a number of vendors/ suppliers.
Cost
Estimated capital, 3D-year O&M, and 30-year present worth costs for each alternative,
including the options considered for the third, fourth, and fifth alternatives, are
presented in Table 2-2.
State Acceptance
This. interim remedial action will be initiated pursuant to the Interim Measure
provisions of PGDP's Kentucky Hazardous Waste Management Permit issued by the
KDEP. An RI Addendum, FS, and Proposed Remedial Action Plan, have been approved
by the KDEP and the EP A. The KDEP concurs with this interim remedial action,
consistent with the requirements of the Hazardous Waste Management Permit.
25
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Community Acceptance
As indicated in Part 3 of this ROD, the Responsiveness Summary, no groups or
organizations opposed this interim remedial action. .
. 2.9
Selected Remedy'
Based upon the evaluation of the alternatives utilizing the nine CERCLA criteria, the
remedy which best meets the threshold, balancing, and modifying criteria for the scope
and objectives of this interim action is Alternative 5. This alternative has been refined
through a series of negotiations and meetings between the DOE, the EP A, and the KDEP
from that presented in the approved FS. The modifications presented in the selected
remedy will allow greater flexibility, expedited field investigation activities, and
promote an incremental approach to implementation of the interim remedial action. The
DOE will prepare a detailed design for this interim remedial action in accordance with
the requirements specified in the Declaration of this ROD. The remedial design and
remedial action phase activities for the interim action will be finalized following
completion of additional investigative activities planned for SWMV 2. A schedule of
remedial design activities is presented in the appendix of this ROD.
The selected remedy will consist of the following elements, at a minimum:
.
A low permeability, multilayered cap constructed over the areal limits of SWMU 2. The
cap will be designed to direct rainfall away from the unit and inhibit infiltration
of precipitation into the unit. The cap will also serve as a physical barrier to
inhibit direct contact with buried waste materials and soil contamination. The
conceptual capping option may consist of compacted soil as contour material, a
geosynthetic day liner, a geomembrane liner, and a drainage layer with a
vegetative soil cover.
.
A ground water monitoring program implemented in the uppermost aquifer, the RGA, to
detect the potential release of contaminants from SWMU 2. The monitoring program
will also evaluate the cap's effect(s) on the shallow ground water level in the
VCRS and fill data gaps. Any waste soil generated during sampling and
remedial action activities will be managed within the limits of SWMV 2 and
placed on the unit as contour material for the cap. All other wastes [such as
personal protective equipment (PPE)) will be initially containerized and
managed at the PGDP in accordance with approved protocols.
Institutional controls implemented to further prevent access to SWMU 2. Deed
restrictions may be utilized to ensure the DOE retains ownership of the property
which SWMV 2 encompasses. Deed restrictions also may prevent future uses of
the property which could result in the spread of contamination, such as installing
wells or excavating. Since contaminants will remain in the unit following this
interim remedial action, the DOE will conduct administrative reviews of the
action and monitoring data no less than once every five years, at least until a
final remedial action has been selected and/ or implemented for SWMU 2.
.
This action will provide overall protection of human health and the environment. It also
can be implemented in compliance with ARARs. This interim action will provide
effectiveness until a final remedy is enacted at SWMV 2. Although treatment will not be
employed, contaminant mobility will be reduced as a result of reduced infiltration. This
alternative will provide short-term effectiveness and may be readily implemented. As
26
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shown in Table 2-3, the total estimated cost for this alternative and cap option is
55,117,000 (present value of $3,761,000).
Table 2-3. Cost Estimates for Interim Action
Direct Costs
Indirect Costs
Total Capital Costs'
51,184 K
$1,431 K
52,615 K
O&M Costs' Year 1
O&M Costs Years 2-30
5- Year Review Costs
Total O&M Costs
$76K
51,350 K
$54 K
51,480 K
Total Contingencyb
$1,022 K
Total CostC
$5,117 K
Present Valued
$3,761 K
K=l,OOO
a - Capital costs for cap only; monitoring well and piezometer capital costs
incorporated into first year O&M.
b - Total contingency is conclusive of direct, indirect, and all O&M costs
associated contingencies.
c - Cost estimates intended to be consistent with EP A guidance which
recommends a +50% to -30% level of accuracy.
d - Present value estimates based on a 30-year time span with a 7% discount
rate.
2.10
Statutory Determinations
This interim action is protective of human health and the environment; complies with
CERCLA [as amended by Superfund Amendments and Reauthorization Act of 1986
(SARA)], statutory requirements of K.R.S. 224.46-530 and federal and state ARARs
directly associated with this action; and is cost effective. This action uses permanent
solutions to the maximum extent practicable, given the limited scope of the action.
Because this action does not constitute the final remedy for SWMU 2, the statutory
preference for remedies employing treatment that reduces toxicity, mobility, or volume
through treatment as principal elements will be addressed at the time of selection of the
final r~sponse action. Subsequent actions are planned to fully address the principal
threats posed by SWMU 2.
Overall Protection of Human Health and the Environment
The selected interim action contributes to protection of human health for the PGDP
employees and the public through institutional controls to limit the potential for direct
exposure and engineering controls to mitigate the infiltration and migration of
27
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contaminants from SWMU 2 until a final action is selected and implemented. The
remedy provides effective management of all residual wastes generJted during
implementation of the action.
Applicable or Relevant and Appropriate Requirements
Congress specified in Section 121 of CERCLA that remedial actions for cleanup of
hazardous substances must comply with requirements, criteria, standards, or limitations
under federal or more stringent state environmental laws that are applicable or relevant
and appropriate to the hazardous substances or circumstances at a site. Inherent in the
interpretation of ARARs is the assumption that protection of human health and the
environment is ensured.
The following is an explanation of the terms used throughout this section:
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 CF.R. ~ 300.5).
Relevant and appropriate 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, while not applicable to
a hazardous substance, pollutant, 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 CF.R. ~ 300.5).
Chemical-specific requirements are usually "health- or risk-based numerical values or
methodologies which, wherl applied to site-specific conditions, result in the
establishment of numerical values" (53 Fed. Reg. 51437, 1988). These values establish the
acceptable amount or concentration of a chemical that may remain in, or be discharged
to, the ambient environment.
Location-specific requirements "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, 1988). Some examples of ~pecial locations include
floodplains, wetlands, historic places, and sensitive ecosystems or habitats.
Action-specific requirements are usually IItechnology- or activity-based requirements or
limitations 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,
1988). Selection of a particular remedial action at a site will invoke the appropriate
action-specific ARARs that may specify particular performance standards or
technologies, as well as specific environmental levels for discharged or residual
chemicals. .
The CERCLA requires that the RCRA and other environmental laws be evaluated as
ARARs [42 U.S. CA. ~ 9621 (d)(2)(A)" and 40 CF.R. ~ 300.430(f)(1)(i)(A)]. This in no way
limits, takes away, or negates the ~DEP's RCRA authority at the PGDP.
Requirements under federal or state law may be either applicable or relevant and
appropriate to CERCLA cleanup actions, but not both. However, if a requirement is not
28
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applicable it must be both relevant and appropriate for compliance to be necessary. In
the 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, CERCLA ~ 121(d)(4) provides several ARAR waiver options that may be
invoked, providing that the primary requirement for protection of human health and the
environment is met. .
Pursuant to CERCLA ~ 121(e), remedial actions under CERCLA conducted entirelv
onsite (as defined in 40 CF.R. ~ 300.5) must comply with the substantive provisions ~f
laws and regulations, but are exempt from the procedural or administrative
requirements [42 USCA. ~ 962(e)(1)]. In order to ensure that CERCLA response actions
proceed as rapidly as possible, the EPA has affirmed its position on permit and
administrative exemptions in the final NCP (40 CF.R. ~ 300). Substantive requirements
pertain directly to the actions or conditions at a site, while administrative requirements
facilitate their implementation (e.g., permit applications and procedural requirements).
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 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 (55 Fed. Reg. 8745, 1990). Criteria or
guidance developed by the EP A, other federal agencies, or states may assist in
determining, for example, health-based levels for a particular contaminant or the
appropriate method for conducting an action for which there are no ARARs. This other
information is to be considered (TBC) guidance and may be used when developing
CERCLA remedies. The TBC guidance generally falls within three categories: (1) health
effects information; (2) technical information on how to perform or evaluate
investigations or response actions; and (3) policy.
Response actions under the NCP will comply with the provisions for response action
worker safety and health in 29 CF.R. ~ 1910.120 (40 C.F.R. ~ 300.150). These regulations
are designed to protect the safety and health of workers; however, they are not
considered ARARs. Requirements, standards, and regulations of the Occupational
Safety and Health Act of 1970 (29 USC ~ 651 et seq.) and of state laws, not directly
referenced in Section 300.150 of the NCP must also be complied with where pertinent.
Federal Occupational Safety and Health Administration requirements include, among
other things, construction standards, general industry standards, and general duty
requirements (40 CF.R. ~ 300.150). In addition, Section 300.150 of the NCP specifies that
all government agencies and private employers are directly responsible for the health
and safety of their own employees.
The DOE, in DOE Order 5480.4, Environmental Safety and Health Standards, establishes
requirements for mandatory environmental protection, safety, and health standards for
all DOE and DOE contractor operations while providing a list of references and sources
of Environmental Safety and Health standards. This is an internal standard for the
protection of workers within the DOE and is not an ARAR. The DOE Order should be
followed during design, construction, operation, modification and decommissioning.
In addition to establishing general occupational protection standards, the DOE
establishes standards for occupational radiation protection of workers at its facilities in
10 CF.R. ~ 835. Pursuant to this regulation, exposure of general employees resulting
from the DOE activities, other than planned special exposure or emergency exposure
situations, shall be controlled so the following annual dose limits are not exceeded: total
29
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effective dose equivalent of 5 rerns; the sum of the deep dose equivalent for external
exposures and the committed dose to any organ or tissue other that the lens of the eye of
50 rems; a lens of the eye dose equivalent of 15 rems; and a shallow dose equivalent of
50 rerns to the skin or to any extremity. Again, DOE Orders pertaining to worker
protection are internal standards and are not ARARs.
Potential chemical-, location-, and action-specific requirements which exist for this
interim action are described in the following paragraphs.
Chemical-specific applicable or relevant and appropriate requirements
Radiation Protection of the Public and the Environment, DOE Order 5400.5, limits radiation
exposure to members of the public to an effective dose equivalent of less than 100
millirE!rns/year (mrem/yr) from all exposure modes and a dose of less than 5 mrem/yr
to any organ. The Order regulates exposure of the public as a consequence of all the
DOE activities, including routine activities, remedial actions, and naturally occurring
radionuclides released by the DOE processes and operations. In addition, this Order
mandates that the OOE personnel and contractors shall strive to ensure that radiation
doses to members of the public are as low as reasonably achievable below the
appropriate limits. The OOE Order 5400.5 is TBC guidance for the radioactive waste that
. is left in place at SWMU 2. However, this Order is expected to be promulgated in the
Code of Federal Regulations (CF.R.) in August 1995 and will become an applicable
requirement for the PGDP upon promulgation. ..
On-site activities involved with construction of the cap such as site grading and
smoothing, earthmoving, and material stockpiles (Le., clay, soil, etc.) will produce
airborne pollutants. It is not expected that any radionuclide emissions will result from
. the site preparation of SWMU 2. However, if radionuclide emissions were to occur,
emission standards for DOE facilities would apply. The regulations promulgated
pursuant to the Clean Air Act of 1970 (CAA) set emission standards for radionuclides
other than radon from the OOE facilities. The OOE is required to ensure that emissiQns
from its facilities shall not exceed those amounts that would cause any member of the
public to receive, in any year, an effective dose equivalent Qf 10 mrem/yr (40 CF.R. 9
61.92). The regulations in 40 CF.R. 9 61.92 are applicable requirements to OOE facilities.
Also, Radiation Protection of the Public and the. Environment, DOE Order 5400.5, and
Radioactive Waste Management, OOE Order 5820.2A, which are TBC Guidance, refer to
the CAA for emission level standards for radionuclides. .
Location-specific applicable or relevant and appropriate requirements
No wetlands haVE! been identified in the area of the proposed action. However, potential
wetlands have been identified in adjacent drainage ditches. These ditches run east and
west parallel to Virginia Avenue, and north and south parallel to the access road east of
SWMU 3. Final wetland determination for these areas was not possible due to health
and safety restrictions denying access to any ditches located on the PGDP.
Consequently, for the purposes of this section, these areas are considered to be wetlands.
Therefore, location-specific ARARs pertaining to wetlands are included in the event
these areas are identified as wetlands in the future. Also, a functions and values analysis
of these wetlands was completed to assess these areas in their present condition for
possible ARAR purposes should they be identified as wetlands in the future.
Although all ARARs discussed in this section are applicable, they will be met by
avoidance of the resources. However, if impacts become apparent, due to construction
or other plan modifications, additional requirements (e.g., final wetland determination
30
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and meeting ARARs) will need to be addressed and/or initiated to comply with the
ARARs.
Construction of the cap must avoid or minimize adverse impacts on wetlands and act to
preserve and enhance their natural and beneficial values [Executive Order 11990, 40
CF.R. ~ 6.302(a), 40 CF.R. Part 6; Appendix A, and 10 CF.R. Part 1022].
Construction in wetlands should be avoided unless there are no practicable alternatives
[40 CF.R. ~ 6.302(a)]. Degradation or destruction of wetlands must be avoided to the
extent possible [40 CF.R. ~ 230.10 and 33 USCA. ~ 1344(b)(1)]. Considerations about
protection of wetlands must be incorporated into planning, regulating, and decision-
making [10 CF.R. ~ 1022.3(b)]. Any action involving the discharge of dredged or fill
material into wetlands must be avoided to the extent possible (33 USCA. ~ 1344, 40
CF.R. Part 230, and 33 CF.R. Parts 320 to 330).
Discharges of dredged or fill material for which there are practicable alternatives with
fewer adverse impacts, or those which would cause or contribute to significant
degradation, are prohibited [40 CF.R. 9 230.1O(a)]. Discharges are also prohibited unless
there are no practicable alternatives, and practicable, appropriate mitigation methods
are available [40 CF.R. 9 230.10(d)]. Further, 40 CF.R. 9 230.10(b) prohibits discharges
that cause or contribute to violations of state water quality standards, violate toxic
effluent standards or discharge prohibitions (33 US.CA. 9 1317), or jeopardize
threatened or endangered species or their critical habitat under the Endangered Species
Act (16 USCA. ~ 1531, et seq.). If it becomes apparent that impacts to wetlands are
unavoidable, due to construction plans or other modifications, the specific requirements
of 33 CF.R. 9 330 (nationwide permits), or 33 CF.R. 9 325 (processing of general
permits), and statutes governing discharges of dredged or fill material into waters of the
United States would become applicable.
Action-specific applicable or relevant and appropriate requirements
On-site construction activities involved with the construction of the cap, such as site
grading and smoothing, earthmoving, and material stockpiles (i.e., clay, soil, etc.) will
produce airborne pollutants. Although SWMU 2 is well within the DOE property
boundary, precautions must be taken to prevent particulate emission levels caused by
construction activities from exceeding the Kentucky Air Quality regulations found in
401 K.A.R. 63:010 et seq. The Kentucky Air Quality regulations contain general standards
of performance governing fugitive dust emissions (401 KA.R. 63:010 et seq.). Most roads
leading to SWMU 2 are asphalt or concrete and traffic would not create dust; however,
in the event that roads made of dirt or gravel were used, the regulations in 401 KA.R.
63:010 9 3(1) require the use of water or chemicals, if possible, and/ or placement of
asphalt or concrete on roads and material stockpiles to control dust. Visible fugitive dust
must not be discharged beyond the property line of where the dust originated [401
K.A.R. 63:010 9 3(2)]. Additionally, all open bodied trucks which operate outside the
property boundary and which may emit materials that could be airborne must be
covered [401 KA.R. 63:010 9 3(4)]. This regulation would be applicable.
Storm water discharges from construction activities onsite at the PGDP will be regulated
by the KrDES Permit (KY00004049) established pursuant to 401 KA.R. 5:055. Remedial
activities will generate storm water runoff from SWMU 2 into Outfall 015 which is
regulated by the KPDES Permit. The PGDP is exempted from the Kentucky General
Permit for Storm Water Point Sources (KYR 100000) under 401 K.A.R. 5:055 because it
has an individual KPDES Permit. Pursuant to 401 K.A.R. 5:055, the PGDP's KPDES
31
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Permit specifies that BMPs and sediment and erosion controls be implemented at a site
to control stormwater runoff. "
The interim remedial action may involve the installation of monitoring wells which are
regulated under 401 KA.R. 6:310 S 13. Under this regulation, monitoring wells must be
installed to maintain existing natural protection against the introduction o( pollutants
into aquifers and to prevent the entry of pollutants through the borehole [401 KA.R.
6:310913(2)]. In addition, the well shall be constructed to prevent the intermingling of
ground water from different aquifers [401 KA.R. 6:310913(2)].
Pursuant to 401 KA.R. 6:310 S 13, the appropriate materials for the purpose of the well
shall be used during the construction of mohitoring wells. In order to prevent pollution
of the ground water samples, 'the annular space above the sampling depth shall be
sealed with a suitable material, such as cement grout or bentonite [401 KA.R. 6:3109
13(3)]. Also, the well shall be completed at least four inches above the ground level or
have a waterproof flush mount device capable of preventing surface water runoff,
pollutants and contaminants from entering the well [401 KA.R. 6:310 913(3)]. The well
shall also have a locking cap within 30 days of its construction [401 KA.R. 6:3109 13(3)].
Lastly, monitoring wells must be properly abandoned within 30 days of the last
sampling" date or upon the determination that the well is found to be inadequate
[401 K.A.R. 6:310 S 13(6)]. The Kentucky regulations for monitoring well construction are
applicable to the well installation involved with this interim remedial action.
This interim remedial action will generate a minimal amount of waste. The waste
generated from the installation of the two piezometers and ground water monitoring
wells will likely be managed within the operable unit and placed on SWMU 2 as part of
the low permeability, multilayered cap. However, there is a remote possibility that PPE
worn by workers during site preparation and construction activities would be
determined to be hazardous or radioactively contaminated waste. The remaining
ARARs in this section will only apply in the event that PPE is determined to be RCRA
hazardous or in the event that soil is not managed inside of SWMU 2 and is determined
to be RCRA hazardous.
Although the waste will be left in place and capped, there may be excess soil and PPE
from site grading and smoothing and from well installation that will need to be
managed and ultimately disposed. Regardless of the amount, the excess waste will be
stored in accordance with applicable ARARs. The PPE and any soil not placed in the cap
will be characterized to determine if the waste is RCRA hazardous 401 KA.R. 34:020 9 4
and/ or radioactive. If the excess material is hazardous, then it will be containerized and
stored onsite or shipped offsite for treatment or disposal. "
Pursuant to 401 KA.R. 32:030 9 5, on-site accumulation of hazardous waste may occur
for 90 days or less without being placed in a RCRA permitted storage area, if the waste
is placed in containers that comply with 401 KA.R. 35:180. The regulation requires that
containers holding the waste be in good condition (401 KA.R. 35:180 9 2). Also, the
waste must be stored in containers lined with materials that are compatible (401 KA.R.
35:180 9 3). Furthermore, containers must be managed to ensure that: the containers are
always closed during storage, except when necessary to add or remove .waste;
containers are not opened, handled, or stored in any manner which may rupture the
container or cause it to leak; and the containers are labeled with the notation
"Hazardous Waste" and the date upon which the accumulation began (401 KA.R.
" 35:18094). Also, inspections must be conducted at least weekly to determine if there are
leaks or deterioration of the containers (401 KA.R. 35:180 9 5). These selected
requirements in 401 KA.R. 35:180 are applicable to the management of hazardous waste
32
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i
I
I
I
i
i
1-
stored onsite for less than 90 days if any RCRA hazardous waste is derived from this
action.
Only a remote possibility exists that excess soils and PPE would be contaminated with
ignitable, reactive, or incompatible waste that would need to be managed. If such wastes
are excavated during this remedial action, special precautions must be taken when
managing ignitable, reactive, or incompatible wastes. Containers holding ignitable or
reactive waste must be located at least 15 m (49 ft) from the facility's property line (401
KA.R. 35:180 ~ 6). In addition, potentially incompatible wastes (as defined in 401 KA.R.
35:030) must not be placed in the same container or be placed in an unwashed container
that previously held an incompatible waste, unless there is compliance with 401 KA.R.
35:020 ~ 8 (2) [401 KA.R. 35:180 ~ 7(1)-(2)]. Lastly, a container holding hazardous waste
that is incompatible with any waste or other materials stored nearby must be separated
from the other materials by means of a dike, berm, wall, or other device [401 KA.R.
35:180 ~ 7(3)]. These requirements apply when ignitable, reactive, or incompatible waste
is stored onsite for less than 90 days.
If waste is accumulated onsite for more than 90 days, it will be stored in a permitted
facility and the requirements in 401 KA.R. Chapter 34 and the permit requirements in
Chapter 38 would apply. However, on-site accumulation of as much as 55 gal of
hazardous waste or one quart of acutely hazardous waste may occur for more than 90
days, provided ~~ 2, 3, and 4(1) of 401 KA.R. 35:180 are followed and the containers are
marked with the notation "Hazardous Waste" [401 KA.R. 32:030 ~ 5(3)(a)]. These
requirements are applicable to on-site storage of hazardous waste for more than 90 days.
Rndioactive Waste Management, DOE Order 5820.2A, establishes policies, guidelines, and
requirements by which the DOE manages its radioactive and mixed waste and
contaminated facilities. The Order ensures that radioactive and mixed wastes shall be
managed in a manner which protects the health and safety of the public, DOE
employees, contractor employees, and the environment. This Order requires a standard
that assures that external exposure to the waste and concentrations of radioactive
material which may be released into surface water, ground water, soil, plants, and
animals results in an effective dose equivalent that does not exceed 25 mrem/yr to any
member of the public. If excess soils and PPE derived from the installation of the low
permeability cap and monitoring wells are determined to be radioactively contaminated
or mixed waste, this Order would be TBC guidance for the management of those
materials. The external exposure limits of this Order would be TBC guidance for the
radioactive waste left in place.
The DOE Order 5820.2A applies to the management of LLW and the design, operational,
and monitoring requirements for disposal of solid LLW containing no RCRA-regulated
materials. The Order specifies that waste must not be pyrophoric. Pyrophoric materials
contained in waste shall be treated, prepared, and packaged to be nonflammable. While
there is only the slightest possibility that pyrophoric material will be excavated for well
installation, the DOE Order 5820.2A would be TBC guidance were such material
encountered.
Contaminated PPE from site preparation activities or any soil not placed atop SWMU 2
may be determined to be RCRA land disposal restricted. Pursuant to 401 KA.R. 37:050
and 40 CF.R. ~ 268.50, the storage of hazardous wastes restricted from land disposal
under 401 KA.R. 37:030 is prohibited, unless the generator stores such wastes in tanks,
containers, or containment buildings onsite solely for the purpose of accumulating such
quantities of hazardous waste as necessary to facilitate proper recovery, treatment, or
disposal. Such storage must be in compliance with the requirements in 401 KA.R. 32:030
33
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~ 5 and 401 KA.R. Chapter 34. Furthermore, each container must be clearly marked with
the identification of its contents, the date each accumulation period began, and the
quantity of each hazardous waste (401'KA.R. 37:050). These regulations apply to the
management of hazar~ous wastes prohibited from land disposal that are stored onsite.
The PGDP has a Part B Permit which abides ~y these standards.
Movement of residuals containing RCRA characteristically hazardous waste and / or
mixed waste that are land-disposal restricted outside of SWMU 2 may trigger the land
disposal restrictions (LDRs) documented in 401 KA.R. 37:030. The DOE and the EPA
entered into a Federal Facility Compliance Agreement (FFCA) Docket No. 92-03-FFR on
June 30, 1992, to allow for the continued storage of radioactive mixed waste containing
an LDR-prohibited hazardous waste component while treatment capacity is being
developed. The FFCA governs all wastes generated at the PGOP. The LOR requirements
will only apply to restricted waste not managed within SWMU 2. In the unlikely event
LDR waste is generated from this interim action and managed outside SWMU 2, the
waste will be subject to and managed consistent with the FFCA.
A summary of ARARs for this remedial action is presented in Table 2-4.
Cost Effectiveness
This interim remedial action employs a remedy which provides overall effectiveness to
prevent further spread of contamination while being proportional to its cost. The action
represents the least expensive alternative to reduce surface water infiltration from
precipitation and future migration of the contaminants while a final remedy is being
devised. Compared to other cap options, such as the RCRA cap, this particular cap is the
most cost effective.
Utilization of Permanent Solutions and Alternative Treatment Technologies
The objectives for this interim action are to stabilize the site by instituting the cap to
reduce infiltration of leachate through unsaturated waste and to delay the potential
breakthrough of uranium to the RGA. With the use of institutional controls, this
remedial action should protect human health and the environment. However, since 'the
waste is left in place, the interim remedial action does not fully address the principal
threats to human health and the environment posed by this unit. Therefore, the principal
threats posed by the current conditions will be fully addressed when a final action for
SWMU 2 is evaluated and selected. .
Reduction of Toxicity, Mobility, or Volume through Treatment
This remedial action is expected to reduce the mobility of unsaturated wastes at the unit.
The volume of water infiltrating through the unit will be significantly reduced as a result
of the multilayered cap. Since the waste is not treated or removed, neither the toxicity
nor the volume of the waste left in place will be reduced under this interim remedial
action. This criterion will be addressed fully when a final action for SWMU is evaluated
and selected.
34
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Table 2-4. Applicable or Relevant and Appropriate Requirements
and To Be Considered Guidance for the Interim Remedial Action
Actions
Requirements
Prerequisites
Federa I
Citation
Title 401
K.A.R.,
Citation
CHEMICAL-SPECIFIC
Protection of the general
public from aU sources of
radiation
VJ
(J1
Emission Standards
General public must not receive an effec-
tive dose equivalent greater than 100
mrem/yr or 5 mrem/yr to any organ from
all exposure modes.
All releases of radioactive material
must be ALARA.
Emissions from DOE facilities shall not
cause members of the public to receive,
in any year, an effective dose equiva-
lent of 10 mrem/yr.
Dose received by the general
public from all sources of ra-
diation exposure at a DOE fa-
ciity - TBC guidance for the
waste left in place
Release of radioactive ma te-
rial from all DOE activities -
TBC guidance for the waste
left in place
Emissions of radionuclides
other than radon from DOE
facilities - applicable if con-
struction activities at the site
produce airborne pollutants -
DOE Orders 5820.24A and DOE
Order 5400.5 would also be TBC
guidance for this requirement
DOE Order
5400.5
DOE Order
5400.5
40 C.F.R.
9 61.92
-------
Table 2-4. Applicable or Relevant and Appropriate Requirements
and To Be Considered Guidance for the Interim Remedial Action (continued)
Actions
Requirements
Prerequisites
Federal
Citation
Title 401
K.A.R.,
Citation
tOCA nON-SPECIFIC
Protection of wetlands
v.>
0\
Avoid or minimize adverse impacts m
wetlands to preserve and enhance their
natural and beneficial values.
Avoid degradation or destruction of wet-
lands to the extent possible.
Incorporate considerations about protec-
tion of wetlands into planning, regulat-
ing, and decisionmaking.
Any federal action that wi!!
have an impact on wetlands - ap-
plicable if avoidance is not ac-
complished
Any action involving discharge of
dredged or fill material into wet-
lands - applicable if avoidance is
not accomplished
Any federal. action that will
have an impact on wetlands - ap-
plicable if avoidance is not ac-
complished
10 CF.R.
~ 1022;
Executive Or-
der 11990; 40
C.F.R. ~ 6:302
(a)
40 CF.R.
~ 230.10;
33 U.S.c.A.
~ 1344 (b)(1) .
10 CF.R.
~ 1022.3(b)
-------
Table 2-4. Applicable or Relevant and Appropriate Requirements
and To Be Considered Guidance for the Interim Remedial Action (continued)
Actions
Requirements
Prerequisites
Federal
Citation
Title 401
K.A.R.,
. Citation
Discharge of dredged or
fill material into waters of
the United States
W
'-J
Discharges for which there are practi-
cable alternatives with fewer adverse
impacts or those which would cause or
contribute to significant degradation are
prohibited.
Significant degradation is also prohib-
ited unless there are practicable alterna-
tives and practicable, appropriate miti-
gation methods are available.
Discharges which cause or contribute to
violations of state water quality stan-
dards, violate toxic effluent standards or
discharge prohibitions, or jeopardize
threatened and endangered species under
the Endangered Secies Act.
Unavoidable discharges can be permit-
ted with a general or nationwide Section
404 Permit.
Any action involving discharge of
dredged or fill material into wet-
lands - applicable if avoidance is
not accomplished
Any action involving discharge of
dredged or fill material into wet-
lands - applicable if avoidance is
not accomplished
Any action involving discharge of
dredged or fill material into wet-
lands - applicable if avoidance is
not accomplished
Any action involving discharge of
dredged or fill material into wet-
lands - applicable if avoidance is
not accomplished
40 CF.R
9 230.10(a)
40 CF.R
9230.1O(d)
40 CF.R
9230.10(b);
33 U.S.CA.
S 1317;
16 U.s.CA.
S 1531
33 USC1\.
1344;
33 CF.R
S 330;
33 CF.R
9325
-------
Table 2-4. Applicable or Relevant and Appropriate Requirements
and To Be Considered Guidance for the Interim Remedial Action (continued)
Actions
Requirements
Prerequisites
Federal
Citation
Title 401
K.A.R.,
Citation
ACTION-SPECIFIC
Site preparation
CJJ
00
Surface water control
Although SWMU 2 is well within the
plant boundary, precautions must be
taken to prevent particulate matter
from becoming airborne.
A responsible party J?:1ust:
.
Use water or chemicals to control
dust from construction activities
and place asphalt, oil, water, or
suitable chemicals en roads and
material stockpiles to control dust;
.
Ensure that no visible fugitive
dust is emitted beyond the prop-
erty line; and
.
Ensure that all . open bodied trucks
are covered if any materials in
truck could become airborne.
Implement good site planning and best
management practices to control storm
water discharge; comply with storm
water runoff requirements of KPOES
Permit KY0004049.
~,
Handling, processing, construc-
tion, road grading, stockpiles,
and land clearing activities -
applicable if it is determined
that airborne dust will reach the
plant fence
Construction activities at indus-
trial sites where storm water run-
off would occur - applicable
63:010 ~ 3
63:010 ~ 3 (l)(a);
63:010 ~ 3 (1)(b)
. 63:010 9 3(2)
63:010 ~ 4(1)
5:055
-------
Table 2-4. Applicable or Relevant and Appropriate Requirements
and To Be Considered Guidance for the Interim Remedial Action (continued)
Actions
Requirements
Prerequisites
Federal
Citation
Title 401
K.A.R.,
Citation
Well installation
(;J
\D
Waste management *
Wells must be installed to:
.
Maintain the existing natural pro-
tection against pollutants into the
aquifer;
.
Prevent the entry of pollutants
through the bore-hole; and
.
Prevent the intermingling of
ground water from different aqui-
fers.
Certain construction requirements shall
be followed, such as:
.
The annular space shall be sealed
with cement grout or bentonite;
.
Completed at least 4 inches above
the ground or have a waterproof
mount device; and
.
Have a locking well cap within 30
days of its construction.
Wells should be properly abandoned
within 30 days of the last sampling
date or the determination is made t hat
the well is unsuitable for use as a moni-
toring well.
Generators of waste shall determine if
it is RCRA hazardous.
Construction or modification of a
monitoring well - applicable
Construction or modification of a
monitoring well - applicable
Generation of waste material
- applicable
40 C.F.R.
9 262.11
6:310 9 13(2)
6:310 9 13(2)
6:3109 13(2)
6:310 9 13(3)
6:310 9 13(3)
6:310913(3)
6:310 9 13(6)
32:010 9 2
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Table 2-4. Applicable or Relevant and Appropriate Requirements
and To Be Considered Guidance for the Interim Remedial Actio.n (continued)
Actions
Requirements
Prereq uisites
Federal
Citation
Title 401
K.A.R.,
Citation
Container storage (onsite) Containers of hazardous waste must be:
- for less than 90 days ,.
.
Maintained in good condition;
.
Compatible with
waste to be stored; and
hazardous
.
Closed during storage (except to
add or remove waste).
~
Containers must not be handled, opened,
or stored in any manner which may rup-
ture the container or cause it to leak.
Inspections must be . conducted at least
weekly to determine leaks or deteriora-
tion.
Containers must be labeled with the
notation "Hazardous Waste."
Storage of RCRA hazardous
waste (listed or characteristic)
not meeting small quantity gen-
erator criteria held for a tempo-
rary period before treatment,
disposal, or storage elsewhere, in
a container (Le., any portable
device in which a material is
stored, transported, disposed, or
handled). A generator who ac-
cumulates or stores hazardous
waste onsite for 90 days or less in
compliance with 40 CF.R. 9
262.34 (a}(1-4) is not subject to
RCRA interim or final status
storage requirements - applicable
to any excavated soil and PPE
identified as RCRA hazardous
waste
40 CF.R.
9265.171
40 CF.R.
9265.172
40 CF.R.
9 265.173(a}
.40 CF.R.
9 265.173(b}
40 CF.R.
9265.174
35:180 9 2
35:18093
35:18094(1}
35:180 9 4(2}
35:18095
35:180 9 4(3}
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Table 2-4. Applicable or Relevant and Appropriate Requirements
and To Be Considered Guidance for the Interim Remedial Action (continued)
Actions
Requirements
Prereq uisites
Federal
Citation
Title 401
K.A.R.,
Citation
Container storage (onsite)
of ignitable, reactive or
incompatible waste for
less than 90 days. *
~
>-'
Containers holding hazardous
must be managed so that:
waste
.
Containers are located at least 15
meters from the property bound-
ary; and
.
Incompatible waste are not placed
in the same container or placed in
an unwashed container that pre-
viously held an incompatible
waste.
Management of ignitable, reac-
tive or incompatible waste - ap-
plicable if any excavated soil or
PPE is determined to be ignit-
able, reactive, or incompatible
waste
40 CF.R.
9 265.176
40 CF.R.
9265.177(a)
40 CF.R.
9265.177(b)
35:18096
35:18097(1)
35:18097(2)
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Table 2-4. Applicable or Relevant and Appropriate Requirements
and To Be Considered Guidance for the Interim Remedial Action (continued)
Actions
Requirements
Prerequisites
Federal
Citation
Title 401
K.A.R.,
.. Citation
Waste management ..
~
Must follow the RCRA permit for on-
site storage more than 90 days.
Hazardous waste may be accumulated
for more than 90 days for as much as 55
gallons of hazardous waste or one quart
of acutely hazardous waste.
Radioactive and mixed waste shall be
managed in a manner which assures the
health and safety of the public, the
DOE, contractor employees, and the
environment.
External exposure to the waste and con-
centrations of radioactive material
which may be released into surface wa-
ter, ground water, soil, plants, and ani-
mals shall not result in. an effective dose
equivalent that exceeds 25 mrem/yr to
any member of the public.
Pyrophoric materials contained in
waste shall be treated, prepared, and
packaged to be nonflammable.
Movement of residuals containing RCRA
characteristic waste and radionuclides
to another unit will trigger LDRs.
Storage of hazardous waste in
RCRA permitted storage area
Accumulation
waste
of
hazardous
Management of. LLW - TBC
Guidance if excavated soil and
PPE is determined to be radioac-
tively contaminated
Management of LLW - TBC
Guidance if excavated soil and
PPE is determined to be radioac-
tively contaminated
HSWA
Permit
KY 8-890-
008-982
DOE Order
5820.2A
DOE Order
5820:2A
Management of LLW - TBC DOE Order
Guidance if excavated soil or PPE 5820.2A
is determined to be pyrophoric
Movement of LDR waste from one..
land disposa~ unit to another -
applicable. if LDR restricted
waste is ex~avated from the unit
40 C.F.R.
9268
Kentucky Permit
KY 8-890-008-982
32:030 9 5(3)(a)
37:030
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Table 2-4. Applicable or Relevant and Appropriate Requirements
and To Be Considered Guidance for the Interim Remedial Action (continued)
Actions
Requirements
Prerequisites
Federal
Citation
Title 401
K.A.R.,
Citation
Waste management
(continued) *
The storage of hazardous waste re-
stricted from land disposal is prohib-
ited, unless the generator stores such
wastes in tanks, containers, or contain-
ment buildings onsite solely for the pur-
pose of accumulating such quantities of
hazardous waste as necessary to
facilitate proper recovery, treatment, or
disposal.
*'"
w
Containers of land disposal restricted
waste must meet other RCRA storage
requirements in addition to being
clearly marked with the identification
of its contents, the date the accumula-
tion began, and the quantity of each
waste.
Continued storage of radioactive mixed
waste containing an LOR prohibited
hazardous waste component is allowed
while treatment capacity is being de-
veloped.
Storage of RCRA restricted haz-
ardous waste onsite - applicable
to any excavated soil or PPE t hat
is detennined to be land disposal
restricted hazardous waste
Container storage of LOR waste -
applicable if any of the exca-
vated soil or PPE is detennined
to an LOR waste
Storage of radioactive mixed
waste onsite - applicable if ex-
cavated soil or PPE is detennined
to be mixed waste
40 C.F.R.
~ 268.50
40 C.F.R.
~ 268.50
FFCA Docket
No. 92-03-FFR
37:050
37:050
These ARARs will only apply if PPE is determined to be RCRA hazardous or excess soil is not managed within the unit.
RCRA listed as an ARAR is a requirement of CERCLA in ROD documentation. By doing this, it in no way limits, takes away, or negates the
Commonwealth of Kentucky's RCRA authority at the site.
-------
Permanent Remedy
This action is an interim remedial action. The DOE will collect additional data necessary
to evaluate a final remedial action for SWMU 2. The final ROD for SWMU 2 may retain
or replace portions or all of the actions conducted pursuant to this ROD. However,
actions conducted pursuant to the ROD are not intended to be inconsistent with likely
final remedial actions. The interim action defined in this ROD will reduce the threat to
human health and the environment while additional characterization information is
obtained to fill data gaps. Additional characterization will allow for the evaluation of a
final remedy in the future.
2.11
Documentation of Significant Changes
The Proposed Remedial Action Plan for Interim Action at Solid Waste Management Units 2 and
3 of Waste Area Group 22 (OOE/OR/06-1315&D3) was made available for a 30-day public
review and comment period May 31 through June 29, 1995. The Proposed Remedial
Action Plan identified Alternative 5, a low permeability, multilayered cap, additional
monitoring, and institutional controls, as the preferred alternative. No written or verbal
comments were received during the 30-day public comment period; therefore, no
significant changes to the remedy, as identified in the Proposed Remedial Action Plan,
were necessary.
2.12
Five-Year Review
This interim action at SWMU 2 will be reviewed periodically until a final remedial
action is selected in a ROD. The CERCLA requires remedial actions which result in
hazardous substances, pollutants, or contaminants remaining at the site above levels
that do not allow for unlimited use and unrestricted exposure, be reviewed no less often
than once every five years after initiation of the sele,cted remedial action. This interim
remedial action will leave waste in place which will require restricted access; therefore,
SWMU 2 will be reviewed no less than once every five years. In addition to the five-year
review, the ground water data will be evaluated annually. The ground water monitoring
program for SWMU 2 will be specified in the forthcoming sampling and analysis plan,
which will be subject to review and approval by the EP A, the KDEP, and the DOE.
44
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PART 3
RESPONSIVENESS SUMMARY
45
-------
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 CERCLA, as amended by SARA, which requires the DOE
as "lead agency" to respond" .,. to each of the significant comments, criticisms, and new
data submitted in written or oral presentations" on the Proposed Remedial Action Plan.
The DOE has gathered information on the types and extent of contamination found,
evaluated remedial measures, and has recommended an interim remedial action to
mitigate leaching of COCs from the buried wastes while the DOE collects additional
data to support evaluation of a final remedial action. As part of the remedial action
process, a notice of availability regarding the Proposed Remedial Action Plan was
published in The Paducah Sun, a major regional newspaper of general circulation. The
Proposed Remedial Action Plan for Interim Action at Solid Waste Management Units 2 and 3 of
Waste Area Group 22 (DOE/OR/D6-1315&D3) was released to the general public May 31,
1995. 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 3D-day public comment period began May 31, 1995, and continued
through June 29, 1995. The Proposed Remedial Action Plan also contained information
which provided the opportunity for a public meeting to be held, if requested. No public.
meeting was requested.
Specific groups which received individual copies of the Proposed Remedial Action Plan
included the local PGDP Neighborhood Council, Natural Resource Trustees, and the
. PGDP Environmental Advisory Committee. In addition, information regarding the
proposed interim remedial action and copies of the Proposed Remedial Action Plan
were made available during a public workshop which the DOE held July 13, 1995.
Public participation in the CERCLA process is required by 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.
3.2
Community Preferencesllntegration of Comments
The Proposed Remedial. Action Plan clearly indicated comments could be issued to a
local DOE representative, the Kentucky Division of Waste Management, or the EP A.
Neither the DOE, the KDEP, nor the EP A received either verbal or written comments
during the 3D-day public comment period. In addition, no substantive comments were
generated during the DOE's July 13, 1~95, public workshop. Since no comments were
received, modifications to this ROD have not been required to integrate public concerns.
46
-------
Appendix
Remedial Design Schedule
-------
Remedial Design Schedule for Interim Action at SWMU 2 of WAG 22
1995 1998 1997
ID Actlvltv Duration Start Finish Otr2 I Otr3 I Otr4 Otr 1 I Otr2 I Otr 3 I Otr4 Otr 1 I Otr2 I Otr3
1 EPA ROD signature & Od 9/11/95 9/11/95 .
KDEP letter of concurrence
2
3 Sampling and Analysis Plan (SAP) 180d 9/1/95 2/27/96 T
Development ....
4 EPA & KDEP review D1 SAP 91d 9/1/95 11/30/95 ~,'-""''',....
5 DOE incorporate EPA & KDEP 59d 12/1/95 1/28/96 ~ !U'SI
comments
6 EPA & KDEP review D2 SAP 30d 1/29/96 2/27/96 ~
rSee footnote AI
7 EPA & KDEP approve SAP Od 2/27/96 2/27/96 .
8
9 Remedial design (RD) phase: Well!! Od 8/15/95 8/15/95
10 Design completed by DOE Od 8/15/95 8/15/95 .
11
12 Sampling activities and 281d 1/29/96 11/4/96 T .....
Remedial action phase: Wells
13 Procurement 134d 1/29/95 6/10/96 ~"""""""~
. rSee footnote BI
14 Mobilization 60d 6/11/96 8/9/96 ~
15 Install wells/soil 87d 8/10/96 11/4/96 ~,,""""
samDlina/aeoDhvsics
16
17 Waste/ground water Interaction 1d 8/30/96 8/30/96 I
meeting
Revised: July 27, 1995 Summary ..... ..... Milestone.
A: D2 SAP submittal date contingent upon receipt of comments on D1 SAP by 12/1/95. Activity I""'","""""'"
B: Procurement contingent upon approval of task order contract and approval of SAP by 2/27/96.
Durations presented in calendar days. Page 1 of 2
-------
Remedial Design Schedule for Interim Action at SWMU 2 of WAG 22
1995 1996 1997
10 Activitv Duration Start Finish atr2 I atr 3 I atr 4 atr 1 I atr2 I atr3 I Qtr4 Qtr 1 I Qtr2 I Qtr3
18 Remedial design (RD) phase: Low 273d 8/31/96 5/30/97
penneability, multilayered ca~- .... ....
~----
19 Design procurement 61d 8/31/96 10/30/96 ~
20 DOE develop 30% design 43d 10/31/96 12/12/96 lSSSSJ
rSee footnote CI
21 EPA & KDEP review 30% 22d 12/13/96 1/3/97 !;S:
design
22 DOE develop 60% design 31d 1/4/97 2/3/97 lSSSJ
23 EPA & KDEP review 60% 17d 2/4/97 2/20/97 f>SI
design
24 DOE develop 90% design 31d 2/21/97 3/23/97 ISSS1
and construction schedule
25 EPA & KDEP review 90% 31d 3/24/97 4/23/97 !;SS'j
design and construction sched.
26 EPA & KDEP approve 90% Od 4/23/97 4/23/97 .
desian and construction sched.
27 Complete design 22d 4/24/97 5/15/97 ~
28 Design certified for construction 15d 5/16/97 5/30/97 [S.1
(CFC)
Revised July 27, 1995 Summary .... .... Milestone.
C: Design activities contingent upon DOE, EPA, and KDEP concurrence Activity r'\. Y' '\...... '\"''\. '" y\. '\. '\. '\." '\. '\. '\.,
to proceed with a definite strategy by 8/30/96
Durations presented in calendar days. Page 2 of 2
-------
Distribution List
-------
U.S. DEPARTMENT OF ENERGY
Dave Dollins
Program Manager
U.s. Department of Energy
P.O. Box 1410 .
Paducah, KY 42001
Richard L. Nace (2 copies)
EM-423
Quince Orchard
U.s. Department of Energy
19901 Germantown Roa-d
Germantown, MD 20874-1290
Jimmie C. Hodges (3 copies)
U.s. Department of Energy
P.O. Box 1410
Paducah, KY 42001
K. Kates, AD-424
U.s. Department of Energy
Chinn fBuilding
167 Mitchell Road
Oak Ridge, TN 37830
Anthony A. Sims, CE-524
U.s. Department of Energy
Maxima Building
107 Union Valley Road
Oak Ridge, TN 37830
Nancy Carnes, CC-I0
U.s. Department of Energy
Turnpike Building-U&L
55 Jefferson Circle
Oak Ridge, TN 37830
Robert C. Sleeman, EW-91
U.S. Department of Energy
Information Resource Center
105 Broadway
Oak Ridge, TN 37830
&fA
Tony Able (5 copies)
U.s. EP A, Region IV
345 Courtlana Street, NE
Atlanta, GA 30365
FOSTER WHEElER
ENVIRONMENT AL CORP.
David Jones (2 copies)
111 Union Valley Road
Oak Ridge, TN 37830
MK-FERGUSON
David Beall (2 copies)
5735 Hobbs Road
C-730 Trailer 0
Kevil, KY 42053
JACOBS ENGINEERING
GROUP
Don Wilkes (2 copies)
Jacobs Engineering Group
175 Freecfom Blvd.
Kevil, KY 42053
JEG.0595.02
DISTRIBUTION
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
LOCKHEED MARTIN ENERGY
SYSTEMS. INC.
Patricia A. Gourieux
(Letter Only)
Lockheed Martin Energy Systems
761 Veterans Ave
Kevil, KY 42053
Jimmy C. Massey (Letter Only)
Lockheed Martin Energy Systems
761 Veterans Ave
Kevil, KY 42053
NATURAL RESOURCE
TRUSTEES
Alex Barber
Commissioner Office
KY Dept. for Environmental
Protection .
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601
James H. Lee
U.S. Department of Interior
Richard B. Russell Federal Bldg.
75 Spring Street, SW Suite 345
Atlanta, GA 30303
Abraham Loudermilk
Tennessee Valley Authority
400 W. Summit Hill Drive
Knoxville, TN 37902
Andrea B. Perkins
U.S. Department of Energy
Information Resource Center
105 Broadway
Oak Ridge, TN 37830
Allen Robison
U.S. Department of Interior
Fish and Wildlife Service
446 Neal Street
Cookville, TN 38501
STATE OF KENTUCKY
Caroline P. Haight
Division of Waste Management
KY Dept. for Environmental
Protection
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601
Tuss Taylor (4 copies)
UK/KDEP
18 Reilly Road
Frankfort Office Park
Frankfort, KY 40601
Lisa Fleming/Todd Mullins
KY Division of Waste Management
4500 Clarks River Road
Paducah, KY 42003
TVA
Ted Whitaker
Plant Manager
Shawnee Fossil Plant
. 7900 Metropoli.s Lake Road
West Paducah, KY 42086
Janet Watts
Manager of Environmental Affairs
50 Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
U.S. ENRICHMENT
CORPORA nON
David Hutcheson
U.S.E.C.
P.O. Box 1410
Paducah, KY 42001
U.S. GEOLOGICAL SURVEY
Martin Rose
U.s. Geological Survey
2301 Bradley Avenue
Louisville, i<:Y 40217
WEST KY WILDLIFE
MANAGEMENT AREA
Charles W. Logsdon
West Kentucky Wildlife Mgnt Area
KY Dept. of Fish and Wildlife
Resources
10535 Ogden Landing Road
Kevil, KY 42053
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