United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R04-91/096
September 1991
Superfund
Record of Decision:
Oak Ridge Reservation (USDOE)
(Operable Unit 4), TN
-------
50272-101
REPORT DOCUMENTATION 1'. REPORTNO..
PAGE EPA/ROD/R04-91/096
l ~
3. Redplent'a Acceulon No.
4. TItle and Slmtl1le
SUPERFUND RECORD OF DECISION
Oak Ridge Reservation (USDOE)
Third Remedial Action
7. Author(a)
5. Report D8te
09/19/91
(Operable Unit 4), TN
6.
8. Perfonnlng Organlz8t1on Rept. No.
II. Perfonnlng Orgalnlzatlon N8me and Addreae
10. Projec:tITa8klWork Unit No.
11. ContrIIet{C) or Gr8nt(G) No.
(C)
(G)
1~ SpoMoring Organiz8llon N8me and Addre..
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & P8rfod Coftnld
800/000
14.
15. Supplementary Notea
1&. Ab8traet (UmIt: 200 worda)
The Oak Ridge Reservation (ORR) (USDOE) (Operable Unit 4) site is a former uranium
isotope processing subsite in Oak Ridge, Roan County, Tennessee. The 1,700-acre K-25
site, which comprises Operable Unit 4 (OU4), is one of several hundred waste disposal
sites or areas of contamination at the ORR site requiring Superfund remedial action.
Land use in the area is predominantly residential. Three drum storage areas are
located in the northeastern portion of the site and consist of two adjacent asphalt
pads covering six acres on the north side of Mitchell Branch, a small stream. A curb
surrounding the pads directs water to a catch basin for each yard, all of which
discharge to Mitchell Branch. Built in the 1940's, the K-25 site was used to
separate uranium isotopes by gaseous diffusion with placement of resulting wastes and
sludge in collection ponds. The storage yards were constructed to temporarily store
sludge that was removed, stabilized, and drummed during closure of the collection
ponds from 1987 to 1989. The storage yards contain 36,000 ninety-gallon drums of
stabilized sludge, 29,000 ninety-gallon drums of raw sludge, and 16,000 gallons of
raw sludge in tanks, contaminated with mixed radioactive and hazardous wastes. The
drums have started to deteriorate and develop pin hole leaks resulting in the release
(See Attached Page)
17. Doeument An8lysls L Descriptors
Record of Decision - Oak Ridge Reservation (USDOE)
Third Remedial Action
Contaminated Medium: sludge
Key Contaminants: metals, radioactive materials
(Operable Unit 4), TN
b. Identifiera/Open-Enclecl Terms
c. COSA 11 FIeIdIGroup
18. Availability Slatement
19. Secl8'ity CIa.. (Thla Report)
None
20. Seel8'ity CIa.. (Thia Page)
Nnn",
21. No. of Pagea
26
22. Ptfce
Sea ANSl-Z3I1.18
See Inll/rUclionll on Rlllf8f88
..77)
(FormMIy NTlS-35)
Depu1mentof ComnMWce
-------
EPA/ROD/R04-91/096
Oak Ridge Reservation (USDOE)
Third Remedial Action
(Operable Unit 4~, TN
Abstract (Continued)
of small quantities of liquids to the pads. In addition, depressions have been observed
in the asphalt pads causing stacked drums to lean. This Record of Decision (ROD)
addresses the sludge stored at the storage yards as an interim action to prevent or
mitigate releases to the environment. Future RODs will address sludge remediation and
disposal. The primary contaminants of concern affecting the sludge are metals and
radioactive materials.
The selected remedial action for this interim remedy includes eliminating free liquids
in sludge through filter press, thermal drying, or similar methods; repacking dry
sludge, followed by onsite storage of containers in existing or new indoor facilities
awaiting remediation and disposal; and processing liquids removed from the sludge
through existing treatment facilities. The estimated capital cost for this remedia+
action is $69,000,000, with an annual O&M cost of $400,000. This interim remedy is
expected to take 20 months.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
-------
DECLARATION
SITE NAME AND LOCATION
U.S. Department of Energy
Oak Ridge K-25 Plant
Oak Ridge, Roane County, Tennessee
STATEMENT OF BASIS AND PURPOSE
This deci~ion document presents the selected interim action for the
K-1417-A and K-1417-B Drum Storage Yards (DSY) and the K-1419 Sludge Treatment
Facility (STF) at the Oak Ridge K-25 Site, in Oak Ridge, Tennessee. This
action was chosen is accordance with the Comprehensive Environmental Response~
Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA) and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision is based on the administrative record file for this
site.
The State of Tennessee and the U.S. Environmental Protection Agency
concur with this interim action for the K-1417-A and K-1417-B Drum Storage
Yards.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, as
well as the physical conditions at the site, if not addressed by implementing
the response action selected in this Record of Decision (ROD) may present a
current or potential threat to human health or the environment.
DESCRIPTION OF THE REMEDY
The principal goal of this interim action is to prevent or mitigate the
imminent threat of release of contaminants to the surrounding environment and
to minimize the threat to human health. An additional goal of this interim
action is to assure that the sludges are managed in compliance with the
requirements of the Resource Conservation and Recovery Act (RCRA). Dewatering
of the raw sludges and decanting of the liquids from the stabilized sludges
will mitigate the releases of contaminants from the drums. Removal of the
drums from the DSYs will eliminate the potential for sludges to affect the
environment. This is not the final action planned for the site as it is part
of Waste Area Group (WAG) 1 at the K-25 Site. Subsequent actions are planned
to address fully the principal threats posed by the conditions at WAG 1 and
these will be defined when the remedial investigation of this area is
completed.
-------
12/19/91 15:08 DOE ENUIRONMENTflL RESTORATION 003
The major components of the interim action remedy consists of the
following;
dewaterlng of the raw sludges and repackaging them Into compatible
containers;
decanting the free liquids from the stabilized sludge drums;
Inspect the stabilized sludge drums and repair or overpack them as -,
required;
treat all liquids through existing treatment facilities;
« move all the containers into new and existing Indoor storage
facilities,
The estimated cost for this interim action remedy is 569 million.
STATUTORY DETERMINATIONS
This interim action is protective of human health and the environment,
complies with Federal and State applicable or relevant and appropriate
requirements for this limited-scope action, and 1s cost effective. This
action is interim and Is not Intended to utilize permanence solutions and
alternative treatment (or resource recovery) technologies to the maximum
extent practicable, given the limited scope of the action. Because this
action does not constitute the final remedy for the Site» the statutory
preference for remedies that employ treatment that reduces1 toxicity, mobility,
or volume as a principal element will be addressed at the tine of the final
response action. Because this 1s an interim action, subsequent actions are
planned to address fully the principal threats posed by the conditions at WAG
1 and these will be defined when the remedial Investigation of this area 1s
completed.
Manager, Field Office Oak Ridge Date
U.S. Department of Energy
Regional Administrator, RigloffiV Date
U.S. Environmental Protection Agency
Director, DOE Oversight' DivJ^lon Date
State of Tennessee ' ~~
Department of Environment and Conservation
-------
DECISION SUMMARY
RECORD OF DECISION
INTERIM ACTION FOR THE
K-1417-A ND K-1417-B DRUM STORAGE YARDS
U.s. DEPARTMENT OF ENERGY
OAK RIDGE K-25 PLANT
OAK RIDGE, TENNESSEE
-------
TABLE OF CONTENTS
Section Page
DECLARATION ii
ACRONYMS vi 1
1. SITE NAME, LOCATION, AND DESCRIPTION 1
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION 2
4. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY 3
5. SITE CHARACTERISTICS 3
6. SUMMARY OF SITE RISKS 4
7. DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES 4
7.1 ALTERNATIVE 1: NO ACTION 4
7.2 ALTERNATIVE 2: DEWATERING AND STORAGE ON-SITE 5
7.3 ALTERNATIVE 3: OVERPACKING AND ONSITE STORAGE 6
7.4 ALTERNATIVE 4: TREAT AND DISPOSE OFF-SITE 6
7.5 ALTERNATIVE 5: TREAT AND STORE ON-SITE 7
8. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 8
8.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT .... 9
8.2 COMPLIANCE WITH ARARS 9
8.3 SHORT TERM EFFECTIVENESS 10
8.4 LONG TERM EFFECTIVENESS AND PERMANENCE 11
8.5 REDUCTION OF TOXICITY, MOBILITY, AND VOLUME BY TREATMENT ... 12
8.6 IMPLEMENTABILITY 12
8.7 COST 13
8.8 STATE ACCEPTANCE 13
8.9 COMMUNITY ACCEPTANCE 13
9. THE SELECTED REMEDY 14
10. STATUTORY REQUIREMENTS 14
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 14
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS 14
10.3 COST EFFECTIVENESS . 15
-------
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES TO THE
. MAXIMUM EXTENT PRACTICABLE. . . . . . . .. . . . . . . . .
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT. . . . . . .
10.6 DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . . . . .
15
15
15
-------
ARAR.
CERCLA
DOE
DSY
EPA
HSWA
. LDR
NCP
NPL
ORR
RCRA
RI/FS
ROD
SARA
STF
SWMU
TDEC
WAG
ACRONYMS.
Applicable or Relevant and Appropriate Requirements
Comprehensive Environmental Response, Compensation,
Act
United States Department of Energy
Drum Storage Yard
United States Environmental Protection Agency
Hazardous and Solid Waste Amendments
Land Disposal Restrictions
National Contingency Plan
National Priorities List
Oak Ridge Reservation
Resource Conservation and Recovery Act
Remedial Investigation/Feasibility Study
Record of Decision
Superfund Amendments and Reauthorization Act
Sludge Treatment Facility
Solid Waste Management Unit
Tennessee Department of Environment and Conservation
Waste Area Grouping
and L i abi 1 ity
-------
. .
1. SITE NAME, LOCATION, AND DESCRIPTION
The Oak Ridge K-25 Site is part of the Oak Ridge Reservation (ORR)
Superfund Site. The site is located approximately five miles from the
residential areas of the City of Oak Ridge, near the confluence of Poplar
Creek and the Clinch River. It occupies approximately 1700 acres of land with
approximately 700 acres enclosed within the security fence.
The K-1417-A and K-1417-B DSYs and K-1419 STF (herein to be referred to
collectively as the DSYs) are located in the northeastern portion of the K-25
Site in Oak Ridge, Tennessee (Figures 1 - 3). The storage yards consist of
two adjacent asphalt pads covering approximately six acres on the north side
of Mitchell Branch, a small stream which drains into Poplar Creek. Each
storage yard is sloped gently toward the south and the southern boundary of
the yard, along most of its length, has a six inch curb. This curb directs
precipitation run-off to a catch basin for each yard. Run-off entering the
basins is then discharged to Mitchell Branch.
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The K-25 Site was constructed in the 1940's for the separation of
uranium isotopes by the gaseous diffusion process. The K-1407-B pond was
constructed in 1943 to collect metal hydroxide sludges and other solids from
various operations at the K-25 site. The K-1407-C pond was constructed to
collect potassium hydroxide scrubber sludges and to hold the sludges removed
from the K-1407-B pond.
The yards were constructed to temporarily store the sludges removed
during closure of the K-1407-B and K-1407-C Ponds following their treatment in
the K-1419 STF. The DSYs were constructed as part of a RCRA change to interim
status for the K-25 Site, with the Part A Application submitted in 6/29/84 and
concurrence by the TOEC on 2/4/86. The TOEC and EPA issued the HSWA permit
for the Oak Ridge Reservation in October 1985, which required remedial actions
to be taken to correct any releases at Solid Waste Management Units (SWMUs) on
the reservation. This included the K-1417 OSYs. Subsequently, in December
1989 the entire Oak Ridge Reservation, which includes the K-25 Site and K-
1417 DSYs, was placed on the CERClA National Priorities list (NPL).
The sludges were removed and treated pursuant to the RCRA closure plans
which were approved in April 1988. From February 1987 through September 1988
sludges were removed from the K-1407 B&C ponds, stabilized at the STFt placed
into drums, and stored on the K-1417 DSYs. Treatment consisted of mixing the
sludges with cement and flyash to form a non-leachable monolith. From
September 1988 through June 1989 the sludges were removed from the ponds and
placed directly into drums and moved to the storage yards. These sludges were
to be treated during the following fiscal year.
The sludges removed from the ponds are classified as mixed wastes.
Mixed wastes contain a hazardous component regulated under Subtitle C of RCRA
and a radioactive waste component regulated under the Atomic Energy Act.
Thus, the DSYs are RCRA-regulated container storage areas.
-------
At the time the ponds were undergoing closure, DOE had expected to
obtain EPA approval to reclassify the treated sludge as non-hazardous, and
then dispose of it as low-level radioactive waste. Therefore, the K-1417 DSYs
were designed to be a temporary storage facility (1-2 years for stabilized
drums and 6 months for unstabilized drums). Subsequently, it became apparent
that there were some quality control problems with the treatment process. As
such, the DOE did not complete the treatment of drummed untreated sludge. The
treated sludge also has not yet been reclassified as non-hazardous. As a
result, the sludge remains classified as a mixed (radioactive/hazardous)
waste, and DOE has continued to store this material due to a nationwide
shortage of mixed waste disposal capacity.
The drums are stacked two or three high, in rows of up to four drums
abreast. This arrangement does not allow for inspection of the drums as
required by RCRA. Due to the presence of high pH liquids and halogens in some
of the drums, the steel drums began to deteriorate and have developed pinhole
leaks which have released small quantities of liquids to the pad.
Additionally the drums are deteriorating from exposure to the elements and the
weight of the drums are causing them to sink into the asphalt pad.
Consequently, the stacked drums are starting to lean and have become unstable.
Conditions have worsened to the point that it was no longer safe for employees
to enter the DSYs to inspect the condition of the drums as required by RCRA.
This, along with the deteriorated condition of the drums, could lead to the
drums toppling over and injuring site workers and also releasing significant
amounts of hazardous waste.
The above problems were brought to the attention of the regulators (EPA
and TDEC). In August 1990, the EPA and TDEC sent a letter to DOE requesting
an action plan to correct the RCRA violations at the K-1417 DSYs and to abate,
prevent, or eliminate the threat to human health or the environment due to the
leaking drums at the storage yards. The requested Action Plan was submitted
to the EPA and TDEC on January 31, 1991 and was accepted by the regulators on
March 18, 1991. It was also recognized that the K-1417 DSYs were a suitable
site for an Interim Action Record of Decision (ROD) under CERCLA.
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Interim Action Proposed Plan for the K-1417-A and K-1417-B Drum
Storage Yards at the Oak Ridge K-25 Site was released to the public on August
16, 1991. This document was made available in the administrative record
maintained at the DOE information Resource Center located at 105 Broadway in
Oak Ridge. The notice of availability was published The Oak Ridger on August
16, 1991. A public comment period was held from August 16, 1991 to
September 16, 1991. In addition to public comment and the accessibility of
the information, a public meeting was held on September 9, 1991. At this
session, representatives from DOE and Martin Marietta Energy Systems, Inc.
answered questions and received comments. A response to the comments received
during the comment period is included in the Responsive Summary, Appendix A of
this Interim ROD.
-------
.
This decision document presents the selected interim action for the
K-I417-A and K-I4I7-B Drum Storage Yards (DSY) and the K-I4I9 'Sludge Treatment
Facility'(STF) at the Oak Ridge K-25 Site, in Oak Ridge, Tennessee. This
action was chosen is accordance with CERCLA, as amended by SARA and, to the
extent practicable, the NCP. This decision is based on the administrative
record and indications of a current or potential threat to human health or the
environment.
4. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
The goal of this interim action is to prevent or mitigate the imminent
threat of release of contaminants to the surrounding environment and to
minimize the threat to human health. An additional goal of this interim
action is to assure that the sludges are managed in compliance with the
requirements of RCRA. This action is intended to o~ly address the raw and
stabilized sludges at the DSYs. It will also enhance the ability to
investigate and remediate the entire area at the DSYs.
The potential exists for the DSYs to impact the aquatic life in Mitchell
Branch should the drums be allowed.to deteriorate to the point that their is a
major release of material. The principal threat to human health is for an
injury to the site workers performing routine inspection and maintenance
duties in the yard resulting from the drums toppling over. Removal of the
liquids from the sludges, repair of the stabilized sludge drums, and removal
of all the drums from the DSYs will address all the concerns at the site.
The K-I4I7 DSYs are one of fifteen solid waste management units that
comprise Waste Area Grouping (WAG) 1 at the K-25 Site. The proposed interim
action for the K-1417 DSYs is not the final action planned for WAG 1, however
it is consistent with any potential final action for WAG 1. Subsequent
actions are planned to address fully the principal threats posed by the
conditions at WAG 1 and other identified WAGs a K-25. These actions will be
defined as the remedial investigation and feasibility studies are completed
for the K-25 WAGs. .
5. SITE CHARACTERISTICS
The K-1417-A and K-1417-B DSYs and K-1419 STF (herein to be referred to
collectively as the DSYs) are located in the northeastern portion of the K-25
Site in Oak Ridge, Tennessee (Figures 1 - 3). The storage yards consist of
two adjacent asphalt pads covering approximately six acres on the north side
of Mitchell Branch, a small stream which drains into Poplar Creek. Each
s~orage yard is sloped gently toward the south and the southern boundary of
the yard, along most of its length, has a six inch curb. All runoff from the
DSYs eventually flows into Mitchell Branch.
The DSYs have about 65,000 drums on them; 36,000 of which contain
stabilized sludges and 29,000 of which contain raw sludges. Each drum
contains about 90 gallons of sludge. In addition there is about 16,000
gallons of raw sludge stored in tanks at the STF. The sludges contain
-------
materials generated from the treatment of plating baths, therefore the sludges
are listed as F-006 wastes under RCRA. The sludges also contain
radionuclides, primarily uranium and technetium, making them a mixed waste (a
waste that contains both a hazardous and radioactive waste component).
6. SUMMARY OF SITE RISKS
CERCLA directs that human health and the environment must be protected
from current and potential exposure to hazardous substances at Superfund
sites. In order to assess the current and potential risks for the K-25 Site,
a full risk assessment is being conducted as part of the RI/FS process.
The principal threats posed by conditions at the DSYs are injury of
workers performing routine inspection and maintenance duties, and
contamination of surface water, and possibly groundwater, by the chronic
and/or catastrophic release of drum contents. There are two primary release
scenarios for the drummed sludges. The first is leakage of free liquids
through holes in the drums caused by corrosion. The second is through
catastrophic failure of the drums either through deterioration or from the
stacked ~rums falling. In either case, the primary exposure pathway is
rainwater run-off carrying the contaminants into to Mitchell Branch with the
potential to adversely impact aquatic organisms. The second possible, though.
minor, pathway is for the contaminants to infiltrate through the asphalt pad
into the soils beneath the pads and eventually into the groundwater. The
principle threats to site workers is through direct exposure to the material
through spills and injury due to falling drums.
Analysis of storm water run-off from the storage yards as well as soil
and sediment samples taken from Mitchell Branch has not indicated any
migration of contaminants from the K-1417 DSYs. The only contaminated media
at the K-1417 DSYs are the drummed sludges which contain low levels of heavy
metals (such as nickel) and radionuclides, principally uranium and technetium.
7. DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES
7.1 ALTERNATIVE 1: NO ACTION
The NCP requires that the No Action alternative be considered through
the detailed analysis. It provides a baseline for comparison of the other
alternatives. This alternative involves leaving the drummed sludges on the
site as they are presently situated. Continued surveillance of the site would
be required to inspect for leaking or fallen drums. Containers in seriously
deteriorated condition would need to be repackaged into new containers. The
continued storage of raw sludges in the DSYs, in the current configuration,
would constitute a continuing RCRA violation. Eventually the drums would
deteriorate to the pOint that they all would have to be replaced. At a future
date, all the sludges would have to be treated and permanently disposed. The
cost and time to implement this alternative are presented below:
-------
Estimated total project cost:
Estjmated annual O&M costs:
S
$
100,000
SOO,OOO/yr
Estimated implementation time:
On going
7.2 ALTERNATIVE 2: DEWATERING AND STORAGE ON-SITE
Alternative 2 involves eliminating free liquids from all sludges,
repackaging all raw sludges and some of the previously treated sludges, and
then removing all the containers from the K-1417 DSYs and placing them into
RCRA compliant storage in existing and new bUildings.
The raw sludges would be removed from the existing drums and tanks and
treated to lower the water content. The treatment would be by filter press,
thermal drying, or a similar method. The dry sludges would then be repackaged
into new compatible containers, removed from the K-1417 DSYs, and placed in
existing or new indoor storage facilities. The liquid removed from the sludge
would be processed through existing treatment facilities.
The stabilized sludge drums would be opened and the free liquid in the
containers removed by decanting or pumping. The drums would be inspected and
depending on their condition, would either be repaired or overpacked. These',
drums would also be removed from the pad and placed in existing or new indoor
storage facilities. The liquid removed from the drums would be processed
through existing treatment facilities.
This alternative will require new storage buildings to be built to house
the drums, with the remainder being stored within the K-31 and K-33 buildings.
Storage of sludges in the existing K.31 and K-33 buildings will require minor
improvements to certain areas to house the drums as well as application of
procedures to prevent PCB contamination of the drums from the gasket drips
within these buildings. At a future date the raw sludges would have to be
treated to meet regulatory levels and the entire sludge inventory permanently
disposed at additional cost.
Estimated total project cost:
Estimated annual O&M costs:
S 69,000,000
s
400,OOO/yr
Estimated implementation time:
20 months
7.3 ALTERNATIVE 3: OVERPACKING AND ONSITE STORAGE
Alternative 3 involves overpacking the raw sludge drums into compatible
containers, and moving them and the stabilized drums into RCRA compliant
storage facilities. The stabilized sludge drums would be inspected.
Depending upon their condition, they would be overpacked or repaired before
being moved into storage.
-------
.
This alternative will require new storage buildings to be built to ho~se
the overpacked drums of raw sludge. The stabilized sludges would have the
free liquid removed prior to being stored within the K-31 and K-33 buildings.
Storage of sludges in the K-31 and K-33 buildings will require minor
improvements to certain areas to house the drums as well as application of
procedures to prevent PCB contamination of the drums from the gasket drips
within these buildings. At a future date the raw sludges would have to be
treated to meet regulatory levels and the entire inventory permanently
disposed at additional cost.
Estimated total project cost:
Estimated annual O&M costs:
S 65,000,000
$
400,OOO/yr
Estimated implementation time:
17 months
7.4 ALTERNATIVE 4: TREAT AND DISPOSE OFF-SITE
. .
This alternative would entail the treatment of the raw sludges into a
form suitable for final disposal followed by their immediate shipment to the
final disposal site. The stabilized sludges would be decanted and shipped for
disposal. The projected method of treatment for the raw sludges is unknown at
this time. Options include calcining technologies, additions of chemicals to'
lower the solubility of metals, chemical fixation processes, and thermal
fixation processes such as vitrification. The goal of final treatment is to
produce a treated sludge suitable for permanent disposal. Treatability
studies to determine the effectiveness of the proposed treatment methods will
be required. The ability to dispose of the stabilized sludges without further
treatment is unknown at this time. If further characterization shows the need
for more treatment, than additional costs will be incurred.
Completion of this alternative will e11min~te the annual operations and
maintenance costs for inspections, repackaging, building upkeep, etc.
associated with the storage of drums.
Estimated total project cost:
Estimated annual O&M costs:
$ 115,000,000
N/A
Estimated implementation time:
30 months
7.5 ALTERNATIVE 5: TREAT AND STORE ON-SITE
This alternative is equivalent to Alternative 4. However, it assumes
that there is no available disposal facility for the drums. This necessitates
the construction of storage buildings to house the treated sludge for an
indefinite period.
Estimated total project cost:
S 80,000,000
-------
Estimated annual O&M costs:
s
400,OOO/yr
Estimated implementation time:
26 months'
.-
-------
8. SUMMARY OF 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 applicable or relevant and appropriate
requirements (ARARs) to CERClA; (2) provides the "best balance" between
effectiveness and reduction of toxicity, mobility, or volume through
treatment, imp1ementabi1ity, and cost; and (3) receives state and community
acceptance. A glossary of the evaluation criteria is provided below:
.-
.
Overall Drotection of human health and the environment - addresses
whether .a remedy provides adequate protection and describes how
risk~ posed through each pathway are eliminated, reduced, or
controlled through treatment, engineering controls, or
institutional controls.
.
ComDliance with ARARs - addresses whether a remedy will meet all
of the applicable or relevant and appropriate requirements of
other federal and state environmental statutes and/or provide
grounds for invoking a waiver.
.
Short term effectiveness - the speed with which the remedy
achieves protection and the remedy's potential to create adverse.
impacts on human health and the environment that may result during
the construction and implementation period.
Lona term effectiveness and Dermanence - the magnitude of residual
risk and the ability of the remedy to maintain over the long term,
reliable protection of human health and the environment once
cleanup goals have been met.
.
.
Reduction of toxicity. mobility. or volume throuGh treatment - the
anticipated performance of the treatment technologies that may be
employed in a remedy.
ImDlementability - the technical and administrative feasibil ity of
a remedy, including the availability of materials and services
needed to implement the chosen solution.
.
.
~ - includes capital and operation and maintenance costs.
State acceDtance - indicates whether the state concurs with,
opposes, or has no comment on the Proposed Plan.
.
.
Community acceDtance - the Responsiveness Summary in the appendix
of the Interim ROD reviews the public comments received from the
public meeting on the Proposed Plan.
8.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
-------
Alternative 1, no action, has the lowest degree of overall protection of
human health and the environment of the alternatives because it would allow
the continued exposure of the drums to the environment, leading to their
further deterioration and consequent chronic or catastrophic release of their
contents. Also, under Alternative 1 the safety hazard to workers responsible
for site inspection and maintenance would increase as the condition of the
drums worsened.
Alternative 2, dewatering and storage on-site, offers a moderate degree
of overall protection of human health and the environment. It removes the
drums from the K-1417 DSYs and places them into inside storage, isolated from
the environment in a relatively short time frame. However, significant
processing and handling will be required at the time the alternative is
implemented and again at a future date for final disposal.
Alternative 3 offers a moderate degree of overall protection of human
health and the environment. It removes the drums from the K-1417 DSYs and
places them into indoor storage units in a relatively short time frame.
However, handling of the drums will be required at the time the alternative is
implemented and significant handling of the sludges will be required at a
future date for final disposal.
Alternatives 4 and 5 each offer a moderate degree of overall protection
of human health and the environment. Significant handling and processing of .
the wastes increases the potential for exposure to people and the environment.
All sludges would remain on the DSYs until treatment is underway. In the
interim, the drums would continue to deteriorate. Treatment would reduce the
mobility of waste constituents and the treated material would be placed into a
secure long term repository following treatment.
8.2 COMPLIANCE WITH ARARS
Since there is no evidence of contaminated groundwater, surface water,
or soils, there are no chemical specific cleanup standards for the K-1417
DSYs. However, the potential exists for the contamination of surface waters
to levels exceeding Water Quality Criteria if the sludges are left on the yard
for an extended time period. The only other chemical specific ARARs
identified are the RCRA Land Disposal Restrictions (LOR) treatment standards
for F006 mixed wastes. Action specific ARARs include RCRA and Tennessee
hazardous waste treatment. and storage regulations.
Alternative 1 would result in continued violations of RCRA and Tennessee
container storage regulations for hazard~us waste. This alternative could
result in Water Quality Criteria violations in the future and does not meet
the LDR requirements. Continued storage of sludges which do not meet the LOR
requirements will require a LOR variance and/or inclusion of the sludges in
the compliance agreement for LOR wastes which is presently being negotiated.
Alternative 2 would be in compliance with RCRA and Tennessee hazardous
waste storage regulations upon completion, however, the raw sludges will not
comply with the LDR requirements. Continued storage of sludges which do not
-------
meet the LOR requirements will require a LOR variance and/or inclusion of the
sludges in the compliance agreement for LOR wastes which is presently being"
negotiated. Additional testing is required to determine if the stabilized
sludges can meet LOR treatment standards. RCRA requirements related to
treatment would be met during the dewatering.
Alternative 3 would be in compliance with RCRA and Tennessee hazardous
waste storage regulations upon completion, however, the raw sludges will not
comply with the LOR requirements. Continued storage of sludges which do not
meet the LOR requirements will require a LOR variance and/or inclusion of the
sludges in the compliance agreement for LOR wastes which is presently being
negotiated. Additional testing is required to determine if the stabilized
sludges can meet LOR treatment standards.
Alternatives 4 and 5 would be in compliance with RCRA and Tennessee
hazardous waste disposal or storage regulations upon completion. Compliance
with the RCRA LOR requirements for storage and disposal would be met for the
treated raw sludges. Additional testing is required to determine if the
stabilized sludges can meet LOR treatment standards. RCRA requirements
related to treatment would be met during the treatment.
8.3 SHORT TERM EFFECTIVENESS
Alternative 1 represents the status quo and does nothing to reduce risks
to human health or the environment over the short-term.
Alternative 2, dewatering and on-site storage, has the second highest
degree of short-term effectiveness among the action alternatives because it
alleviates site problems in a short time frame (20 months), however it
requires significant handling of the raw sludges.
Alternative 3, overpacking, and on-site storage, has the highest
short-term effectiveness among the action alternatives because it alleviates
the site problems in the shortest time period (17 months) and requires the
least amount of handling of the sludges.
Alternatives 4 and 5, treat and dispose or store, each have a moderate
level of short-term effectiveness due to implementation time (26-30 months)
but allow waste to remain in deteriorating drums on the OSYs until treatment
is completed.
8.4 LONG TERM EFFECTIVENESS AND PERMANENCE
Alternative 1, no action, does not reduce site risks and therefore is
not protective of human health and the environment over the long-term because
of the continued exposure of the environment to the sludges. This could
-------
I-~
eventually lead to contamination of the surface waters in the vicinity of the
DSYs. Additionally, there is a continuing risk of ~xposure to the workers,'
and a chance for injuries, due to the need to continually access the storage
yards to maintain the drums. Alternative 1 is not a permanent solution to the
problem. The sludges will require final treatment and disposal at some future
date.
Alternative 2, dewatering and storage on-site, has a moderate degree of
long-term effectiveness. The mobility of the contaminants is reduced by
removing the liquids from the sludges. Also, the chance for waste
constituents to be released to the environment is reduced by placing the raw
sludges into compatible containers and all the drums into indoor storage.
There is a moderate risk to workers remaining because the storage area will
need to be inspected and deteriorated containers replaced. Since the
stabilized drums are not overpacked there is a continued chance for failure of'
these containers. This alternative is not a permanent solution to the problem
because the sludges will require final treatment and disposal at some future
date. '
Alternative 3, overpacking and on-site storage, has a moderate to low
degree of long term effectiveness. The chance for a release to the
environment is reduced by placing the raw sludge drums into overpack
containers and then into inside storage. There is a moderate risk to workers
remaining because the storage area will need to be inspected and deteriorated
containers replaced. Since the stabilized drums are not overpacked there is 'a
continued chance for failure of these containers. This alternative is not a
permanent solution to the problem because final treatment and disposal would
still be required at some future date.
Alternative 4, treat and dispose off-site, offers the highest long-term
effectiveness. The chance for an environmental release is negligible because
the wastes are treated into a non-leachable, immobile form. There are no
long-term human health risks remaining at the site because the drums are
placed into their final disposal site. This a1ternative is considered a
permanent solution to the sludges.
Alternative 5, treat and store on-site, has slightly higher long-term
effectiveness than alternative 2, because the sludges are treated to a final
form. There is a moderate risk to workers remaining because the storage area
will need to be inspected and deteriorated containers replaced. Since the
stabilized drums are not overpacked there is a continued chance for failure of
these containers. This Alternative is not a permanent solution to the problem
because the sludges will require final disposal at some future date. Also, if
the stabilized sludges do not meet the disposal criteria at the time of final
disposal, than additional treatment will need to be provided.
8.5 REDUCTION OF TOXICITY. MOBILITY. AND VOLUME BY TREATMENT
Alternative 1, no action does not reduce the toxicity, mobility, or
volume of the contaminants or sludges.
Alternative 2, dewater and storage on-site, will reduce the mobility of
the contaminants but not the toxicity or volume. The mobility is reduced
-------
through the removal of the free liquids from all the sludges. Some volume,
reduction will be possible through dewatering the raw sludges, but it in not
expected 'to be significant. Since the only treatment being provided is the
removal of the free liquids, there is no reduction of the toxicity of the
contaminants in the sludges. Also, since treatment of the raw sludge is not
provided, the contaminants remain more mobile than in the other action
alternatives.
Alternatives 3, overpack and storage on-site, will not reduce the
mobility, toxicity or volume of the sludges. Since final treatment of the raw
sludge is not provided, the contaminants remain more mobile than in the other
action alternatives.
Alternatives 4 and 5 include treatment to reduce the mobility of the
contaminants, but not the toxicity. The volume of sludge will likely increase
due to the treatment process.
8.6 IMPLEMENTABILITY
The design and engineering requirements for Alternative 1 are the least
of any of the alternatives. The only technical requirement is to overpack
containers found by the inspections to be ready to fail. However, this task
would become increasingly difficult with time ,as containers fail at a higher'
rate. Alternative 1 is not administratively feasible because the regulators
(TDEC and EPA) will not allow the outstanding RCRA violations to continue
indefinitely.
Alternative 2, dewater and storage on-site, is the third easiest to
implement, and almost as easy as alternative 3. Dewatering methods are
readily available and fairly easy to implement. The design and construction
of the new storage buildings is straight forward. and upgrading of existing
space will not be difficult.
Alternative 3 is the second easiest to implement. The design and
construction of the new storage buildings is straight forward and upgrading of
existing space will not be difficult. Design of the new buildings for
Alternative 3 will be more extensive than for Alternative 2 or 5 because
secondary containment design requirements to store liquids would have to be
met.
Deciding on a final treatment method is the most difficult part of
implementing Alternatives 4 or 5. This will require treatability studies and
a stringent quality control program to assure a suitable final waste form.
Presently, Alternative 4 is not administratively feasible because there is no
disposal site in the country that can accept the K-1417 sludges. However,
that situation may change in the near future.
Another set of administrative requirements that would apply to all of
the alternatives are RCRA permitting standards for treatment and storage of
hazardous waste.' Because the interim corrective action will take place at an
existing RCRA interim status facility, treatment may be performed and
container storage capacity expanded under a change to interim status, subject
-------
to TDEC approval. Ultimately, any new,. permanent' storage or treatment units
will require permits. The existing K-1417 DSYs cannot be permitted unle~s
substantial improvements are made.
8.7 COST
The comparative analysis of costs considers only differences in capital,
operation and maintenance, and total estimated costs. Costs for each
alternative have been provided in Section 5 of this plan. The costs provided
in Section 5 only cover the interim action proposed in each alternative. Some
of the alternatives will entail additional costs at a future date to
permanently treat and/or dispose of the sludges. likewise, costs of penalties
for hazardous waste management violations are not included in this analysis.
Alternative 1, no action, is the lowest cost alternative due to the,
limited nature of the response. Alternative 2 at $69 million and alternative
3 at 65 million are the lowest cost alternatives which are protective of human
health and the environment. Alternative 4, treat and dispose off-site, at
$115 million is the only alternative which provides for final resolution of
the problem and therefore, may be the most cost-effective remedy over the
long-term. Alternative 5 at 80 million, along with alternatives 2 and 3,
stabilize the situation but do not reflect future disposal costs. However
alternative 5 provides a more stable waste form.
8.8 STATE ACCEPTANCE
The State of Tennessee, as represented by the Tennessee Department of
Environment and Conservation, DOE Oversight Division, concurs in the selection
of Alternative 2 as an interim action for the DSYs.
8.9 COMMUNITY ACCEPTANCE
Based on comments made by citizens at the public meeting held on
September 9, 1991 and comments received during the public comment period, the
DOE perceives that the community believes the interim action will effectively
protect human health and the environment.
-------
.
9. THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the detailed
analysis of the alternatives, and the public comments, DOE has determined that
Alternative 2, Dewatering and Storage On-site, is an appropriate interim
action until final action for the DSYs area is determined. Based on current
information, this alternative provides the best balance with respect to the
nine criteria used to evaluate the alternatives.
The goal of this interim action is to prevent or mitigate the imminent
threat of release of contaminants to the surrounding environment and to
minimize the threat to human health. An additional goal of this interim
action is to assure that the sludges are managed in compliance with the
requirements of RCRA. Removal of the liquids from the sludges, repair of the
stabilized sludge drums, and removal of all the drums from the DSYs will
address all the concerns at the site.
The proposed interim action for the K-1417 DSYs is not the final action
planned for the DSYs because such goals are beyond the scope of this limited
action. Subsequent actions are planned to address fully the principal threats
posed by the conditions at WAG 1 and Qther identified WAGs a K-25. These
actions will be defined as the remedial investigation and feasibility studies
are completed for the K-25 WAGs.
10. STATUTORY REQUIREMENTS
The DOE believes that the removal of liquids from the sludges and
removal of the drums from the DSYs will satisfy the statutory requirements
providing protection of human health and the environment. The selected
remedy's compliance with the statutory requirements is summarized below.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment by
removing all the sludges from the DSYs, assuring the integrity of all the
containers, and by placing all the containers into RCRA compliant storage
facilities.
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Alternative 2 would be in compliance with RCRA and Tennessee hazardous
waste storage regulations upon completion as well as the Tennessee water
pollution control regulations. RCRA requirements related to treatment would
be met during the dewatering. However, the raw sludges will not comply with
the LDR requirements for storage. Continued storage of sludges which do not
meet the LDR requirements will require a LDR variance and/or inclusion of the
sludges in the compliance agreement for LDR wastes which is presently being
-------
negotiated. Additional testing is required to determine if the stabilized
sludges can meet LDR treatment standards.
10.3 COST EFFECTIVENESS
The interim action remedy employs a proven technology and affords
overall effectiveness proportional to its costs such that the remedy
represents a reasonable value for the money.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTICABLE
The objectives of this interim action are to mitigate the potential
releases of hazardous substances, eliminate the threat to human health, and to
manage the sludges in compliance with the h~zardous waste regulations.
Removal of liquids from the sludges and placing the containers into RCRA
compliant facilities will achieve these goals. This is not the final action
planned for this site or the sludges and DOE will continue to evaluate long
term effectiveness and permanence as part of the development of the final
action for the sludges and the DSYs. .
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
This is not the final action for the disposition of the sludges.
However, the remedy utilizes limited treatment (removal of free liquids) to
reduce the mobility of the contaminants. This l.vel of treatment ia
appropriate for the limited interim action.
10.6 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the DSYs was released for public comment on August
16, 1991, and identified dewatering of the sludges and storage on-site as the
preferred interim action alternative. DOE reviewed all written and verbal
comments submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the alternat;ve. as
it was originally identified in the Proposed Plan, were necessary.
-------
APPENDIX A - FIGURES
Figure 1 - K-25 Site Plan
Figure 2 - Plan View of the K-1417 Drum Storage Yards
Figure 2 - Plan View of the K-1419 Sludge Treatment Facility
-------
«« «*>.**.«
. v ',!-. >,.-» A * «*< «
- -. t ' -.»*
"fc - **" I -**
-..-... ' tf-t****>V
.,»» **^,«*i»^**s*>
.»*.*-. »»
' » ." ;»« »*»*** »w»^»
»w» (****
I«M» "».. "*" tHlMW*
MINIMA W-J«W7t^«
I «»**** *W« 1*41
UWO«fi&«Wi>
:»»
SSI
vMMmwMr««***« ***t*v
!*« WM> *«**««%«<
**» !» Mft^-l*»*» <**»*
i»<^**»»*TmM^
£
«VI**M «*«**»* m
HMCOTV****-*! "
*« it**»4t*ui«*n«
vnvMt »*
«*»«> t"*"*!^ »**1»
Mt %**«
ISKSSSS
!* «. *t» f«ft,r«* <«, it.
**«> M»**<«ttt*-*t*.
S?
!*
ar
sr
;s
»»
S^jrmnT1
«*«.*
hvM>M><
(iK^MM^
^*1*'*^"1* M-jiiriLL..
]*t»r*»<*1***t»fi
«HJ^->.H >MMM^
ssw""
**r««t -^ t-Mf »«vtn*
H«I»- ttm>Mb«|
IHM.4
V«W^im«l*MMI*T
fv*>««Vft
#< ***-M«|
,..-^^^»
f>~fi>« MMtk^fiini**
j» :* ««m'jM«*Xwwl* M
«** BM I
HW^jM* *»! Mita. v «p«
r'tt v>Mf*M l*.
M«M»«a«M f *
WXWf «W*vW>
«v&^r(**«*"*j|
«
-------
ptn Vie- «t Ihc K-MI7 SrfW Wane Siimp: Arc»-
-------
§
p
Flan View of ihc K-1419 Sludge Trcatmcnl Facility.
------- |