PB97-964018
EPA/541/R-97/076
January 1998
EPA Superfund
Record of Decision:
Paducah Gaseous Diffusion Plant
(USDOE) (Waste Area Group 17)
Paducah, KY
9/29/1997
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DOE/OR/06-1567&D1
Record of Decision for Waste Area Group 17
at the Paducah Gaseous Diffusion Plant,
Paducah, Kentucky
September 1997
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CERTIFICATION
Document Identification: Record of Decision for Waste Area Group 17 at the
Paducah Gaseous Diffusion Plant, Paducah, Kentucky,
DOE/OR/06-1567&D1
I certify under penalty of law that I have personally examined and am familiar with the
information submitted in this application and all attachments and that, based on my inquiry of
those persons immediately responsible for obtaining the information contained in the
application, I believe that the information is true, accurate, and complete. I am aware that
there are significant penalties for submitting false information, including the possibility of fine
and imprisonment.
U.S. Department of Energy
/ner and Operator
c.
C. Hodges, Paducah Site Manager Date Signed
Paducah Site Office
U.S. Department of Energy
The Department of Energy has signed as "owner and operator" and Lockheed Martin Energy
Systems, Inc., has signed as "co-operator" this application for the permitted facility. The
Department has determined that dual signatures best reflect the actual apportionment of
responsibility under which the Department's RCRA responsibilities are for policy,
programmatic, funding, and scheduling decisions, as well as general oversight, and the
contractor's RCRA responsibilities are for day-to-day operations (in accordance with general
directions given by the Department of Energy as part of its general oversight responsibility),
including but not limited to, the following responsibilities: waste analyses and handling,
monitoring, record keeping, reporting, and contingency planning. For purposes of the
certification required by 40 CFR Section 270.1 l(d), the Department of Energy's
representatives certify, to the best of their knowledge and belief, the truth accuracy and
completeness of the application for their respective areas of responsibility.
Page I of 2
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CERTIFICATION7
Document Identification: Record of Decision for Waste Area Group 17 at the
Paducah Gaseous Diffusion Plant, Paducah, Kentucky,
DOE/OR/06-1567&D1
I certify under penalty of law that I have personally examined and am familiar with the
information submitted in this application and all attachments and that, based on my inquiry of
those persons immediately responsible for obtaining the information contained in the
application, I believe that the information is true, accurate, and complete. I am aware that
there are significant penalties for submitting false information, including the possibility of fine
and imprisonment.
Lockheed Martin Energy Systems, Inc.
Co-Operator
/ftmmy Q. Massey, Site Mariager Date Signed
t ^/Environmental Management and Enrichment
Facilities
Lockheed Martin Energy Systems, Inc.
The Department of Energy has signed as "owner and operator" and Lockheed Martin Energy
Systems, Inc., has signed as "co-operator" this application for the permitted facility. The
Department has determined that dual signatures best reflect the actual apportionment of
responsibility under which the Department's RCRA responsibilities are for policy,
programmatic, funding, and scheduling decisions, as well as general oversight, and the
contractor's RCRA responsibilities are for day-to-day operations (in accordance with general
directions given by the Department of Energy as part of its general oversight responsibility),
including but not limited to, the following responsibilities: waste analyses and handling,
monitoring, record keeping, reporting, and contingency planning. For purposes of the
certification required by 40 CFR Section 270. ll(d), Lockheed Martin Energy Systems, Inc.'s,
representatives certify, to the best of their knowledge and belief, the truth accuracy and
completeness of the application for their respective areas of responsibility.
Page 2 of 2
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DOE/OR/06-1567&D1
Record of Decision for Waste Area Group 17
at the Paducah Gaseous Diffusion Plant,
Paducah, Kentucky
September 1997
Prepared by
Jacobs EM Team
175 Freedom Boulevard Kevil, KY 42053
Under Contract DE-AC05-93OR22028
Prepared for
United States Department of Energy
Remediation Management Group
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PREFACE
This Record of Decision for Waste Area Group 17 at the Paducah Gaseous Diffusion Plant,
Paducah, Kentucky, DOE/OR/06-1567&D1, was prepared in accordance with
requirements under the Comprehensive Environmental Response, Compensation, and
Liability Act, the Resource Conservation and Recovery Act, and the Kentucky Revised
Statutes Chapter 224, subchapter 46. This work was performed under Work Breakdown
Structure 7.1.09.07.03.08 (Activity Data Sheet 5309). This document follows the outline
for records, of decision contained in the draft Federal Facility Agreement and the
Guidance on Preparing Superfund Decision Documents: The Proposed Plan, The Record of
Decision, Explanation of Significant Differences, The Record of Decision Amendment,
EPA/540/G-89/007. Publication of this document meets a primary document
deliverable milestone for the United States Department of Energy's Remediation
Management Group at the Paducah Gaseous Diffusion Plant. This document provides
the record of information and rationale that the United States Environmental Protection
Agency, the Kentucky Department for Environmental Protection, and the DOE utilized
in the selection of no further action at Waste Area Group 17.
m
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CONTENTS
PREFACE
FIGURES
ACRONYMS AND ABBREVIATIONS.
. m
.. V
. vi
PART 1. DECLARATION
SITE NAME AND LOCATION
STATEMENT OF BASIS AND PURPOSE
DESCRIPTION OF SELECTED REMEDY: NO FURTHER ACTION
DECLARATION STATEMENT
PART 2. DECISION SUMMARY
2.1 Site Name, Location, and Description 1
2.2 Site History and Enforcement Activities 1
2.2.1 Bank Control and Erosion Control Grouping 1
2.2.2 Dam and Structural Support Grouping 5
2.2.3 Bridge Support and Erosion Control Grouping 6
2.2.4 Roadway Stabilization Grouping 7
2.2.5 Isolated Rubble Piles Growing 8
2.3 Highlights of Community Participation 9
2.4 Scope and Role of Operable Unit 10
2.5 Response Action and the Site Management Strategy 10
2.6 Summary of Site Characteristics 10
2.6.1 Surface-Water Characteristics of the Paducah
Gaseous Diffusion Plant Area 10
2.6.2 Surface-Water Characteristics of Waste Area
Group 17 11
2.6.3 Area of Concern Characteristics 11
2.6.3.1 Category 1 Site Results 12
2.6.3.2 Category 2 Site Results 12
2.7 Summary of Site Risks 13
2.7.1 Human Health Risk Assessment 13
2.7.2 Ecological Risk Assessment 14
2.8 Description of the No Further Action Alternative 14
2.9 Explanation of Significant Changes 15
PART 3. RESPONSIVENESS SUMMARY
3.1 Responsiveness Summary Introduction 17
3.2 Community Preferences/Integration of Comments 17
IV
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FIGURES
Figure 2-1. Vicinity Map and Location of Areas of Concern of Waste Area
Group 17 2
Figure 2-2. Surface-Water Features and Permitted Effluent Outfalls in the
Vicinity of the Paducah Gaseous Diffusion Plant 3
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ACRONYMS AND ABBREVIATIONS
The following list of acronyms and abbreviations is provided to assist in the review of
this document.
AGO Administrative Order by Consent
AOC area of concern
BCWMA Ballard County Wildlife Management Area
C.F.R. Code of Federal Regulations
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act of 1980
cm centimeter(s)
cm2 square centimeters
COC chemical of concern
COPC chemical of potential concern
COPEC chemical of potential ecological concern
CSOU comprehensive site operable unit
cpm counts per minute
DOE United States Department of Energy
dpm disintegrations per minute
ELCR excess lifetime cancer risk
EPA United States Environmental Protection Agency
ft foot (feet)
ft3 cubic foot (feet)
FFA Federal Facility Agreement
gal gallon
HSWA Hazardous and Solid Waste Amendments
K.R.S. Kentucky Revised Statutes
KDEP Kentucky Department for Environmental Protection
km kilometer(s)
KOW Kentucky Ordnance Works
KPDES Kentucky Pollutant Discharge Elimination System
1 liter
m meter(s)
m3 cubic meter(s)
mgd million gallons per day
Nal sodium iodide
OU operable unit
PCB polychlorinated biphenyl
pCi/g picocurie per gram
PGDP Paducah Gaseous Diffusion Plant
ppm parts per million
PRAP proposed remedial action plan
RCRA Resource Conservation and Recovery Act
ROD record of decision
SARA Superfund Amendments and Reauthorization Act of 1986
TVA Tennessee Valley Authority
USEC United States Enrichment Corporation
WAG waste area group
WKWMA Western Kentucky Wildlife Management Area
yd3 cubic yard(s)
VI
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PARTI
DECLARATION
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DECLARATION FOR THE RECORD OF DECISION FOR
WASTE AREA GROUP 17
SITE NAME AND LOCATION
Waste Area Group 17
Paducah Gaseous P ffusion Plant
United States Department of Energy
Paducah, Kentucky
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedy for Waste Area Group (WAG) 17
at the Paducah Gaseous Diffusion Plant (PGDP) near Paducah, Kentucky. The remedy
outlined in this document was chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986, the National
Oil and Hazardous Substances Pollution Contingency Plan, and the Kentucky Revised
Statutes (K.R.S.) Chapter 224, subchapter 46. This decision is based on the
administrative record for this site.
With participation from the Kentucky Department for Environmental Protection
(KDEP), both the United States Environmental Protection Agency (EPA) and the United
States Department of Energy (DOE) entered into an Administrative Order by Consent
(ACO) effective November 23, 1988. The ACO was drafted pursuant to Sections 104
and 106 of CERCLA, which provide authority for conducting remedial actions in
response to releases of hazardous substances, pollutants, or contaminants. The PGDP
was placed on the CERCLA's National Priorities List May 3" 1994 (effective date June
30, 1994).
The DOE was issued a Kentucky Hazardous Waste Management Permit and an EPA
Hazardous and Solid Waste Amendments of 1C>84 (HSWA) permit July 16, 1991. The
KDEP portion of the Resource Conservation and Recovery Act (RCRA) permit was
issued pursuant to Chapter 224 of the K.R.S. by authority granted from the EPA to the
KDEP. The EPA issued its portion of the RCRA permit pursuant to the HSWA. The
RCRA permits require the proper treatment, storage, and disposal of waste; corrective
action (i.e., cleanup); closure of regulated units; and investigation of off-site
contamination. The DOE is currently negotiating a Federal Facility Agreement (FFA)
with the EPA and the KDEP to integrate the overlapping requirements of the CERCLA
and the RCRA that apply to the PGDP. A draft of this FFA has been made available for
public comment and the parties are now engaged in finalizing the agreement in light of
comments submitted to them.
The EPA and the KDEP have participated in the development of this record of decision
(ROD), including review and comment on the content of the document. The DOE and
the EPA, with the concurrence of KDEP and the Commonwealth of Kentucky's Cabinet
for Health Services Radiation Control Branch, have selected no further action for WAG 17.
DESCRIPTION OF SELECTED REMEDY: NO FURTHER ACTION
Waste Area Group 17 consists of 37 areas of concern (AOCs) that were identified as
suspected sources of off-site contamination in the Site Management Plan, Paducah Gaseous
Diffusion Plant, Paducah, Kentucky, DOE/OR/07-1207&D3; therefore, a remedial
investigation was conducted. Based on the results of the Resource Conservation and
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Recovery Act Facility Investigation/Remedial Investigation Report for Waste Area Grouping I 7
at Paducah Caseous Diffusion Plant, Paducah, Kentucky, DOE/OR/07-1404&D2, the DOE
selected no further action as the remedy for 28 of the 37 WAG 17 AOCs. The 28 AOCs
that are selected for no further action are 103, 104, 110, 111, 112, 114, 115, 116, 117
118, 119, 120, 121, 123, 124, 125, 126, 127, 128. 146, 147, 148, 149, 150, 151, 152, 184,
and 197. The remaining nine AOCs will be transferred to WAG 25 (i.e., AOCs 93, 105
106, 107, 108, 109, 113, and 175) and WAG 18 (i.e., AOC 129). The process that led
the DOE to a no further action decision is consistent with the cleanup strategy for the
PGDP, as outlined in the Site Management Plan, Paducah Caseous Diffusion Plant, Paducah,
Kentucky, DOE/OR/07-1207&D3. The Kentucky Hazardous Waste Management Permit
(KY8-890-008-982) will be modified upon signature of this ROD by designating the
previously mentioned 28 of the 37 AOCs of WAG 17 as no further action and including
them in Appendix A-2 (Table A-5) of the permit. The remaining nine AOCs will be
transferred into the listings for WAG 18 and WAG 25.
DECLARATION STATEMENT
The DOE, under federal authority, has eliminated a potential risk posed by WAG 17 by
remediating AOC 124 through a removal action. The removal action began in July 1996
and was completed April 15, 1997.
Metals (e.g., lead) were detected at elevated concentrations in one sample at AOC 127;
however, they will not be addressed under the DOE's Remediation Management Group.
Area of Concern 127 is located on Western Kentucky Wildlife Management Area
property. The detected metal concentrations are believed to originate from illegally
dumped trash in the area and not from the PGDP. The EPA and the KDEP agree that
the elevated metals detected did not originate from the WAG 17 concrete rubble or the
PGDP. Consequently, AOC 127 is included in the no further action remedy.
No remedial action is necessary for protection of human health and the environment at
WAG 17, and the CERCLA requirements are not triggered. Consequently, there is no
need to evaluate the nine CERCLA criteria.
Under the no further action scenario, no additional action will occur at the WAG 17
AOCs. Also, no institutional controls or engineering controls will be implemented and
there are no costs associated with implementing the no further action decision. This
remedy will not result in hazardous substances remaining ortsite above health-based
levels; therefore, the five-year review requirement will not apply to
WAG 17. KFJ
Date:
Rodney R. Nelson
Assistant Manager for Environmental Management
United States Department of Energy
Date:
__ _
RichaVd D. Green ' ^ \
Acting Director, Waste Management Division
United States Environmental Protection Agency, Region 4
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PART 2
DECISION SUMMARY
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DECISION SUMMARY
2.1 Site Name, Location, and Description
The Paducah Gaseous Diffusion Plant (PGDP), located in western Kentucky, is an
operating uranium enrichment facility owned by the United States Department of Energy
(DOE) (Figure 2-1). The DOE leased the plant production facilities to the United States
Enrichment Corporation (USEC) July I, 1993. The USEC contracts with Lockheed
Martin Utility Services, Inc., to provide operation and maintenance services. Lockheed
Martin Energy Systems, Inc., provides environmental restoration and waste management
services for the PGDP under the DOE's Environmental Management Program.
The 28 areas of concern (AOCs) addressed in this record of decision (ROD) consist of
concrete rubble and the surrounding soil. The concrete rubble is believed to have
originated from the PGDP where it may have served as roadways, sidewalks, curbing,
buildings, transmission tower bases, cylinder supports, and construction rubble. Most of
the concrete material at the WAG 17 AOCs is currently used for a number of purposes,
including bank and erosion control, dam and structural support, and roadway
stabilization. However, some of the materials are simply isolated rubble piles. The WAG
17 AOCs are accessible to the public and have been classified as nonsecure. The AOCs
are located within the boundaries of the DOE reservation, the Tennessee Valley
Authority (TVA) Shawnee Steam Plant reservation, the Western Kentucky Wildlife
Management Area (WKWMA), the Ballard County Wildlife Management
Area (BCWMA), and on private property immediately west of the DOE reservation
(Figure 2-1).
2.2 Site History and Enforcement Activities
This section presents descriptions of the 28 AOCs of WAG 17, which are separated into
groups based on the purpose of the rubble piles. The information provided in this
section was derived from the PGDP Environmental Restoration Health Physics Special
Purpose/Routine Radiological Survey Results (Survey No. 92-SP-317-S); the Preliminary
Radiological Characterization of Ogden Landing Road Concrete Rubble Site, IT/NS-80-131;
and the Results of the Site Investigation, Phase II, Paducah Gaseous Diffusion Plant, Paducah,
Kentucky, KY/SUB/13B-97777C P-03/1991/1. This section also identifies any prior
enforcement activities that have o'-'-urred at the 28 r^OCs in this ROD. Map locations of
the AOCs are presented in Figures 2-1 and 2-2.
The results of the Resource Conservation and Recovery Act Facility Investigation/Remedial
Investigation Report for Waste Area Grouping 17 at Paducah Gaseous Diffusion Plant,
Paducah, Kentucky, DOE/OR/07-1404&D2, are described in Section 2.6.3 of this ROD.
2.2.1 Bank Control and Erosion Control Grouping
Concrete material at AOCs 115, 116, 118, 127, 149, and 151 serves as bank and erosion
control along bodies of water. The following information provides further details of the
AOCs in this grouping.
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I 1 T*nness«e Valtoy AutrionTy (TVAJ
Murac(»l W«m Supply W.ts
IKevl KV ind M.lropota. n.)
Location of
Area of Concern
WKWMA = West Kentucky Wildlilell
Management A' I'
TVA
Shawnee
Sleam Plant
*,./ Ballard County
Wildlife
Management
0Jacobs EM Team. 1997
Figure 2-1. Vicinity Map and Location of Areas of Concern of Waste Area Group 17
2
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Mcxlilied Irom CH2M HILL. 1990
DJacobs EM Team. 1997
Figure 2-2. Surface-Water Features and Permitted Effluent Outfalls
in the Vicinity of the Paducah Gaseous Diffusion Plant
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Area of Concern 115 is located in the TVA reservation along Little Bayou
Creek and the Slough Dam, 305 m (1,000 ft) west of the old TVA ash
disposal area. The material at this site is composed of concrete slabs, rubble
with some steel, and conduit pipes, most of which appears to have
originated from TVA activities. This material was placed on the southwest
bank of Little Bayou Creek for bank support, channeling (for transport of the
TVA ash-transport water), and also to serve as a levee for the "wetlands"
slough. The approximate volume of rubble material is 764.1 m1 (1,000 yd1).
Beta and gamma screenings at this AOC revealed no radiation above
background levels.
Area of Concern 116 is located in the TVA reservation on the north bank of
Bayou Creek. The material at this site is composed of concrete rubble that
was probably generated during PGDP road upgrades. The concrete is being
used in an attempt to halt erosion at a minor tributary run-off ravine entering
the creek. The approximate volume of the rubble is 22.9 m3 (30 yd3). Beta and
gamma radiation screening of the concrete and gamma radiation screening of
the soil revealed no radiation above background levels.
Area of Concern 118 is located in the WKWMA at the Bayou Creek sampling
station where West Boone Road meets Bayou Creek. The material at this site
is composed of concrete rubble and slabs that likely originated from PGDP
road construction. The concrete was placed on the bank above and below the
sampling station to control erosion. The approximate volume of the concrete
is 15.3 m3 (20 yd3). Radiation screening of the rubble found one slab of
cor"~rete '"ith beta and gamma readings slightly above background levels. The
slab was marked in the field with red paint.
Area of Concern 127 is located in the WKWMA at a culvert on Gravel Pit
Road, approximately 160 m (528 ft) north of Heath-Woodville Road. The
material at this site includes concrete slabs that are believed to have
originated from the PGDP. The concrete was used to control erosion at this
culvert. The volume of the concrete is approximately 7.6 m3 (10 yd3). Beta
and gamma screening of the concrete and gamma radiation screening of the
soil revealed no radiation above background levels.
Area of Concern 149 is located within the BCWMA on a dam face at the
west end of Happy Hollow Lake. The material at this site is composed of
concrete slabs. The origin of this material is unknown. The concrete is used
for erosion control on the dam face. The volume of concrete at the dam is
approximately 11.5 m3 (15 yd3). Beta and gamma radiation screening
revealed no radiation above background levels.
Area of Concern 151 is located within the BCWMA at the dam on the west
end of Mitchell Lake. The material at this site is composed of concrete slabs
and rubble. The amount of concrete, if any, derived from the PGDP is
unknown. The concrete is currently used to control erosion on the face of the
dam. The total volume of the structure is approximately 2,292.5 m3 (3,000
yd3), of which an unknown amount is concrete rubble. Beta and gamma
radiation screening revealed no radiation above background levels.
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2.2.2 Dam and Structural Support Grouping
Concrete material at AOCs 103, 104, 112, 146, 147, and 150 currently is associated
with dam construction and provides structural support. The following information
provides further details of the AOCs in this grouping.
Area of Concern 103 is located south of the DOE reservation boundary near
the intersection of the PGDP entrance highway and Dykes Road. The
material at this site is composed of concrete, soil, and gravel spoils from the
construction of a cylinder storage yard south of the C-333 Process Building. It
was used to construct a dam and create a fish pond in the WKWMA. The
total volume of the dam is approximately 1,911.3 m3 (2,500 yd3) with
concrete visible only at the northwest corner of the structure. Beta and
gamma radiation screening of the concrete and gamma radiation screening of
the soil revealed no radiation above background levels.
Area of Concern 104 is located in the WKWMA at the south end of the fish
pond referred to in the description of AOC 103. The material at this site
consists of concrete spoils from an unknown source that is used as part of a
levee for the pond. The volume of concrete is not known. Beta and gamma
radiation screening of the concrete and gamma radiation screening of the soil
revealed no radiation above background levels.
Area of Concern 112 is located within the WKWMA at a dam on a second
fish pond north of the DOE reservation. The AOC is composed of concrete
slabs that partially originate from the PGDP road upgrades. The dam
appears to be built of soil from the pond area with gravel and concrete rubble
added for stability. The volume of concrete cannot be determined accurately
due to the sporadic distribution of the concrete rubble and because it is
nearly all underwater. Beta and gamma radiation screenings of the concrete
above water showed no radiation above background levels.
Area of Concern 146 is located in the BCWMA approximately 17.7 km (11
miles; ..est of the PGDP where a roadway crosses over a dam on Shelby
Lake. The BCWMA headquarters are situated approximately 305 m (1,000
ft) to the east of the AOC. The material at this location is composed of
concrete rubble with an unknown portion possibly originating from the
PGDP. The concrete was used in construction of the dam and currently
supports the dam face. The approximate volume of concrete at this AOC is
1,528.2 m3 (2,000 yd3). Elevated levels of beta radiation were measured
during the screening at AOC 146. Alpha radiation scanning was also
conducted, but no radiation above background levels was detected. The
elevated beta radiation levels ranged from 12,000 to 70,000 disintegrations
per minute (dpm)/100 cm2. Areas with elevated radiation levels were smear
tested in the field for transferable contamination, but none was detected.
Area of Concern 147 is located within the BCWMA at Butler Lake Dam,
which is located on the west end of Butler Lake. The dam is used to control
the lake level and provide a roadway. The material at this site is composed
of concrete rubble, which likely originates from various sources, including the
PGDP. The concrete was used in construction of the dam and now supports
the dam face. The volume of the dam is approximately 1,529 m3 (2,000 yd3),
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with concrete rubble making up an indeterminate amount. Beta and gamma
radiation screening of the concrete revealed no radiation above background
levels at this AOC.
Area of Concern 150 is located within the BCWMA at a dam on the west end
of Caster Lake. The dam controls the lake level and provides part of a
roadway. The material at this site is composed of concrete rubble with an
unknown quantity, if any, originating from the PGDP. The concrete rubble
was used to construct the dam and control erosion on the dam's face. The
volume of the dam is approximately 2,293.5 m3 (3,000 yd3), of which an
unknown fraction is concrete rubble. Beta and gamma radiation screening of
the concrete at this unit revealed no radiation above background levels.
2.2.3 Bridge Support and Erosion Control Grouping
Concrete material at AOCs 114, 117, 119, 120, 121, and 128 is used for support and
erosion control at bridges and culverts in WAG 17. The following information provides
further details of the AOCs in this grouping.
Area of Concern 114 is located on the TVA reservation north of the
WKWMA boundary. The AOC is composed of concrete rubble from a PGDP
source. The rubble is used for support and erosion control at a culvert bridge
that crosses a small tributary of Little Bayou Creek. The approximate volume
of concrete at this location is 30.6 m3 (40 yd3). Beta and gamma radiation
screening of the concrete and gamma radiation screening of the soil revealed
no radiation above background levels.
Area of Concern 117 is located in the western part of the TVA reservation
where a bridge crosses Bayou Creek. The material at this site consists of
concrete rubble from a PGDP source. The rubble is used to control erosion
around the bridge and to support the nearby creek bank. The approximate
volume of concrete at this location is 11.5 m3 (15 yd3). Beta and gamma
screening of the concrete rubble found one piece with a reading of 90 cpm
above background levels. The remainder of the concrete rubble had no
radiation above background levels.
Area of Concern 119 is located within the WKWMA outside the western
boundary of the DOE reservation where a steel bridge crosses Bayou Creek.
The material at this site appears to be demolished sidewalks that most likely
originated from the PGDP. The concrete slabs have been placed along the
creek banks underneath, upstream, and downstream of the bridge for erosion
control. The approximate volume of concrete is 3.8 m3 (5 yd1). Beta and
gamma radiation screening of the concrete and gamma radiation screening of
the soil revealed no radiation above background levels.
Area of Concern 120 is located on the DOE reservation at the north end of
the C-611-Y Lagoon for the C-611 Water Treatment Pl.-nt. Specifically, the
area involves the effluent ditch and the water line bridge. The material at this
site consists of concrete slabs, rubble, and very large blocks [0.1 m3 (4 ft3)]
from the PGDP that have been placed under the bridge and along the effluent
ditch for erosion control. The approximate volume of the concrete is 7.6 m3
(10 yd3). Beta and gamma radiation screening of the concrete and gamma
radiation screening of the soil revealed no radiation above background levels.
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Area of Concern 121 is located on the western edge of the DOE reservation
where Rice Springs Road crosses one of the tributaries of Bayou Creek. The
concrete rubble at this site is composed of slabs from the PGDP that now are
used as an abutment of a condemned bridge. The concrete slabs were also
used to construct a ford that replaced the condemned bridge. The
approximate volume of concrete is 0.8 m3 (1 yd3). The concrete constituting
the ford showed no radiation above background levels.
Area of Concern 128 is located just inside the southern boundary of the DOE
reservation near the crossing of South Acid Road with Bayou Creek. The
material at this site consiscs of concrete slabs, gravel, and soil from a source
assumed to be from within the PGDP. The concrete slabs are used for erosion
control on creek banks underneath, upstream, and downstream of the bridge.
A levee also exists north of the road and east of the creek and is composed
of concrete slabs, gravel, and soil. There is approximately 15.3 m3 (20 yd3) of
concrete at the AOC; however, this estimate should be considered a
minimum, as it is difficult to estimate the amount of concrete in the levee.
Beta, gamma, and alpha radiation screening revealed no radiation above
background levels.
2.2.4 Roadway Stabilization Grouping
Concrete material at AOCs 126, 148, and 197 is used to stabilize roadways in the
WKWMA and the BCWMA. The following information provides further details of the
AOCs in this grouping.
Area of Concern 126 is located in the WKWMA near the entrance road to the
gravel pits. The gravel pits were a source of gravel for the former Kentucky
Ordnance Works (KOW), the PGDP, and the WKWMA. Slabs of concrete
from an unknown source are visible on both sides of the entrance and may
have been used to fill holes along the roadway. The approximate volume of
concrete cannot be easily determined, but approximately 0.8 m3 (1 yd3) is
visible, b^ta and gamma radiation screening of I... concrete and gamma
radiation screening of the soil revealed no radiation above background levels.
Area of Concern 148 is located within the BCWMA at the culverts near Burnt
Slough, which is approximately 549 m (1,800 ft) south of the Ohio River. The
material at this site is composed of concrete block rubble and it is unknown
what fraction, if any, of this material is from the PGDP. Concrete block
rubble is used at this location to stabilize the edge of the roadway. There
appears to be approximately 15.3 m3 (20 yd3) of concrete rubble at this
location. Beta and gamma radiation screening of the concrete revealed no
radiation above background levels.
Area of Concern 197 is located on private property north of the PGDP and
the WKWMA on Bayou Creek. The concrete rubble serves as a roadbed at a
low-water crossing of the creek. The rubble was placed at this location in the
late 1980s. The concrete consists of 20 to 25 pieces within a 9.1 m x 15.2 m
(30 ft x 50 ft) arta. Some concrete pieces are partially submerged in the creek
bed and others are located on the eastern bank of the crossing. The
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approximate total volume of concrete rubble at this AOC is 0.8 m3 (1 yd3).
Radiological surveys (alpha, beta, and gamma) of accessible concrete
surfaces above the water level of Bayou Creek found no radiation above
background levels.
2.2.5 Isolated Rubble Piles Grouping
Areas of Concern 110, 111, 123, 124, 125, 152, and 184 consist of piles of concrete that
have no specific purpose. The following information provides further details of the
AOCs in this grouping.
Area of Concern 110 is located approximately 61 m (200 ft) east of the
PGDP security area but inside the DOE reservation on an abandoned
construction road that once led to the C-337 Process Building. The concrete
rubble is stored in piles on both sides of the roadbed and was generated from
PGDP road upgrading projects. There is approximately 15.3 m3 (200 yd3) of
concrete at this site. Beta and gamma radiation screening found radiation
above background levels on expansion joint material that was still attached
to various slabs of concrete. The average reading for this material was
approximately 150 cpm above background levels. No radiation in the soil
was detected above background levels.
Area of Concern 111 is located inside the plant boundary and lies adjacent
to the abandoned access road portion of Ogden Landing Road, which runs
east to west through the DOE reservation and north of the PGDP area. The
access road is abandoned and traffic use has been restricted by the dumping
of concrete construction spoils at the east and west ends of the access road
Some of the concrete is from the PGDP and is in very large pieces that
possibly were used as footing material for transmission towers. The
approximate volume of the concrete is 1,146.8 m3 (1,500 yd3). A detailed beta
and gamma radiation survey was conducted and surface soil samples taken
at this AOC. The radiation survey was conducted on a 6 m (20 ft) grid
pattern. Between the east and west areas, 28 grids were surveyed and it was
concluded that 13 of the grids showed levels of radiation that exceeded Oak
Ridge Operations Radioactive Contamination Control Policy for nonwork
surface contamination in a nonradiological area (3,000 dpm/100 cm2). Ten
surface soil samples were taken along Ogden Landing Road. The surface soil
samples contained concentrations of total uranium well below the reference
concentration level of 30 pCi/g of total uranium for unrestricted access to
off-site soil.
Area of Concern 123 is located within the WKWMA, southwest of the PGDP
near the intersection of South Acid Road and Rice Springs Road. It is a
partially paved area in the former KOW that has received concrete from
various PGDP areas and uranium hexafluoride tank supports (cylinder
saddles) from the C-745-A Cylinder Yard. Other parties, such as the
WKWMA, remove concrete from this site for their use. The volume of
concrete at this AOC is approximately 382 m to 764 m3 (500 to 1,000 yd3).
The beta and gamma radiation screening showed radiation above background
levels only on the uranium hexafluoride storage tank supports. These
readings ranged from 200 to 500 cpm from isolated areas on the supports.
Those areas were marked with red paint.
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Area of Concern 124 is located within the WKWMA, 30.48 to 60.96 m (100
ft to 200 ft) directly south of AOC 123, near the intersection of South Acid
Road and Rice Springs Road. The AOC is in an area where sidewalk slabs
and other concrete rubble from the KOW and the PGDP have been placed.
The approximate volume of concrete at the site is 15.3 m3 (20 yd3). During
previous radiation screenings, a contaminated concrete pipe [30.5 cm inside
diameter x 122 cm (12 inches inside diameter x 4 ft)] was found on the
surface of the AOC. Survey readings from inside the pipe were 45,000 cpm
above background levels. The pipe was removed from the site by PGDP
personnel. Beta and gamma radiation screening of the concrete slabs and
rubble showed no radiation above background levels. However, samples
collected during the-remedial investigation for WAG 17 indicated elevated
levels of radionuclides in the soil. The DOE then performed a removal action
during which the soil was excavated, placed in containers, and transported
to a secured waste management area at the PGDP.
The location of AOC 125 is in the WKWMA north of South Acid Road near
the intersection of the road and the railroad spur leading to the PGDP. The
materials at this site are comprised of rails, roadbed, and crossries from the
KOW and possibly the PGDP. Concrete curbs from parking areas in the
PGDP have also been deposited along the road. Approximately 38 m3 (50
yd3) of railroad spoils and approximately 3.8 m3 (5 yd3) of concrete curbing
are present at this location. Beta and gamma radiation screening of the
concrete rubble found three areas with radiation above background levels.
These areas are discrete rusty spots on the concrete, with readings of
2,500 cpm above background levels from one area and 250 cpm above
background levels from each of th" oth°" two areas. The three areas were
marked with red paint. Surveys of the soil found no radiation above
background levels.
Area of Concern 152 is located within the BCWMA near the east end of
Mitchell Lake 610 m (2,000 ft) southwest of the curve on Kentucky State
Highway 473. The site contains concrete rubble, used brick, and gravel that
are being stored for future use at the BCWMA. An unknown fraction of this
concrete rubble originates from the PGDP. The volume of waste is
approximately 38.2 m3 (50 yd3). Beta .- id gamma radiation screening of the
concrete revealed no radiation above background levels.
Area of Concern 184 is located within the DOE reservation and south of the
C-611 Water Treatment Plant. The AOC is composed of two chunks of
concrete from an unknown source. The total volume of concrete is
approximately 0.2 m3 (0.2 yd3). Beta and gamma radiation screening of the
concrete revealed no radiation above background levels.
2.3 Highlights of Community Participation
A notice of availability was published in The Paducah Sun, a regional newspaper, July
25, 26, and 27, 1997, which announced the beginning of the 45-day public review period
for the Proposed Remedial Action Plan for Waste Area Group 17 at the Paducah Gaseous
Diffusion Plant, Paducah, Kentucky, DOE/OR/06-1566&D2. The public comment period
began July 26, 1997, and ended September 8, 1997. Specific groups that received
individual copies of the proposed remedial action plan included the Natural Resource
Trustees and the Site Specific Advisory Board.
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2.4 Scope and Role of Operable Unit
The DOE's plan for addressing WAG 17 was to determine if any contamination was
present at the AOCs. If contamination was present, the DOE determined whether it
exceeded standards- set for the protection of human health and the environment. The
results of the investigation can be found in the Resource Conservation and Recovery Act
Facility Investigation/Remedial Investigation Report for Waste Area Grinding 17 at Paducah
Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/07-1404&D2.
In areas where previous walk-over surveys (i.e., during the site investigation) detected
potential radiological contamination above background levels, concrete and soil
sampling was performed to define the nature of the radiological activity. Radiation dose
readings were also collected in these areas to ensure annual dose limits outlined in the
DOE Order 5400.5, Radiation Protection of the Public and the Environment, were not
exceeded. In addition to characterization of the sites for radionuclide contamination,
samples were also collected to determine if polychlorinated biphenyls (PCBs) and/or
metal contamination were present at suspected AOCs. Both of these contaminants are
associated with past activities at the PGDP. The sampling ensured a thorough
characterization of these AOCs and provided data from which the nature and extent of
contamination could be determined.
2.5 Response Action and the Site Management Strategy
The PGDP presents unusually complex problems in terms of hazardous waste
management and environmental releases. The DOE's proposed strategy is to divide the
site into operable units (OUs) grouped by source areas and comprehensive site operable
units (CSOU'X one each for ground water and surface water. Discrete response actions
will be selected and implemented for each source area OU, as well as the CSOUs, which
are impacted by commingled releases from the source area OUs. Prioritization for
investigation and possible remedial action has been assigned to each of the CSOUs
(ground water and surface water OUs) and source area OUs depending on their
potential for contributing to off-site contamination.
The identification, charactc'-^tion, and, where necessary, removal of sources of
contamination is consistent with the cleanup strategy for the PGDP as outlined in the
Site Management Plan, Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/C"-
1207&D3.
2.6 Summary of Site Characteristics
The following are descriptions of surface water for the PGDP and individual AOCs since
it is the only suspected pathway for contamination movement in WAG 17.
2.6.1 Surface-Water Characteristics of the Paducah Gaseous Diffusion Plant Area
The sources for the following information are the Report of the Paducah Gaseous Diffusion
Plant Groundwater Investigation Phase III, KY/E-150, and the Northeast Plume Preliminary
Characterization Summary Report, DOE/OR/07-1339&D2.
The PGDP is located in the western portion of the Ohio River Basin (Figure 2-1). A local
drainage divide causes the plant's surface water to flow to the east and northeast
toward Little Bayou Creek or to the west and northwest toward Bayou Creek. Both
Bayou and Little Bayou creeks are perennial streams that discharge into the Ohio River.
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Bayou Creek flows northward along the western boundary of the plant from
approximately 4 km (2.5 miles) south of the plant to the Ohio River. Little Bayou Creek
originates within DOE property and flows northward along the eastern boundary of the
plant. Little Bayou Creek joins Bayou Creek in a marsh located approximately 4.8 km (3
miles) north of the PGDP; ultimate discharge is into the Ohio River. Other surface-water
bodies located in the area surrounding the PGDP include the Ohio River, Metropolis
Lake, Crawford Lake, and numerous small ponds, gravel pits, and settling basins.
At the PGDP, manmade drainage ditches receive storm water and effluent from the
plant. These waters are routed through outfalls and eventually discharge into Bayou and
Little Bayou creeks. The majority of the flow in these creeks can be attributed to effluent
water from the plant. The 18 KPDES-permitted outfalls have a combined average daily
flow of 18.5 million I/day (4.88 mgd) and are monitored by the PGDP.
The BCWMA is located in northern Ballard County in the floodplain of the Ohio River
(Figure 2-1). Seven oxbow lakes are present in the area, but no creeks. The entire area is
inundated by Ohio River flood water on an average of every three years.
2.6.2 Surface-Water Characteristics of Waste Area Group 17
The AOCs within WAG 17 are located within the Ohio River floodplain in the BCWMA
and the Bayou Creek watershed (Figure 2-1). Isolated rubble piles outside of the
BCWMA are not connected to any water bodies. Rubble piles in the BCWMA are
inundated by the Ohio River when large-scale flooding occurs.
2.6.3 Area of Concern Characteristics
The Resource Conservation and Recovery Act Facility Investigation/Remedial Investigation
Report for Waste Area Grouping 17 at Paducah Gaseous Diffusion Plant, Paducah, Kentucky,
DOE/OR/07-1404&D2, organized the WAG 17 AOCs into three categories for
streamlined sampling purposes. Category 1 AOCs are those that demonstrated
radiological contamination of concrete or soil during the previous investigations and
which, because of PCBs and metals associated with plant activities, were also sampled.
Category 2 AOCs have indicated no evidence of radiological contamination of concrete
or soil during the previous investigations, but were possibly contaminated with PCBs
and metals. Category 3 AOCs indicated no evidence of radiological contamination of
concrete or soil, but are located within areas of known radiological and PCB
contamination. Category 3 AOCs were not investigated as part of this study and will
not be addressed in this ROD (i.e., AOCs 93, 105, and 175 will be transferred to WAG
25 and AOC 129 will be transferred to WAG 18).
The Resource Conservation and Recovery Act Facility Investigation/Remedial Investigation
Report for Waste Area Grouping 17 at Paducah Gaseous Diffusion Plant, Paducah, Kentucky,
DOE/OR/07-1404&D2, used field screening and analytical laboratory data
to determine the nature and extent of contamination of the WAG 17 AOCs. The nature
and extent of radionuclides were determined for Category 1 AOCs and the extent
of potential PCB and metal contamination was determined for both Category 1 and
2 AOCs.
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The AOCs are categorized as follows:
Category 1 AOCs 110, 111, 117, 118, 121, 123, 124, 125, 127, and
146; and
Category 2 AOCs 103, 104, 112, 114, 115, 116, 119, 120, 126, 128, 147,
148, 149, 150, 151, 152, 184, and 197.
Specific analytical and field methods are explained in detail in the Resource Conservation
and Recovery Act Facility Investigation/Remedial Investigation Report for Waste Area
Grouping 17 at Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/
07-1404&D2, report. For the purposes of this ROD, beta/gamma refers to radiation
detected with open window Geiger-Mueller (pancake) detectors and gamma refers to
radiation detected with sodium iodide (Nal) scintillation crystal detectors. The AOCs
that pose a potential risk are described in the following text.
2.6.3.1 Category 1 Site Results
The remedial investigation results identified two AOCs (124 and 127) that posed a
potential risk to human health and the environment. Area of Concern 124 has since been
remediated through a removal action and AOC 127 contamination is believed to have
originated from a non-DOE source.
Area of Concern 124.
Historical radiation surveys (i.e., site investigations) identified a concrete pipe with
elevated radiation levels at AOC 124. This pipe was removed during initial radiation
surveys of the project. No other elevated radiation levels were detected at AOC 124
during the initial investigations; however, the historical survey was focused on the
concrete rubble piles and not on the surrounding soils. During the remedial investigation,
several metals were detected in the soil at AOC 124 at levels slightly above background
concentrations, including arsenic and mercury. Radionuclide contamination, including
uranium, was also detected at AOC 124 above background concentrations. After
review iiig the data, the DOE initiated a removal action in late July 1996 that is
documented in the Action Memorandum for Area of Concern (AOC) 124, Waste Area Group
(WAG) 17 at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/07-
1477&D2. A portion of the soil was excavated, placed in containers, and transported to
a secured waste management area at the PGDP. After the area was excavated, soil
samples were collected and tested to verify that all contamination had been removed.
The data generated from these samples indicated that additional soil needed to
be removed. This additional remediation was completed April 15, 1997. By removing
detected contamination, the DOE has reduced the risk to an acceptable level at
AOC 124.
Area of Concern 127.
Metals (e.g., lead at 539 ppm) were detected in one sample at AOC 127. Area of
Concern 127 is located on WKWMA property and the lead detected at this location has
been attributed to unauthorized dumping of household trash.
2.6.3.2 Category 2 Site Results
Category 2 sites are those sites for which historical radiation walk-over data indicated
no radiological contamination of concrete or soil, but which could be contaminated with
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PCBs because there is no available evidence to rule out PCB contamination. For this
reason, the sampling strategy for Category 2 sites included a visual inspection and PCB
soil screening. If the PCB screening results suggested the presence of PCBs at a site, a soil
sample was collected and sent for laboratory analysis to confirm the presence of PCBs
and identify the specific PCB isomers.
The PCB screening locations are identified on site maps provided in the Resource
Conservation and Recovery Act Facility Investigation/Remedial Investigation Report for Waste
Area Grouping 17 at Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/07-
1404&D2. Positive detections were obtained at one of the 28 AOCs in WAG 17 (i.e.,
AOC 120). All of the detected laboratory PCB analytical results are below 1 ppm,
which is the CERCLA and the KDEP screening level for residential land use.
2.7 Summary of Site Risks
Based on the information presented in the baseline risk assessment included in the
Resource Conservation and Recovery Act Facility Investigation/Remedial Investigation Report
for Waste Area Grouping 17 at Paducah Gaseous Diffusion Plant, Paducah, Kentucky,
DOE/OR/07-1404&D2, no human health risks exist at WAG 17 above acceptable
levels as defined by the United States Environmental Protection Agency (EPA). Area of
Concern 124 was not included in this assessment due to the removal action that was
conducted at this AOC. Minimal ecological concerns were identified at AOCs 121 and
127 during the screening ecological risk assessment. A more thorough evaluation of
potential ecological risks will be performed during the sitewide baseline ecological risk
assessment to be performed as part of the WAGs 18 and 25 Surface Water Integrator
Unit investigation. Metal contamination at AOC 127 is not associated with DOE
activities.
2.7.1 Human Health Risk Assessment
Data from the site investigation and newly collected data were evaluated in the human
health risk assessment included in the Resource Conservation and Recovery Act Facility
Investigation/Remedial Investigation for Waste Area Group 17 at the Paducah Gaseous
Diffusion Plat:., 'iducah, Kentucky, DOE/OR/07-1404&D2. To identify chemicals of
potential concern (COPCs), all constituents detected in concrete, surrounding soils, and
sediments were evaluated using established guidelines. Chemicals of potential concern
identified at the WAG 17 AOCs include metals, PCBs, and ladionuclides.
The potential for human contact with COPCs found in concrete, soil, and sediment is
evaluated in the exposure assessment of the Resource Conservation and Recovery Act
Facility Investigation/Remedial Investigation Report for Waste Area Grouping 17 at Paducah
Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/07-1404&D2. After consideration
of all data, the report identifies the most appropriate scenarios for exposure to these
media at all AOCs as the recreational user and industrial worker under current
conditions, and the recreational user, industrial worker, rural resident, and excavation
worker under future conditions.
The toxicity assessment evaluated the toxic characteristics of COPCs in relation to
human health based on a review of available scientific evidence. To characterize the
potential toxicity of a particular contaminant, ti.~ .ypc of effect it can produce and the
concentration needed to produce that effect must be known. The contaminants are
evaluated as a chemical or radiological hazard. Chemical and radionuclide
contaminants are divided into two broad groups according to their effects on human
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health: contaminants that exhibit carcinogenic effects and contaminants that exhibit
noncarcinogenic or systemic effects.
The risk characterization quantified the potential carcinogenic and noncarcinogenic risks
for each of the defined exposure pathways for the COPCs. The dose-response
characteristics of the contaminants integrated with the exposure intake estimates are
used to generate estimates of excess lifetime cancer risk (ELCR) for chemicals or
radionuclides and the likelihood of noncarcinogenic effects. From this information, a
chemical of concern (COC) list is developed (for the list of COCs and the corresponding
risk tables, refer to the Resource Conservation and Recovery Act Facility
Investigation/Remedial Investigation Report for Waste Area Grouping 17 at Paducah Gaseous
Diffusion Plant, Paducah, Kentucky, DOE/OR/07-1404&D2. The criteria used to define
COCs in the Resource Conservation and Recovery Act Facility Investigation/Remedial
Investigation Report for Waste Area Grouping 17 at Paducah Gaseous Diffusion Plant,
Paducah, Kentucky, DOE/OR/07-1404&D2, is based on KDEP guidance that is
appropriate for determining baseline risks. To evaluate potential risks at these AOCs,
actual exposure times to potential receptors are used as discussed in the Resource
Conservation and Recovery Act Facility Investigation/Remedial Investigation at the Paducah
Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/07-1404&D2. As noted in the
report, when site-specific exposures provided by the WKWMA are used, the resultant
risks are well below the KDEP's de minimis level at every AOC. Consequently, no action
is required at any AOC to protect human health.
The uncertainties associated with the baseline risk assessment would generally lead to
an overesrimation of risks at the units. Since all risks are within acceptable limits, the
effects of these uncertainties are minimal. For a more complete discussion of the
uncertainties associated with baseline risk assessment, refer to the Resource Conservation
and Recovery Act Facility Investigation/Remedial Investigation Report for Wuste /\rea
Grouping 17 at Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/07-
1404&D2.
2.7.2 Ecological Risk Assessment
The screening ecological risk assessment for WAG 17 evaluated chemical and
radionuclide contaminants in surface soils and radionuclides in sediments. No ecological
risks were found to be associated with radionuclides in stream sediments at any of the
AOCs of WAG 17. Two AOCs, 127 and 121, were identified as having potential
ecological risks from metals. Chromium, lead, aluminum, and zinc are chemicals of
potential ecological concern (COPEC) at AOC 127; however, as previously discussed,
the source of this contamination is not the WAG 17 concrete rubble or the PGDP. At
AOC 121, chromium was the only COPEC identified, and it is present just slightly
above background levels. These screening risk assessment results indicate that an action
is not required at WAG 17 to protect ecological receptors from metal contamination
deposited by DOE.
2.8 Description of the No Further Action Alternative
According to EPA guidance [Guidance on Preparing Superfund incision Documents: The
Proposed Plan, The Record of Decision, Explanation of Significant Differences, The Record of
D^ision Amendment (EPA/540/G-89/007)], if there is no current or potential threat .,
human health and the environment, then no action is warranted, and the CERCLA
requirements for remedial actions are not triggered. Consequently, there is no need to
evaluate the nine CERCLA criteria.
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Under the no further action scenario, no additional action will occur at the remaining
WAG 17 AOCs. No new institutional controls or engineering controls will be
implemented and there are no capital, operating, or monitoring expenses associated with
implementing the no further action decision.
2.9 Explanation of Significant Changes
The Proposed Remedial Action Plan for Waste Area Group 17 at the Paducah Gaseous
Diffusion Plant, Paducah, Kentucky, DOE/OR/06-1566&D2, was made available for a
45-day public review and comment period that began July 26, 1997, and ended
September 8,1997. A public meeting was held August 26, 1997. The DOE identified no
further action for WAG 17. All written and verbal comments submitted during the public
comment period were reviewed by the DOE, and it was determined that no significant
changes to the remedy were necessary.
15
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PARTS
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
3.1 Responsiveness Summary Introduction
The responsiveness summary has been prepared to meet the requirements of Sections
113(k)(2)(b)(iv) and 117(b) of the CERCLA as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), which requires the DOE as "lead agency" to
respond "...to each of the significant comments, criticisms, and new data submitted in
written or oral presentation" on the WAG 17 Proposed Remedial Action Plan (PRAP).
The DOE has gathered information on the types and extent of contamination found and
recommends no further action. As part of the remedial action process, a notice of
availability regarding the PRAP was published in The Paducah Sun, a major regional
newspaper of general circulation. The Proposed Remedial Action Plan for Waste Area Group
17 at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/06-1566&D2,
was released to the general public July 26, 1997. This document was made available at
the DOE's Environmental Information Center in the West Kentucky Technology Park in
Kevil, Kentucky, and at the Paducah Public Library. A 45-day public comment period
began July 26, 1997, and continued through September 8, 1997. A public meeting was
held August 26,1997, at which time the DOE presented information pertaining to WAG
17 to the public and responded to questions. Specific groups that received individual
copies of the WAG 17 PRAP included the Natural Resource Trustees and the Site
Specific Advisory Board.
Public participation in the CERCLA process is required by the SARA. Comments
received from the public were considered in the selection of the remedial action for the
site. The responsiveness summary serves two purposes: to provide the DOE with
information about the community preferences and concerns regarding the remedial
alternatives and to show members of the community how their comments were
incorporated into the decision-making process.
3.2 Community Preferences/Integration of Comments
COMMENT: "On page four of the Proposed Remedial Action Plan for Waste Area Group 1 7
at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky (DOE/OR/06-1566&D2), it
says 'A portion of the soil was excavated, plac d in containers, and transported to a
secured waste management area at the Paducah Gaseous Diffusion Plant. By removing
detected contamination, the Department of Energy has reduced the risk to an acceptable
level at Area of Concern 124.' How can that reduce the risk to put it into Waste
Management, when Waste Management has been rated as the highest risk at the
facility?"
RESPONSE: The text accurately states the risk at Area of Concern (AOC) 124 has been
reduced. This AOC is located outside the DOE security fence and could be accessed by
the general public. The Department of Energy (DOE) has determined that off-site current
and future risk is a priority for cleanup. The soil that was placed in Waste Management
is securely stored and monitored in accordance with the appropriate regulations and
requirements. The Waste Management facility is listed as a top priority for
programmatic planning based on several factors and not risk alone.
17
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COMMENT: "If the agency followed every procedure in the standard operating
procedures for determining the 'no further action' finding then it could be justified.
However, if any of the procedures for making this determination, such as strictly
following all guidance for scanning for radionuclides, are not adhered to, then this
determination is questionable."
RESPONSE: The Department of Energy followed and aulieixd to the standard operating
procedures as referenced in the Resource Conservation and Recovery Act Facility
Investigation/Remedial Investigation Report for Waste Area Grouping 17 at the Paducah
Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/07-1404&D2.
COMMENT: "The commentors continue to believe that a site-wide Environmental
Impact Statement (EIS) is required under the National Environmental Policy Act
(NEPA). Separating these individual projects without considering the cumulative effects
of all projects at the site violates the spirit and letter of the NEPA."
RESPONSE: Under the draft Federal Facility Agreement, final action decisions for
integrator units will be addressed as part of the comprehensive site operable unit
(CSOU). The CSOU study will include baseline risk assessments that will evaluate the
impacts of any cumulative risks being contributed to the integrator units by sources. The
baseline risk assessment for the CSOU will include a human health risk assessment
conducted in conjunction with the Ground Water Integrator Unit [i.e., Waste Area Group
(WAG) 26] and an ecological risk assessment and human health risk assessment
conducted in conjunction with the Surface Water Integrator Units (i.e., WAG 18 and
WAG 25) according to the Site Management Plan, Paducah Gaseous Diffusion Plant,
Paducah, Kentucky, DOE/OR/07-1207&D3).
National Environmental Policy Act values were incorporated into the WAG 17
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
documents, pursuant to DOE's 1994 Secretarial Policy on NEPA and DOE Order 450.1.
The Secretarial Policy states that "DOE will hereafter rely on the CERCLA process for
review of actions to be taken under CERCLA and will address NEPA values and public
involvement procedures as provided...."
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DISTRIBUTION
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DISTRIBUTION
U.S. DEPARTMENT OF ENERGY KENTUCKY DEPARTMENT OF
Myrna Redfiela
U.S. Department of Energy
P.O. Box 1410
Paducah, KY 42001
Nancy Games, CC-10
U.S. Department of Energy
Turnpike Building-U&L
55 Jefferson Circle
Oak Ridge, TN 37830
Jimmie C. Hodges (3 copies)
U.S. Department of Energy
P.O. Box 1410
Paducah, KY 42001
Paul A. Hofmann
U.S. Department of Energy
3 Main Street
Oak Ridge, TN 37830
K. Kates, AD-424
U.S. Department of Energy
Chinn I Building
167 Mitchell Road
Oak Ridge, TN 37830
Anthony A. Sims, CE-524
U.S. Department of Energy
Maxima Building
107 Union Valley Road
Oak Ridge, TN
;y Koat
37830
Robert C. Sleeman, EW-91
U.S. Department of Energy
Information Resource Center
3 Main Street
Oak Ridge, TN 37830
James W. Wagoner
EM-421
Quince Orchard
U.S. Department of Energy
19901 Germantown Road
Germantown, MD 20874-1290
EPA
CarTR. Froede, Jr. (5 copies)
US. EPA, Region 4
61 Forsyth Street
Atlanta, GA 30303
JACOBS ENGINEERING
GROUP INC.
Don J. Wilkes (2 copies)
Jacobs Engineering Group Inc.
175 Freedom BlvcT
Kevil, KY 42053
SYSTEMATIC MANAGEMENT
SYSTEMS
W. F. Redfield
U.S. Department of Energy Site Office
5600 Hobbs Road
West Paducah, KY 42086
FISH AND WILDLIFE
Wayne Davis
Environmental Section Chief
KY Department of Fish and Wildlife
Resources
#1 Game Farm Road
Frankfort, KY 40601
LOCKHEED MARTIN ENERGY
SYSTEMS, INC
Patricia A. Gourieux (3 copies)
Lockheed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053
Jimmy C. Massey
Lockneed Martin
761 Veterans Ave.
Kevil, KY 42053
Energy Systems
K. L. Holt (2 copies)
Lockheed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053
NATURAL RESOURCE
TRUSTEES
Alex Barber
Commissioner's Office
KY Dept. for Environmental
Protection
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601
Abraham Loudermilk
Tennessee Valley Authority
400 W. Summit Hill Drive
Knoxville, TN 37902
Andrea B. Perkins
U.S. Department of Energy
Information Resource Center
3 Main Street
Oak Ridge, TN 37830
Allen Robison
U.S. Department of Interior
Fish and Wildlife Service
446 Neal Street
Cookville, TN 38501
STATE OF KENTUCKY
Robert H. Daniell, Director
Division of Waste Management
KY Dept. for Environmental
Protection
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601
Tuss Taylor (4 copies)
UK/KDEP
18 Reilly Road
Frankfort Office Park
Frankfort, KY 40601
Todd Mullins
KY Division of Waste Management
U.S. Department of Energy Site Office
5600 Hobbs Road
West Paducah, KY 42086
TVA
Ted Whitaker
Plant Manager
Shawnee Fossil Plant
7900 Metropolis Lake Road
West Paducah, KY 42086
Janet Watts
Manager of Environmental Affairs
5D Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
Barry Walton
Office of General Council WT-10A
400 W. Summit Hill Dr.
Knoxville, TN 37902
U.S. ENRICHMENT
CORPORATION
David Hutcheson
U.S.E.C.
P.O. Box 1410
Paducah, KY 42001
U.S. GEOLOGICAL SURVEY
Martin Rose
U.S. Geological Survey
2301 Bradley Av, >
Louisville, KY 40217
WEST KY WILDLIFE
MANAGEMENT AREA
Matt Vick
Paducah Gaseous Diffusion Plant
Hobbs Rd., C-730-T2
Paducah, KY 42002
i:r,.in 97.27
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