United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R04-91/095
September 1991
<& EPA Superfund
Record of
Oak Ridge Reservation (USDOE)
(Operable Unit 3), TN
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co
50272-101
REPORT DOCUMENTATION 11. REPORT NO. 12 3. ReclpIent'a Acceeeion No.
PAGE EPA/ROD/R04-91/095
4. Title and SubtiUe 5. Reporl Date
SUPERFUND RECORD OF DECISION 09/19/91
Oak Ridge Reservation (USDOE) (Operable Unit 3), TN
6.
Second Remedial Action
7. Author(a) 8. Perfonnlng OrganlzeUon Rapt. No.
8. Perfonnlng Orgalnlzation Name end Addre.. 10. ProjectlTallklWork Unit No.
11. Contrect{C) or Grant(G) No.
(C)
(G)
12 Sponsoring Organization Name end Addre.. 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Notea
16. Abetrac1 (Limit: 200 worda)
The Oak Ridge Reservation (ORR) (USDOE) (Operable Unit 3) site is an active nuclear
weapons component manufacturing facility located in Oak Ridge, Anderson County,
Tennessee. The Y-12 plant, which is addressed as Operable Unit 3, is one of several
hundred waste disposal sites or areas of contamination at the ORR site requiring
Superfund remedial action. The site occupies the upper reaches of East Fork Poplar
Creek (EFPC) in Bear Creek Valley. From 1940 to the present, the Y-12 plant has been
used to produce nuclear weapons components. From 1955 to 1963, mercury was used in a
column-exchange process to separate lithium isotopes. Mercury spills from this process
resulted in mercury and mercury-contaminated sediment being pumped from the basements
of buildings into three concrete sedimentation tanks connected to storm sewers, which
discharge to EFPC. Testing of the three concrete tanks showed that the tank sediment
contained mercury, and that contaminated waste is still being discharged into two of
the three tanks. This Record of Decision (ROD) focuses on the contaminated sediment in
the sedimentation tanks as an interim action. Future RODs will address principal
threats posed by plant conditions including eliminating mercury from the storm sewer
(See Attached Page)
17. Document Analyaia L Deacriptors
Record of Decision - Oak Ridge Reservation (USDOE) (Operable Unit 3), TN
Second Remedial Action
Contaminated Medium: sediment
Key Contaminants: metal (mercury), radioactive materials
b. ldentifiera/Open-Ended Terms
Co COSATI FietdlGroup
18. Availability Statement 18. Security CI..a (Thla Reporl) 21. No. 01 Pagea
None 24
20. Sec:urtty CI..a (Thla Page) 22. PrIce
Nonf>
'11'
i'
(See ANSl-Z38.18)
See 'm,truCliona on Rave"",
(Formerly NTfS-35)
Dtpertment d' Commerce
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EPA/ROD/R04-91/095
Oak Ridge Reservation (USDOE)
Second Remedial Action
(Operable Unit 3), TN
Abstract (Continued)
system. The primary contaminants of concern affecting the sediment are mercury, a metal,
and radioactive materials.
The selected interim remedial action for this site includes removing mercury-contaminated
sediment, liquids, solids, oils, and oily water from tanks, followed by offsite treatment
and disposal; stabilizing mixed wastes from one of the tanks, followed by onsite
disposal; screening the wastewater removed from the tanks for hazardous and radiological
contamination prior to sediment removal, followed by onsite treatment of the wastewater;
solidifying mixed wastes, followed by onsite storage; and monitoring ground water and
sediment. The estimated capital cost for this remedial action is $0, with an annual O&M
cost of $586,000. This interim remedy is expected to take only five months to implement.
PERFORMANCE STANDARDS OR GOALS:
Not provided.
-------
Record of Decision
Interim Action
for the
Mercury Tank Remediation
September 1991
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FI~AL DRAFT
Record of Decision
Interim Action for the ~fercury Tank Remediation
Sepremb~r 1991
Prepared for
U.S. Department of Energy
Oak Ridge Y-12 Plant
Oak Ridge, Anderson County, Tennessee
Prepared by
Radian Corporation
120 South Jefferson Circle
Oak Ridge, Tennessee 37830
Doc. #D910723.1SF51
CKR. ')! -05S
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DR.-\FT F!:\.-\L
CONTE:\TTS
ACRONYMS AND INIT!ALIS~tS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
DECLARA TIO~ ..........................................
1. SITE ~A~tE. LOCATION, AND DESCRIPTION. . . . . . . . . . . . . . . . . .
2.
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . .
3. HIGHLIGHTS OF COM~(L'NITY PARTICIPATION. . . . . . . . . . . . . . . .
4. SCOPE AND ROLE OF RESPO~SE ACTION \\'ITHI~
SITE STRATEGY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5. SUMMARY OF SITE CHARACTERIZATIONS. . . . . . . . . . . . . . . . . . .
6. SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7. DESCRIPTION OF ALTER~ATIVES .................,.......
7.1
7.2
7.3
ALTERNATIVE I-NO ACTION. . . . . . . . . . . . . . . . . . . . . . . .
ALTERNATIVE 2-ABANDON TANKS IN PLACE. . . . . . . . . . . .
ALTERNATIVE 3-REMOV AL AND DISPOSAL OF
CONTAMINATED SEDIMENT. . . . . . . . . . . . . . . . . . . . . . . . .
8. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . .
8.1
OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COMPLIANCE WITH ARARs . . . . . . . . . . . . . . . . . . . . . . . . . .
LONG-TERM EFFECTIVE~ESS AND PERMANENCE. . . . . . . . .
REDUCTION OF TOXICITY. MOBILITY, OR VOLUME OF
THE CONTAMINANTS THROUGH TREAT~tENT . . . . . . . . . . . .
SHORT-TERM EFFECTIVENESS. . . . . . . . . . . . . . . . . . . . . . .
COST........................................ .
STATE ACCEPTANCE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COMMUNITY ACCEPTANCE. . . . . . . . . . . . . . . . . . . . . . . . .
8.2
8.3
8.4
8.5
8.6
8.7
8.8
9. THE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10. STATUTORY REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
O~IO~.J ;SF~I
10.1 PROTECTION OF HU~tAS HEALTH ASD
THE ENVIRONME~T . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10.2 ATTAINMENT OF ARARs . . . . . . . . . . . . . . . . . . . . . . . . .
111
V
,VI
5
6
6
7
. 8
8
8
9
10
11
11
12
..,
lw
12
13
13
13
[3
1~
. .
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F[\'AL DR.-\FT
10.3 COST EFFECTIVE:--IESS """"""""." . . . . . . . . . . .
10.4 UTILIZATION OF PER~fANEST SOLUTIONS
AND ALTERNATIVE TREA T~1ENT TECHNOLOGY
OR RESOURCE RECOVERY TECH:--JOLOGIES TO
THE MAXIMUM EXTENT PRACTICABLE. . . . . . . . . . . . . . . . .
10.5 PREFERE:--ICE FOR TREAT~1ENT AS A PRINCIPAL
ELE~1ENT """"""""""""""'" . . . . . . .
10.6 DOCCMENTATION OF SIGNIFICANT CHA:'-IGES . . . . . . . . . . . .
Appendix A. RESPONSIVENESS SUMMARY. . . . . . . . . . . . . . . . . . . . . . .
O~;O~.:SF~I
1\'
l~
15
15
15
A-I
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ARAR
CERCLA
DOE
EFPC
LOR
MOU
O&~
ORR
RCRA
RI/FS
ROD
the Site
UEFPC
0910'"::' :SF~I
ACRONDIS A.~D I~ITIALIS~IS
- applicable or relevant and appropriate requirement
Comprehensive Environmental Response, Compensation,
1980
U.S. Depan:ment 01' Energy
East Fork Poplar Creek
land disposal restriction
Memorandum of Undemanding
operation and maintenance
Oak Ridge Reservation
Resource Conservation and Recovery Act
Remedial Investigation/Feasibility Study'
Record of Decision
Oak Ridge Y-12 Plant
Upper East Fork Poplar Creek
\'
FI:\AL DR.;FT
and Liab" :ty Act or"
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FI\.-\L DR,~FI
DECLARATIO:\T
SITE NAME ~-\ND LOCATION
U ,S, Department of Energy
Oak Ridge Y -12 Plant
Oak Ridge, Anderson County. T ~nnessee
STATE~fENT OF BASIS AND PURPOSE
This decision document presents the selected interim action for the :-'1ercury T J:1k
Remediation at the Oak Ridge Y.l:! Plant (the Site). in Oak Ridge. T~nnessee, which was .:hosen
in accordance with the Comprehensiv~ Environm~ntal R~ponse, Compensation. and Liability A.:t
of 1980, as amended by the Superfund Amendments and Reauthorization Act ot' 1986 and. to the
extent practicable, 'the National Oil and Hazardous Substances Pollution Contingency Plan, This
decision is based on the administrative record file for this site.
The State of Tennessee and the U,S. Environmental Protection Agency concur with this
interim action for the Mercury Tank Remediation.
ASSESSMENT OF THE SITE
ActUal or threatened releases of hazardous substances from this site, if not address~d by
implementing the response action selected in this interim action Record of Decision (ROD). mJY
present a current or potential threat to public health. welfare, or the environment.
DESCRIPTION OF THE REMEDY
The major goal of this interim action is to reduce the amount of mercury-contaminated
sediment and elemental mercury entering the storm sewer system from three tanks at t.f)e Site
The storm sewer system empties into the Upper East Fork Poplar Creek (UEFPC), E:mtlng
monitoring data indicate that several areas within the Site are contributing a significant ~O!1iOn
of the mercury loading to UEFPC. Removal of sedimentS from the three tanks will eliminate 3
known source of mercury-contaminated sediment from contact with surface water in u'i~ S,Jr:-:1
sewer system. This interim action is intended to prevent the spread of contaminated sur:':!.::
water by removing a known source of contaminantS early during the investigative process t-~:.,:)re
the Remedial Investigation/Feasibility Study (RI/FS) for UEFPC and/or the RI/FS for \:er'::.iry
Use Areas at the Site have been completed. This is not the final action planned t'or .:::,::~.;i:,:,:~
0910~ :SFH
\'1
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F!\;\L D~.~FI
.releases to UEFPC from the Site. Subsequent actions are planned to fully address .he ~r:n.;ipa!
threatS posed by the conditions at the Site. These actions will be defined when the prcviously
mentioned ~I/FSs are complete.
The major components of the interim action remedy consist of the following:
. removal of oil and oily water in Tank 2101-U.
. removal of mercury-contaminated sediment from Tanks 2100-U and 2101-L'.
. removal and solidification of mixed wastes from Tank :104-U, and
. removal of water from all three ranks.
The estimated cost for the interim action remedy is 5536.000.
o~:a:-~. :SF!!
\' II
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12/19/31 15:00 DOE ENUIRONIENTflL. RESTORfiTION 002
STATUTORY DETERMINATIONS
•This interim action is protective of human heal(h and the environment, complies with
Federal and "State applicable or relevant and appropriate requirement! for this limited-scope
action, and is cost-effective. This action is interim and is not intended to use permanent solutions
and alternative treatment (or resource recovery) technologies to the maximum extent practicable,
given the limited scope of the action. Because this action does not constitute the final remedy
for the Site, the statutory preference for remedies that employ treatment that reduces toxicity.
mobility, or volume as a principal element will be addressed at the time of the final response
action. Subsequent actions are planned to fully address the principal threats posed by this Site.
Because this is an interim action ROD. review of this site and of this remedy will be continuing
as part of the development of the final remedy for UEFPC and/or .Mercury Use Areas.
Rejional Administrator. Region IV w ' Date
U.S. Environmental Protection Agency
U-
anager, Oak Ridge Field Office Daw
U.S. Department of Energy
Director. DOE Oversight Division- •"* Date
State of Tennessee
Department of Environment and Conservation
vjii
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0910"'::'. :SF!:
DECISIO:\' SL~[\L\RY
RECORD OF DECISION
I~TERlM ACTION
FOR THE ~[ERCVRY TANK RE~IEDIATION
c.s. DEPART:\IE~T OF E~ERGY
OAK RIDGE Y-12 PLA.~T
OAK RIDGE, TE~NESSEE
r: I \' .1, L DR..1, FT .
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FI \'.-\ L D R..-\ FT
1. SITE ~A.\fE, LOCATIO~, A~D DESCRIPTIO~
The Y-12 Plant (the Site) is part of the Oak Ridge Reservation (ORR) Superfund Site and
is located adja..:ent to the city of Oak Ridge in Anderson County, Tennessee. The Site occupies
the upper reaches of East Fork Poplar Creek (EFPC) in Bear Creek Valley, which lies between
Pine Ridge to the north and Chestnut Ridge to the south.
The site is drained by a storm water sewer system that discharges directly to Cpper East
Fork Poplar Creek (UEFPC). Tied into the storm sewer system are three ..:oncrete sedimentation
tanks that receive flow from basement sumps located in two buildings that formerly housed a
mercury-based lithium separation process. The location at' these buildings are shown in Fig. 1.
The three tanks receiving discharges from the basement sumps are locared outside
Buildings 920 1-~ and 9201-5 and are shown in Fig. :. The ranks are of concrete ..:onstruction
and are divided into two compartments. The wall dividing the ..:ompartments is open at the top.
which allows liquids to flow between the two compartments when the tank is full. A schematic
diagram of the tanks is shown in Fig. 3.
As a result of past spills and intentiQnal wastewater dis.:harges. these tanks are tilkd with
mercury-contaminated sediment. Recent sampling indicates that finely divided. mercury-
contaminated sediment is still being discharged to two of the three tanks. All three ranks have
been identified as .;:ontributing ex.;:essive mercury to L'EFPC.
2.
SITE HISTORY AND E~FORCE:\'IE~T ACTIVITIES
The Y-12 Plant was constructed in the 1940s and primarily makes nuclear weapons
components. In 1953, the Site was involved in the first production-scale separation of lirhium
isotopes for the development of hydrogen bombs. The lithium separation process involved
separating the 6Li isotope from the 7U isotope. Because 6Li dissolves more readily in me~;ury.
a column-exchange (Colex) process that used mercury as the solvent was developed to e:ma.:t the
6Li isotope. The Colex process was conducted from 1955 to 1963 in Buildings 920 I ~ and 9:01-
5. The location of these buildings can b~ seen in Fig. I. \fercury spills resulting from the
lithium separation process have been documented in the administrative record. \fer;:.ory i'rom
these spills found its way into sumps in the basement fan rooms of the twO buildings. \Ier;~ry
and mercury-contaminated sediment was then pumped from the basement sumps thrcu~h :hr~~
concrete tanks into the storm sewer system. Floor drains in ~a.;h building also Jral:1;:~ .:-::'J :.~~
storm sewer system through the tanks: th~se tanks a':ditionall y rec~ived discard;d l~. .:., l5:1.
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JII11-. L.tlt~ '1':::::---
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y (.~ ~ }ftl~A
,,,IY !IO. 11111
Y-12 PLANT
[=:J UU/lDINGS 0201-'1
AND 0201-5
Fig. I. Location or Buildings 9201-4 and 9201-5 atthc Y -12 Plant
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rorLAft alES
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"i~. 2. Tank 11I(;aliIlIlS al Uuildings 9201-4 and 9201-5.
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30' . 30' Manhole,
9' deop wlO.7' deep
&ump In SW corne,.
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2. 'A' . 24' '" opening w/32' I( 32' sloel covo,.
3. 'D' . 30' I( 30' equipmenl I>eso. 24'", 0.l'0nloo 1$ Ilkoly.
4. Tolnl deplh of lump . 9.1' Irom lop 01 $Ia&l to Inve,..
30' II 30' Opening
wlSlee' Cover
re1 a~~ 0
- 4'",2''''' Conduil, TVp. Typ'.
2' II 0.85' Column 10 Slob
l 0.85',4'1010,10, Wall
~
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Scala
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lop 01 ,lab. 9'
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\IIhi~h resulted from washing m~rcury with a water/nitric a~id solution. Th~s~ rr.e;~.:.::lsms
account for the majority of mercury and mercury-contaminated sedim~nt contained in the :anks.
Tank 2 to I-U has been abandoned in place and no longer receives water from the fan room
sumps. Water previously entering Tank:: IO\-U has been redirected to Tank: IOO-C; therefore.
Tank: IOO-t; now re~eives all water pumped frolTl the fan room sumps in Building 9201-~. TanK
2104-U currently has water ftowing only through the north compartment.
In May 1983, a Memorandum of Understanding (~10U) was signed by the C.S.
D~partment of Energy (DOE). the U.S. Environmental Protection Agency (EPA). and the State
of Tennessee concerning compl iance with pollution control standards at the Y - t: Plant. Among
Other things in the ~10U. DOE agreed to submit to EPA and the State of Tennessee J report
describing all Y -1:: Plant J ischarg~s to U EFPC and int~rim control m~asures for th~ same and
submit a master monitOring plan for surface and groundwater at the Site. Discharges [0 LEFPC
were also the subject of a Complaint and Order issued against the Y -12 Plant by the Tennessee
Department of Health and Environment in September 1983.
On December 21, 1989, the ORR was added to the National Priorities List. Past releases
of mercury from the Y -12 Plant to area surface waterS was a principal factor in the I ist'ing
decision.
3. HIGHLIGHTS OF CO~f.\[UNITY PARTICIPATION
The Interim Action Proposed Plan for the M~rcury Tank Remediation at the Site 1,\,3S
released to the public on June 28. 1991. This document was made available in the administrative
record maintained at the DOE Information Resource Center located at 105 Broadway In Oak
Ridge. The notice of availability was published in The Oak Ridger on July 7, 14, and: 1. ; 991.
Notices were also published in The Roane County News and the Knoxville Joumal on J~i~ 3. ; 5.
and 22, 1991, and the Knoxville News-SeJl/inel on July 21 and 30. 1991. A public ~:Jrr.:r.er.t
period was held from June 30, 1991 to July 30, 1991. In addition to publi~ comment 1.10 :'-.e
accessibility of the information, a public information session was held on July 22, 1991 :1,[ :~;s
session, representatives from DOE and ~tartin ~farietta Energy Systems ~ainter.Jr.;~ l:-.J
Operations answered questions and received commentS. A response to comments rece:\'eJ '='';~::-:~
the comment period is included in the Appendix A. Responsiveness Summary of :..~:s .~.:~~.'7':
action Record of Decision (ROD).
This decision do~ument presents the selected interim action for the \ter :'';~\ ~ ~~"
Remediation at the Site. chosen in a..:.:ordance with the Comprehensive Environment:!! ~:: -: . -, ~.
O~I07:;! :SF!!
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,--
6
r[\.;L SR..\FT
Compensation, and Liability A.:t of 1980 (CERCLA), as amenJ~ hy the Superfund Am~:1dma,[s
and Reauthorization Act of 1986 and, to the extent practicable, the \'ational Oil and Hazardous
Substances ~ollution Contingency Plan (:--:CP), The decision for this site is based on the
administrative record and indications of a .:urrent or potential threat to public heJlth. welfare. or
the environment,
4. SCOPE A..'\!D ROLE OF RESPO~SE ACTIO~
\VITHIN SITE STRATEGY
The major goal of this interim action is to reduce .the amount of mercury-contaminated
sediment from entering the stOrm sewer system by minimizing the putential for water to
resuspend mercury-cuntaminated sediment while passing thruugh the tanks, This actiun is
intended to address only contaminated sediment contained in the tanks. It will also enhance the.
capabilities of the two remaining operating tanks to settle mercury-contaminated sediment pumped
from the fan room sumps.
Mercury is one of the major contaminants leaving the plant by surface water transport.
Removal of the sediment from the tanks mitigates one of the surface water sources. \.-tethods for
treating the fan room sump water prior to its entering the tanks are being considered: ho'-'
-------
I
-
I
Fi\AL :i<.-\Fi"
Tank 2100-U now rec~i\'es all wJl~r rurr.r~d from the t'J:1 room sumps in Bui:Jin~ 9:01.~.
Discharges through this tank have be~n 3S high as :5.000 gal pu day. \lercury.;oncentrations
in the sediment for the north and south .;ompartme:1ts are iO.OOO ppm and 29.000 ppm.
respectively. as recorded by a single sampling event. The estimated volume of sedim~nt in both
~ompanments is 190 ftJ. .
Tank 2104-U now has water flowing only through the north ~ompartment. \1:r.:w.y
concentrations in the sediment for the north and south compartments are 6560 ppm a:1d 19~ ppm.
respe.:tivel y. Sampl ing data ind iC3te that rad iological contamination is present in Tank: 1 O~- U
sedimentS: resulting in the classification of this material as mixed waste (a waste that .;ontains
both a hazardous waste component and a radioactive waste comronent). Sediment in Tank : iO~-
LJ is level with the invert ot' the dis~harge ['ire in the sump. The estimated volume of seJim~!1t
for both compartments is I ~O ftJ.
6. ST.J~[\1ARY OF SITE RISKS
CERCLA directs that human health and the environment must be protected from .:urrent
and potential exposure to hazardous substances at Superfund sites. 11'\ order to assess the .:urrent
and potential risks for the Y-12 Plant. a full risk assessment is being conducted as p3rt or' :::e
RI/FS process.
Analytical resultS of water samples collected from the tanks show mercury .;onc:ntr:H1ons
ranging from 7 ppo to 1600 ppb. Elemental mercury also has been found in .;atch basins and
storm sewer lines downgradient from the tanks, Tank 2104.LJ is believed to be a possible source
of the mercury in the catch basins. As the mercury-contaminated water from these tanio;s leaves
the plant, it enters UEFPC, which discharges to EFPC. The potential exists for absor';tlon or'
mercury by on.site and off.site aquatic organisms, In addition. EFPC flows through the ;:ty or'
Oak Ridge where the public has access to the creek. Implementation of the interim a.:::on v. ill
help reduce the amount of mercury-contaminated sediment that could be discharg~d to L' EF?C.
The major goal of the interim action is .to reduce the mercury-contaminated s:;::,r:-:::~l
entering the storm sewer system by minimizing the potential for water passing through :..":~ :~:-.:"':s
to resuspend men:ury-~ontaminat~d sedim~nts. This al::ion will al:hi~\'e sigr.iIi':Jnt :'is:'': ,~';';~:._'::
~arly in the Superfund investigation prol:~ss.
DQIO~.lSF~1
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s
i-1:\,.l.L DR.-\FT
Actual or threatened releases of hJ.nrdous subm.nces from the Site. if not adc~essed ';,y
. . implementing the response action selected in this interim action ROD. may presem a current or
?otentialth'r~at to public health, welfare. or the environment.
,. DESCRIPTIO:\! OF ALTER~ATIVE.s
. 7.1
AL TER~A TlVE l-~O ACTION
The ~CP requires that the So A..:tion alternative be considered through the de::!iied
analysis. It provides a baseline for comparison of other alternatives. Under the :\0 .-\-::ion
alternacive. no sour..:e control remedial measures would be undertaken at the Site.
Capital ..:ost . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Annual Operation and \tair.tenan..:e (O&\{) COstS. . . . . . . .
Surface water monitoring will be required: however.
it is already being conducced as pare of the
daily monitoring program at the plant.
\fonths to implement. . . . . . . . . . . . . . . . . . . . . . . . . .
50
50
o
The ~o Action alternative would not eliminate any eJtposure pathways or redu-:e i...'1e leve!
of risk.
7,2
ALTERNATIVE 2-ABANDON TANKS 1='1 PLACE
To prevent mercury-contaminated sediment from ftowing into the scorm sewer symm. the
valves on the tanks could be adjusted co divert water around the tanks. This alter::3t1\ e is
applicable only to Tanks 2l00-U and 2l04-U. Tank 2l01-U has already been abandcned in
place. Existing valves on Tanks 2l00-U and 2l04-U can be opened to allow water pum~ed :'~0m
the fan room sumps to discharge directly to the storm sewer. The tanks would be .:!eaned JnJ
removed at a later date when Building 9201-4 is demolished under the Decontaminat:on ..i::d
Decommissioning Program.
Capital cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Annual O&M COSts. . . . . . . . . . . . . . . . . . . . . . . . . . .
\-10nths to implement. . . . . . . . . . . . . . . . . . . . . . . . . .
so
50
I
This alternative reduces the possibility of mer~ury'..:onraminated sediment ir. ::-.e :,,:-.":5
entering the Stvrrn sewer: however. it eliminates the opportunity for sediment an': ~e: ~_:'.
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.pumped from th~ fan room sum[)s to settle in the tanks b~f0re '!'Icing Jis-:hargcd to the storm
sewer.
7..3
ALTER:-':ATIVE .3-RE~IO\'AL A~'D DISPOSAL OF CO:\TA~II;\'ATED
SEDI~IE:--;T
This alternative removes m~r~ury--:ontaminated sediment, liquids. and solids from L'~
tanks. Oil and oily watu in Tank 210 I-U would be removed and s~nt to an off-site pumitted
hazardous waste facility for tr~atment and dis[)osal. \fucury--:ontaminated scdim~nt \~ould also
be removed from Tanks 21 OO-U and 210 I-U and s~nt to an off-site p~rmitted hazardous wast~
management fa~ility, \fixed wastes in Tank 2104.U would be solidified to immobilize mer-:ury.
r:.!dionudides. and liquids and Sent to a permitted hazardous waste stOr3g~ facility within ORR,
Water removed from all thr~~ tanks beture s~diment removal would be s~reened tor h:u:ardous
and radiologi~al ~ontamination and sent to the West End Tr~atment Facility. whi~h is lo-:ated
within the Site. Tank 210 I-U would b~ monitored to verify that additional water is not enr~ring
the tank. Sediment volumes in Tanks ~ 100-U and 2104-U would be monitored to d~termine th~
rate of sediment accumulation in each tank. These l)bs~rvations would be us~d to d~termin~ a
schedule for periodic removal of s~diment from the tanks.
Capital cost. . . . . . . . . . . . . . . . . . . , . , . . . . . . . . . .
Annual O&~1 cOStS. . . . . . . . . . . . . . , , . . . . . . . . . . .
Months to implement. . . . . . . . . , , , . . , , . . . . . . . , . .
SO
S5S6.000
5
This alternative removes a known source of mercury-contaminated sediment from contact
with water in the storm sewer system. It also allows for the continued use of Tanks 21 OQ-U and
2104-U as settling basins to trap sus[)ended particles of mercury and sediment pumped from the
fan room sumps. This action would achieve significant risk reduction ~arly in the Sup~rfund
process.
8. SUNtMARY OF COMPARATIVE ~~ALYSIS
OF ALTE~"ATIVES
This section provides th~ basis for determining which alternative (I) m~~ts the L'1res;'ulJ
criteria of overall protection of human health and the environm~nt and compl iance with ar-~ IICJ:,I e
or relevant and appropriate requirements (ARARs) to CERCLA: (2) provides the "best 'Jala:-.-:e"
between ~ffectiveness and reduction or' toxi~ity. mobility. or volum~ through (r:~t:;;e~(.
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. implem~mability. and cost: and (3) re;:eives state and community acceptance. A glvssary of th~
evaluation criteria is provided bdow:
8.1
.
O~'erall protection 01 human heallh and enl'ironmml-addresses whether a
remedy provides adequate protection and describes how risks posed through
each pathway are eliminated. reduced. or controlled through tre:ltme:1t
engineering controls or institutional controls.
.
Compliance wiJh ARARs-addresses whether a remedy will meet 311 of the
applicable or relevam and appropriate requirements of other federal and st3te
environmental statutes and/or provide grounds for invoking a waiver.
.
Long- Tenn effectireness and pennanence-the magnitude of residual risk 3nd
the ability of a rem~Jy to maintain over the k)ng term reliable protection or'
human health and the environm~nt ()nc~ cleanup gl'als have b~en met.
.
Reduction 01 toxicit.v, mobility, or volume thro/lgh treatmelll-the anticipated
performance of the treatm~nt technologies that may b~ ~mployed in a remedy.
.
Short- Tenn effecli~'elless-the speed with wh ich the remedy achieves protection
and the remedy's potential to create adverse impactS on human health and the'
environment that may result during the construction and implementation period.
.
ImplemenlabiJily-the technical and administrative feasibility of a rem~dy.
including the availability of materials and services n~ed~d to impl~m~nt the
chosen solution.
.
Cost-includes capital and O&~ costs.
.
State acceptance-indicates whether the state concurs with. opposes. or has no
comment on the Proposed Plan.
.
Community acceptallce-the Responsiveness Summary in the appendix or' the
ROD reviews the public comments received from the public meeting on the
Proposed Plan.
OVERALL PROTECTION OF HU1\lA~ HEALTH A:\1> THE ENVIRO:\.\IE:\T
The No Action alternative is not protective of human health and the environment. [t
continues to allow the transport of the mercury-contaminated sediment from the tanks i:1:o the
storm sewer.
Alternative 2. Abandon Tanks in Place. removes mercury-contaminated sedime:1t :n :..":e
tanks from contact with the storm sewer but does not allow the tanks to be used as sett!;:1g :aSi:1S
for water pumped from the fan room sumps.
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F! \.-\ L ;)K.~ FT
, Alternative 3, R~moval and 0 isposal of Contaminated S~d iment. remov~s :h~ .~ontar.1ir.at~d
material from the tanks and allows the tanks to continue to function as s~ttling basins. This
alternative pro_vides prote~tion of human h~alth and the environment by redu~ing or cor.rrolling
the risk through removal of the contaminated sediment and therefore preventing the spread of
.:ontamination.
8.2
CO~IPLrA~CE WITH ARARs
For Alternatives I and 2, no ARARs need to be met. For Alternative 3. the Resource
Conservation and Recovery Act (RCRA), Tennessee hazardous/mixed waste management
regulations are applicable for treatment, storage, and/or disp.osal of tank sediments. In 3ddition.
DOE orders for management of radioactive.'mixed wastes are consiJered relevant. All .-\RARs
will be met 3S the interim action is implemented. The RCRA land disposal reStriction (LOR)
requirements will be met as explained below.
The RCRA LOR treatment standards for 0009 (mercury) hazardous and mixed wastes
were promulgated by the Environmental Protection Agency (EPA) on June 1. 1990. However,
due to a nationwide shortage of treatment capacity. EPA established a :-year national .:apacity
variance for the classes of wastes contained in the three tanks at the Y -12 Plant. Th is variance
e:
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8.4
REDUCTIO~ OF TOXICITY, :,>tOBIUTY, OR VOLL':'>tE OF
THE CONTA~tlNA~TS THROt;GH TREAT\tE~'T
Alter"atives I and 2 provide no treatment to reduce the tOxicity. mobility. or volume of
the contaminant. Alternative 3 will produce four separate waste streams. some of which wiil be
treated to reduce the toxicity. mobility, and/or volume of contaminants. The mobility of mer.:ury
and radionucl ides in the mixed waste removed from Tank 21 O~-U will be reduced by
solidification. However. this is only an interim measure. The need for further treatment .....-lil
be evaluated as part of the development of the final action UEFPC and/or the ~1er:ury Cse
Areas. which are expected to involve much larger quantities of mercury-contaminated suils.
Ultimately, the mercury-contaminated hazardous and mixed waste will have to be treated to
RCRA LDR treatment standards for D009 waste. \1er.::ury-contaminated sedime:m r~:T1o\'ed
from Tanks 2100-U and: I Ol-U and sent to a permitted olf-site hazardous waste manage:;;ent
facility mayor may not be treated by a thermal mercury recovery pro.:ess prior to Jis[1osal
depending on the date of shipment. If treated. the toxi.:ity and volume of .:ontaminant ....ould be
reduced. Oil and oily water in Tank 210 I-U will he sent to an off-site permitted hazardous waste
management facility for treatment. Oils and high organic content wastes are typically treated by
incineration. which reduces the volume. toxicity. and mobility of contaminams. Contaminated
water removed from the tanks will he treated on-site to reduce toxicity before discharge.
Alternative 3 is also expected to improve the settling of sedimencs and elemental mercury In '.Iiater
pumped from the fan room sumps. This should decrease discharges of mercury :0 L' EF?C.
8.5
SHORT-TERM EFFECTIVE:\TESS
There would be no adverse effects to human health or the environment from implememing
any of these alternatives. Any short-term risk to workers involved in completing Alternative 3
would be reduced through the implementa[ion of a detailed site-specific health, and safety plan.
Alternative 3 is effective in the short-term because it would prevent a known S0wr:e of
contamination from discharging to the storm sewer system.
8.6
COST
The estimated cost for Alternati\'~ 3 is S586,OOO. For this action there would b~ no ~JS:S
for monitoring the tanles after ..:leaning because of ~urrent monitoring programs in pI3-:~ :H :.~~
Y-12 Plant.
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:=;\" -\L :)R.-\fl
8.7
STATE ACCEPTA:\'CE
The State of T~nnesse~. as represented by the T..:nness~e Department of Environ:7::::1t anu
Conservatio-n, DOE Oversight Division. concurs in the selection of Alternative 3 as an interim
action for the Site.
8.8
CO:\I:'>ltJNITY ACCEPT A:\'CE
Based on comments made by citizens at the public information and comm~nt session held
on July 22. 1991 and comments received during the public comment period. DOE per;e:\'es :"":3t
the community believes the interim action will effectively protect hum:m health 3nj the
environment.
9. THE SELECfED RE~IEDY
Based upon consideration of the requirementS of CERCLA. the detailed analysis of the
alternatives, and the public comments. DOE has determin~ that Alternative 3. Removal and
Disposal of Contaminated Sediment. is an appropriate interim action until a final 3c::on ~'or
UEFPC and/or Mercury Use Areas at the Y -I: Plant is determined. Based on '::.ment
information. this alternative provides the best balance with respect to the nine criter:a used to
evaluate alternatives.
"
The major goal of the interim action is to r~duce mercury-contaminated sed i rr.ent :lnd
elemental mercury entering the storm sewer system from three tanks. Although the interim :lction
will not completely prevent mercury from entering the storm sewers. it will rerr.ove kn0wn
sources of contamination currently in direct contact with water entering storm sewers. This
interim action will achieve significant risk reduction early in the Superfund process.
The final remedy for eliminating mercury from the storm sewer system is not addressed
in this interim action ROD because such goals are beyond the limited scope of :.his 3c::on.
Subsequent interim or final actions are planned to address the groundwater pumped into :.he stOrm
sewer system by the fan room sumps. The final remedy for releases of mercury and .:t.1er
contaminantS to UEFPC will be addressed by the finjl remedial action ROD for L'EFPC .md.'or
the ~ercury Use Areas.
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10. STA TCTORY REQllRE:\IE~TS
DOE -beli~ves that the remo\'al and disposal of contaminated sediment wiil satisfy t."~
statutory requirements providing protection of human health and th~ environment. wiil att.1in
ARARs directly associated with this action. and will b~ cost-effective. S~ctions 10.1 :....rough
10.6 b~low summarize the statutory requirements for th~ Site.
10.1 PROTECTIO~ OF HL'~IA:-I HEALTH A:\""O THE E:-IVIRO:\:\IE:\T
The selected remedy prote;;ts human h~alth and the environment through re;:'1\)\'al uf tr.e
contaminated sediment and preventi0n of the spread of contamination.
10.2 Arr"\IN:\IE~T OF THE ARARs
Th~ selected rem~dy will comply with all id~ntified ARARs for this limited action.
RCRA. Tennessee hazardous/mixed waste management regulations, and T ~nnessee water
pollution control regulations are aprlicable for treatment. storage, and/or disposal or removed
sediment. In addition. DOE ord~rs for management of radioactive/mix~d wastes ....:11 ~~
followed.
10.3 COST EFFECTIVENESS
The interim action remedy employs a proven technology and affords overall dfe~:I\'eness
proportional to its costs such that the remedy represents a reasonable value for the r:,oney
lOA uIILIZATION OF PER;\IA~ENT SOLUTIO~S A~1> ALTER.~:HI\'E
TREATMENT TECHNOLOGY OR RESOtJRCE RECOVERY TECH\OLOGIES
TO THE MAXIMUM E:-"'l'ENT PRACTICABLE
The objective of this interim action is to reduce mercury-contaminated sedim~~t lna
elemental mercury entering the stOrm sewer system from three tanks. Removal L'r' :he
contaminated sediment will achieve reduction in the contamination at the Site and will er'_'":an..:e
the attainment of a permanent rem~dy. This is not the final action planned for the Site. .l~J DOE
will continue to evaluate loog-term effectiveness and permanence as part of the deve!cprT'.e~t :;r'
the final action for UEFPC and/or ~tercury Use Areas at the Y-12 Plant. Comple::c:1 ,,:' ::.e
RIfFS process will fully address the principal threats posed by the conditions at :he S.:e .:-:e
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FI\AL DR..~FT
.5nal decision document will address utiliz:Hion of a permanent solution fur th~ r~I~:lS~s from th~
Site via the ~urface water pathway.
10.5 PREFERE;\'CE FOR TREA T~IE;\,T AS A PR1;\,CIPAL ELDIE!'.&
This is not the final action planned for controlling releases to UEFPC from the Y-12 Plant.
The final remedy for ~Iiminating mercury from the storm sewer system is not addressed in this
interim action ROD because such goals are beyond the limited scope of this action. However.
as explained in S~,~t. 8.*, treatment appropriate to the limited scope of this action will be utilized
as necessary to meet ARARs. The selected remedy will utilize solidification to treat 140 ff of
mixed waste. If required for di~rosal. 340 ft3 of mercury-contaminated sediment will be treated
at on off-site permitted hazardotls waste managem~nt facility by a th~rmal tr~atm~nt process Tor
recovery of mercury. Oil and oily wat~r will be treat~d at an otf-site p~rmittcd hazardous waste
management facility. Contaminated water will be treated at an on-site wastewater treatment plant.
Finally, removing accumulated sediments from the orerating tanks will restore their sedimentation
(treatment) function.
10.6 DOCUMEi\'T A TION OF SIG~IFICANT CHANGES
The Proposed Plan for the Site was released for public comment on June 28. 1991. and
the removal and disposal of contaminated sediment as the preferred interim action alternative '.~ as
identified. DOE reviewed all written and verbal comments submitted during the puhl ic ;cmment
period. Upon review of these comments, it was determined that no significant changes to the
alternative as it was originally identified in the Proposed Plan were necessary.
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