PB94-964003
EPA/ROD/R04-94/169
July 1994
EPA Superfund
Record of Decision:
Paducah Gaseous Diffusion Plant,
Paducah, KY
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DOE/OR/06-1213&D3
Record of Decision
for Interim Action Source Control
at the North-South Diversion Ditch,
Paducah Gaseous Diffusion Plant,
Paducah, Kentucky
March 1994
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DOE/OR/06-1213&D3
Record of Decision
for Interim Action Source Control
at the North-South Diversion Ditch,
Paducah Gaseous Diffusion Plant,
Paducah, Kentucky
March 1994
Prepared by
Science Applications International Corporation
DE-AC05-91OR21950
P.O. Box 9 Kevil, Kentucky 42053
Prepared for
U.S. Department of Energy
Environmental Restoration and Waste Management
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CONTENTS
NOTATIONS vi
Part 1. Declaration for the Record of Decision
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of Selected Remedy
Declaration
Part 2. Decision Summary 1
21 Site Name, Location, and Description 2
2.2 Site History and Enforcement Activities 5
23 Highlights of Community Participation 9
2.4 Scope and Role of Operable Unit or Response Action 10
This Response Action and the Site Management Strategy 10
Future Response Actions Associated with this Response Action 11
2.5 Operable Unit Characteristics 11
Contaminant Characteristics 11
Radioactive Contaminants 11
Non-radioactive Contaminants 13
2.6 Summary of Site Risks 14
2.7 Description of Alternatives ."15
Alternative 1 - No Action 16
Alternative 2 - Source controls, institutional controls and
engineering controls 16
Alternative 3 - Source controls, institutional controls and
engineering controls including the installation of a pipeline and lift
station 16
Alternative 4 - Source controls and institutional controls 16
2.8 Summary of the Comparative Analysis of the Interim Alternative 17
Overall Protection of Human Health and the Environment 19
Compliance with ARARs 20
Long-term Effectiveness and Permanence 20
Reduction of Toxicity, Mobility, or Volume through Treatment 20
Short-term Effectiveness 20
Implementability 21
Cost ,.21
State Approval 21
Community Acceptance 21
2.9 Selected Remedy 22
2.10 Statutory Determination 24
Protection of Human Health and the Environment 25
Compliance with ARARs 25
Chemical-Specific ARARs 27
Action-Specific ARARs 33
Location-Specific ARARs 36
Cost Effectiveness 36
11
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Utilization of Permanent Solutions and Alternative
Treatment Technologies 36
Preference for Treatment as a Principle Element 36
2.11 Documentation of Significant Changes 37
Part 3. Responsiveness Summary 38
3.1 Responsiveness Summary Introduction 39
32 Summary and Response to Local Community Concerns 40
3.3 Comprehensive Response to Specific Legal and Technical
Comments 41
111
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FIGURES
Figure 1. PGDP Vicinity Map 3
Figure 2. Area Map, Paducah Gaseous Diffusion Map 4
Figure 3. Selected Interim Remedial Action for the North-South Diversion Ditch.. 6
Figure 4. Weekly Flow Measurements in the North-South Diversion Ditch 7
Figure 5. Example of a Gabion 23
IV
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TABLES
Table 1. 1991-1993 Weekly Flow Measurements in the
North-South Diversion Ditch 8
Table 2. Comparison of Potential Alternatives 18
Table 3. Estimated Cost of Source Control Action 24
Table 4. ARARs for the North-South Diversion Ditch Project Area to be Covered
from Virginia Avenue to C-616-C Lift Station Record of Decision 28
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NOTATIONS
The following list of acronyms, and abbreviations are provided to assist in the
review of this document. Acronyms used in Tables only are defined in those
respective tables.
AGO
AEA
ANSI
AR
ARARs
CERCLA
C.F.R.
DCG
DOE
EQs
EPA
GM
HSP
HSWA
K.A.R.
K.R.S.
KDEP
KPDES
MCL
MM US
NCP
NRC
NSDD
PCBs
pCi/g
pCi/1
PGDP
RCRA
ROD
SARA
SDWA
SMP
TBC
"Tc
230Th
TSCA
TSS
235U
ACRONYMS AND ABBREVIATIONS
Administrative Order by Consent
Atomic Energy Act of 1954, as amended
American National Standards Institute
administrative record
applicable or relevent and appropriate requirements
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended
Code of Federal Regulations
derived concentration guides
U.S. Department of Energy
ecological quotients
U.S. Environmental Protection Agency
Geiger Miiller
Health and Safety Plan
Hazardous and Solid Waste Amendments
Kentucky Administrative Record
Kentucky Regulatory Statutes
Kentucky Department for Environmental Protection
Kentucky Pollutant Discharge Elimination System
maximum contaminant level
Martin Marietta Utility Services, Inc.
National Oil and Hazardous Substances Pollution Contingency Plan
neptunium 237
Nuclear Regulatory Commission
North-South Diversion Ditch
polychlorinated biphenyls
picocuries per gram
picocuries per liter
Paducah Gaseous Diffusion Plant
plutonium 239
Resource Conservation and Recovery Act, as amended
record of decision
Superfund Amendments and Reauthorization Act of 1986
Safe Drinking Water Act
Site Management Plan
to be considered
technetium 99
thorium 230
Toxic Substances Control Act
total suspended solids
uranium 235
VI
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DECLARATION FOR THE RECORD OF DECISION
FOR INTERIM ACTION SOURCE CONTROL
AT THE NORTH-SOUTH DIVERSION DITCH
SITE NAME AND LOCATION
North-South Diversion Ditch
Paducah Gaseous Diffusion Plant
Paducah, Kentucky
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim action for the North-South Diversion
Ditch (NSDD) at the Paducah Gaseous Diffusion Plant (PGDP) in Paducah, Kentucky, chosen
in accordance with the Resource Conservation and Recovery Act of 1976 (RCRA),
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA) and the National Oil and Hazardous Substances Contingency Plan (NCP). This
decision is based on the administrative record documentation file for this site.
The PGDP was proposed for inclusion on the National Priorities List (NPL) on May 10, 1993,
and was issued a Kentucky Hazardous Waste Permit and Environmental Protection Agency
Hazardous and Solid Waste Permit on July 16, 1991. On January 28, 1993, the U.S.
Department of Energy (DOE) was directed by the Kentucky Department for Environmental
Protection (KDEP) and the U.S. Environmental Protection Agency (EPA) to submit a work
plan to implement an interim measure at the NSDD. This interim action will be initiated
pursuant to the Interim Measure provisions of PGDP's Kentucky Hazardous Waste Permit
issued by the Kentucky Division of Waste Management, the Hazardous and Solid Waste
Permit issued by the Environmental Protection Agency and this Record of Decision. The
Division of Waste Management concurs with the DOE and the EPA on the selected interim
action, in accordance with the requirements of the Kentucky Hazardous Waste Permit. This
action will serve as an incremental step toward comprehensively addressing site problems.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the North-South Diversion
Ditch, if not addressed by implementing the response action selected in this Record of
Decision (ROD) /for:,Interim Action, may present an imminent and substantial
endangerment to puhjil^health, welfare, or the environment.
DESCRIPTION OF SELECTED RJEMEDY
- ' '"""'*-
The primary objective of this interim remedial action is to initiate control of the source 'of
continued contaminant releases into the NSDD and mitigate the spread of contamination
from the NSDD. The surface water system at PGDP will be addressed comprehensively in a
subsequent operable unit (hereinafter defined as the "Surface Water Integrator Operable
Unit"). The NSDD is one part of the Surface Water Integrator Operable Unit. This interim
action at the NSDD constitutes an incremental step towards comprehensively addressing
site-wide problems. This action will mitigate the introduction of contaminants into the
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NSDD, decrease the migration of contaminants already present in the NSDD, and decrease
the potential for direct contact with the contaminated material. Final remedial decisions for
the NSDD and the surface water integrator operable unit will be made through the remedial
investigation and remedy selection process after the nature and extent of contamination in
the surface water system and the contribution of contaminants into the surface water
system from source operable units are more fully understood.
The- principal threats associated with the NSDD are the potential for transport of
contaminants to offsite areas, continued contaminant releases into the NSDD, and the
potential for worker exposure to contaminants within the NSDD. The major components
of the interim action remedy include:
The effluent discharged from the C-400 Cleaning Building shall be treated to
reduce radionuclide concentrations. PGDP shall install an ion exchange filtration
unit in the C-400 Cleaning Building to reduce radionuclides- concentrations in the
effluent before it is discharged into the ditch. The proposed ion exchange unit
will require a calibration period of six months or more after installation in order
to optimize the removal of the radionuclides. The target treatment level for
radionuclides will be the Safe Drinking Water Act and Kentucky Public and
Semi-Public Drinking Water Regulations Maximum Contaminant Levels (MCL).
The treatment level will be re-evaluated through the baseline risk assessment
and remedy selection process to be conducted to determine the final remedial
action for the NSDD and Surface Water Integrator Operable Unit.
The effluent from the C-600 Steam Plant shall be treated to remove fly ash from
the effluent prior to discharge to the NSDD. Fly ash which accumulates in the
NSDD may potentially become cross contaminated due to other materials in the
ditch and would subsequently increase the volume of contaminated material
which may need to be addressed in a future final action. Settling lagoons will be
used for source control treatment of the C-600 steam plant fly ash effluent.
However, final design of the fly ash source control may be modified as the
detailed design process proceeds.
Lift station(s) shall be installed in the NSDD near the C-400 Building and C-600
Steam Plant. The lift station(s) shall discharge into a pipeline to transport
permitted effluent discharges and storm water runoff from the southern end of
the NSDD to the Ditch 001 Lift Station. The installed pipeline will discharge into
the NSDD by the Outfall 001 Lift Station. This will bypass approximately 50% of
the existing NSDD, thereby reducing the potential for mobilizing contaminated
sediments in the vicinity of the NSDD. Elimination of a constant flow of effluent
and storm water through the bypassed portion of the NSDD will also reduce the
amount of contaminated surface water available for infiltration into the ground
water. This reduced infiltration will also mitigate leaching from the existing
contaminated sediments and soil into the ground water.
A gabion type rock structure with nonwoven geotextile" material secured to the
upstream side shall be installed near the Ditch 001 Lift Station. This sediment
trap will mitigate the potential for contaminant transport from the Bypassed
portion of the NSDD to offsite areas.
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Warning signs shall be installed at intervals not to exceed 100 feet, on both sides
of the ditch, from Virginia Avenue to the C-616 Lift Station. These signs shall
give notice that elevated levels of radionuclides, metals, and PCBs are present in
the area.
The KDEP and EPA have participated in the development of the ROD, including review
and comment on the content of the document. All KDEP and EPA comments issued to DOE
have been incorporated into the ROD.
DECLARATION
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;
complies with federal and state applicable or(relevant and appropriate requirements for the
scope of this limited action, and is cost effective. Although this interim action is not
intended to fully address the statutory mandate for permanence and treatment to the
maximum extent practicable, this interim action does utilize treatment and thus is in
furtherance of that statutory mandate. Although partially addressed in this remedy, the
statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principle element will be addressed by both this and the final response action.
Subsequent actions are planned to address fully the principal threats posed by the conditions
at this site. Because this remedy will result in hazardous substances remaining onsite above
health based levels, a review will be conducted within five years after commencement of
the remedial action and every five years thereafter until a final remedial alternative is
selected and implemented for this unit. These reviews will be conducted to ensure that the
selected remedy continues to provide adequate protection of human health and the
environment. Because this is an Interim Action ROD, review of this unit and of this
remedy will be ongoing, as DOE continues to develop final remedial alternatives for the
North-South Diversion Ditch and the Surface Water Integrator Operable Unit.
V
.Date..
William D. Adams
Assistant Manager, Environmental Restoration and Waste Management
U.S. Department of Energy
Date
John H. Hankinson, ]r'
Regional Administrator
U.S. Environmental Protection Agency, Region IV
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PART 2
DECISION SUMMARY
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DECISION SUMMARY
2.1 Site Name, Location, And Description
The United States Department of Energy (DOE) is conducting cleanup activities at the
Paducah Gaseous Diffusion Plant (PGDP) under its Environmental Restoration and
Waste Management Program. These cleanup efforts are necessary to address
contamination that has resulted from historic operation of the plant. Remedial
activities are being conducted in consultation with the Commonwealth of
Kentucky's Division of Waste Management and the United States Environmental
Protection Agency (EPA).
The Paducah Gaseous Diffusion Plant (PGDP), located in Western Kentucky (Figure
1), is an active Uranium Enrichment facility which is owned by DOE. Effective July 1,
1993, DOE leased the plant production operation facilities to the United States
Enrichment Corporation (USEC) which in turn contracted with Martin Marietta
Utility Services, Inc. (MMUS) to provide operations and maintenance services.
Martin Marietta Energy Systems, Inc. manages the environmental restoration and
waste management activities for DOE at PGDP.
The PGDP is an active uranium enrichment facility which supplies fuel for
commercial reactors. Construction of the plant began in 1951, and started operating
in 1952. The PGDP uses gaseous diffusion to provide a physical separation process
which allows for enrichment of the uranium. Commercially produced uranium
hexafluori.de (UF6) is composed primarily of uranium-238 (238U), and a small
percentage of uranium-235 (^U). The gaseous diffusion process is premised on the
fact that UF6 with fissionable 235U is slightly lighter than UF6 with 238U. Therefore, as
the UF6 passes through the gaseous diffusion plant's cascade system, separation of
235U from 238U takes place. This separation results in enriched uranium (slightly
higher percentage of 235U). This enriched uranium is then transported to other DOE
facilities for further enrichment.
The PGDP is situated on a 1,350 acre reservation (Figure 2) approximately four miles
south of the Ohio River and about ten miles west of Paducah, Kentucky.
Approximately 740 acres of the reservation are within a security area and buffer zone
which has restricted access to the general public. Beyond the DOE-owned buffer zone
is an extensive wildlife management area of approximately 6,000 acres.
The PGDP is located within the drainage basins of Big Bayou and Little Bayou Creeks,
which meet about three miles north of the site and discharge into the Ohio River.
Big Bayou Creek, which flows along the western boundary of the plant, is a perennial
stream with drainage extending from approximately two and one-half miles south of
the plant to the Ohio River. Little Bayou Creek, which originates in the West
Kentucky Wildlife Management Area (WKWMA), flows north toward the Ohio
River along a course that includes sections of the eastern boundary of the plant.
During dry weather, much of the flow in both creeks is due to controlled effluent
releases from PGDP. The North-South Diversion Ditch (NSDD) originates within
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WILDLIFE MANAGEMENT AREA
PGDP
DOE RESERVATION
MUNICIPALITY
TVA
MUNICIPAL WATER SUPPLY WELLS
(Kevil, KY and Metropolis, IL)
Paducah Gaseous Diffusion Plant
Paducah, Kentucky
Figure 1. PGDP Vicinity Map
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1OOO 2OOO 3OOO 4OOO 5OOO
FEET
Figure 2. Area Map, Paducah Gaseous Diffusion Plant
4
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the plant boundaries and joins with Little Bayou Creek to the north of the plant.
Both creeks flow through the wildlife management area and may potentially be used
for recreational purposes. However, neither creek is currently used as a drinking
water source.
The PGDP is located within the Jackson Purchase region of Western Kentucky. The
ground water in the area of the plant consists of the Regional Gravel Aquifer located
within the Lower Continental Deposits and the McNairy Flow System.
2.2 Site History and Enforcement Activities
The NSDD is located in the north central portion of the security area (Figure 3). The
portion of the ditch within the security area is approximately 2600 feet long and
varies in width from 15 to 36 feet. The .depth ranges from one-half to 5 feet. The
portion of the NSDD located within the security fence, flows from Virginia Avenue
to the C-616-C Lift Station. The ditch receives stormwater runoff from the steam
plant (C-600), process buildings (C-335 and C-337), cooling tower (C-635), and the
switchyards (C-535 and C-537). The NSDD also receives wastewater from the cleaning
building (C-400) and residual fly ash with associated metals from the steam plant (C-
600). Weekly flow measurements for the NSDD for the period of January 1991
through October 1993 are presented in Table 1 and Figure 4.
The NSDD receives wastewater containing radionuclides from the cleaning building
(C-400). The soil and sediment in the ditch has been contaminated by radionuclides
and polychlorinated biphenyls (PCBs). Potential sources of PCB contamination
include dust palliative areas surrounding the nearby cascade buildings (C-335 and
C-337), a pipeline and vault area southwest of the ditch (C-616-L) and the switchyards
(C-535 and C-537).
The DOE in the role of "Lead Agency," as defined in the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), is conducting cleanup activities at
PGDP under its Environmental Restoration and Waste Management Program.
Pursuant to Executive Order No. 12580, 3 C F R 193 (1987), 53 Fed. Reg. 2923 (January
29, 1987), the Lead Agency is required to assume responsibility for ensuring that
sufficient action is taken to cleanup its sites m order to provide protection for
human health and the environment. Remedial activities are being conducted in
consultation with the Commonwealth of Kentucky and the EPA.
In the fall of 1988, EPA and DOE entered into an "Administrative Order by Consent"
(ACO) under Sections 104 and 106 of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLAi, as amended, to address offsite
contamination from PGDP. Pursuant to the ACO. PGDP conducted an investigation
to determine the nature and extent of contamination. Results of this effort were
published in a document entitled Results of the $tte Investigation, Phase I (KY/ER-4,
March 1991). A subsequent investigation sought to further characterize the extent of
contamination. Results of this investigation were published in Draft Results of the
Site Investigation, Phase II (KY/SUB/13B-97777CP-03/1991/1, October 1991). A
revised version of this document was submitted to EPA and the Commonwealth of
Kentucky in April 1992. Alternatives for remediation were identified, evaluated, and
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" PropowdPlp.no. L"t Station
Proposed » ^^
Settling Lagoons . ^"
i\ C-616-L
UH Station
Figure 3. Selected Interim Action for the North-South Diversion Ditch
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Weekly Flow Measurements in the NSDD
From 1/7/91 to 10/25/93
6000-r
5500
5000-..
.a'
I
1/7/91 4/1/91 6/24/91 9/23/91 12/16/91 3/9/92 6/8/92 9/8/92 11/16/92 2/16/93 5/17/93 8/9/93
DATE
Figure 4. Weekly Flow Measurements in the North-South Diversion Ditch
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1991-1993 Weeky Flow Measurements in the NSDD
Date Flow mGD
1/7/91 169
1/14/91 120
1/21/91 109
1/28/91 98
2/4/91 98
2/11/91 68
2/19/91 109
2/25/91 109
3/4/91 88
3/11/91 98
3/18/91 98
3/25/91 88
4/1/91 77
4/8/91 169
4/15/91 120
4/22/91 68
4/29/91 77
5/6/91 68
5/13/91 88
5/20/91 908
5/28/91 908
6/3/91 20
6/10/91 50
6/17/91 68
6/24/91 59
7/1/91 169
7/8/91 59
7/15/91 77
7/22/91 132
7/29/91 59
8/5/91 15
8/12/91 59
8/19/91 169
9/3/91 109
9/9/91 88
9/16/91 98
9/23/91 795
9/30/91 666
10/7/91 817
10/14/91 1080
10/21/91 326
10/28/91 1030
11/4/91 432
11/11/91 1000
11/18/91 1410
11/25/91 908
12/2/91 5090
12/9/91 1150
12/16/91 908
12/23/91 1030
12/30/91 817
1/6/92 1030
1/13/92 862
1/20/93 1030
1/27/92 908
2/3/92 ' 908
2/10/92 840
2/18/92 625
2/24/92 955
3/2/92 908
3/9/92 795
3/16/92 955
3/30/92 1690
4/6/92 885
4/13/92 88
4/20/92 109
4/27/92 955
5/4/92 931
5/11/92 88
5/18/92 98
5/26/92 109
6/1/92 88
6/8/92 77
»
6/15/92 88
6/22/92 109
6/29/92 109
7/6/92 88
7/13/92 109
7/20/92 88
7/27/92 120
8/3/92 120
8/10/92 109
8/24/92 120
8/31/92 120
9/8/92 144
9/14/92 169
9/21/92 283
9/14/92 169
9/21/92 283
9/28/92 169
10/5/92 169
10/12/92 169
10/19/92 908
10/26/92 908
11/2/92 1280
11/9/92 1410
11/16/92 1290
11/23/92 1550
11/30/92 800
12/7/92 908
12/14/92 1300
12/21/92 1410
12/28/92 1150
1/4/93 5510
1/11/93 1230
1/25/93 1920
2/1/93 1410
2/8/92 862
2/16/93 1380
2/22/93 1030
3/1/93 1130
3/8/93 908
3/15/93 955
3/22/93 1150
3/29/93 979
4/5/93 979
4/8/93 795
4/19/93 908
4/26/93 1030
5/3/93 1150
5/17/93 144
5/24/93 1230
6/1/93 1030
6/7/93 1030
6/14/93 1030
6/21/93 144
6/28/93 109.-
7/7/93 169
7/12/93 452
7/19/93 955
7/26/93 169
8/2/93 120
8/9/93 80
8/16/93 182
8/23/93 209
8/30/93 315
9/7/93 253
9/13/93 283
9/20/93 330
9/27/93 315
10/4/93 1300
10/11/93 1280 '
10/18/93 1150
10/25/93 1150
Table 1. 1991-1993 Weekly Flow Measurements in the North-South Diversion Ditch
8
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published in the document Draft Summary of Alternatives for Remediation of
Offsite Contamination at the Paducah Gaseous Diffusion Plant (DOE/OR-1013,
December 1991). Additional specific information on the NSDD is available in the
Interim Corrective Measures Work Plan for the North-South Diversion Ditch
Virginia Avenue to C-616-C Lift Station (September 1993).
On July 16,1991, EPA and the Commonwealth of Kentucky jointly issued permits
under the Resource Conservation and Recovery Act (RCRA), as amended by the
Hazardous and Solid Waste Amendment of 1984 (HSWA). The EPA permit contains
only provisions of HSWA, while the Commonwealth of Kentucky permit contains
provisions to address hazardous waste management as well as provisions similar to
HSWA. The HSWA provisions require evaluation of hazardous constituent releases
and implementation of interim and final corrective measures to address such
releases.
On May 10,1993, the PGDP was proposed for inclusion on the National Priorities List
(NPL). The identification of a site on the NPL indicates that a site warrants further
investigation to assess the nature and extent of the public health and environmental
risks associated with the site and to determine what CERCLA remedial actions may
be appropriate. Federal facilities, such as the PGDP, may be placed on the NPL even if
they are also subject to the corrective action mandates of RCRA Subtitle C. Therefore,
environmental restoration activities must satisfy both CERCLA and RCRA
corrective action requirements.
2.3 Highlights of Community Participation
On November 7, 1993, a notice of availability was published in The Paducah Sun, a
regional newspaper, regarding the Proposed Plan. This notice appeared in The
Paducah Sun from November 7 until November 14, 1993. The Proposed Remedial
Action Plan for Source Control at the North-South Diversion Ditch was released to
the public on November 8, 1993. The plan was made available for public review at
the Paducah Public Library and the offsite Administrative Record Center located in
Kevil, Kentucky at the West Kentucky Technology Park. A public comment period
was held November 8,1993 through December 8,1993.
Specific groups that received individual copies of the Proposed Plan included the
local PGDP Neighborhood Council, Natural Resource Trustees, and the PGDP
Environmental Advisory Committee. Informal meetings were held with the PGDP
Neighborhood Council and PGDP Environmental Advisory Committee on
December 9, 1993 and December 13, 1993, respectively. At these meetings, DOE
personnel briefed the groups on the proposed action and solicited both written and
verbal comments.
Phone calls and/or visits were made to various stakeholders, including neighbors
and representatives of environmental groups, to advise them of the public comment
period and briefly explain the Proposed Plan. Proposed Plans were mailed to those
contacted. A response to the comments received during the public participation
period is included in the Responsiveness Summary, which is part of this Record of
Decision.
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The Proposed Plan contained a notice of the availability of a public meeting to
discuss the NSDD and proposed actions. However, no requests for a public meeting
were received.
This decision document presents the selected interim remedial action for the NSDD
at PGDP, chosen in accordance with CERCLA, as amended by the Superfund
Amendments and Reauthorization Acts of 1986 (SARA), EPA and Commonwealth
of Kentucky permits issued under RCRA, as amended by HSWA, and the NCP. The
decision for this interim action at this site is based on administrative record (AR)
documentation.
2.4 Scope and Role of Operable Unit or Response Action
This Response Action and the Site Management Strategy
The PGDP presents unusually complex problems in terms of hazardous waste
management and environmental releases. Therefore, a Site Management Plan
(SMP) has been drafted to specify the strategy for investigating and remediating
hazardous substance releases at the site. The draft SMP is currently being revised
following review by EPA and the Commonwealth of Kentucky. The proposed
strategy in the draft SMP is to divide the site into operable units grouped by source
areas and environmental media. Discrete response actions will be selected and
implemented for each operable unit to address the source areas (i.e., source operable
units) and the environmental media (i.e., integrator operable units) impacted "by
commingled releases from source operable units. Prioritization in the draft SMP for
investigation and possible interim remedial actions have been assigned to each of
the integrator operable units and source operable units depending on their potential
for contributing to offsite contamination. Because integrator units serve as migration
pathways that transport contamination from source operable units to offsite
receptors, they receive the highest priority for undergoing initial evaluation and
interim actions.
Consistent with the site management strategy described in the draft SMP, this action
is intended as an incremental step toward addressing the surface water system
integrator operable unit. The NSDD contributes to offsite surface water
contamination that may continue to migrate and contaminate clean resources and
potentially expose additional offsite receptors The primary objective of this interim
action is to stabilize the NSDD through decreasing the levels of contamination
entering the NSDD and decreasing the migration of contaminants from the NSDD.
By implementation of this interim action, increased stabilization of the site will be
achieved, while a final remedy for the Surface Water Integrator Operable Unit is
being developed.
The source control measures in this record of decision (ROD) constitute the first
phase in remediation of the NSDD and aKo. a step toward comprehensive
remediation of the surface water integrator operable unit. This action can be rapidly
implemented while remedial investigations can be conducted for the remainder of
the NSDD and Surface Water Integrator Operable Unit. This phased approach is
consistent with the NCP, which advises initiation of early actions as soon as possible
10
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after a problem is identified for which an early action is appropriate, and early
actions should be coordinated with final remedies such that they are the first phase
of the overall remedial action.
Future Response Actions Associated with this Response Action
The remedial action described by this ROD is not the final action for NSDD.
Following issuance of the ROD for this source control measure, a remedial
investigation will be initiated to evaluate additional remedial alternatives to
implement a final remedy which will provide definitive protection of human
health and the environment. This remedial investigation will be consistent with the
requirements of both the draft SMP and the draft Federal Facility Agreement being
developed by the DOE, EPA, and KDEP. This study may lead to a Proposed Plan for a
second interim action and/or a final actio'n for the NSDD or the entire Surface Water
Integrator Operable Unit.
Although a site investigation, public health and ecological assessment, and an
alternative evaluation was performed for the PGDP site as a whole, a final action
cannot be recommended until further characterization activities have been
completed. Before a final action can be recommended for the NSDD portion of the
surface water integrator operable unit, a baseline risk assessment must be completed
for the surface water integrator operable unit, including ecological risk. Additionally,
a more complete characterization of the NSDD needs to be performed and the
interaction of all source operable units with the surface water integrator operable
unit must be better defined. Although additional data will be needed before the
selection of a final action, sufficient information is available to support the interim
remedial action presented in this document. This interim action should not be
inconsistent with nor preclude implementation of any currently anticipated final
remedy.
2.5 Operable Unit Characteristics
Contaminant Characteristics
Environmental samples obtained from the NSDD have identified contaminant
levels that indicate a need for interim action. These sampling events include the
collection of: six sediment/soil samples and two surface water samples that were
collected as part of the Phase I and Phase II Site Investigations, and a radiological
walkover survey to assess gross radionuclide contamination and to identify
radiological hot spots. As part of the PGDP monitoring operations, weekly water
samples are taken from the NSDD near the C-616-C Lift Station and samples from
the uranium recovery unit filtrate solution in the C-400 Building are characterized.
prior to release into the NSDD.
Radioactive Contaminants
The data collected indicate that the NSDD may contribute to offsite "Tc and
uranium (U) contamination of the surface water and sediment. The data also
suggests that the NSDD is potentially contributing to offsite ground water
11
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contamination. Technetium-99 has been detected in onsite and offsite ground water
at concentrations above 1,000 Ug/1. Technetium-99 in the NSDD has been recorded at
levels as high as 45315 picocuries per gram (pCi/g) in the soil and 139 picocuries per
liter (pCi/1) in the surface water. Samples from the uranium recovery unit filtrate
solution in the C-400 Building have recorded levels of "Tc from 81,000 pCi/1 to
170,000 pCi/1. Although the levels of "Tc are below DOE Order 5400.5 Radiation
Protection to the Public and the Environment derived concentration guidelines of
100,000 pCi/1 at the permitted Kentucky Pollutant Discharge Elimination System
(KPDES) outfalls, the levels may be contributing to the offsite ground water "Tc
contamination. However, the derived concentration guideline for "Tc was
developed to protect aquatic organisms, not human beings. The current federal and
state maximum contaminant level (MCL) for beta emitters in drinking water,
including "Tc, is 4 mrem/yr. The effluent from the uranium recovery unit typically
exceeds these limits. The derived concentration guideline of 100,000 pCi/1 is
equivalent to a dose of 1 rad per day.
Monitoring of the surface water in the NSDD has also detected elevated levels of
total uranium, beta radiation and alpha radiation. Concentration of alpha radiation,
measured as total alpha emitters in pCi/1, have exceeded the MCL of 15 pCi/1.
Measured total uranium levels have exceeded the proposed MCL of 20 micrograms
per liter (p.g/1). While the NSDD is not a source of drinking water, comparison with
criteria such as drinking water MCLs provides an indicator of the potential site risks
and potential impacts on the local shallow ground water system. Radionuclides
concentrations in the surface water fluctuated only slightly along the length of the
NSDD.
A radiological survey of the NSDD was conducted as part of the Phase I Site
Investigation in March, 1990. The radiological survey consisted of the three
following activities: a walkover survey of each bank of the NSDD using high
efficiency gamma scintillation detectors; ground-contact, open-window, and closed-
window measurements at 500-foot intervals along each bank of the NSDD using
thin-end window Geiger-Miiller (GM) detectors; and soil sampling at two
background stations and five stations where the surveys indicated elevated
radioactivity on the banks of the creeks and ditches. An additional sediment sample
was collected during the Phase II Site Investigation. During the walkover survey,
readings which were often more than 3 times background were found.
Sediment and soil samples were taken from the NSDD by PGDP personnel in
November, 1988. The seven samples were analyzed for total U, 235U, "Tc, 239Pu,
^Np, and 230Th. Levels of the analyzed radionuclides were found to be as high as:
U - 118 pCi/g, 23»Pu - 4.3 pCi/g, ^U - 0.71 wt. percent, ^Np - 42.2 pCi/g, "Tc - 45,315
pCi/g, ^OTh -106 pCi/g.
The level of radionuclides, especially "Tc, decreased significantly from a high
reading around the C-400 Building (45,315 pCi/g) to a low reading near the NSDD 001
Lift Station (no detect). Elevated beta and gamma levels were observed at most
locations during the ground-contact open-window and closed window GM detectors.
12
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The highest levels of radionuclides were detected at a isolated hot spot about 4 feet
from the storm drain located between Virginia Avenue and the NSDD (across from
the C-400 Building). The location adjacent to the C-400 Building discharge pipe
suggests the discharge from the C-400 is the source of the hot spot. The boundary of
this area is approximately 227 feet long and 3- to 15-feet wide. The gamma walkover
readings at this hot spot measured 30,000 to 120,000 cpm (counts per minute) which
is approximately 3 to 12 times the average background reading. The GM
measurements were approximately 1,800 gross cpm (unshielded) which is up to 45
times greater than the average background reading.
Filtrate samples are taken from the Uranium Recovery Unit located inside the C-400
Building prior to the release of the fluid into the NSDD. As of March 12, 1993, the
discharge of effluent from the C-400 Uranium Recovery has been halted by DOE
until a treatment alternative can be implemented.
Non-radioactive Contaminants
Toluene was found at an estimated concentration of 210 ppb in the NSDD sediments
near the C-400 Building. Toluene could be residual from the C-601 fuel spill of March
9,1979. A total of 17,300 gallons of diesel was inadvertently released and then flowed
to Big Bayou Creek via Ditches 008 and 015. Additionally, trichloroethylene was
detected in one surface water sample in the NSDD.
Initial characterization of the NSDD indicated the presence of Aroclor 1260 (PCB) at
levels as high as 11 ppm. These PCBs probably accumulated in the ditch largely due
to adsorption of the PCBs on the residual coal particles from the C-600 Steam Plant.
Only two of the six sediment/soil samples collected during the Phase I and II Site
Investigations were analyzed for PCBs. Potential sources of PCB contamination
include dust palliative areas surrounding the C-335 and C-337 Cascade Buildings,
SWMU 165, C-616-L Pipeline and Vault contamination area, and the C-535 and C-537
Switchyards.
A PCB surface water characterization project was performed at PGDP by the United
States Army Corps of Engineers during August 1991 to April 1992. This study
evaluated surface water PCB concentrations in an effort to identify PCB sources. The
project included 16 surface water sampling events in both the plant ditches and
storm sewers during both dry and wet periods. The samples were analyzed both for
PCBs, radioactivity, and Total Suspended Solids (TSS). Out of the 461 samples taken,
only 19 had detectable (greater than 0.1 ppb) PCBs present. The surface water data did
not detect any identifiable source of PCB contamination nor did the PCB detects
correlate with the TSS in the sample. There were no PCB detects downstream of
PGDP outfalls in both Big and/or Little Bayou Creeks. The samples which relate to .
the NSDD were taken in Ditch 001 before being lifted into the NSDD and in Ditch 001
after it leaves the C-616-F Full Flow Lagoon. There were no PCB detects downstream
of the C-616-F Full Flow Lagoon. PCBs were detected in one sample (0.17 ppb) in
Ditch 001 prior to being lifted into the NSDD. However, there were no corresponding
detects in the other three downstream sampling points.
13
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Sampling data on surface water and sediments in the NSDD show elevated levels of
some metals. These metals are most likely associated with the fly ash that
accumulates in the NSDD. The level of metals present in the surface water will be
evaluated through the remedy selection process for the final ROD for the NSDD and
the Surface Water Integrator Operable Unit.
2.6 Summary of Site Risks
The 1991 Draft Results of the Public Health and Ecological Assessment, Phase II
(PHEA), found that the critical exposure pathway is related to the offsite migration
of onsite contaminant sources. The PHEA also recommended action to eliminate the
offsite migration of these contaminants to the outside of the Paducah Gaseous
Diffusion Plant's boundaries and recommended remedial action to eliminate this
offsite movement. Based on the preliminary results of these studies, DOE, EPA, and
Kentucky Department for Environmental Protection (KDEP) have decided that there
is sufficient potential risk to the public and environment to warrant this action. The
principal goals of this interim remedial action are to implement source control
measures which will mitigate the introduction of contaminants into the ditch,
decrease the migration of the contaminants which are present in the ditch, and
decrease the potential for direct contact of contaminated material. Accomplishment
of these goals will help stabilize and mitigate further environmental degradation
within, and downgradient to, the NSDD.
Site investigations involving surface water and sediment indicated various
contaminants at the NSDD which may pose a risk to human health and the
environment at PGDP. The NSDD is located within the confines of the PGDP
security fence and is accessible to any person with site access. The following
contaminants were detected during site investigations: Trichloroethylene, PCBs,
chromium, copper, nickel, vanadium, and zinc; and in the sediment: chromium,
copper, zinc, cobalt, manganese, selenium, thallium, and vanadium.
The following radioactive elements have been released into the NSDD: Technetium-
99, Plutonium 239, Thorium 230, Neptunium 237, Uranium 234, Uranium 235, and
Uranium 238. Elevated levels of radionuclides have been measured in the surface
water and sediment within the NSDD.
If no interim action were taken to address the NSDD, the potential exists for
exposure of plant maintenance personnel to the contaminants within the ditch
through their routine activities. To estimate risk assume that the maintenance
worker is exposed for 4 hours per event, 12 times per year, over a 25-year exposure
period. Complete exposure pathways assessed for the current maintenance worker
include direct gamma irradiation from contaminated sediment and soil, dermal
contact with soil, sediment and debris, inhalation of re-suspended particulate during
mowing, and incidental ingestion of contaminated surface water, soil, and sediment.
The estimated carcinogenic risk for maintenance worker scenario evaluated in this
assessment is 1 x 10"4, which has been determined by the EPA to be an unacceptable
risk level. The majority of this risk is associated with particulate inhalation of
radiological contaminants during mowing. Hazard quotients calculated for the
14
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exposure pathways were all less than 1, indicating that the exposure intakes are less
than the reference doses (RfDs) and the potential for lexicological harm is low.
Species of terrestrial and aquatic organisms reported to reside at, or visit, the site, and
which can be expected to reside at or visit the site in the future, include various soil
and sediment dwelling invertebrates (e.g., earthworms, chironomids), aquatic and
terrestrial insects and their larvae, frogs and salamanders, small mammals (e.g.,
hawks). Larger terrestrial mammals and fish are not currently present at the site and
there are no known Federal or State threatened or endangered species located within
the PGDP perimeter area.
When evaluating the exposure of aquatic and terrestrial biota to contaminants of
potential concern from site sources; soil, surface water, and sediment will be
considered the primary environmental exposure media. Complete exposure
pathways for aquatic organisms include contact with and ingestion of water and
sediment, or by direct ingestion of biota. Terrestrial organisms are exposed to
contaminants in the soil through ingestion of soil where sediments and surface
water have overflowed from the NSDD during floods or through ingestion of
contaminated organisms. Uptake of contaminants by plants can lead to subsequent
exposure to herbivores and omnivores from ingestion of contaminated vegetation.
The risk assessment for metals, PCBs, and volatile organic chemicals relies on
aquatic and sediment toxicity data; there is no toxicity data for the contaminants of
potential concern in soil. When the observed concentrations in the environment
were compared to toxicity threshold concentrations, 11 of the 27 contaminants
emerged as the contaminants of potential concern: Chloroform, Aroclor 1260, and 9
metals. The ecological quotients (EQs) for those contaminants of potential concern
for which EQs could be calculated ranged from 1 to 922. Barium (922), Aroclor 1260
(220), aluminum (18), and cobalt (25) had the highest EQs in sediments at the NSDD.
The highest EQ for a contaminant of potential concern in surface water was 4 for the
metal copper. The risk from radionuclides and chloroform in surface water could
not be calculated because there was no toxicity data to establish a toxicity threshold.
The contaminants of potential concern in sediment and surface water with large EQs
strongly suggest that, in the absence of remediation, populations of aquatic
organisms living in the NSDD will continue to he at nsk from adverse effects likely
to reduce population sizes. Predators of aquatic organisms may be at equivalent
levels of risk due to bioaccumulation of PCB* The risk to terrestrial organisms
exposed to contaminants in the soils adjoining the NSDD is due to radionuclides,
the ecological effects of which are uncertain due to the absence of terrestrial wildlife
toxicity data.
2.7 Description of Alternatives
Four separate alternatives are considered for source control of the NSDD. Federal
law requires the consideration of a no action alternative which is Alternative 1.
Three additional alternatives consider combinations of treatment, engineering
controls and institutional controls. The screening and evaluation process identified
one alternative that will quickly and effectively reduce risk by controlling the spread
15
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of contamination in and near the NSDD and reduce the potential for further
contamination entering the ditch.
Alternative 1 - No Action
Pursuant to 40 C.F.R. 300.430(e)(6) of the NCP, DOE is required to consider a no action
alternative. This alternative is useful as a baseline for comparison between potential
alternatives. Under this alternative no further action would be taken.
Alternative 2 Source controls, institutional controls and engineering controls
This alternative includes the following four separate actions: (1) institutional
controls utilizing posted warning signs that will notify PGDP personnel that the
NSDD contains elevated levels of radionuclides, PCBs and metals; (2) construction of
a silt trap gabion just beyond the contaminated portion of the NSDD; (3) construction
of an ion exchange unit inside the 0-400 Building that will reduce the levels of
technetium and other radionuclides in the effluent discharged to the NSDD by the
Uranium Recovery Unit; and (4) construction of a source control treatment for fly
ash removal from the C-600 Steam Plant effluent. Settling lagoons will be used for
source control treatment of the C-600 Steam Plant fly ash effluent. However, the
final design of the fly ash source control may be modified as the detailed design
process proceeds. Further, the location for the effluent discharge will be determined
through the remedial design process by DOE, EPA and the Kentucky Department for
Environmental Protection.
Alternative 3 - Source controls, institutional controls and engineering controls
including the installation of a pipeline and lift station
This alternative includes the four actions listed in Alternative 2 plus .the installation
of a lift station and above ground pipeline to transport runoff and effluent from the
southern end of the NSDD to the area of the Outfall 001 Lift Station located just
beyond the highly contaminated portion of the NSDD. This action will significantly
reduce the buildup and infiltration of contaminated water in the NSDD, mitigate
dispersal of contamination to areas outside of the site, and decrease the potential for
plant personnel to come into contact with the contaminated surface water.
Alternative 4 - Source controls and institutional controls
This alternative includes excavation of the contaminated soil and sediment in the
NSDD and initiates institutional controls by posting warning signs. Initial estimates
indicate that approximately one foot of soil will be excavated over an area of
approximately 74,169 ft2 resulting in the generation of approximately 14,834 drums of.
waste. The drums will require storage until proper treatment and disposal can be
conducted.
The implementation of Alternatives 2, 3, or 4 would have little or no significant
physical effect on the environment. These alternatives would not adversely affect
any wetlands, flood plains, or historic sites. All of the alternatives could be
implemented within 17 months. This time period includes design by DOE with
16
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approval by EPA and KDEP and the bid and award process as required by federal
regulations.
2.8 Summary of the Comparative Analysis of the Interim Alternative
This section provides the basis for determining which alternative (i) meets the
threshold criteria of overall protection of human health and the environment, state
approval, and compliance with applicable or relevent and appropriate requirements
(ARARs), and (ii) provides the best balance between effectiveness and reduction of
toxicity, mobility, or volume through treatment, implementability, and cost, and (iii)
satisfies community acceptance. A summary of the comparative analysis of
alternatives is included in Table 2.
Nine criteria are required by 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. Because this action is intended to
integrate both RCRA and CERCLA requirements, state approval has been substituted
for state acceptance and listed as one of the threshold criteria. This change is
necessary to reflect that this interim action will be implemented under the
provisions of the Kentucky Hazardous Waste Permit and must also fulfill these
RCRA requirements:
1. Overall protection of human health and the environment. Requires that the
alternative adequately protect 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. The alternatives must be assessed to determine if
they attain compliance with applicable or relevant and appropriate
requirements of both state and federal law.
3. Long-term effectiveness and permanence. 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.
The degree to which the alternative employs recycling or treatment to reduce
the toxicity, mobility, or volume of the contamination.
5. Short-term effectiveness. 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.
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Table 2. Comparison of Potential Alternatives
Alternative
1-NO FURTHER
ACTION
2- SIGNS,
GABION
STRUCTURE, ION
EXCHANGE, AND
SETTUNG
LAGOONS
3-SIGNS,
GABION
STRUCTURE, ION
EXCHANGE,
SETTLING LA-
GOONS, AND
PIPELINE
4-SIGNSAND
EXCAVATION
Overall Protection
of Human Health
and the Environment
No change
Additional off-site
releases in surface and
ground water are
greatly reduced by
sediment and source
control. Signs will reduce
potential exposure of
PGDP employees to
contaminated sediment.
In addition to protection
provided by Alternative 2,
the diversion of flow
through a pipeline will
bypass a portion of the
ditch and will reduce
exposure to the contami-
nated water piped to the
lift station.
Reduces potential
exposure and further
releases to off-site ground
and surface water by
removing contaminated
sediments.
Compliance with
ARARs
Does not achieve
response
objectives or satisfy
state and local
requirements.
ARARs would be
achievable
ARARs would be
achievable
ARARs would be
achievable
Long-Term
Effectiveness
and
Permanence
Not
applicable
Intended for
short-term use; i
might not be «
effective as
long-term :
remedial action.
Similar to
Alternative 2
Reduces long-
term risks of
exposure. May
need to be
repeated.
Reduction of
Toxicity,
Movement,
and Volume
No change
Decreases mobility and
HHplume of contaminants
Wscharged at the sources.
Toxicity of water reduced.
Contaminants in the ditch
will continue to infiltrate
into the ground water.
Will generate approxi-
mately 7 drums of
hazardous waste/year.
Decreases mobility and
volume of contaminants
discharged at the
sources. Will reduce the
infiltration of contamina-
' tion into the ground
water. Will generate
approximately 7 drums
of hazardous waste/
year. Installation of lift
station will generate
about 200 drums of
hazardous waste.
Reduces mobility. No
charge in volume or
toxicity of contaminants
in excavated materials.
Will generate 14,834
drums of hazardous
waste.
Short-Term
Effectiveness
,1
Not applicable
Immediate
decrease in
migration of
contaminants to
surface water.
In addition to
effectiveness
provided by
Alternative 2, the
diverting of flow
through a pipeline
will bypass the
contaminated
portion of the ditch
and will further
reduce contaminant
releases to surface
and ground water.
Handling,
transporting, and
disposing of
excavated
materials require
additional safety
measures to ensure
the protection of
workers, the
public, and the
environment.
Implementability
Not applicable
Standard remedia-
tion technique with
no technical barriers
to implementation.
Requires frequent
inspections and
maintenance.
Reversible. Will not
affect implementa-
tion of final remedy.
Similar to Alterna-
tive 2. Additional
inspection and
maintenance
activities will be
necessary for the
pipeline.
Standard
remediation
technique with no
technical barriers to
implementatioa
Irreversible, will
generate large
volume of waste.
Cost*
No
additional
costs
$820,862
$1,419,525
$19,535,860"
oo
* Calculated using 5-year operating time, discount rate=7.00%, inflation rate=3.50%; ** Includes an estimated $14,834,000 cost for waste management
-------
6. Implemenlability. Potential difficulties associated with implementing the
alternative. This may include: technical feasibility, administrative feasibility,
and the availability of services and materials.
7. Cost. The costs associated with the alternatives. These expenditures include
the capital cost, annual operation and maintenance and the combined net
present value of capital and operations and maintenance costs.
8. State approval. The incorporation of any formal comments by the Kentucky
Division of Waste Management to the Interim Measure for the NSDD.
9. Community acceptance. The consideration of any formal comments by the
community to the Proposed Plan for interim remedial action.
*
The criteria listed above are categorized into three groups. The first, second, and
eighth categories are threshold criteria. The chosen final alternative must meet the
threshold criteria to be eligible for selection. The five primary balancing criteria
include criterion three through seven. The last criterion is termed the modifying
criterion. The modifying criterion was evaluated following issuance of the Proposed
Plan for public review and comment.
Overall Protection of Human Health and the Environment
Protection of human -health and the environment is a threshold criteria.
Alternatives must meet this criteria in order to be eligible for selection. Alternatives
2, 3, and 4 would provide protection of human health and the environment for the
scope of this interim action.
As discussed in Section 2.6, Summary of Site Risks, there is sufficient potential risk
to human health and the environment to warrant this interim action. Therefore,
Alternative 1 does not meet this threshold criteria.
Alternative 2 would provide protection through source control of contaminant
inputs into the NSDD, engineering controls for limiting the potential for
contaminant migration, and institutional controls to limit potential direct exposure.
Alternative 3 would provide protection in the same manner as Alternative 2.
However, additional protection would be provided by limiting the potential for
contaminant transport and infiltration into the subsurface environment through
engineering controls: a pipeline.
Alternative 4 would provide protection through the removal of contaminated
materials from the NSDD. Institutional controls would also be implemented to limit
potential exposure to residual contamination.
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Compliance with ARARs
Compliance with ARARs is also a threshold criteria. Alternatives must meet this
criteria in order to be eligible for selection. Alternatives 2, 3, and 4 would achieve
ARARs. A detailed description of ARARs is included in this document only for the
selected remedy. This is included in Section 2.9.
Long-term Effectiveness and Permanence
This criteria is generally not relevant to measures implemented as interim actions.
However, the selected alternative is expected to be effective until a final remedial
decision is implemented for the NSDD.
Alternatives 2 and 3 will not remove contaminants from the NSDD. However, they
would provide some protection from potential exposure to the contaminants
through institutional controls and source control. Alternative 4 would remove
contaminants from the NSDD. However, other contaminated areas at PGDP and
process wastewater from the active facilities may recontaminate the NSDD. Over the
long term, this may result in having to excavate materials from the NSDD again in
the future.
Long-term effectiveness and permanence will be addressed through a final remedial
decision made for the NSDD and the Surface Water Integrator Operable Unit.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Alternatives 2 and 3 would reduce the volume of contaminants through source
control treatment measures. Alternative 3 would also reduce the mobility of
contaminants within the NSDD by reducing the flow of water through the most
highly contaminated portion of the NSDD Alternative 3 would also mitigate any
potential cross contamination from the surface water system to the shallow ground
water system at the NSDD. Alternative 4 would reduce the toxicity, mobility, and
volume of contaminants within the NSDD bv excavating the materials. However,
excavated materials would not be treated to remove or destroy contaminants.
Excavated materials would require storage and/or disposal at permitted facilities.
Short-term Effectiveness
Remediation of the NSDD will be a long-term process due to the contamination
from halogenated hydrocarbons and radionuchd^s This interim action will provide
effective short-term stabilization of the contaminated NiSDD. Alternatives 2, 3, and 4
would provide protection immediately upon completion of construction and
calibration activities.
None of the evaluated alternatives would pose a threat to nearby communities.
Alternatives 2, 3, and 4 all require that workers perform activities in or near
contaminated areas. Alternative 4 would require the handling of a large volume of
contaminated materials during excavation and pacLaging. Workers associated with
the implementation of the selected alternative will abide by the requirements of a
20
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site-specific Health and Safety Plan (HSP). The HSP will be prepared as part of the bid
package and submitted to the selected contractor prior to the award of the project.
Prior to implementation of this interim action the EPA and KDEP will be afforded
the opportunity to review the HSP. The draft HSP will be modified by the contractor
to reflect pertinent comments submitted by the Regulatory Agencies.
Alternatives 2, 3, and 4 would require similar time periods for installation and each
would expose workers to potentially contaminated materials and work time in
contaminated areas. However, the time and type of work performed varies between
the alternatives.
Implementability
Alternatives 2, 3, and 4 can be implemented using standard engineering practices
with materials and equipment that is readily available. Site conditions are not
expected to prevent implementation or maintenance of the alternatives.
Cost
The total projected costs presented in the Proposed Plan were Alternative 2
$820,862, Alternative 3 - $1,370,862, and Alternative 4 - $19,535,860. The majority of
the costs associated with Alternative 4 are related to waste management
requirements for radioactive and/or hazardous waste. The cost estimate fpr
Alternative 3 has been further refined and has a capital cost of $1,342,511 and a
present worth cost of $1,419,525 as reflected in Table 2.
State Approval
The Interim Corrective Measure Work Plan developed pursuant to PGDP's
hazardous waste permits, Proposed Remedial Action Plan and Draft ROD were
issued for review and comments to both the Commonwealth of Kentucky and the
EPA. The Kentucky Division of Waste Management concurs with this action,
consistent with the requirements of the facility's Hazardous Waste Permit issued by
the Commonwealth of Kentucky.
Community Acceptance
As evidenced by the comments received during the public comment period, the
selected interim remedy specified in the Record of Decision for Interim Action is
supported by the local community.
No comments were received by DOE from any group or organization opposing this
interim action. Community response to the alternatives is presented in the
Responsiveness Summary which addresses comments received during the public
meeting and the public comment period.
21
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2.9 Selected Remedy
Based upon the evaluation of the alternatives in regard to the nine criteria, the
remedy which best meets the threshold, balancing, and modifying criteria for the
scope and objectives of this interim action is Alternative 3. The DOE will prepare a
detailed design of the treatment unit in accordance with the requirements of the
ROD for this interim action, and in accordance with the Interim Corrective Measure
Work Plan for the North-South Diversion Ditch, Virginia Avenue to C-616-C Lift
Station: The Interim Corrective Measure Work Plan pursuant to PGDP's Kentucky
Hazardous Waste Permit and EPA Hazardous and Solid Waste Permit will be
approved at the same time as this ROD is approved.
The selected remedy will consist of the following elements at a minimum:
t
The effluent discharged from the C-400 Building shall be treated to reduce
the concentration of radionuclides. The target level for treatment shall be
the MCLs established under the Safe Drinking Water Act. Sufficient
engineering controls shall be utilized to achieve this goal. An ion
exchange unit shall be installed to treat this effluent.
The effluent discharged from the C-600 Steam Plant shall be treated to
remove fly ash from the effluent prior to discharge to the NSDD. Settling
lagoons will be used for source control treatment of the C-600 Steam Plant
fly ash effluent. However, the final design of the fly ash source control
may be modified as the detailed design process proceeds. Design of the
discharge routing from the steam plant will be determined through the
remedial design process by DOE, EPA and the Kentucky Department for
Environmental Protection.
Lift station(s) shall be installed in or near the NSDD, near the C-400
Building and the C-600 Steam Plant. A pipeline shall be installed to
transport permitted effluent and storm water runoff from the installed lift
station(s) at the southern end of the NSDD to the Ditch 001 Lift Station.
A gabion type rock structure with nonwoven geotextile material secured
to the upstream side shall be installed in the NSDD at or near the Ditch
001 Lift Station. A conceptual drawing of this structure is provided in
Figure 5.
Signs shall be installed at intervals not to exceed 100 feet, on both sides of
the ditch, from Virginia Avenue to the C-616 Lift Station. These signs
shall provide notice that elevated levels of radionuclides, metals, and
PCBs are present in the area.
The actions proposed in the selected alternative will not cause an increased risk to
workers or PGDP personnel during their construction or use. The silt trap gabion, lift
station with pipeline and warning signs will be in and near the contaminated areas.
Personal protective equipment and adequate worker safety procedures will be used to
ensure that implementation of these proposed measures do not pose a risk to worker
22
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. .
Figure 5. Example of a Gabion
23
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health and safety. The selected alternative can be implemented using standard
engineering practices with materials and equipment that are readily available. Site
conditions are not expected to prevent the implementation or maintenance of these
proposed actions.
The proposed ion exchange unit will require a calibration period of six months or
more after installation, in order to optimize the removal of the radionuclides. The
source control for fly ash, silt trap gabion and lift station with pipeline will
immediately reduce the volume of contaminated effluent flowing through the ditch
and into the Outfall 001 Lift Station. The estimated present worth cost of the selected
actions is $1,419,525. Table 3 presents a more detailed breakdown of the estimated
costs for this action. This cost is within 4% of the cost presented in the Proposed Plan
and is not a significant change.
Table 3. Estimated Cost of Source Control Action
Source controls, institutional controls and engineering controls
including the installation of a pipeline and lift
Capital Investment:
1. Ion Exchange unit:
2. Warning Signs:
3. Gabion:
4. Fly Ash Controls:
5. Lift Station and Pipeline:
Subtotal
Contingencies @ 35%:
Total Capital Investment:
$74,074
$1,860
$29,630
$481,481
$407,407
Estimated Operation and Maintenance Expense (annually): $17.000
TOTAL PRESENT WORTH COSTS*
* Net Present Value assuming an inflation rate of 3.5%,
a discount rate of 7% and five years of operation: $1,419,525
2.10 Statutory Determinations
The DOE, EPA and Kentucky Division of Waste Management concur that the source
controls will satisfy the statutory requirements of K.R.S. 224.46-530(g) and CERCLA
121(b) for providing protection of human health and the environment, attaining
applicable or relevant and appropriate requirements directly associated with this
24
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action, being cost-effective, utilizing permanent solutions and alternative treatment
technologies to the maximum extent practicable, and exhibiting a preference for
treatment as a principle element.
Protection of Human Health and the Environment
The selected interim action initiates protection of human health for the PGDP
employees and the public through treatment of wastes entering the NSDD,
institutional controls to limit the potential for direct exposure, and engineering
controls to mitigate the infiltration and migration of contaminants from the NSDD
to the subsurface environment and offsite until a final action is selected and
implemented. The remedy provides effective management of all residual wastes
generated during implementation of the action.
Compliance with ARARs
The Comprehensive Environmental Response, Compensation, and Liability Act of
1980 was passed by Congress and signed into law on December 11, 1980 (Public Law
96-510). This act was intended to provide for "liability, compensation, cleanup, and
emergency response for hazardous substances released into the environment and
the cleanup of inactive waste disposal sites." Adopted on October 17, 1986 (Public Law
99-499), SARA did not substantially alter the original structure of CERCLA but
provided extensive amendments to it. This amendment also renumbered Section
107(g) on Federal Facility Compliance as Section 120(a) and added several provisions
affecting response actions at federal facilities in the balance of Section 120. Among
these provisions is Section 120(f) which requires federal facilities to provide states
with the opportunity to participate in response actions as specified in Section 121.
Section 121 requires that remedial actions for cleanup of hazardous substances must
comply with requirements or standards under federal or more stringent state
environmental laws which are applicable or relevant and appropriate to the
hazardous substances or particular 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 environmental protection requirements, criteria, or limitations
promulgated under federal or state law that specifically address a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance
at a CERCLA site" (53 Fed. Reg. 51435, December 2\.
Relevant and appropriate requirements are "those cleanup standards, standards of
control, and other substantive environmental protection requirements, criteria, or
limitations promulgated under federal or state law 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" (53 Fed. Reg. 51436).
25
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"Chemical-specific requirements are usually health- or risk-based numerical values
or methodologies which, when applied to site-specific conditions, result in the
establishment of numerical values" (53 Fed. Reg. 51437). 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). Some examples of special locations
include floodplains, wetlands, historic places, and sensitive ecosystems or habitats.
Action-specific requirements "are usually technology- 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). Selection of a particular remedial action at a site will invoke appropriate
action-specific ARARs that may specify particular performance standards or
technologies, as well as specific environmental levels for discharged or residual
chemicals.
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 applicable it must be both relevant and appropriate for compliance to be
necessary. In cases where both a federal and a state ARAR are available, or where two
potential ARARs address the same issue, the more stringent regulation must be
selected. However, CERCLA § 121(d)(4) provides several ARAR waiver options that
may be invoked, providing that the primary requirement of protection of human
health and the environment is met.
In order to expedite the cleanup process, Congress exempted certain CERCLA
response actions from any federal, state, or local requirement to obtain permits. 42
U.S.C. section 9621(e)(l). This section applies only to response actions "conducted
entirely onsite," defined in the NCP to mean "the area! extent of contamination and
all suitable areas in very close proximity [which are] necessary for implementation of
the response action." 40 C.F.R. section 300.5. Although laws that would otherwise
apply with full force to non-CERCLA onsite activities do apply to CERCLA response
actions, they do so only to the extent that they are ARARs. Consequently, only
substantive requirements apply, not procedural ones. Regulatory requirements to
obtain permits are procedural or administrative in nature, not substantive, and do
not apply to CERCLA onsite response actions. 55 Fed. Reg. 8666, 8756 (March 8,1990).
In an effort to further distinguish between substantive and administrative
requirements, EPA offers the following examples. Substantive ARARs include
acceptable concentrations for specific chemicals under the Safe Drinking Water Act
(SDWA) or technology-based requirements under RCRA. Administrative
requirements involve the approval of or consultation with administrative bodies,
issuance of permits, documentation, reporting, and recordkeeping (53 Fed. Reg.,
51443).
26
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Since ARARs do not exist for every chemical or circumstance likely to be found at a
Superfund site, other information not meeting the definition of an ARAR may be
used to determine what is protective or may be useful in developing Superfund
remedies. Therefore, 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). Criteria or guidance
developed by EPA, 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 information is
classified as to-be-considered (TBC) guidance and generally falls within three
categories (health effects information, technical information on how to perform or
evaluate investigations or response actions, and policy).
The EPA's treatment of state ARARs is fully consistent with the way EPA has treated
federal requirements under the current NCP, in which federal guidance and
nonpromulgated guidelines are put in a separate category ("other information to be
considered") from potential ARARs. Like their federal counterparts, state guidance
and other nonpromulgated guidelines may still be considered in determining an
appropriate, protective remedy; but neither federal nor state guidance should be
treated as potential ARARs (53 Fed. Reg., 51437).
The response action for the NSDD involves installation of a gabion filter system, ion
exchange system, fly ash control, pipeline, and institutional controls. Selection of
this alternative will allow for project execution to proceed without requiring an
ARAR waiver while meeting all applicable or relevant and appropriate
Commonwealth of Kentucky and federal regulations as well as DOE orders and
American National Standards Institute (ANSI) standards. Proceeding with the
selected remedy will meet chemical, location, and action-specific ARARs as described
in the text below. An additional overview of the ARARs for the NSDD may be
obtained by reviewing Table 4.
Chemical-specific
The Kentucky Water Quality Standards nondegradation policy is intended to
safeguard the surface waters of the Commonwealth for designated uses, preventing
the creation of any new pollution, and abating existing pollution [401 K.A.R. §
5:029(2)]. The KPDES permit, KY0004049, is the implementing vehicle for this
applicable regulation.
Based upon sampling results, PCB levels as high as 11,000 Mg/kg were detected in the
sediment and soil of the NSDD; consequently, PCBs may be found in the surface
water. Under 401 K.A.R. § 5:055, PGDP is required to obtain a permit for the
dischargeof plant waste water. Waste water discharged from PGDP is regulated by
KPDES Permit No. KY0004049 which also establishes effluent limitations for PCBs at
KPDES outfalls. Concentrations of PCBs discharged from the treatment system into
the water should not exceed 0.000079 |ig/l.
Effluent from the ion exchange system will discharge into the NSDD, which in turn,
ultimately flows through KPDES Outfall 001. The KPDES permit which was issued by
27
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Table 4. ARARs for the North-South Diversion Ditch Project Area to be Covered from Virginia Avenue to C-616-C Lift Station
Record of Decision
Actions
Requirements
Prerequisites
Federal
Citation
Title 401,
KAR Chapter
CHEMICAL-SPECIFIC
Treatment of contaminated
surface water
Prevent creation of any new pollution
Treatment to KPDES permit limitations for
Outfall 001 - 0.000079 \igfl for PCB
Treatment to SDWA MCLs for Outfall 001 -
0.5 Hg/1 for PCB and 4 mrem/yr for "Tc
Discharge must not exceed DCGs for
radionuclides; discharge of 0.71% of 235U
should not exceed 0.87 mg/1 and discharge for
"Tc should not exceed 100,000 pCi/1 for
protection of aquatic organisms
Direct discharge to a surface water body
- applicable
Direct discharge to a surface water body
- relevant and appropriate
Direct discharge to a surface water body
which feeds into a drinking water
aquifer - TBC guidance
Direct discharge to a surface water body
-TBC guidance
40 CFR 141.15;
141.16; & 141:61
40C.F.R. 141-
143
DOE Order 5400.5
5:029(2)
5:055
8:550
Protection of warm water aquatic
habitat
Prevent toxicity contribution to aquatic life
Discharge impacting productive warm
water aquatic communities -
applicable
5:031(4)
N> Protection of the general public
from all sources of radiation
The general public must not receive an
effective dose equivalent greater than 100
mrem/year
All releases of radioactive material must be
"as low as reasonably achievable" (ALARA)
Dose received by the general public
from all sources of radiation exposure
at a DOE facility - TBC guidance
Releases of radioactive material from
DOE activities - TBC guidance
- DOE Order 5400.5
DOE Order 5400.5
ACTION-SPECIFIC
Site preparation
Precaution must be taken to prevent
paniculate matter from becoming airborne
A responsible party must:
Use water or a chemical to control dust;
Place asphalt or concrete on roads and
materials stockpile to control dust;
Ensure that no visible fugitive dust is
emitted beyond the property line; or
Ensure that all open bodied trucks are
covered if any materials in truck could
become airborne.
Handling, processing, construction,
road grading, and land clearing
activities - applicable
63:010
63:010
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Table 4. ARARs for the North-South Diversion Ditch Project Area to be Covered from Virginia Avenue to C-616-C Lift Station
Record of Decision (Continued)
Actions
Requirements
Prerequisites
Federal
Citation
Title 401,
KAR Chapter
Container Storage (on-site)*
ro
Containers of hazardous waste must be:
>. Maintained in good condition;
Compatible with hazardous waste to be
stored; and
Closed during storage (except to add or
remove waste)
Inspect storage areas weekly for deterioration
of containers and the containment system
Container storage areas must have a crack and
gap free base sufficiently impervious to
contain leaks or spills; a base that is sloped
or a containment system designed/operated to
drain and remove liquids resulting from
spills, leaks, or precipitation unless
containers are elevated or protected from
exposure to accumulated liquids
Containment system with a capacity of 10%
of container volume. Run-on into
containment system must be prevented unless
sufficient excess capacity exist. Remove
spilled/leaked waste in a timely manner to
prevent overflow to the containment system
and manage such material appropriately under
RCRAorCWA
At closure, remove all hazardous waste and
residues from the containment system and
decontaminate or remove all containers,
liners, bases, or soils containing hazardous
waste or hazardous waste residues and manage
such materials as appropriate under RCRA
Storage of RCRA hazardous waste
(listed or characteristic) not meeting
small quantity generator criteria held
for a temporary period before
treatment, disposal, or storage
elsewhere, in a container (i.e., any
portable device in which a material is
stored, transported, disposed of, or
handled). A generator who accumulates
or stores hazardous waste on-site for
90 days or less in compliance with 40
CFR 262.34(a)(l-4) is not subject to
RCRA interim or final status storage
requirements - applicable
40 CFR 264
(Subpart I)
40 CFR 264.171
40 CFR 264.172
40 CFR 264.173
40 CFR 264.174
40 CFR 264.175
34:180
34:180.2
34:180.3
34:180.4
34:180.5
34:180.6
40 CFR 264.178
34:180.9
* 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 independent RCRA authority at the site.
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Table 4. ARARs for the North-South Diversion Ditch Project Area to be Covered from Virginia Avenue to C-616-C Lift Station
Record of Decision (Continued)
Actions
Requirements
Prerequisites
Federal
Citation
Title 401,
KAR Chapter
Container Storage (on-site)
(continued)
An owner or operator of any facilities used for
the storage of PCBs and PCD items must
comply with the following requirements:
the facilities must meet the following
criteria:
adequate roof and walls to prevent rain water
from reaching PCBs storage containers
an adequate floor which has continuous
curbing with a minimum six inch high curb
no drain valves, floor drains, expansion,
joints, sewer lines, or other opening that
would permit liquids to flow from the curbed
floors and curbing constructed of
continuous smooth and impervious materials
to prevent or minimize penetration of PCBs,
ind
n<4 k*alc>) » fV>o«l »ater ckvali<>n
(Oouiruneni volume at two timct internal
volume of la/|etl IVB t/1uk or 25* of I»U|
intern*) volume of all It'B article* anJ
containers
PCBs concentrations >50 ppm in
liquid waste which is stored on-site
applicable
40 CPR 761.65(b)
37:050.2(6)
40 CFR 761.65(b)
37:050.2(b)
Waste Management
Must handle and dispose of radioactive waste
in a manner that is protective of public health
and the environment
Land disposal restrictions must be addressed
If individuals generate or transport
hazardous waste - applicable
DOE Older
5820.2A (TBC
guidance)
40 CFR 268
Transportation of hazardous
waste
Waste must be manifested
Transporters of hazardous waste must follow
detailed standards
Waste exhibits a RCRA hazardous
waste characteristic as defined by
Subpart C of 40 CFR § 261 and off site
transportation occurs
If hazardous waste is transported -
applicable
40 CFR 262
40 CFR 263
40 C.F.R. 260.10
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Table 4. ARARs for the North-South Diversion Ditch Project Area to be Covered from Virginia Avenue to C-616-C Lift Station
Record of Decision (Continued)
Actions
Requirements
Prerequisites
Federal
Citation
Title 401,
KAR Chapter
Transportation of hazardous
waste
(continued)
Waste must be packaged and transported in
accordance with DOT requirements
The waste is considered a RCRA
hazardous waste by characteristic, or a
hazardous substance that equals or
exceeds a reportable quantity; and
transportation in commerce occurs.
If DOE does not close off road
to public use during transport;
If the transport does not occur
In a DOE operated government
vehicle; or If access to the
roads Is not controlled by the
use of gates and guards -
applicable
49 CFR §§ 172,
173, 178, and 179
Worker Protection
Comply with the provisions for response
action worker safety and health in 29 CFR
1910.120 and any other applicable worker
safety standards (29 CFR 1910, 29 CFR
1926)
Maintain worker exposures to ALARA
Maximum exposure to occupational workers;
5 rem/year (stochastic); SO rem/year
(nonstocbastic) effective does equivalent
Comply with provisions for worker safety in
confined spaces in ANSI Z117.1
Response actions carried out under the
National Contingency Plan - not
generally considered an ARAR as it is a
requirement of the NCP
Internal and external sources of
continuous exposure to occupational
workers at a DOE facility - TBC
guidance
Internal and external sources of
continuous exposure to occupational
workers at a DOE facility - TBC
guidance
Response actions at DOE facilities
which require workers to enter confined
spaces - TBC guidance
40 CFR 300.150
DOE Order
5480.11
DOE Older
5480.11
DOE Order 5480.4
LOCATION-SPECIFIC
None
-------
the Kentucky Division of Water, to implement the requirements of 401 K.A.R. §
5:055, contains limits appropriate for the surface water use classification designated
by the Commonwealth of Kentucky. KPDES Outfall 001 flows into Big Bayou Creek
which has been designated as a warm water aquatic habitat. Warm water aquatic
habitat criteria which are allowable in-stream concentrations for specific substances
are designed to protect aquatic life from acute and chronic toxicity [401 K.A.R.
5:031(4)].
Effluent limitations are applicable at outfalls where monitoring takes place and are
only enforceable at KPDES outfalls. The requirements of 401 K.A.R. § 5:055, as
implemented through the KPDES permit No. KY0004049 would be a relevant and
appropriate requirement for effluent discharged from the ion exchange because the
PCB limit imposed by the permit must be met at the outfall. Therefore, if the KPDES
permit limit is not exceeded in the water discharged from the ion exchange system,
the system would not cause the permit limit to be exceeded at Outfall 001.
The SDWA and the Kentucky Public and Semi-Public Drinking Water Regulations
are TBC guidance for this action. These regulations along with DOE's guidance to
reduce exposures to radiation to levels "As Low As Reasonably Achievable"
(ALARA) are being used as treatment goals to limit the introduction of
radionuclides into the NSDD. The MCLs will be the target treatment levels for
radionuclides being discharged from the C-400 Cleaning Building. These levels were
selected for the target treatment level based upon the technical judgment of DOE,
due to the limited characterization and risk information available, and the need for
action to stabilize the unit and prevent further degradation. The most protective
standards available, the MCLs, were selected for use in the action. The required
treatment levels for radionuclides in the unit will be re-evaluated through the
remedy selection process for the final ROD for the NSDD and the Surface Water
Integrator Operable Unit.
Quantities of "Tc and uranium have been found in the soil and sediment of the
NSDD. DOE Order 5400.5, Radiation Protection of the Public and the Environment,
limits radiation exposure to members of the public to an effective dose equivalent of
less than 100 mrem/year, a dose of less than 5 mrem/year to any organ, and an
effective dose of less than 4 mrem/year through drinking water. To achieve these
standards, DOE Order 5400.5 also specifies derived concentration guidelines (DCGs)
for radionuclides in water and air. According to DOE Order 5400.5, uranium
concentrations in surface water at 0.71% 235U should not exceed 0.87 milligrams per
liter (mg/1) and "Tc in surface water should not exceed 100,000 picocuries per liter
(pCi/1). In addition, DOE Order 5400.5 mandates that DOE personnel, and contractors
strive to ensure that radiation doses to members of the public are as low as
reasonably achievable (ALARA) below the appropriate limits.
DOE Orders are applicable internal requirements for DOE facilities; therefore, they
are not legally enforceable requirements. DOE Order 5400.5 would be TBC guidance
for the discharge of radionuclides to the NSDD.
32
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Action-specific
Onsite construction activities may be necessary to prepare the site for
implementation of the chosen alternative. These construction activities could
produce airborne pollutants. Elevation of particulate concentrations resulting from
earth-moving and site-grading activities may exceed the Kentucky Air Quality
regulations found in 401 K.A.R. § 63:010 et seq. which contain General Standards of
Performance governing fugitive dust emissions.
The regulations in 401 K.A.R. § 63:010(3) require the use of water or chemicals if
possible and/or to place asphalt or concrete on roads and material stockpiles to
control dust. The regulation also requires that visible fugitive dust in the ambient air
must not extend beyond the property line of the dust originating facility. All open
bodied trucks operating outside the property boundary which may emit airborne
materials must be covered.
The treatment unit may generate spent ion exchange elements or other treatment
residuals. The clean-up activity will generate decontamination water which is used
to clean the construction equipment as well as personal protective equipment.
Additionally, excavation of soil to place the gabion structure and filter will result in
waste requiring management. All waste will have to be characterized to determine if
the waste is hazardous [401 K.A.R. 34:020(4)], if it contains PCBs above 50 ppm
(40 C.F.R. § 761.60), and/or is radioactive POE Order 5400.5).
DOE Order 5820.2A Radioactive Waste Management establishes policies, guidelines,
and minimum requirements by which DOE manages its radioactive and mixed
waste and contaminated facilities. The Order ensures that radioactive arid mixed
wastes shall be managed in a manner which assures protection of the health and
safety of the public, DOE, contractor employees, and the environment. The
management of low-level radioactive waste must be managed in such a manner that
external exposure to the waste and concentrations of radioactive material which may
be released to the surface water, ground water, soil, plants and animals results in an
effective dose equivalent which does not exceed 25 mrem/year to any member of the
public. Additionally, reasonable effort should be made to maintain releases of
radioactivity in effluents to the general public as low as reasonably achievable. DOE
Order 5820.2A should be evaluated as TBC guidance.
Kentucky regulations applicable to generators of hazardous waste are detailed in 401
K.A.R! § 32 et seq. Onsite accumulation of hazardous waste may occur for 90 days or
less without a permit or without having interim status if requirements found in 401
K.A.R. § 32:030(5) are followed. This regulation details container marking
requirements and KDEP notification requirements. If hazardous waste is stored for.
more than 90 days, requirements of 401 K.A.R. Chapter 34. Chapter 34 specifies the
standards for owners and operators of hazardous waste storage, treatment and
disposal facilities.
If these wastes are determined to be RCRA and Atomic Energy Act (AEA) mixed
waste, then RCRA will apply to the hazardous waste component and the AEA will
apply to the radioactive component of the waste [10 C.F.R. § 962(b)]. Movement of
33
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treatment residuals containing RCRA-characteristic waste and radionuclides to
another unit will trigger the 40 C.F.R. § 268.1 et seq. (Land Disposal Restrictions), an
applicable ARAR for this alternative. DOE and EPA entered into Federal Facility
Compliance Agreement Docket No. 92-03-FFR on June 30, 1992. This FFCA allows
the storage of radioactive mixed waste containing an LDR prohibited hazardous
waste component while treatment capacity is being developed. Whether the waste is
characterized as RCRA characteristic, LLW, or mixed waste, it will be stored at an
appropriate facility at PGDP which meets the substantive requirements of RCRA.
If the liquid waste contains only PCBs at concentrations greater than, or equal to,
50 ppm, then 401 K.A.R. § 37:050(2)(6) prohibits the storage of such waste unless the
storage facility meets the Toxic Substances Control Act (TSCA) requirements found
in 40 C.F.R. § 761.65. If the liquid waste contains only PCBs at concentrations less
than 50 ppm, then the waste can be stdred by following the requirements in 401
K.A.R. § 34:180 et seq. which entails the use and management of containers. Chapter
34 establishes minimum standards for new hazardous waste sites or facilities and
minimum standards for the use and management of containers.
A storage facility which contains PCBs must meet the minimum TSCA
requirements found in 40 C.F.R. § 761.65(b). These requirements are an adequate roof
and walls to prevent rain water from reaching the stored PCBs and an adequate floor
which has continuous curbing with a minimum six inch curb. These floor curbings
must be made of continuous smooth and impervious materials to prevent or
minimize penetration of PCBs. Moreover, the facility must not contain drain valves,
floor drains, expansion joints, sewer lines, or other openings that would permit
liquids to flow from the curbed area. Finally, the facility must not be located below
the 100-year flood water elevation.
If wastes are shipped offsite for treatment and/or disposal, the following regulations
will apply. 49 C.F.R. § 172 et seq. lists and classifies those materials which the
Department of Transportation (DOT) has designated as hazardous materials (49
C.F.R. §§ 172.101 and 172.102) for purposes of transportation and prescribes the
requirements for shipping papers (Subpart C of 49 C.F.R. § 172), package marking
(Subpart D of 49 C.F.R. § 172), labeling (Subpart E of 49 C.F.R. § 172, and transport
vehicle placarding applicable to the shipment and transportation of those hazardous
materials (Subpart F of 49 C.F.R. § 172).
Additional requirements which are applicable to the transportation of hazardous
material are located in 40 C.F.R. subparts 263 et al. These regulations detail standards
for which persons transporting hazardous waste in the United States must adhere,
including a manifest system, recordkeeping, and hazardous waste discharges.
However, these regulations do not apply to on-site transportation of hazardous
waste by generators or by owners or operators of permitted hazardous waste
management facilities. 49 C.F.R. subpart 271 would be considered potentially
applicable since it applies to each person who offers a hazardous material for
transportation and each carrier who transports the material.
34
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There is currently no criteria for qualifying radioactive waste as clean and acceptable
for offsite shipment as non-radioactive waste. Radioactive or mixed waste can,
however, be shipped to approved Nuclear Regulatory Commission (NRC) licensed
facilities. Waste generated from this project will be stored onsite until
characterization can be completed or disposal criteria can be met.
Requirements for providing and maintaining emergency response information
during transportation and at facilities where hazardous materials are loaded for
transportation, stored incidental to transportation or otherwise handled during any
phase of transportation are delineated in Subpart G of 49 C.F.R. § 172. Training
requirements for employees involved with the handling of hazardous waste
(hazmat) are included in Subpart H of 49 C.F.R. § 172. Training ensures that a hazmat
employee has familiarity with Subpart H requirements, is able to recognize and
identify hazardous materials, and has knowledge of emergency response
information, self-protection measures, and accident prevention methods and
procedures. Subpart I of 49 C.F.R. § 173 sets forth requirements for transportation of
radioactive materials by carriers and shippers. Package requirements, radiation level
limitations, contamination control, and general transportation requirements are
included in Subpart I. These regulations are applicable since provision and
maintenance of said emergency response information is required for any
contaminated material generation.
Specifications for packagings and containers used for the transportation of hazardous
materials in commerce are included in 49 C.F.R. § 178 et seq. Subpart K of 49 C.F.R:" §
178 consist of guidelines for packagings of Class 7 (radioactive) materials. 49 C.F.R. §
179 et seq. prescribes specifications for tanks that are to be mounted on, or form part
of, a tank car and which are used in the transportation of hazardous materials in
commerce.
The NCP (40 C.F.R. § 300.150) requires all response actions to comply with the
provisions for response action worker safety and health found in 29 C.F.R. § 1910.120.
In addition, DOE Orders which address occupational safety would be applicable
internal TBC guidance for DOE projects These Orders are 5480.11, Radiation
Protection for Occupational Workers and S4SO 4. Environmental Protection, Safety,
and Health (ES&H) Protection Standards.
DOE Order 5480.11 establishes radiation protection standards and program
requirements for DOE and DOE contractor operations with respect to the protection
of the worker from ionizing radiation. The Order applies to all DOE operators and
contractors performing work for DOE. Furthermore, in accordance with DOE's
policy, radiation protection standards must be implemented which are consistent
with the Presidential approved guidance to Federal Agencies promulgated by the
EPA and based on recommendations by authoritative organizations.
DOE Order 5480.4 specifies and provides requirements for the application of the
mandatory environmental protection, safety, and health standards which are
applicable to all DOE and DOE contractor operations while providing a list of
references and sources of ES&H standards. The Order should be followed during
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design, construction, operation, modification, and decommissioning. Specifically,
this Order is applicable where DOE has authority to establish and enforce
environmental protection, safety and health protection program requirements.
In order for construction to be conducted on the lift station, a PGDP employee will
have to work in a confined space. DOE Order 5480.4 states that safety for a worker in a
confined space must meet the standards documented in the American National
Standards Institute's criterion entitled "Safety Requirements for Working in Tanks
and Other Confined Spaces" ANSI Z117.1 (1989). ANSI standards provide minimum
safety requirements to be followed while entering, exiting and working in confined
spaces at normal atmospheric pressure. This standard is intended to establish
minimum requirements and procedures for the safety and health of employees who
work in, and in connection with, confined, spaces.
Location-specific
There are no location-specific ARARs for this alternative.
Cost Effectiveness
The interim action remedy employs a proven technology which affords overall
effectiveness proportional to its costs such that the remedy represents reasonable
value. This action will utilize a relatively inexpensive technology to initiate control
of the source and mitigate the spread of contamination in the NSDD. This limited
scale operation should reduce the cost of the overall remediation of the integrator
operable unit by retarding the migration of the high concentration effluent portion
of the NSDD.
Utilization of Permanent Solutions and Alternative Treatment Technologies
The objectives for this interim action are to stabilize the site by instituting source
controls to decrease the introduction of contaminants into the ditch, and installing
engineering controls which will decrease mobilization of the most contaminated
portion of the ditch. This action should provide protection of human health and the
environment. However, it does not fully address the principal threats to human
health and the environment posed by the NSDD operable unit. This is not the final
action planned for NSDD. contamination. Subsequent actions will fully address the
principal threats posed by the conditions at the PGDP. Utilization of a permanent
solution will be addressed in the final decision document for the NSDD and the
surface water integrator operable unit.
Preference for Treatment as a Principle Element
This interim action satisfies the statutory preference for treatment as a principal
element of the action. This statutory preference will also be addressed in the final
decision document for the NSDD and the Surface Water Integrator Operable Unit.
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2.11 Documentation of Significant Changes
The Proposed Remedial Action Plan for Source Control at the North-South
Diversion Ditch, was made available for public comment on November 8, 1993. The
Proposed Remedial Action Plan identified Alternative 3, source controls,
institutional controls and engineering controls including the installation of a
pipeline and lift station, as the preferred alternative. DOE has 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 remedy, as it
was originally identified in the Proposed Remedial Action Plan, were necessary.
During the development of the final remedial alternatives for the Surface Water
Integrator Operable Unit, including the NSDD, the necessity of action implemented
under this ROD for interim action will be reevaluated. The final ROD for the surface
water system may retain or replace portions or all of the actions conducted through
this ROD. However, nothing conducted pursuant to this ROD is deemed
inconsistent with likely final remedial actions.
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PARTS
RESPONSIVENESS SUMMARY
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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 the 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 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
initiate control of the contamination found in NSDD. As part of the remedial action
process, a notice of availability was published in The Paducah Sun, a regional
newspaper, regarding the Proposed Remedial Action Plan on November 7, 1993.
This notice appeared in The Paducah Sun from November 7th until November 14th
of 1993. The Proposed Remedial Plan for Source Control at the North-South
Diversion Ditch was released to the public on November 8,1993. This document was
made available at both the onsite and offsite administrative records and at the
Paducah Public Library. A public comment period was held from November 8, 1993
through December 8,1993.
Specific groups which received individual copies of the Proposed Remedial Action
Plan included the local PGDP Neighborhood Council, and the PGDP Environmental
Advisory Committee. Informal meetings were held with each group on December.-9,
1993 and December 13,1993, respectively. At these meetings DOE personnel briefed
the groups on the proposed action and solicited both written and verbal comments.
Phone calls and/or visits were made to various stakeholders, including neighbors
and representatives of environmental groups, to alert them to the public comment
period and briefly explain the Proposed Plan. Proposed Remedial Action Plans
and/or Interim Corrective Measures were mailed to those contacted.
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: to provide DOE with
information about the community preferences and concerns regarding the remedial
alternatives and to show members of the community how their comments were
incorporated into the decision making process. This document summarizes both the
oral and written comments during the various informal meetings and telephone
calls, and the written comments received during the public comment period
running from November 8,1993 through December 8, 1993.
As evidenced from the comments received during the public comment period, the
selected interim remedy specified in the Record of Decision for interim action is
supported by both the community and governmental agencies. No comments were
received from any group or organization opposed to this interim remedial action.
Comments received during the public comment period for the interim remedial
action are summarized below. Comments and responses have been divided into two
parts and are categorized by topic within the Responsiveness Summary. Part I
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represents local community concerns, and Part II specific legal and technical
questions. The comments below have been paraphrased in order to effectively
summarize them in this document. Copies of the written comments are available
for review at the administrative records.
3.2 Summary and Response to Local Community Concerns
COMMENT: The United States Department of the Interior (USDOI) stated, "We
support the efforts of DOE to reduce contaminant mobility and volume. To ensure
this is occurring, we recommend regular monitoring of the discharge after
treatment."
RESPONSE: The effluent which flows through the NSDD is discharged out the
001 KPDES Outfall. Consistent with the' requirements of the KPDES permit this
outfall is monitored for radionuclides on a monthly basis. Additionally, all
discharges from C-400 will be sampled prior to release to ensure they comply with
the target treatment goals specified in this Record of Decision.
COMMENT: "Any contamination which has left the reservation should be
excavated and returned to the site. Signs and fences inside the complex will be
satisfactory, unlike those placed on the offsite portion of the North-South Diversion
Ditch. Fences offsite are not tall enough to restrict deer from entering portions of the
ditch. This constitutes a pathway of contamination to humans who would hunt the
deer or other small animals. Also, some of the fences are not fully enclosed."
RESPONSE: This interim action is intended to mitigate the movement of onsite
contamination by providing source control to the contaminated portions of the
NSDD which are located within the boundaries of the PGDP security fence. Remedial
activities for dealing with areas outside the PGDP security fence will be evaluated
through a feasibility study for the surface water integrator operable unit.
On July 15, 1993, construction was completed on the signs and fencing as specified in
the Interim Corrective Measure Work Plan for Institutional control of Offsite
Contamination in Surface Water. The objectives of this work plan was to implement
a system of institutional controls that would identify the areas of contamination
through the posting of warning signs and reMnct casual public access to the creeks.
This document was released for a thirty dav public comment on October 30,1992. No
written comments were received.
To ensure protection of individuals which hunt in the areas adjacent to the PGDP,
DOE and the WKWMA have instituted a biological sampling program. Through this
program, a representative number of deer arv sampled to ensure that they don't pose .
a health risk to personnel utilizing the WKWMA
COMMENT: "Since there is funding of 3 1 million dollars in the FY 94 budget to
correct the problems associated with the North-South Diversion Ditch and you show
expenses of 2,194,724 dollars, does this reflect an attitude of the future that it's not
worth the effort to remediate the site completely'"
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RESPONSE: The cost estimate cited in the Proposed Remedial Action Plan For
Source Control At The North-South Diversion Ditch estimated a cost of $1,370,860
for the selected interim remedial action. These estimates have been further refined
to a capital cost of $1,342,511 and a present worth cost of $1,419,525. DOE believes that
these interim actions are a key component towards providing protection for human
health and the environment, while progressing to final remedies for each operable
unit. The decision to not implement a final action at the NSDD at this point in time
was not based on economic factors.
DOE is committed to proceed to final actions for each operable unit once sufficient
information is known to ensure that the selected remedy will provide protection to
human health and the environment and comply with all applicable or relevant and
appropriate requirements. Final remedial decisions for the NSDD and the Surface
Water Integrator Operable Unit will be made through the remedial investigation
and remedy selection process after the nature and extent of contamination in the
surface water system and the contribution of contaminants from source operable
units are more fully understood.
3.3 Comprehensive Response to Specific Legal and Technical Comments
COMMENT: "The control of contaminates should start at the source. I am
satisfied with the installation of the Ion Exchange unit to remove the radioactive
contaminates before they reach the environment. What I am not comfortable with
are the terms 'Derived Concentration Guideline Level, Best Management Practice,
and As Low As Reasonably Achievable.' The contractor and the Department of
Energy determine these figures. Past experience has been if the acceptable levels
cannot be met, you will increase the allowable levels. Historically the levels of
releases have been too high, as shown in the sediment samples of the ditch."
RESPONSE: This Record of Decision serves as a legally enforceable document.
Both EPA and Kentucky's Division of Waste Management have the authority to
make DOE comply with the requirements of this document. The target level for
treatment for radionuclides was determined through consultation with both EPA
and KDEP. DOE has selected these target treatment levels to provide protection to
human health and the environment by safeguarding both the surface water and the
underlying ground water.
COMMENT: DOE "failed to mention the sewer system that consists of a network
of piping that collects surface drainage and building, roof, and floor drainage that is
released to nine effluent ditches leading to Big and Little Bayou Creeks. The
sediments within these pipes contain PCBs and radioactive contaminants which
would also constitute a source of contamination. The use of silt trap, lift station, and
piping will slow the contaminates in the North-South Ditch; but by not addressing
the other nine ditches which constitute another major pathway for contamination,
your efforts will be minimal."
RESPONSE: This interim action at the NSDD constitutes an incremental step
towards comprehensively addressing the Surface Water Integrator Operable Unit.
The sewer system and ditches cited in the comment are to be investigated and
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remediated as part of Waste Area Group 18. DOE, EPA, and KDEP are currently
negotiating the generic baseline schedules for the Waste Area Groups. These
schedules will be part of the PGDP Site Management Plan. Once agreement has been
reached on the generic baseline schedule, DOE will have a projected start date
available to the public for initiation of the remedial activities for WAG 18.
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