PB97-964017
EPA/541/R-97/075
November 1997
EPA Superfund
Record of Decision:
Oak Ridge Reservation (USDOE),
Clinch River & Poplar Creek Operable Units,
Oak Ridge, TN
9/23/1997
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
100 ALABAMA STREET. S.W.
ATLANTA. GEORGIA 30303-3104
SEP 1 9 1997
4WD-FFB
MEMORANDUM
SUBJECT:
FROM:
THRU:
TO:
CLINCH RIVER AND POPLAR CREEK OPERABLE UNIT
RECORD OF DECISION
OAK RIDGE RESERVATION, OAK RIDGE, TN
Victor L. Weeks, RPM
Oak Ridge Reservation
Camilla B. Warren, Chief
DOE Remedial Section
Jon D. Johnston, Chief
Federal Facilities Branch
Jewell A. Harper, Deputy Director
Waste Management Division
Richard D. Green, Acting Director
Waste Management Division
This is to recommend your signature for the attached Record
of Decision (ROD) which provides for dredging restrictions and
fish consumption advisories for off-site surface water located
down-stream of Oak Ridge Reservation, Oak Ridge, Tennessee. The
Department of Energy and the State of Tennessee have signed the
ROD. The ROD will become final upon your signature. To
establish a basis for your signature, please find the attached
information concerning this ROD.
At tachment s
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (4O% Postconsumer)
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DOE/OR/02-1547&D3
Record of Decision
for the Clinch River/Poplar Creek Operable Unit,
Oak Ridge, Tennessee
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DOE/OR/02-1547&D3
Record of Decision
for the Clinch River/Poplar Creek Operable Unit,
Oak Ridge, Tennessee
Date Issued—August 1997
Prepared by
Jacobs EM Team
125 Broadway Avenue
Oak Ridge, Tennessee
under contract DE-AC05-93OR22028
Prepared for
U.S. Department of Energy
Office of Environmental Management
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PREFACE
This Record of Decision for the Clinch River/Poplar Creek Operable
Unit, Oak Ridge, Tennessee (DOE/OR/02-1547&D3) was prepared in
accordance with requirements under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 and documents the
selected remedy. This work was performed under Work Breakdown
Structure 1.4.12.3.1.02 (Activity Data Sheet 9302, "Watts Bar"). This
document provides the Environmental Restoration Program with
information about the selected remedy for Clinch River/Poplar Creek
Operable Unit, which involves continuance of existing institutional
controls and long-term monitoring of water, sediment, and fish. This
document summarizes information from the remedial
investigation/feasibility study (DOE/OR/01-1393&D3) and the proposed
plan (DOE/OR/02-1429&D2).
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ACRONYMS AND ABBREVIATIONS
Ag
ARAR
As
AWQC
B
Be
Cd
CERCLA
CFR
cm
Co
COE
Cr
CR
CRM
Cs
Cu
DOE
EIS
EPA
ETTP
Fe
FFA
FS
g
ha
Hg
IAG
in.
kg
Ib
LOG
m
Mn
NCP
NEPA
Ni
ORR
ORREM
ORREMSSAB
OU
oz
silver
applicable or relevant and appropriate requirement
arsenic
ambient water quality criteria
boron
beryllium
cadmium
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980
Code of Federal Regulations
centimeter
cobalt
U.S. Army Corps of Engineers
chromium
Clinch River
Clinch River mile
cesium
copper
U.S. Department of Energy
environmental impact statement
U.S. Environmental Protection Agency
East Tennessee Technology Park
iron
Federal Facility Agreement
feasibility study
gram
hectare
mercury
interagency agreement
inch
kilogram
pound
Local Oversight Committee
meter
manganese
National OU and Hazardous Substances Pollution Contingency Plan
National Environmental Policy Act of 1969
nickel
Oak Ridge Reservation
Oak Ridge Reservation Environmental Monitoring
Oak Ridge Reservation Environmental Management Site Specific
Advisory Board
operable unit
ounce
JTOOS396H.IWR/MBH
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Angus 28, 1997
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ACRONYMS AND ABBREVIATIONS (continued)
Pb lead
PC Poplar Creek
PCB polychlorinated biphenyl
PCM Poplar Creek mile
RCERB Roane County Environmental Review Board
RI remedial investigation
ROD record of decision
SARA Superfund Amendments and Reauthorization Act of 1986
Se selenium
Sr strontium
TBC to be considered
Tc technetium
TDEC Tennessee Department of Environment and Conservation
TVA Tennessee Valley Authority
U uranium
USC United States Code
V vanadium
WBRIWG Watts Bar Reservoir Interagency Working Group
yd yard
Zn zinc
mOS396ll.1V/R/MBH
IV
August 28, 1977
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PART 1. DECLARATION
JTOQS396II.IWR/MBH August 28 1997
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SITE NAME AND LOCATION
U.S. Department of Energy
Oak Ridge Reservation
Clinch River/Poplar Creek Sediment and Biota Operable Unit
Oak Ridge, Tennessee
STATEMENT OF BASIS AND PURPOSE
This record of decision (ROD) presents the selected remedy for the Clinch River
(CR)/Poplar Creek (PC) Operable Unit (OU) sediment and biota within the areal extent described
here. Surface water is not addressed in this ROD. This remedial action was selected in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), 42 United States Code (USC) 9601 et seq., and to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) [Title 40 Code of Federal
Regulations (CFR) 300]. This decision is based on the administrative record for this site.
This ROD is issued by the U.S. Department of Energy (DOE) as the lead agency. The
U.S. Environmental Protection Agency (EPA) and Tennessee Department of Environment and
Conservation (TDEC) are supportive agencies as parties to the Federal Facility Agreement (FFA)
for this response action, and they concur with the selected remedy.
ASSESSMENT OF THE OU
If actual or threatened releases of hazardous substances from this OU are not addressed
by implementing the response action selected in this ROD, such releases could present a current
or potential threat to public health, welfare, and/or the environment.
DESCRIPTION OF SELECTED REMEDY
The selected remedy for the CR/PC OU addresses the sediments and biota in the Watts
Bar and Melton Hill Reservoirs from Clinch River mile (CRM) 0.0 at the confluence of the
Clinch and Tennessee rivers upstream to CRM 44 near the Solway Bridge. The OU includes the
JT0053961I.IWR/MBH 1-2 August 28. 1997
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Poplar Creek embayment from the creek mouth at CRM 12 upstream to its confluence with East
Fork Poplar Creek at Poplar Creek mile (PCM) 5.5. Because the Clinch River forms the
southern and eastern boundary and Poplar Creek (along with East Fork Poplar Creek) drains the
northern and western boundaries, this OU receives all surface waters leaving the Oak Ridge
Reservation (ORR) and thus has received many ORR-related contaminants.
This OU does not include surface water. The Surface water OU will be addressed in a
separate ROD following remediation of upstream contaminant sources. Some surface water
related items are discussed in this ROD for information purposes. The selected alternative's
surface water sampling and irrigation survey activities will be conducted to allow later preparation
of a ROD that addresses surface water. The CR/PC OU, previously designated for purposes of
the remedial investigation (RI), has been redesignated as two OUs: one for CR/PC sediment and
biota and one for CR/PC surface water. A decision has been made to select a remedy Tor the
CR/PC sediment and biota OU and defer a decision on the CR/PC surface water OU until
upstream remedial actions are completed and contaminant input is minimized. References in this
ROD to the CR/PC OU apply only to sediment and biota.
The response action was chosen from a full range of actions that could possibly address
the two primary risks identified in the RI. The two primary risks to human health posed by
CR/PC are exposure to (1) mercury, chromium, arsenic, and 137Cs in deep sediment of the main
river channel and (2) polychlorinated biphenyls (PCBs), chlordane, arsenic, and mercury in fish
tissue. Present ecological risk in CR/PC is not serious enough to warrant an action that would
be harmful to the environment in the short-term. The selected remedy does not address
ecological risk.
The selected remedy components are as follows:
• existing institutional controls to control potential sediment-disturbing activities,
• fish consumption advisories to reduce exposure to contaminants in fish tissue,
• annual monitoring to detect changes in CR/PC contaminant levels or mobility, and
• survey to confirm effectiveness of fish consumption advisories.
DOE will be responsible for undertaking any appropriate CERCLA response actions
required based on monitoring data. An interagency agreement (IAG) among DOE, TDEC, EPA,
Tennessee Valley Authority (TVA), and the U.S. Army Corps of Engineers (COE) became
effective February 1991. The IAG provides for the coordination and review of permitting and
other use activities that could result in the disturbance, resuspension, removal, and/or disposal
of contaminated sediments or potentially contaminated sediments in Watts Bar Reservoir.
JTOOS396II.IWR/MBH 1-3 Augun 28. 1997
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Existing controls on sediment-disturbing activities are defined in Rules of the Tennessee
Department of Environment and Conservation, Chapter 1200-4-7, "Aquatic Resource Alteration
Permit Process"; Section 26A of the Tennessee Valley Authority Act of 1933; and Section 10 of
the Rivers and Harbors Act of 1910 (COE authority).
STATUTORY DETERMINATIONS
The selected remedy protects human health and the environment, complies with federal
and state requirements that are legally applicable or relevant and appropriate requirements
(ARARs), and is cost-effective. This remedy uses permanent solutions and alternative treatment
technologies to the maximum extent practicable for this OU. However, because treatment of
the principal threats of the site was not found to be practicable, this remedy does not satisfy the
statutory preference for treatment as a principal element.
The following factors contributed to the decision that active removal and/or treatment is
not practicable for the sediment or biota of CR/PC:
• Sediments determined to pose a risk to human health in a future risk scenario do not
pose a current risk because they are underwater year round, are covered by cleaner
sediments, and are relatively stable and do not migrate.
• Removing sediment or fish from the OU in a volume sufficiently effective to reduce
risk would be a massive, very expensive, and destructive undertaking.
• Removing sediment from the OU would kill all existing organisms that live in the
sediment, leave the habitat less suitable for rehabitation in the short-term, and kill
many fish because of sediment loading during dredging.
Hazardous substances above health-based levels will remain in the OU if this remedy is
implemented. Because hazardous substances are to remain in the OU, it is recognized by DOE,
TDEC, and EPA that Natural Resource Damage claims, in accordance with CERCLA, may be
applicable.
This ROD does not address restoration or rehabilitation of any natural resource injuries
that may have occurred at the OU, or whether such injuries have occurred. DOE has agreed to
fund a pilot study of the Watts Bar OU that will examine natural resource issues, and that may
provide a model for addressing such issues for this OU; however, this study has not yet been
/T005396II.1WR/MBH 1-4 August 28. 1997
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completed. In the interim, neither DOE nor TDEC waives any rights or defenses they may have
under CERCLA Section 107(a)4(c). A review will be conducted within 5 years after
commencement of remedial action, according to CERCLA Section 121, to ensure that the controls
and advisories for CR/PC continue to adequately protect human health and the environment.
Also, DOE has agreed to provide status reports to TDEC and EPA on the monitoring and
assessment program for CR/PC. Monitoring results will be summarized in the annual ORR
Remediation Effectiveness Report.
JT005396I1.IWR/MBH 1-5 Augua 28, 1997
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APPROVALS
Rodney R. Nelson, Assistant Manager
U.S. Department of Energy
Oak Ridge Operations Office
Date
Earl C. Leming, Director
U.S. Department of Energy Oversight Division
Tennessee Department of Environment and Conservation
Date
°n
Richard D. Green, Acting Director
Waste Management Division
U.S. Environmental Protection Agency—Region 4
Date
JT0053961I.1WR/MBH
1-6
Augun 28, 1997
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PART 2. DECISION SUMMARY
/1T»5396IUWR/MBH
Augua 28, 1997
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OU NAME, LOCATION, AND DESCRIPTION
The CR/PC OU consists of the Watts Bar and Melton Hill Reservoir sediment and biota
from CRM 0.0 at the confluence of the Clinch and Tennessee rivers upstream to CRM 44 near
the Solway Bridge. The OU includes the Poplar Creek embayment from the creek's mouth at
CRM 12 upstream to its confluence with East Fork Poplar Creek at PCM 5.5 (Fig. 2.1). DOE
will address surface water within this OU following completion of decision documents and actions
taken at the upstream sources of contamination.
The Clinch River flows out of Virginia into the state of Tennessee, leaving Morris Lake
to enter the OU in Melton Hill Reservoir and then into Watts Bar Reservoir. The river flows
within Anderson, Knox, Loudon, and Roane counties in the OU. These TVA reservoirs provide
flood control, hydropower generation, navigation, municipal and industrial water supply, wildlife
habitat, and recreation. Poplar Creek drains portions of ORR and enters the Clinch River near
the downstream end of the OU. The shorelines of the OU are used primarily for agricultural,
recreational, residential, and industrial purposes.
OU HISTORY AND ENFORCEMENT ACTIVITIES
On November 21,1989, EPA placed ORR on the National Priorities List under CERCLA.
On January 1, 1992, an FFA was implemented by DOE, EPA, and TDEC. The agreement
provides a procedural framework and schedule for evaluating, prioritizing, and managing areas
of contamination on ORR. The agreement specifies that CERCLA procedures be followed to
evaluate and remediate contamination problems.
CR/PC is contaminated because of past activities at DOE's ORR and non-DOE industrial
and municipal sources. ORR comprises three major installations—Oak Ridge National
Laboratory, Oak Ridge Y-12 Plant, and East Tennessee Technology Park (ETTP; formerly Oak
Ridge K-25 Site). These facilities were built in the 1940s as research, development, and process
facilities in support of the Manhattan Project. Activities at these facilities have resulted in the
release of hazardous substances and radioactive contamination to the on-site and off-site
environment. In January 1997, DOE presented the public with the proposed plan for CR/PC and
solicited public comments. The proposed plan presented monitoring, advisories, and institutional
controls as the preferred remedial action.
JTOB396II.IWR/MBH 2-2 . August 28. 1997
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OAK.RTOGE
LITTLE EMORY f\
RIVER
CRM
(LIMIT OF D
PCM
(LIMIT OF
Oik RlcWe Resection
RNL
EastT
Tecfino
SCALE IN MILES
CRM 0.0
(LIMIT DF DU)
INGSTON
ORR
FACILITY
•• OPERABLE UNIT
• WATER INTAKE
Location of Clinch River/Poplar Creek
Operable Unit
OOE • Clinch River - Otk Ridge. Tennessee
TENNESSEE
RIVER LcdNUlK till
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The current or threatened release of hazardous substances from ORR is the focus of
current source control actions specified under CERCLA. These releases are being quantified at
the source; similarly, remedies will be accomplished at the source. The CR/PC RI (DOE 1996a)
determined contaminant concentrations in CR/PC fish, water, and sediment and the threat those
contaminants might pose to human health and the environment. The measurement of ambient
concentrations in these media inevitably integrates all contaminant sources previously mentioned
for ORR, as well as any non-ORR sources that contribute to CR/PC.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
An Rl/feasibility study (FS) (DOE 1996a) was conducted in accordance with CERCLA
requirements, including the public participation requirements of CERCLA -Sections
113(K)(2)(B)(i-v) and 117. Newspaper notices in The Oak Ridger and The Knoxville News-
Sentinel December 5, 1996, and The Roane County News December 6, 1996, .indicated the
availability of documents at the Information Resource Center in Oak Ridge, Tennessee, and
announced public meetings. The RI/FS and proposed plan (DOE 1996b) were released to the
public in December 1996. DOE encourages public participation in commenting on the preferred
alternative for CR/PC and set a comment period of December 4, 1996, to January 24, 1997.
Public meetings were held January 14, 1997, in Kingston, Tennessee, and
January 16, 1997, in Oak Ridge, Tennessee. The "Responsiveness Summary" of this ROD
summarizes the major issues raised during the public comment period. This decision document
presents the selected remedial action for management of CR/PC in accordance with CERCLA,
as amended, and NCP to the maximum extent practicable. The decision for this site is based on
the administrative record.
SCOPE AND ROLE OF THE OU
Melton Hill and Watts Bar Reservoirs, which include the CR/PC OU, are the first
impoundments downstream of ORR. Any surface waters originating on or passing through ORR
flow into the CR/PC OU. Because the reservoirs are efficient sediment traps, CR/PC OU
sediments contain contaminants released from ORR and have the potential of receiving current
or future contaminant releases. The selected remedy for the CR/PC OU addresses potential risks
caused by human ingestion of contaminated fish and exposures of humans and biota to
contaminated sediments.
JT005396II.1WR/MBH 2-4 August 28, 1997
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Surface water is not a part of this OU. Following completion of upstream source
remediations, DOE will address surface water ambient water quality criteria (AWQC)
exceedances and will issue a separate ROD. To provide sufficient data to issue this other ROD,
DOE will collect surface water samples and will survey irrigation activities as part of the
monitoring program in the selected remedy of this ROD. Surface water risk assessment and
AWQC are discussed in this ROD for informational purposes only.
SUMMARY OF OU CHARACTERISTICS
Reservoirs within this OU were built by TVA to provide navigation, flood control, and
hydroelectric power generation. Land surrounding the reservoir is currently used for residential,
agricultural, industrial, and recreational purposes. Waters of the reservoir are used for-tlomestic
water supply, industrial water supply, fish and aquatic life, recreation, irrigation, livestock
watering, wildlife, and navigation. There are four potable water intakes within the OU: city of
Oak Ridge, the West Knox Utility District, ETTP, and a part-time system at Clark Center
Recreation Park.
The CR/PC OU is an integrator of waterborne substances in the surface waters leaving
ORR. Once these substances enter the CR/PC OU, they may be found in the water, sediment,
or biota. The fate of a substance depends on the flow rate of the surface water and the physical
and chemical properties of the substance. Dissolved substances are usually flushed through the
reservoirs in a matter of weeks, whereas particle-associated substances may accumulate in the
sediments and remain indefinitely.
In the OU, peak concentrations of metals and radionuclides are found in deep-water
sediments in the old river or creek channel. The highest concentrations of each are generally
buried 20-60 cm (8-32 in.) in the deep-water sediments. DOE-re!ated contaminants are found
in proportion to the water depth, with little contamination in near-shore sediment. Those few
DOE-related contaminants above background levels in the near-shore sediments are arsenic in
McCoy Branch, and chromium and manganese in Poplar Creek.
Particle-associated and dissolved contaminants accumulate in CR/PC OU biota.
Contamination of CR/PC OU fish with PCBs, As, Hg, l37Cs, and pesticides is documented in the
RI. Sampling data indicate that sediment and surface water contamination by organic compounds
is minimal. Inorganic contaminants in CR/PC OU sediments are similar to those found in other
TVA reservoirs. They include Ag, As, B, Be, Cd, Cr, Cu, Fe, Hg, Mn, Ni, Pb, Se, V, and Zn.
Radionuclides detected in sediment include l37Cs, *°Co, °*U, ^U, and "Tc.
JTO0539611.IWR/MBH 2-5 August 28, 1997
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SUMMARY OF OU RISKS
A baseline risk assessment evaluated potential current and future risk to human health and
the environment posed by radioactive and chemical contaminants at CR/PC if remedial action was
not taken. Results from this assessment were used to determine a need for action at the site.
Risk to human health was evaluated for the following exposure scenarios, each of which
contains one or more pathways through which exposure occurs: (1) use of untreated surface
water as drinking water, (2) fish consumption, (3) recreational shoreline use during winter
drawdown, (4) swimming, (5) hunting or consumption of waterfowl, (6) agricultural use of main
channel sediments that could be placed on shore, and (7) irrigation with untreated surface water.
Surface water meets current drinking water standards. The greatest unacceptable risk to
human health from contaminants in CR/PC is associated with the consumption of certain PCB-
contaminated fish species. Mercury, chlordane, and arsenic in fish also pose potential risks.
Children are potentially at greater risk than adults because of their low body weight. Catfish
consumption poses a risk in the entire OU. Consumption of bass from the Clinch River below
Melton Hill Dam is a risk, and all fish species within Poplar Creek are considered a risk for
consumption. Consumption of largemouth bass, bluegill, and catfish from Poplar Creek posed
a risk to human health in the RI, and TDEC advisories warn against consumption of any fish
from Poplar Creek.
Recreational shoreline use is considered an acceptable risk to the public (see Part 3 of this
ROD, Issue 2, response to second comment). Swimming is also considered an acceptable risk,
and consumption of local/resident geese is an acceptable risk to human health.
If deep-water sediments were dredged and used for fanning or gardening, several
contaminants could pose an unacceptable risk to human health through consumption of the
resulting agricultural products (e.g., vegetables, milk, meat, etc.). If they are left in place, these
sediments do not pose a risk to human health because no exposure pathway exists.
Section 5.3 of the RI presents the toxicity assessment for contaminants causing these risks
to human health. PCBs have generally been shown to cause cancer in laboratory animals, but
little evidence is available for humans. Chlordane is also a suspected carcinogen. Arsenic is a
proven carcinogen and can cause nervous system and cardiovascular damage. Mercury causes
nervous system and kidney damage. Cesium-137 can cause cancer.
JT0053961I.IWR/MBH 2-6 Augua 28. 1997
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Significant ecological risks were identified in Poplar Creek but not in the Clinch River.
The weight of evidence suggests that toxic effects are causing a risk of a 20 percent reduction in
fish species richness and abundance. Habitat factors and upstream coal mining may also be
impacting richness and abundance in Poplar Creek. Although risks to benthic invertebrates in
Poplar Creek are not high and the evidence is not consistent, the weight of evidence suggests that
toxic effects are causing a risk of a 20 percent reduction in benthic invertebrate species richness
and abundance. Sediment pore water and water above sediments were not found to be toxic, but
some whole sediment samples were found to be lethal to an amphipod. Risks to fish-eating
wildlife are estimated to be insignificant. Risks to bats inhabiting Poplar Creek are estimated to
be insignificant, but swallows might be at risk of a 20 percent reduction in population production
if feeding exclusively on Poplar Creek emergent aquatic insects. Animals foraging on
hypothetical dredge spoil were estimated to be at risk.
DESCRIPTIONS OF ALTERNATIVES
The following four alternatives were evaluated in detail within the FS: no action;
institutional controls and advisories; source containment, removal, and disposal; and removal and
disposal.
ALTERNATIVE 1—NO ACTION
CERCLA requires that the no action alternative be evaluated to establish a baseline for
comparing the other action alternatives. Under this alternative, DOE would not initiate any
monitoring, controls, actions, or commitments to address potential risks to human health or the
environment.
ALTERNATIVE 2—INSTITUTIONAL CONTROLS AND ADVISORIES
This alternative uses three methods to protect human health. First, state public fish
consumption advisories (precautionary advisories and no- consumption advisories) would limit
or prevent consumption of contaminated fish. Second, regulatory and institutional authorities
administered by EPA, TDEC, COE, TVA, and DOE would be used to ensure that any
disturbance of contaminated sediments would be done in a manner that is protective of human
health and the environment. Third, a monitoring program would detect changes in contaminant
concentrations in fish, turtles, and sediment, and would include a survey to confirm the
effectiveness of the fish consumption advisories. This alternative does not address ecological
risk. Surface water related monitoring would also take place.
mOS3961I.IWR/MBH 2-7 . Augua 28. 1977
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ALTERNATIVE 3—SOURCE CONTAINMENT, REMOVAL, AND DISPOSAL
To protect human health and the environment, this alternative uses the actions in
Alternative 2 plus containment of the most contaminated near-shore sediment [3.6 ha (9 acres)]
and removal/disposal of 137,046 m3 (179,250 yd3) of the most contaminated deep-water
sediments. The containment would be constructed of geotextile, geomembrane (plastic), and rock
riprap. The removal would be accomplished with mechanical excavation and dredging, with
sediments being dewatered and disposed of as necessary, based on characterization data.
ALTERNATIVE 4—REMOVAL AND DISPOSAL
This alternative protects human health and the environment and is similar to Alternative 3
because it includes removal of 137,046 m3 (179,250 yd3) of deep-water/main channel sediments.
However, rather than in situ containment, Alternative 4 includes removal and disposal of
173,172 m3 (226,500 yd3) of near-shore sediment.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives were evaluated against the nine EPA criteria developed to measure overall
feasibility and acceptability of remedial alternatives. The first two criteria must be met in initial
screening of any alternative considered for selection in the ROD. The next five criteria represent
the primary balancing criteria upon which the analysis is based, considering technical, cost,
institutional, and risk considerations. The last two criteria (modifying criteria) were evaluated
after a regulatory agency review and a public comment period.
This section demonstrates the balancing of trade-offs among alternatives necessary to select
a remedy that uses institutional controls rather than active response measures. The rationale for
the determination that active response measures are not practicable is presented in Part 1 of this
ROD under "Statutory Determinations."
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The no action alternative would not protect human health or the environment because of
the risks associated with sediment disturbance or fish consumption within the OU. Alternative 2,
Institutional Controls and Advisories, would protect human health by advising either limited or
no consumption of contaminated fish species and by eliminating unsafe disturbance and contact
with main channel sediments. Alternative 2 does nothing to protect the environment because the
/TOOS396I1.IWR/MBH 2-8 Augua 28. 1997
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short-term damage to the environment that removing contaminated sediment would cause would
impact the environment more significantly than the current impacts from contamination.
Alternatives 3 and 4 would protect human health and would protect the environment in the long
term by removing or capping sediment, but would cause short-term destruction of benthic
organisms, fish, and habitat. All of the alternatives would address the risk from fish consumption
equally.
COMPLIANCE WITH ARARs
Alternative 1 does not protect human health or the environment and does nothing to
comply with ARARs. Alternatives 2, 3, and 4 would comply with all ARARs or requirements
to-be-considered (TBCs) for the portion of the OU covered by this ROD.
SHORT-TERM EFFECTIVENESS
Alternative 1 is not effective. In Alternatives 2, 3, and 4, fish consumption advisories and
the permit program for sediment-disturbing activities for the CR/PC OU are already in place.
Alternative 2 is effective in the short-term and includes no additional sediment-disturbing
activities, but does not address ecological risk. The containment and removal associated with
Alternatives 3 and 4 would be harmful to the environment in the short-term because existing
benthic organisms, some fish, and benthic habitat would be destroyed.
LONG-TERM EFFECTIVENESS AND PERMANENCE
Alternative 1 is not effective. Alternative 2 has potential for good long-term effectiveness.
Health risks following implementation of this alternative would not exceed current levels because
the controls and advisories are already in place. Future risks would be diminished by natural
processes (radioactive decay and chemical degradation for sediments), and potential decrease in
contaminant concentrations in fish as source areas are remediated through other DOE project
activities. Because wastes would be left in place, the permanence of this alternative would rely
on the institutional controls and the existence and funding of those state and federal agencies
responsible. Additional controls could be implemented easily if conditions change in the future.
Alternatives 3 and 4 may have greater long-term effectiveness than Alternative 2 because
contaminants would be contained or removed from the OU. The permanence of alternatives
would rely on safe, effective storage and disposal of all the wastes removed from CR/PC. These
alternatives offer a somewhat permanent fix for ecological risks.
mXB396H.IWR/MBH 2-9 Augusl 28. 1997
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REDUCTION OF TOXICITY, MOBILITY, AND VOLUME THROUGH TREATMENT
Active treatment does not take place in Alternative 2. Alternatives 3 and 4 would reduce
volume in the long-term through dewatering, and mobility would be reduced through containment
of sediments, but not through treatment.
EMPLEMENTABILITY
The main components of Alternative 2 have already been implemented. The monitoring
plan would be easily implemented as a revision to the existing monitoring program for Lower
Watts Bar Reservoir. Alternatives 3 and 4 would be difficult to implement because of numerous
federal and state regulations and stringent work practices that must be satisfied before initiating
and completing a major dredging and disposal project. Control of risk from fish consumption
is implementable for all alternatives.
COST
Present-worth cost for implementing Alternative 2 for 30 years is approximately
$3.6 million. Using the assumptions provided in the FS regarding volumes of material to be
contained or removed, Alternative 3 present-worth cost is approximately $109.6 million, and
Alternative 4 would cost approximately $123.5 million. A sampling program would help further
define remediation areas, and significant increases or decreases in volume might occur that would
raise or lower the costs of these estimates.
STATE ACCEPTANCE
This criterion evaluates whether the state agrees with, opposes, or has no comment on the
preferred alternative. The state of Tennessee concurs with the selected remedy.
COMMUNITY ACCEPTANCE
Community acceptance addresses the issues and concerns the public may have regarding
each of the alternatives. The "Highlights of Community Participation" section in this part of the
ROD summarizes the community participation efforts and activities associated with this project.
Part 3 of the ROD summarizes all public comments on the remedial alternatives and presents
DOE's responses to those comments. The preferred alternative was modified based on public
comments (see "Documentation of Significant Changes" in this part of the ROD). The public
accepts the selected remedy in its current form.
/TO053961I.1WR/MBH 2-10 Augua 28. 1997
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SELECTED REMEDY
DOE, with concurrence from EPA and the state of Tennessee, has determined that controls
and advisories are the most appropriate remedy for the CR/PC OU, based on a review of
CERCLA requirements, detailed analysis of the alternatives, and public comments. Alternative 2
provides much better short-term effectiveness and far lower costs than the other alternatives.
Alternative 2 represents the best balance among the evaluation criteria for remedial actions.
CONTINUANCE OF EXISTING CONTROLS AND ADVISORIES REGARDING CR/PC
ACTIVITIES
One threat to human health posed by the CR/PC OU is consumption of certain species of
fish. Under the Tennessee Water Quality Control Act, Rules of the TDEC 1200-4-3,~TDEC is
authorized to issue fish consumption advisories to protect the public. TDEC's Division of Water
Pollution Control currently posts two types offish consumption advisories at more than 20 public
and private access points surrounding the CR/PC OU. A precautionary advisory, the mildest
form of advisory, warns children, pregnant women, and nursing mothers to avoid eating sauger
and catfish from the Clinch River arm of Watts Bar Reservoir. All other people are warned to
limit consumption of those fish to 0.54 kg (1.2 lb)/month. A no-consumption advisory warns
the public to avoid eating catfish from Melton Hill, striped bass from the Clinch River arm, or
any species from Poplar Creek. CR/PC OU advisories are issued because of PCB content in fish
tissues (and for Poplar Creek, mercury and other contaminants). Recent revisions (July 30,1995)
to fish advisory procedures have changed the standards so that the no-consumption advisory is
for typical consumers and protects to a level of an excess cancer risk of 10~4, while the
precautionary advisory is for sensitive consumers such as children and pregnant women and
protects to a level of 10~s. When an advisory is issued or changed, a press release is issued and
signs are placed at frequently used access points. A list of advisories is printed in the Tennessee
Fishing Regulations, published by the Tennessee Wildlife Resources Agency. Telephone numbers
are provided with the advisories if the public desires further information regarding an advisory.
The FFA agencies, TVA, and COE have formed a permitting working group. The current
interagency agreement for Watts Bar Reservoir Permit Coordination establishes a procedure for
review of potential sediment-disturbing operations in the Clinch River below Melton Hill Dam,
including Poplar Creek. The interagency agreement working group reviews requests for projects
such as construction of beaches, boat ramps, docks, marinas, buoy anchors, fences, fish
attractors, retaining walls, pump stations, culverts, and submerged lines or piping for their
potential to disturb sediment. DOE provides technical analysis and risk assessment assistance
when required. DOE must consider, propose, and implement appropriate response actions if an
JIDOS396II.IWR/MBH 2-11 Augua 28, 1997
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existing control or advisory becomes ineffective for any reason or if a sediment-disturbing activity
would, because of sediments contaminated by DOE activities, be potentially harmful to human
health and/or the environment.
MONITORING PLAN
Monitoring of sediment and fish will be continued to determine whether there is a change
in the currently calculated risk that would pose a threat to human health and/or the environment.
Turtles will also be monitored initially to build data on PCB levels in turtle flesh. DOE
monitoring will be coordinated with EPA, TDEC, TVA, and other federal, state, and local
agencies. Also included will be a survey program to confirm that fish consumption advisories
are effective. The scope of this monitoring program will be determined and agreed upon in the
remedial action work plan submitted to EPA and TDEC following approval of this" ROD.
Monitoring will begin in fiscal year 1998 and will continue as long as necessary. Data will be
incorporated into the ORR Remediation Effectiveness Report annually and will be available to
the public. Collected data will be used in the CERCLA-required 5-year-review of the remedial
action. If data warrant, a review will be conducted earlier. Concurrent with this plan, some
surface water related monitoring will also be conducted.
STATUTORY DETERMINATIONS
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Analysis of existing data reveals no unacceptable risk to human health or the environment
from sediments or fish consumption in the CR/PC OU under the conditions that this remedy will
maintain DOE will ensure that future sediment-disturbing activities within the CR/PC OU will
be done in a manner that continues to be protective of human health and the environment.
Natural sedimentation will continue to cover existing contamination and reduce its availability to
the environment. Also, radioactive decay of l37Cs will lessen its contribution to risk over time.
DOE will monitor for any increase in contaminant levels and could respond to any increases in
the overall system or to areas of higher concentrations should such areas be found. There will
be no unacceptable short-term risks or cross-media impacts from implementation of this remedy.
Institutional controls will continue to limit access and exposure.
JIDOS3961I.IWR/MBH 2-12 Augun 28. 1997
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COMPLIANCE WITH ARARs
The selected remedy complies with all ARARs or TBCs shown in Table 2.1.
COST EFFECTIVENESS
Actions under CERCLA must consider the estimated total present-worth cost of the
alternatives. Alternative 2 is cost-effective for the protection of human health and the
environment.
USE OF PERMANENT SOLUTIONS TO THE MAXIMUM EXTENT PRACTICABLE
DOE believes the selected remedy represents the maximum extent to which permanent
solutions can be used in a cost-effective manner for the CR/PC OU. Of the remediation
alternatives, DOE believes the selected remedy provides the best balance of trade-offs in terms
of long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through
treatment; short-term effectiveness; implementability; and cost. As previously discussed,
Alternatives 3 and 4 may provide a more permanent solution but are not very practicable or
feasible because of the extreme cost and destruction of habitat and organisms associated with
sediment removal.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The statutory preference for treatment will not be met because removal and treatment of
the contaminated sediment and fish is not feasible at this time. As previously discussed, the
sediments are stable and their removal would be expensive and destructive. The negative effects
of sediment removal would outweigh any potential benefits from treatment.
DOCUMENTATION OF SIGNIFICANT CHANGES
The chosen alternative that was presented to the public in the proposed plan was changed
by the addition of three elements to the monitoring program: (1) turtle sampling, (2) survey of
fish consumption to confirm the effectiveness of the advisory program, and (3) survey of local
irrigation practices to determine whether irrigation poses a threat to human health or the
environment.
JT005396II.1WR/MBH 2-13 August 28. 1997
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Table 2.1. ARARs and TBC guidance for Alternative 2 for the Clinch River/Poplar Creek OU, Oak Ridge, Tennessee
Prerequisites
Chemical- or radlonudlde-speclflc
Location-specific
Residual concentrations of radionuclides in soils shall be
derived using the basic dose limit of 100 mrem/year and
the DOB RESRAD model with site-specific input
parameters
The public must not receive an effective dose equivalent
greater than 100 mrem/year
All releases of radioactive material must be ALARA
None
Residual radioactive materials left in place
without restrictions—TBC
Dose received by the public from all sources
of radiation exposure and routine activities,
including remedial action, at a DOE
facility-TBC
Releases of radioactive material from DOE
activities—TBC
DOE Order 5400.5(IV)
DOE Order 5400.5
DOE Order 5400.5
I
N-»
^
Action-specific
Institutional controls
Controls include periodic monitoring, as appropriate; Interim management of residual radioactive
appropriate shielding; physical barriers to prevent access, material above acceptable guidelines—TBC
•fences, and warning signs; and restrictions on land use
Controls recommended for long-term management of
contamination left In place include restrictions on land
use, deed restrictions, well-drilling prohibitions, etc.
Long-term management of contamination left
in place—TBC
DOE Order
5400.5{IV)(6)(c)
40 CFR 300.430(e)(3)
ALARA = as low as reasonably achievable
ARAR = applicable or relevant and appropriate requirement
CFR = Code of Federal Regulations
DOE = U.S. Department of Energy
mrem = millirem
OU = operable unit
RESRAD = Residual Radioactivity (computer model)
TBC = to be considered
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Turtles were sampled in response to findings that identify local consumers and levels of
PCBs in turtle tissue that may be a risk to human health. The fish consumption advisory survey
is being conducted to satisfy the public's questions on how well the advisories are known to the
general public. The irrigation survey is being conducted because the assumptions used in the risk
assessment are questionable and the lack of human health risk concerns needs to be confirmed.
REFERENCES
DOE (U.S. Department of Energy). 1996a. Remedial Investigation/Feasibility Study of
the Clinch River/Poplar Creek Operable Unit, DOE/OR/01-1393/&D3. Oak Ridge
Operations, Oak Ridge, TN.
DOE. 1996b. Proposed Plan for Clinch River/Poplar Creek Operable Unit, Oak Ridge,
Tennessee, DOE/OR/02-1429&D2. Oak Ridge, TN.
EPA (U.S. Environmental Protection Agency). 1989. Exposure Factors Handbook,
EPA/600/8-89/043. Office of Health and Environmental Assessment, Washington,
DC.
EPA. 1985. Handbook Remedial Action At Waste Disposal Sites (Revised), EPA/625/6-
85/006. Office of Emergency and Remedial Response, Washington, DC.
TV A (Tennessee Valley Authority). 1990. Tennessee River and Reservoir System Operation
and Planning Review, Final Environmental Impact Statement, TVA/RDG/EQS-91/1.
Knoxville, TN.
TVA. 1987. Watts Bar Reservoir Land Management Plan (Final Draft). Knoxville, TN.
JTOQS3961I.1WR/MBH 2-15 August 28. 1997
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PARTS. RESPONSIVENESS SUMMARY
m
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RESPONSIVENESS SUMMARY
This section of the ROD documents formal public comments on the proposed plan for
CR/PC OU, Oak Ridge, Tennessee, and DOE's response to those comments. Comments were
submitted in writing or made verbally at the two public meetings. The public comment period
was December.5, 1996, through January 24,1997. A public meeting was held January 14, 1997,
at Roane State Community College in Harriman, Tennessee; and January 16, 1997, at Pollard
Auditorium in Oak Ridge, Tennessee. In addition to these meetings and the notices announcing
them, DOE has periodically met and provided fact sheets to interested members of the public.
This responsiveness summary serves three purposes. First, it informs DOE, EPA, and
TDEC of community concerns about the site and the community's preferences regarding the
proposed remedial alternative. Second, it demonstrates how public comments were integrated
into the decision-making process. Third, it allows DOE to formally respond to public comments.
This report was prepared pursuant to the terms of the 1992 FFA signed by DOE, EPA,
and TDEC, as well requirements contained in the following:
• CERCLA as amended by SARA, 42 USC, Section 9601, etseq.;
• NCP, 40 CFR 300; and
• Community Relations in Super/and, A Handbook, January 1992, EPA/540/R-92/009.
After reviewing transcripts from public meetings and written comments, DOE grouped
comments according to common issues, summarized each comment (sometimes direct quotes are
provided rather than a summary), and prepared a response to each issue and comment.
ISSUE 1: FISH CONSUMPTION ADVISORIES
Comment: Bob Peele stated that the wording in the proposed plan and the actual state fish
consumption advisories was different and confusing with regard to the amount of fish that can
be safely consumed. Ms. Barbara also questioned the differences in wording regarding the
amount of fish safe to consume.
Comment: Kenneth Campbell stated that there are areas around the Clinch River which
are not posted with fish consumption advisory signs, and wondered how the public was to be
made aware of the advisories without those signs being posted.
m005396U.IWR/MBH 3-2 Augua 28, 1997
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Comment: Alfred Brooks stated that recent studies have shown that turtles have higher
concentrations of PCBs than fish do and that turtles should be added to the consumption
advisories. Mr. Brooks also thought there should be more effort to provide information on the
risk (or lack of risk) of fish consumption to tourists and try to help them understand that
occasional consumption of these fish is not a problem.
Comment: The Local Oversight Committee (LOG) stated that the fish consumption
advisories do not prevent people from eating contaminated fish and that DOE should acknowledge
this fact in the evaluation of the preferred alternative.
Comment: The Oak Ridge Reservation Environmental Management Site Specific
Advisory Board (ORREMSSAB) also questions whether the fish consumption advisory program
actually prevents people from eating contaminated fish. They recommend a program be
implemented to determine the effectiveness of the advisory program, and they would like more
detailed advisories that indicate the amount of fish consumption that is considered unsafe as well
as appropriate methods for cleaning and preparing fish for consumption.
Response: The TDEC Division of Water Pollution Control issues fish consumption
advisories to fulfill the requirements of state law and to keep the public informed of potential
health hazards. Two types of advisories are used: "No Consumption" advisories warn people
not to eat any amount of the listed species, while a "Precautionary Advisory" suggests that no
more than 0.5 kg (1.2 lb)/month of the listed species be consumed. The advisories are
determined based on actual concentrations of contaminants (like PCBs) in fish tissue compared
to the U.S. Food and Drug Administration guidelines or using EPA risk assessment methodology.
The risk assessment prepared for the CR/PC OU in the RI was performed using EPA
methodology. The EPA method uses a consumption rate of 54 g (1.9 oz) of fish tissue per day
as a conservative estimate of the amount of fish a local resident might eat throughout his/her
lifespan. The risk assessment determined that there is a risk to the public if a resident eats that
amount of fish for 30 years; however, no attempt was made to determine a "safe" amount of fish
that could be eaten. The management of risk is difficult to undertake for an entire population and
an amount that may seem safe to one individual may seem very risky to another. The proposed
plan quoted the fish consumption advisories verbatim; however, the presentation at the two public
meetings did contain a reference to that 54 g (1.9 oz)/day amount and this may have caused some
confusion. The state advisory program contains a no-consumption advisory on certain fish
species that may be considered "safe" to eat once a month or five times a year or for one week
each year (as a tourist might do), but by law the program must try to protect the most sensitive
members of our population and the people who may be accustomed to eating fish several times
a week during most of their lives.
JT0053%IUWR/MBH 3-3 AKgua 28, 1997
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The fish consumption advisories are provided in special brochures, the Tennessee Fishing
Regulations, in TVA's annual Riverpulse report, and on signs posted at most public access points
that are paved or maintained by government funds. TDEC has agreed that some public access
areas may not be posted or may have had the signs stolen or vandalized (a common problem),
and they will try to correct this problem. In addition to listing which species should be avoided
in the various lakes, the advisories describe methods of preparing and cooking the fish to reduce
the amount of contaminants consumed.
Turtles were not considered in the risk assessment and are not addressed in this ROD;
however, TDEC conducted turtle sampling and analysis for PCBs recently and the report was
made available to the public in May 1997. Based on the data provided in this report, TDEC will
determine whether posting the reservoirs to advise against consumption of turtles is necessary.
Turtle sampling will be added to the scope of the monitoring program mandated in this ROD.
In response to these comments, a survey will be added to the monitoring program in an effort
to confirm the effectiveness of the fish consumption advisory program.
ISSUE 2: RISK ASSESSMENT AND REMEDIAL INVESTIGATION QUESTIONS
Comment: Bob Peele and the ORREMSSAB wanted to know why manganese is treated
as a ubiquitous, non-DOE-related contaminant in some areas of the RI or proposed plan, and is
listed as related to K-25 Site activities in other areas of the RI.
Response: Statements in the executive summary and in other areas of the RI refer to
manganese as ubiquitous in surface waters throughout the region, and therefore to some extent
the sediments throughout the region also contain some manganese. The sediments immediately
downstream of ETTP contain elevated levels of manganese thought to be related to DOE
operations. Manganese concentrations were triggering human health risk criteria throughout the
operable unit, not just downstream of ETTP. The elevated levels in Poplar Creek were "more"
elevated than naturally high background levels, possibly because of coal mining upstream in
addition to DOE activities; however, they made no significant change in the risk associated with
that area of the OU.
Comment: ORREMSSAB—In the proposed plan, only sediments in the main channel of
the Clinch River or main creek bed of Poplar Creek are noted to present potential risk to human
health. Nothing is said in the plan about how the preferred alternative protects the public from
contamination of near-shore sediments. A reader could conclude that no significant levels of
contaminants were found to be present in near-shore sediments. For instance, Tables E-35
through E-37 (Appendix E, RI/FS) clearly show that a number of contaminants exceed the
JTO053961I.IWR/MBH 3-4 August 28. 1997
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acceptable noncarcinogenic hazard index of 1.0 for several reaches of the Clinch River and
Poplar Creek. The excess lifetime cancer risk of 10"* (1 occurrence of cancer in 10,000 people)
is also exceeded when risks are added across pathways for some subreaches.
There is no indication in the plan why these risk levels are acceptable. An alternative to
reduce these risks should be favored unless there is valid reason to discount these high levels.
Either some institutional control to inhibit human contact with near-shore sediment in the less safe
reaches must be devised and shown effective, or the most seriously contaminated near-shore areas
that are accessible should be treated in a manner similar to Alternative 3 or 4.
The FS indicates that many of the high risk levels are within the reservation along Poplar
Creek and are therefore under institutional control preventing residential use. Since such control
is important, the ORREMSSAB recommends that this control be listed in the-preferred
alternative. Such controls must also seek to prevent sediment contact by fishermen who may
access Poplar Creek by boat and wade in shallow portions.
Response: By far, the majority of the noncarcinogenic hazard for Clinch River and Poplar
Creek near-shore sediments is derived from manganese. Manganese is a naturally occurring and
ubiquitous metal, present at relatively high concentrations throughout East Tennessee. No other
contaminant by itself exceeds the hazard index of 1.0. The carcinogenic risk is only exceeded
when risks are summed for all contaminants and all pathways in a given subreach. No single
pathway would be determined to be a pathway of concern. Two subreaches (one in Poplar Creek
and one in the Clinch River) when added across all contaminants and all pathways do provide a
carcinogenic risk of 1.8 and 1.1 x 10"4, respectively. However, in both cases, the risk is driven
by the presence of chromium. Chromium usually occurs in two states in the environment, Cr(m)
and Cr(VI). Chromium-6 is much more toxic but reacts over time to form Cr(ni). The
conservative risk assessment methodology used for this RI assumes all chromium to be Cr(VI),
assumes 8 hours of exposure each day for 175 days per year (the entire period of water
drawdown) for 30 years, uses models to predict airborne particle generation from sediments, and
uses the upper 95 percent confidence level concentrations of contaminants rather than actual
values or means/averages. Given the extreme conservatism built into the risk assessment, the fact
that sediments rarely dry out enough to generate dust during the winter months, and the fact that
the hazard is primarily driven by manganese, the FFA parties have concluded that no real threat
is being posed to the public. The area within Poplar Creek that is slightly worse than the Clinch
River area is within ORR and is controlled so that residential development cannot take place.
The fishermen in question would definitely not be at risk based on exposure durations.
JTOOS3961I.1WR/MBH 3-5 August Z8. 1997
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Comment: Mr. Campbell, Ms. Bryan, and the ORREMSSAB question the amount of data
obtained at Kingston City Park. They wonder if enough sampling occurred and if the samples
were deep enough, and how safe it is for children to swim and wade in these public recreation
areas.
Response: In 1991, TVA collected five 30-cm (12-in.) core sediment samples from the
swimming area at 12 recreation areas on the Tennessee River, including Southwest Point Park
(just downstream of Kingston City Park), and 7 areas on the Clinch River. These data indicate
no health risks in the Kingston area any different from those throughout the state. DOE has in
the past conducted near-shore sampling throughout the Clinch River/Watts Bar system; those data
support the conclusion that near-shore recreation areas are not contaminated to the extent that
human health risk is a problem for the child recreational user. A comparison of the TVA data
from Southwest Point Park with the DOE data and preliminary remediation goals fronrthe RI
indicate that the risks associated with this particular recreation area are not high enough to be of
any concern to the recreational user. In addition, TDEC recently completed a radiation screening
of public recreation and access areas along the Clinch River and will make this report available
to the public in March 1997. TDEC's results indicate background levels of radionuclides at these
recreation areas. The radionuclides are known to be a very good indicator of DOE-related
contamination at a site because most of the high releases of contaminants in the past were
accompanied by radioactive contamination. In summary, DOE, TDEC, and TVA all have
determined that the safety and welfare of recreation area users is not at risk because of DOE-
related contamination (and based on TVA data, any other source of contamination).
Comment: The ORREMSSAB recommends that exposure to near-shore sediment should
be included in the swimming/wading scenario.
Response: The risks to individuals in the shoreline use scenario were driven by inhalation
of sediments, not dermal contact. In the summer, when swimming and wading take place, no
inhalation of sediments takes place and risks are low.. Additionally, EPA guidance documents
for conducting risk assessments state that "in most cases it is unnecessary to evaluate human
exposures to sediments covered by surface water." The surface water tends to be the carrier for
contaminants that will permeate the skin, and evaluation of dermal contact to the water itself is
sufficient to fully characterize the risks.
Comment: On pages 2-8 of the RI/FS it says that sediments were dredged from the
Clinch River between Grubb Island and Melton Hill Dam in 1952 and 1962 and dredged
materials were placed on Grubb and Jones Islands. Much of this stretch of the river is
downstream and in close proximity to White Oak Creek and is likely to have been contaminated.
m»5396ll.1WR/MBH 3-6 August 28. 1997
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Exposure to these materials was not addressed in the risk assessment and risk remediation of the
islands is not included in the Plan. The ORREMSSAB recommends that remediation of the
islands or controls on use thereof should be included in the Plan unless it is being addressed
under another activity.
Response: TVA, as published in Sediment Characterization Task 2 Instream Contaminant
Study in April 1985, found that samples collected on Grubb Island (CRM 18.3) and Jones Island
(CRM 19.7, 20.1, 20.5, and 20.6) revealed concentrations of contaminants in the range of those
reported for the Tennessee River upstream of any DOE influence, indicating no significant
contamination on the islands. Additionally, TVA owns these islands and restricts them to
recreational use for which all near-shore sediments in the OU are not a risk.
Comment: In Table B-5 (Appendix B, RI/FS), metal concentrations in surface water are
compared to ambient water quality criteria. One column in this summary table is labeled
"maximum detection limit." It is unclear whether the column should read "minimum detection
limit" or "maximum detected" and the reader is unable to conclusively compare the data to the
ambient water quality criteria. The ORREMSSAB recommends that clarity be provided in the
RI/FS report.
Response: The column should read "minimum detection limit" and it was presented in
Table B-5 as a way of flagging those criteria for which compliance is difficult to evaluate. It is
useful in those cases where all or most values are nondetects and the maximum detection limit
is less than the criteria. It also serves to note those criteria/analyte combinations where at least
some of our data are inadequate (i.e., if the minimum detection limit is greater than the
criterion). In these situations it is difficult to evaluate compliance, and this table seemed an
appropriate way to identify these situations. In general, the detection limits were adequate for
the purpose of evaluating compliance in those reaches investigated most thoroughly (Poplar
Creek, McCoy Branch, and the lower Clinch River). Detection limits are less adequate for some
of the upstream "reference" reaches or for certain analytes that Oak Ridge Reservation
Environmental Monitoring (ORREM) measured but th&RI team did not. In both cases, we relied
primarily on ORREM data and we have more problems with detection limits. As a rule, though,
our data are adequate for contaminants of concern in the reaches of concern. Neither the RI/FS
nor the proposed plan will be revised; rather, the responses to comments will be documented in
this ROD.
m»5396II.IWR/MBH 3-7 Angus 28. 1997
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Comment: It is known that people living in areas adjacent to the Operable Unit I ingest
turtle meat. Sampling of turtle tissue is not reported in the RI/FS or considered in the risk
assessment. The ORREMSSAB recommends that this potential exposure scenario should be
evaluated and the results included in the plan.
Response: Although turtles were not assessed and are not addressed by this ROD, TDEC
has completed a study on PCBs in turtles and the report was made available in May 1997. It is
expected that the turtles will have concentrations similar to or higher than the fish on which a risk
assessment was performed. TDEC is considering the addition of turtles to the advisory program.
Turtles will be sampled as part of the monitoring program associated with the preferred
alternative.
Comment: On page 5-19 of the RI/FS it is stated that only adults were considered for
exposure to carcinogens in the risk assessment because the end result would not be substantially
different than if children were considered. It is generally accepted in the health sciences
community that children may be more susceptible to the effects of carcinogens than adults.
Therefore, the ORREMSSAB recommends that risk calculations for child exposures to
carcinogens should be conducted and the RI/FS amended to include them. In addition, the
ORREMSSAB recommends that the fact that children were not evaluated when considering
exposure to carcinogens be included in the uncertainty analysis in the RI/FS. Discussion of
increased susceptibility of children, as well as other populations such as pregnant women, should
also be included in the uncertainty analysis.
Response: Children were evaluated separately for those pathways where differences in
body weight and ingestion patterns cause children to be more susceptible. (See RI Tables E41
versus E42 and E44 versus E45.) Even though children have a greater exposure factor compared
with that of adults (a factor of roughly 2; intake is typically half that of adults, but body weight
is only a fourth), this factor is applicable to only 6 years of the 30-year exposure period for
carcinogens. The combination of these parameters results in a factor of about 1.2 over the full
30-year exposure period. Given the uncertainties - and considerable conservatism in risk
assessment, this is not considered "substantial."
Comment: Ms. Barbara wanted to know why an Environmental Impact Statement (EIS)
wasn't performed instead of an FS.
Response: In accordance with DOE policy, separate NEPA documentation is not required
for DOE's CERCLA actions; NEPA values have been incorporated throughout the CERCLA
process (i.e., RI/FS), cumulating in this ROD.
JIt)a539611.IWR/MBH 3-8 Angus 28. 1997
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Comment: Mr. Alfred Brooks asked what the primary cause of risk is in fish
consumption.
Response: PCS concentrations account for the majority of risk to human health from fish
consumption.
Comment: Mr. Phelps asked about genetic damage in fish; stated that the pine tree
damage on ORR was caused by nuclear accidents; asked about "Sr sampling; stated that star wars
was a cover-up for *°Sr dangers; asked about the "bear creek barrier"; wanted to know if the
uranium and mercury formed an amalgam as they mixed in the creeks downstream of Y-12; and
warned against using national security as a reason for not answering questions.
Response: The Clinch River and Poplar Creek have the same number offish deformations
and problems as the national average of 1 to 2 percent, based on approximately 2,000 fish
sampled in the last 5 years. Pine beetles are known to be the cause of the dead pines.
Strontium-90 was included as an analyte in all appropriate samples taken during the RI.
Strontium-90 tends to be soluble and flow immediately downstream when released into a riverine
environment. Known sources of "'Sr throughout ORR are being addressed, and any process
discharges are treated for—""Sr before release. Within the CR/PC OU, all *°Sr concentrations
are well below the levels known to cause human health risks. DOE is unaware of the star wars
coverup problem, or of any "bear creek barrier." Although some industrial processes are capable
of combining mercury and uranium, the natural environment within a creek or river does not
provide the conditions necessary for chemical interaction between these elements. There are no
known national security issues associated with this project or remedial action.
Comment: Mr. Peele asked about the exceedances of ambient water quality concentrations
mentioned in the proposed plan.
Response: This ROD does not include surface water. In upper McCoy Branch
embayment, the AWQC for human recreation was exceeded for arsenic. This criterion assumes
that X concentration in surface water equals Y concentration in fish tissue (and furthermore that
Y concentration is harmful to fish, although Y is based on FDA tissue concentrations). By
sampling fish and analyzing them for arsenic, DOE showed that fish were not being impacted by
the periodic high levels of arsenic in the surface water. Those arsenic levels did not exceed
drinking water standards. In Poplar Creek, mercury exceeded the AWQC for fish and aquatic
life but again did not exceed drinking water standards. Actions ongoing at ORR are addressing
both the source of arsenic to McCoy Branch and the source of mercury to Poplar Creek. It is
hoped that these actions will eventually lower the surface water concentrations to below the
mXB396II.IWR/MBH 3-9 August 28. 1997
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AWQC. Allowing these other actions time to be effective is much more sensible than spending
enormous amounts of time and money attempting to treat McCoy Branch embayment or Poplar
Creek.
Comment: Mr. Earl Allred asked if the concentrations of contaminants in fish are getting
lower with time, and if there is anything that can be done other than wait.
Response: Fish samples collected after the RI was published do show a definite decrease
in '37Cs and mercury concentrations in fish tissue from the earlier data used in the RI report.
PCBs are more of an international/regional/statewide problem, and those levels will decline much
more slowly. PCBs were designed to be very difficult to destroy and they will remain in the
environment and the biota for a longer period of time. DOE is taking measures to reduce and
eliminate sources of contamination (including PCBs) to the river systems, but with PCBs there
are so many other non-DOE sources that the problem is likely to remain for some time.
Comment: Marina Hyman asked if the major concentrations of mercury and arsenic are
on the bottoms of the rivers and creeks, or also on the sides. She also asked where the drinking
water for Oak Ridge is collected.
Response: The majority of the sediment contamination is within the old river and creek
channels at the bottom. Where a channel approaches the sides or the banks, some contamination
may be near the shore but would still be submerged beneath the deeper water. Shallow waters
near the shore typically have much less contamination than the deeper water areas. Oak Ridge
gets its drinking water from the Clinch River within Melton Hill Lake, where the water meets
drinking water standards and has little if any DOE-related contamination.
ISSUE 3: MONITORING AND ASSESSMENT PROGRAM
Comment: Mr. Campbell asked if the monitoring program would include grab samples
of sediment, and how many years it would last. The ORREMSSAB suggested that surface water
be included in the monitoring program, that it should include suspended sediment during flooding
or low flow conditions, and that potable water intakes be sampled. The LOC and the
ORREMSSAB also recommends that turtles be sampled in the monitoring program. The
ORREMSSAB recommends that plans to inhibit irrigation be included in the monitoring program.
The ORREMSSAB desires to participate in the meetings that will be held to determine the exact
details of the monitoring program. Ms. Bryan wanted to know if the water intakes are
monitored, what analyses are performed, and under what laws. Mr. Josh Johnson asked what
projections were made to come up with the $3.6 million cost estimate for the remedial action.
JT0053961I.IWR/MBH 3-10 August 28, 1997
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The LOG questioned if the $3.6 million included the cost of the fish consumption advisory
program, or the revenue loss to downstream communities from loss of tourism.
Response: The monitoring program will consist of surface water sampling near municipal
intakes, sediment core samples throughout the OU, fish and turtle samples throughout the OU,
a survey to confirm the effectiveness of the fish consumption advisory program, and a survey to
determine the amount of long-term irrigation occurring within the OU. The exact locations,
analytes, and numbers of samples will be determined in May 1997 at a meeting with DOE,
TDEC, EPA, and other stakeholders who may desire to send a representative (such as TVA,
COE, and the ORREMSSAB). The program would last as long as necessary, with regulatory
review at least every 5 years. Widi the current amount of data on surface water and the absence
of any real threat to human health from the surface waters within this OU, extensive
storm/drought sampling is not necessary or cost-effective. Contaminants leaving ORR are-diluted
tremendously as they enter Poplar Creek or the Clinch River, and high flow events compound
that dilution. During low flow periods, very few contaminants will be washing out of the
contaminated areas on ORR to enter the system. The analyses are performed on unfiltered
samples that include any suspended sediments collected during the sampling event.
If the survey data indicate that there are people who irrigate to the extent that it could be
a risk, DOE would address that problem through some type of remedial action. Similarly, if the
surveys determine that fish consumption is a realistic threat to the local population, DOE would
work with TDEC to address that problem in a protective manner.
Water intakes are monitored by the treatment plant in order to determine what treatment
techniques will be needed to clean that water to the desired level. Legally, treatment plants
monitor the water they discharge either to the public utilities or to the environment. The Safe
Drinking Water Act of 1974 regulates the drinking water plants and determines in part what
analyses they perform. DOE will monitor the water around the intakes as part of the monitoring
program, and will analyze the samples for all DOE-related contaminants that may pose a risk to
human health. The waters within the OU already meet drinking water standards (other than
possible biological contamination) before the water is run through the treatment plant, which
makes it safe for the public to drink.
The cost estimate for this monitoring program was based in part on the cost of a similar
program already implemented for Lower Watts Bar Reservoir. The cost may increase slightly
because the monitoring program is being expanded as a result of public comments. Not included
in the cost estimate were sampling of turtles, a survey of fish consumers, and a survey for
irrigation activity. Finally, the cost quoted in the proposed plan was a "present-worth cost," and
JTD05396II.IWR/MBH 3-11 August 28. 1997
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was labelled as such. The present-worth cost of a remedial action is the amount of money that
would have to be invested today at some standard interest rate and rate of inflation to fund the
projected costs out to 30 years. Thus the present-worth cost may appear low because it is not
the total amount of money that will be spent during those 30 years. The cost of the fish
consumption advisory program is not included because this is an ongoing program that was in
existence long before this project began and is done to fulfill the requirements of state law. Any
revenue loss due to decreased tourism is not something that can be calculated readily and would
also not be due solely to DOE contaminants. PCBs are the primary contaminant of concern in
fish tissue and are attributable to almost every industry and municipality within the watershed.
The advisory program is implemented within this OU in the same manner as it is throughout the
state of Tennessee (and other states as well), and has little to do with DOE influences or releases.
ISSUE 4: PRIVATE SECTOR IMPACTS ON THE OPERABLE UNIT
Comment: The Roane County Environmental Review Board (RCERB) offers the
following comments: (1) the Site Background section of the proposed plan should acknowledge
the high state of flux of land use on the ORR; (2) private sector activities in the vicinity of the
ORR are not closely monitored for releases of contaminants; and (3) the text of the proposed plan
implies that contaminant sources have been eliminated and that risks will decrease over time. The
text should clarify if this assumes DOE operations only, or if it considers risks from potential
increases in private sector activities that historically had been done by DOE. The LOG offered
a related comment: the proposed plan would have benefitted greatly by the inclusion of NEPA
values into the RI/FS process such that the impact of DOE's changing mission on the ORR would
have been addressed. This would have included the transfer of DOE waste management activities
to private-sector firms and the range of potential activities within the OU.
Response: The changes in land use are not very significant from the standpoint of this
OU. Current use on ORR is industrial and future land use is assumed to be industrial. Current
releases from DOE activities are regulated and monitored according to state and federal law, as
will any releases that may occur from future private.sector activities. There is no reason to
believe that private sector activities will release any more contaminants than DOE activities. We
were unable to find a statement in the proposed plan implying that sources of contamination have
been removed; in fact, on page 3 there is a statement that upstream contaminant sources are still
present. DOE cannot be liable or guarantee through this ROD that private sector businesses are
complying with state and federal laws regarding contaminant releases; however, DOE is
addressing its own sources of contamination and it is safe to assume that releases to the OU will
decline over time. For a discussion of NEPA's relationship to this process, see the response to
JT005396I1.1WR/MBH 3-12 Augua 28, 1997
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Ms. Barbara in Issue 2 above. Again, this OU does not include ORR or surrounding lands, and
the change in land use from DOE industrial to private sector industrial is not expected to impact
this river system to any significant extent.
ISSUE 5: SEDIMENT-DISTURBANCE CONTROLS
Comment: Mr. Earl Allred asked what limits and permitting would be considered for
dredging in Poplar Creek or the Clinch River, and how would the disposal of the dredged
sediments be handled.
Comment: The ORREMSSAB and the RCERB want to know how the proposed dredging
for a barge terminal at HTTP would be handled and would input from downstream users be
solicited.
Comment: The RCERB wants to add text that states that "dredging for barge docks" and
"barge activity" will trigger Watts Bar Reservoir Interagency Working Group (WBRIWG)
review.
Comment: The LOC recommends that the WBRIWG be expanded to cover other issues
such as fishing and recreation and should include members from the Tennessee Wildlife
Resources Agency; city of Oak Ridge; Roane, Meigs, and Rhea county governments; and
possibly other stakeholder groups.
Response: The Interagency Agreement for Watts Bar Reservoir Permit Coordination was
established for one reason: to allow the agencies with permit authority over actions taken in
Watts Bar Reservoir (TVA, COE, and TDEC) to discuss proposed sediment-disturbing activities
with DOE and EPA relative to any DOE contaminants that may be present in the sediments
before conducting the normal permit review process. The WBRIWG consists of the above named
groups because of their permit authority or their knowledge of the sediment contamination and
how that contamination may impact the public if disturbed. The basic process of obtaining a
permit is the same for any organization or individual: (1) an application is completed and
submitted to TVA/COE/TDEC (depending on scope of activity); (2) if the proposed activity
would occur within Watts Bar Reservoir or its tributaries, the application is forwarded to the
WBRIWG for review; (3) the WBRIWG reviews available data for the location involved or DOE
collects any necessary data on sediment contamination; (4) if the location appears to be
uncontaminated or clean enough to pose no significant health risks, then the application is
forwarded back to TVA/COE/TDEC for their standard review process; and (5) if the location
appears to be contaminated and sediments may pose a health risk, DOE works with the applicant
JT005396I1.1WR/MBH 3-13 August 28. 1997
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to determine how best to approach the conduct of the requested activity (assuming
TVA/COE/TDEC permit the action based on their own statutory program of review). The
interagency agreement covers any potential sediment-disturbing activity (other than locations
predetermined to be free of DOE-related contaminants) and thus barge terminal construction
would be covered. Barge activity is ongoing on the reservoir and need not be permitted or
reviewed by the working group.
If dredging is necessary in a location with contaminated sediments, DOE will assume the
financial and waste management responsibility that is over and above the costs that would
normally be incurred and the dredging and subsequent disposal of sediments will take place in
accordance with best management practices and in compliance with all state and federal laws
regarding downstream impacts and disposal of hazardous and/or radioactive materials. Assuming
that construction of the barge terminal is subject to federal review, it would also be -subject to
public review and comment through the NEPA process.
Fishing or other recreational activities do not qualify as potential sediment-disturbing
activities and would not fall under the charter for the WBRIWG. Other agencies under other
laws regulate fishing, wildlife, and boating activities, and general recreation does not seem in
need of regulation. The use of the WBRIWG to review or permit other activities is not necessary
or legally valid. The addition of other members and groups to the WBRIWG is unnecessary for
the permitting process as it now works in accordance with the statutory authorities of TVA, COE,
and TDEC.
ISSUE 6: OTHER CONCERNS
Comment: The LOG recommends adding water intakes to the site map and making the
OU boundaries clearer.
Comment: The RCERB suggests adding water, flow directions to the map.
Response: These items will be added to the map in the ROD.
Comment: The LOG asks if any steps are being taken to reduce arsenic input to the OU.
Response: There are two sites previously used for coal ash disposal upstream of McCoy
Branch embayment on which DOE is completing CERCLA documentation. This could help
decrease the amount of arsenic leaching from the coal ash into the embayment. The remedial
action on one of these sites, the Filled Coal Ash Pond, is complete.
JTOOS396II.1WR/MBH 3-14 Angus 28. 1997
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Comment: The ORREMSSAB recommends that if Poplar Creek surface water
contamination is seen to increase, DOE review the possibility of treating the whole flow of Poplar
Creek.
Response: Treating the entire flow of Poplar Creek would involve the construction of an
enormous plant with acres of water holding ponds similar to a plant for a large city like New
York City. The cost of this effort would likely consume DOE's entire Environmental Restoration
budget for several years. This does not seem reasonable or cost-effective for a creek that did not
exceed drinking water standards during the RI.
Comment: Mary Bryan/the ORREMSSAB desires the opportunity to comment early in
the RI phase of a project.
Response: We are currently following the CERCLA process for obtaining public input
and comments. The DOE public relations department is continuing to work with the
ORREMSSAB and has begun providing early drafts of DOE's CERCLA documents to the
ORREMSSAB for review.
Comment: Mr. Peele recommends that DOE issue periodic reminders and begin education
campaigns in the schools regarding the controls and advisories that are part of this remedial
action.
Response: The only control really applicable to the general public is the fish consumption
advisory program implemented by TDEC. DOE will be conducting a survey as part of the
monitoring program to determine whether this program is entirely effective. Should the program
be found ineffective, DOE will work with TDEC to increase public awareness of these controls.
The same holds true for irrigation practices within the OU. The sediment disturbance controls
are for deep sediments that are not exposed to the general public and cannot legally be removed
or disturbed without following the permitting process of TVA, COE, and TDEC.
Comment: Riley Sain recommends that DOE, in the final ROD, (1) clearly state that
surface waters are not included in this OU, (2) identify the OUs to which these waters have been
relegated, and (3) provide an estimate of the schedule under which the public can anticipate a
final ROD on this portion of the environment surrounding the ORR.
Response: The ROD does state that surface waters are not part of this OU. The surface
waters will be formally placed into another OU, although they will be monitored as part of the
monitoring program mandated hi this ROD to allow DOE and the public to note the changes in
JTOB39611.1WR/MBH 3-15 August 28, 1997
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contamination levels that occur over time. When DOE has completed the CERCLA actions that
are addressing the sources of contaminants entering these surface waters, data will be gathered
through the monitoring program to verify that the two AWQC which were exceeded either have
or have not been met. Addressing these downstream surface waters prior to completing the
upstream cleanup activities would not be the most effective way to handle this problem; however,
if after DOE completes source cleanups the surface waters still fail to meet AWQC, DOE will
take steps to solve this problem.
Comment: The Friends of Oak Ridge National Laboratory, Alfred Brooks, and Stuart
Clark all recommend that DOE implement the alternative selected in the Proposed Plan.
Response: That is being accomplished through the formal CERCLA process and the
approval of this ROD.
JTOOS396I1.IWR/MBH
3-16
August 28. 1997
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