PB97-964028
EPA/541/R-97/210
February 1998
EPA Superfund
Record of Decision:
Oak Ridge Reservation (USDOE) OU 14
Oak Ridge, TN
9/24/1997
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DOE/OR'C2-1630&D2
Record of Decision
for the Surface Impoundments Operable Unit,
Oak Ridge National Laboratory,
Oak Ridge, Tennessee
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DOE/OR/02-1630&D2
Record of Decision
for the Surface Impoundments Operable Unit,
Oak Ridge National Laboratory,
Oak Ridge, Tennert:ee
Date Issued—September 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 Surface Impoundments Operable Unit,
Oak Ridge National Laboratory. Oak Ridge. Tennessee (DOE/OR/02-
1630&D2) was prepared in accordance with leqr'ren.ents under the
Com. 'eh->nsi' =: Environmental Response. Compensator., and Liability
Act of 1980 to present the selected remedy for the Surface
Impoundments Operable Unit (SIOU) to the public. This work was
performed under Work Breakdown Structure 1.4.12.6.1.01 (Activity
Data Sheet 3301, "ORNL WAG 1"). This document provides
information about the selected remedy, which includes removal of
surface water and sediments within the SIOU; construction of treatment
facilities; treatment of the sediments, as required to meet disposal facility
waste acceptance criteria; containerization of treated waste; and transport
of all treated waste to Envirocare of Utah, the Nevada Test Site, or other
appropriate facilit.es. This document also relies on information from the
remedial investigation/feasibility study (DOE/OR/02-1346&D2). the
proposed plan (DOE/OR/01-1427&D3/R1), and an engineering support
study (X-OE-791).
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ACRONYMS AND ABBREVIATIONS
Am
ARAR
CERCLA
CPH
Ci
Co
Cs
DOE
DOT
EIS
Envirocare
EPA
FFA
PS
ft
ha
km
LDR
m
M&I
mrem
NCP
NEPA
NPDES
NTS
O&M
ORNL
ORR
ORREMSSAB
OU
ppm
PWTP
Pu
RCRA
rem
RFP
RJ
ROD
SIOU
Sr
TDEC
TSCA
amenc-joi
applicable or relevant and appropriate requirement
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980
Code of Federal Regulations
curie
cobalt
cesium
U.S. Department of Energy
U.S. Department of Transportation
environmental impact statement
Envirocare of Utah, Inc.
U.S. Environmental Protection Agency
Federal Facility Agreement
feasibility study
foot
hectare
kilometer
land disposal restriction
meter
management and integration
millirem
National Oil and Hazardous Substances Pollution Contingency Plan
National Environmental Policy Act of 1969
National Pollutant Discharge Elimination System
Nevada Test Site
operation and maintenance
Oak Ridge National Laboratory
Oak Ridge Reservation
ORR Environmental Management Site Specific Advisory Board
operable unit
polychlorinated biphenyl
parts per million
Process Waste Treatment Plant
plutonium
Resource Conservation and Recovery Act of 1976
roentgen equivalent man
request for proposal
remedial investigation
record of decision
Surface Impoundments Operable Unit
strontium
Tennessee Department of Environment and Conservation
Toxic Substances Control Act of 1976
JTIAUUV'O' 1MI. CJE
III
Sepiemhcr 15.
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ACRONYMS AND ABBREVIATIONS (continued)
USC United States Code
VVAC wa1 e;-..vi:e criteria
yd yard
i-ir i Ml. CJi: jv Scpcmhcr I?
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PARTI. DECLARATION
'+.i~n~ IMLCJE . Scp
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SITE NAME AND LOCATION
U.S. i^r—iment of I -rgx.
Oak Riclge Reservation
Surface Impoundments Operable Unit
Oak Ridee National Laboratory
Oak Ridge, Tennessee
STATEMENT OF BASIS AND PURPOSE
This record of decision (ROD) presents the selected remedial action for the Surface
Impoundments Operable Unit (SIOU) on the U.S. Department of Energy (DOE) Oak Ridge
Reservation (ORR) in Oak Ridge. Tennessee. The action was chosen in accordance with the
Comprehensive Environmental Response. Compensation. an.J L,ability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of 1986. 42 United States
Code (USC) 9601 et seq. and. to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
This decision is based on the administrative record for SIOU, including the remedial
investigation (RI)/feasibility study (FS) (DOE 1995), proposed plan (DOE I997a), the
engineering support study (Energy Systems 1996), and other documents for this site.
DOE is the lead agency for this action. The U.S. Environmental Protection Agency
(EPA) and the Tennessee Department of Environment and Conservation (TDEC) are supportive
agencies as panics of the Federal Facility Agreement (FFA) for this response action. EPA and
TDEC concur with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from SIOU, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
11 ••>*«-«i- I Ml. CJI 1_2 NepwrnN.-! 15 !•*'•
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DESCRIPTION OF THE SELECTED REMEDY
This response action fits into the overall ORR cleanup strategy by addressing treatment
and removal of contaminated sediment, water, and incidental soils at SIOU. The selected remedy
addresses the principal threats to industrial workers and mitigates the release of contamination
to groundwater by (1) removal of the sediments from SIOU ap.d C2) transport of all treated waste
to an approved disposal facility [e.g., Ntr. ~Ja Test Sue (NTS) and Envirocare of Utah. Inc.
(Envirocare)J. The selected remedy, which is Alternative 6 in the FS and the proposed plan and
is described in Pan 2 of this ROD, includes (1) removal of surface waters, sediments, and
approximately 0.03 m (0.1 ft) of subimpoundmem soil within SIOU; (2) discharge of surface
water to the existing Process Waste Treatment Plant (PWTP); (3) treatment of sediments to meet
applicable or relevant and appropriate requirements (ARARs) and disposal facility waste
acceptance criteria (WAC); (4) containerization of the treated wastes; and (5) transport of treated
waste to appropriate waste disposal facilities and disposal therein. The remedy calls for wastes
other than those characterized as polychlorinated biphenyl (PCB) waste to be disposed of at NTS
or another appropriate facility.
The remedy calls for wastes characterized as PCB waste to be treated to a level equivalent
to destruction by incineration (< 2 ppm PCS/ before off-site disposal at Envirocare. EPA is
promulgating a revision to the Toxic Substances Control Act of 1976 (TSCA) PCB disposal
regulations, which may impact the requirements for this action at Impoundments C and D.
Should 40 Code of Federal Regulations (CFR) 761 be revised to offer other options in the
handling, treatment, and disposal of PCB wastes, alternate endpoints in compliance with the new
regulation will be documented and used, as appropriate. Concurrence from EPA and TDEC will
be obtained before altering the selected remedy to follow the revised regulation, if promulgated.
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 to the remedial
action, and is cost-effective. This remedy uses permanent solutions and alternative treatment or
resource recovery technologies to the maximum extent practical and satisfies the statutory
preference for remedies that reduce toxicity, mobility, or volume as a principal element.
The selected remedy effectively addresses the contaminant source* that are included in the
scope of the action for SIOU and, on completion of the remedial action, no additional studies or
JT'«>1<«-07 IML CIF. J-3 Sepxrmher 15. 1-W
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reviews will be required under this ROD to ensure that the remedy for SIOU surface water and
sediment continues to adequately protect human health and the environment. While sources
within the scope of the SIOU are addressed, it is recognized that the surface impoundments are
within an industrial complex with other sources of contamination and impacted environmental
media, including contamination in groundwater and surface soils within the boundaries of SIOU.
The Bethel Valley watershed decision-making process, which includes the surface impoundments
area, will address residual contamination at the site
JT'JO.KN'07 IML.CIt 1-4 Sepiemher 15. IW
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APPROVALS
Rodney R. Nelson, Assistant Manager
U.S. Department of Energy
Oak Ridge Operations
Date
Earl C. Leming, Director
U.S. Department of Energy Oversight Division
Tennessee Department of Environment and Conservation
Date
\
Richard D. Green, Acting Director
Waste Management Division
U.S. Environmental Protection Agency—Region 4
Date
JTO&W707 IML/CJE
1-5
September 15.
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PART 2. DECISION SUMMARY
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SITE NAME, LOCATION, AND DESCRIPTION
Figure 2.1 shows ORR in Anderson and Roane Counties near the city of Oak Ridge in
East Tennessee, approximately km (20 miles) northwest of Knoxville, Tennessee. The
reservation comprises 14.300 ha (35,300 acres) of federally owr.ed land and houses three major
installations -th^ Oak PMge National Laboratory (ORNL), tlu- Oak Ridge Y-12 Plant, and the
East Tennessee Technology Park (formerly the Oak Ridge K-25 Site or Oak Ridge Gaseous
Diffusion Plant).
ORNL is subdivided into various watersheds. SIOU is in the Bethel Valley watershed and
consists of Impoundment A (3524), Impoundment B (3513), and Impoundments C and D (3539
and 3540). SIOU is in the south-central pan of ORNL's main plant area, north of White Oak
Creek (Fig. 2.2).
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The impoundments were used to manage low-level radioactive liquid wastes generated
from experiments and material processing at ORNL. Sediments are radiologically and chemically
contaminated. Impoundments A and B are unJined and release contaminants to the environment
as a result of groundwater intrusion. Water covering the sediments in these two impoundments
provides radiation shielding and prevents airborne release of sediments. Impoundments C and
D are clay-lined, not in contact with groundwater, and are not known 'o be leaking. Other
sources in Bethel Valley also contribute to groundwater contamination, which could continue to
contaminate surrounding soils after remediation of the impoundments.
The primary chemicals of concern identified in the SIOU sediments are mercury and
PCBs. The principal radionuclides of concern and their estimated activity (in curies) are 24lAm
(3), IJ7Cs (133), MCo (1), U8Pu (< 1), ^'Pu (7), and *>Sr (36).
IMPOUNDMENT A (3524)
Impoundment A was excavated in natural clay in 1943 and used for short-term storage of
wastewater and final precipitation of radioisotopes before discharge to White Oak Creek. This
impoundment initially consisted of two unlined impoundmev ts separated by a berm. In the early
1950s, the berm separating the impoundments was removed, forming one impoundment that
received process wastewater only. From 1949 to 1957, effluent from Impoundment A was
rrooww: IML/CJE 2-2 s^picmixr i?. iw
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DOE Oak Ridge Reservation id vicinity
MODIFIED FROM DOE 1993
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Surface Impoundments Operable Unit
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nuinped to Impoundment B (3513). In 1957, the PVVTP was placed on line; Impoundnu..t .\ was
used as an equalization basin for intermediate storage and collection of process wastewater for
the treatmei.. lam until 1989. Impoundment A was used re-:.'ntly as an em Tgency storage basin
for overflow from the process wastewater storage tanks duri.ig storms. This impoundment is no
longer needed for overflow because a surge tank installed in June 1996 provides adequate storage
capacity.
Impoundment A contains approximately 1,100 m3 (1,400 yd1) of low-Ievei radioactive
sediment. The sediment is not hazardous waste as defined by the Resource Conservation and
Recovery Act of 1976 (RCRA), and PCB levels are < 50 ppm.
IMPOUNDMENT B (3513)
Impoundment B was excavated in natural clay in 1944, is unlined, and was used as a
settling basin for low-level radioactive waste streams that were diluted with process wastewater.
From 1944 to 1947, excess water in the impoundment flowed through pipes on the
impoundment's southern berm directly into White Oak Creek. These pipes were plugged in
1947. From 1957 to 1976, Impoundment B received waste that did not require treatment in
PWTP. Wastewater from PWTP was also discharged into the impoundment to allow particulate
settling. The impoundment has not been used since 1976. Over the past few years, seeps
through the southern berm of this impoundment have discharged to White Oak Creek.
Temporary corrective actions have been implemented to mitigate this problem until a final remedy
for the impoundments is completed.
Impoundment B contains approximately 2,400 m3 (3,160 yd3) of low-level radioactive
sediment. The sediment is not RCRA-hazardous waste, and PCB levels are < 50 ppm.
IMPOUNDMENTS C AND D (3539 AND 3540)
Impoundments C and D are compacted clay-lined impoundments built in 1964 to receive
process wastewater from Building 4500. Historically, if contaminant levels were acceptable the
process waste was discharged into White Oak Creek after verification of radionuclide content and
pH adjustments of water in the ponds. Wastewater from Building 4500 exceeding acceptable
limits was pumped to Impoundment A (3524) before treatment at PWTP. Impoundments C and
D were taken out of service in 1990 but were available for overflow from the process wastewater
storage tanks during storms until the new surge tank was installed in 'une 1996.
IML.CIf: 2-5 September 15.
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Impoundments C and D contain < 30 m3 (40 yd3) ol sediment with very low levels of
radioactive contamination (0.3 Ci). PCB levels are between 50 and 500 ppm. Further
characterization is needed to confirm whether the waste meets the definition of RCRA-hazardous
waste. Details of the sampling and characterization plan will be approved by TDEC and EPA.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
DOE issued the proposed plan for SIOU June 30, 1997. DOE published a public notice
about the project in The Knoxville News-Sentinel, The Roane County News, and The Oak Ridger
June 30, 1997, and set a public comment period from June 30. 1997 to July 30, 1997. DOE held
a public meeting March 30, 1995, to provide information about SIOU. A public meeting
July 15, 1997. presented the preferred alternative described in the proposed plan and solicited
public input. All public comments on the proposed plan are identified and addressed in the
"Responsiveness Summary" section of this ROD.
PROJECT SCOPE AND SUMMARY OF SITE CHARACTERISTICS
The purpose of this project is reduction of risk by cleanup and remediation of the four
surface impoundments. Media specifically included in the scope of this project are the surface
water and sediment in the impoundments that resulted from liquid waste treatment. Incidental
soil that may be encountered during sediment and water remediation will be handled
appropriately. Groundwater and surface soils within the boundaries of SIOU will be specifically
addressed under the Bethel Valley watershed ROD.
For remediation options involving waste removal or relocation on site, DOE anticipates
that the impoundments will be excavated to 0.03 m (0.1 ft) below the as-built elevation of the
floor of the impour^r"»nt excluding bedrock and riprap. D ,Kths of subimpoundment soil removal
will be developed in the remedial action work plan. Sediments and surface water are the media
of concern at SIOU and account for more than 95 percent of the site contamination. Excavation
of the sediment and an additional 0.03 m (0.1 ft) of the natural or compacted subimpoundment
clay will ensure that the remedial action objectives have been met, releases from SIOU
contaminant sources will be minimized, and risks resulting from these releases will not exceed
acceptable levels in nearby surface waters of White Oak Creek.
/TOl\io>)T07 IML-CJE 2-6 S^picmher 15. IW
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Table 2.1 provides a summary of Contaminant concentrations and sediment volumes in the
impoundments. Other site characteristics are provided under "Site History and Enforcement
Activities."
SUMMARY OF SITE RISKS
The risk assessment presented in Chapter 3 and Appendix C of the Rl/FS contains a
detailed discussion of site risks. Ecological and human health risk summaries follow.
ECOLOGICAL RISKS
The ecological risk assessment evaluated risks to aquatic (such as fish) and piscivorous
(fish-eating, such as raccoons and birds) wildlife receptors. Risk and hazards were calculated at
likely exposure locations using current contaminant concentrations, and contaminant
concentrations were modeled for future conditions. Estimated contaminant concentrations were
compared to acceptable wildlife exposure levels based upon National Ambient Water Quality
Criteria.
In the RI, exposures of wildlife receptors in the impoundments were clearly unacceptable.
Exposure levels are exceeded for aquatic receptors in White Oak Creek and White Oak Lake,
although exposures are not completely due to contamination originating from SIOU. The SIOU
contribution to ecological risk is reduced because leaks are controlled in the Impoundment B
berm.
HUMAN HEALTH RADIOLOGICAL RISKS
Radiation levels in the sediments ai SiOU are extremely hazardous. Without the water
cover on Impoundments A and B providing shielding from radiation, an industrial worker on the
bank of an impoundment would receive the maximum allowable annual occupational dose of
5 rem in approximately 100 hours from direct exposure to gamma radiation. In addition, if the
sediments dried up and became airborne, inhalation of '.Ipha-emitting radionuclides, including
Plutonium and americium, would greatly increase the risk of lung cancer over a widespread area.
DOE mandates institutional controls to ensure regulatory compliance for exposures to on-
site individuals and to prevent long-term direct contact with the sedimen's, which would result
in a near certain probability of cancer. Radiological risks to future on-site employees and
residents were evaluated, assuming 5 days during which the water cover over Impoundment A
IML.OE 2-7 September 15. i-w
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Table 2.1. Site characteristics at SIOU, ORR, Oak Ridge, Tennessee
'-en* A
Tmpoun
ats
CandD
Radioactive COCs
:4'Am
l37Cs
MCo
»'Pu
:":40Pu
*>Sr
Primary chemical COCs
Mercury
PCBs
Sediment volume (yd3)
Average (pCi/g dry)
16,000
210.000
3,000
1,100
17.000
91.000
Mean (mg/kg)
396
35
1.400
Average (pCi/g dry)
4.2GO
450.000
1,300
630
19,000
73.000
Mean (mg/kg)
340
41
3.163
Average (pCi/g dry)
< 270
54
5
0
93
96
Mean (mg/kg)
760
180
< 40
Am = amehcium
Co = cobalt
COC = contaminant of concern
Cs = cesium
g = gram
kg = kilogram
< = less than
mg = milligram
ORR = Oak Ridge Reservation
PCB = polychlorinated biphenyl
pCi = picocurie
Pu = plutonium
SIOU = Surface Impoundments Operable Unit
Sr = strontium
yd = yard
(3524) is lost. Risks to on-site employees and residents, primarily from direct external exposure
to gamma radiation from the unshielded sediments, would range up to 8 x 102 and 2 x 10"',
respectively (i.e., 8 in 100 and 2 in 10 additional cases of cancer over those expected under
natural conditions). These risks greatly exceed the EPA target risk range of 1 x 10"* to 1 x 10*
(i.e., 1 in 10,000 to 1 in 1 million additional cases of cancer over those expected under natural
conditions).
Potential future off-site residents would also have unacceptable risks from radioactive
contaminants should institutional controls be lost. For these receptors, the main risk is inhalation
of windblown particulates derived from the sediments, assuming the sediments dry out for a S-day
period. The risks range up to 7 x 10J for receptors at White Oak Creek and 5 x 103 for
receptors at White Oak Dam and Clinch River (i.e., 7 in 1,000 and 5 in 1,000 additional cases
IML/OE
2-8
Sepconher 15. IW7
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of cancer over ihose expected under natural conditions). Sufficiently conservative assumptions
were used to estimate these risk levels; it is very unlikely that the risks are underestimated.
If uncontrolled, the principal, short-lived radionuclides of concern (""Sr, l37Cs. and *°Co)
would be expected to present unacceptable risks for hundreds of years. The principal long-lived
radionuclides of concern (^'Pu, B9Pu, and y'Am) would present un?cceptable risks for thousands
01' years or more.
HUMAN HEALTH CHEMICAL RISKS
Risks to current and future on-site employees from heavy metals and organic chemical
carcinogens were calculated to be acceptable, as were risks to future residents beyond the current
DOE boundary at Clinch River near White Oak Creek.
Based on the resi.its of modeling contaminant migration una:• ?p:able risks were estimated
for future residential use of surface water by receptors at White Oak Creek (2 x 103) and at
White Oak Dam (8 x 104) (i.e., 2 in 1,000 and 8 in 10,000 additional cases of cancer over those
expected under natural conditions).
Chemical carcinogenic risks calculated for the exposure scenarios were always less
significant than radiological risks in all scenarios. For example, the maximum chemical risk
calculated was 2 x 103 for future on-site residents, compared to a radiological risk of 2 x 10'
for the same exposure scenario (i.e., 2 in 1,000 and 2 in 10 additional cases of cancer over those
expected under natural conditions). Actions taken to reduce radiological risk would effectively
reduce chemical risk.
DESCRIPTION OF ALTERNATIVES
Alternatives were developed in Chapters 4 and 5 and Appendix D of the RI/FS to achieve
the following remedial action objectives:
• prevent direct exposure to, direct contact with, and inhalation or ingestion of
contaminated sediments by humans and animals;
• prevent movement of contaminants to groundwater and f"-face water;
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• control failure of the impoundments' berms and embanki.ients; and
• H. vent the bioaccumulation of contaminants in .-cological receptors.
The alternatives evaluated in the FS ranged from no action to complete removal of
contaminated sediments with off-site disposal. The alternatives were screened, based on
f.ffectivene's, impL..>ci.:abii'ty, and cost, x develop a shorter list of alternatives for detailed
analysis. The final alternatives retained for detailed development and analysis in the FS include
the following:
• Alternative 1—no action
• Alternative 2—multilayer cap and institutional controls
• Alternative 3—consolidation cell with simple dewatering
• Alternative 4—consolidation cell with ex situ treatment
• Alternative 5—off-SIOU consolidation cell
• Alternative 6—removal, treatment, and disposal
After the FS for SIOU was issued, an engineering support study (Energy Systems 1996)
was performed and additional characterization information was obtained. These data were
incorporated into the alternatives discussed in the proposed plan. EPA, TDEC, and DOE agreed
that only three alternatives warranted detailed discussion in the proposed plan. They are
Alternative 1—no action. Alternative 3—on-site consolidation cell, and Alternative 6—removal,
treatment, and disposal.
All alternatives assume that all water removed from the impoundments would be treated
at the existing PWTP. Natural disasters such as earthquakes, floods, and tornados are considered
in the design for all alternatives except the no action alternative.
The radiuuviivity levels of the sediment in the impoundments require that remedial design
(1) protect workers from exposure to gamma radiation and (2) contain sediment to prevent
airborne releases of alpha-emitting radionuclides. Engineering controls (such as ndhtion
shielding, double-contained piping, and remotely operated equipment) and operational controls
(such as establishing contamination zones, providing high levels of personal protective equipment,
restricting access to only qualified and necessary personnel, monitoring exposures, and
monitoring and controlling processes) were included for each alternative to address radiation
hazards.
IMI..CIE 2-10 Stpicmlxrr 15
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Following are descriptions of the six alternatives considered in the RI/FS. The costs are
revisions to the initial estimates in the RJ/FS developed nearly 3 years ago. These costs were
reviewed and updated before is«:'iing the proposed plan J"ne 30, 1997. On Jni '7 1997, DOE
released the request for proposal (RFP) for the management and integration (M&I) contract. 1 ne
ROD cost estimates have been revised to reflect the M&I contract approach. Detailed cost
estimates from the proposed plan and this ROD are available at the Information Resource Center,
105 Broadway Avenue. Oak Ridge, Tennessee, to suj'ixr. the cost ahown for Alternatives 1, 3.
and 6. Alternatives 2, 4, and 5 were not analyzed in detail in the proposed plan; costs for these
alternatives have been modified for consistency, but a less detailed analysis has been performed.
ALTERNATIVE 1-NO ACTION
Total capital cost: SO million
Present value of capital cost: SO million
Time to implement: 0 years
Annual operation and maintenance (O&M) cost, years 1-30: SI67,000
Present value of total O&M cost: SI.82 million
Alternative 1 assumes that existing institutional controls are maintained for a reasonable
period (e.g., 30 years). These controls include restricting access to contaminated areas with
fences and guards, establishing and marking radiation areas, training workers, training or
escorting visitors, monitoring radiation levels at the impoundments, monitoring exposure to each
employee and visitor, and maintaining water cover on the impoundments for shielding and
containment of the sediments. After this period, the site is assumed to be abandoned. This
alternative makes no new provisions for containment, removal, treatment, or disposal of wastes.
Unacceptable risks are present at all receptor locations considered after loss of institutional
controls.
The no action alternative does not meet the remedial action objectives or CERCLA
requirements for protection cf human health and the environment.
ntOW-07 IMl. OK ' 2-11 Sepcmber 15.
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ALTERNATIVE 2—MULTILAYER CAP AND INSTITUTIONAL
CONTROLS
Total capita! cost: 56.12 million
Present value of capital cost: S5.28 million
Time ro implement: 1.75 years
Annual O&M cost, years 1.75-30: S77.000
Present value of total O&M cost: 5586,000
Alternative 2 proposes installation of a multilayer cap over the impoundments to prevent
airborne contamination and direct exposure. Institutional controls would limit access to
groundwa:er. White Oak Creek, and White Oak Lake to control exposure to contaminants
released from SIOU. Surface water in the impoundments, which would be removed during cap
installation, would be treated at the PWTP. Releases of contamination to grounduater and
eventually to surface water would continue.
This alternative does not meet the remedial action objective of preventing movement of
contaminants to groundwater and surface water. It would not meet some ARARs, and waivers
for those ARARs would not be justifiable.
ALTERNATIVE 3—ON-SITE CONSOLIDATION CELL
Total capital cost: 512.4 million
Present value of capital cost: 510.2 million
Time to implement: 4 years
Annual O&M cost, years 5-30 586,000
Present value of total O&M cost: 5554,000
Alternative 3 includes constructing an engineered consolidation cell at Impoundment A
(3524) and consolidating the sediment from all impoundments into the cell. Surface water from
the impoundments and leachate collected from the consolidation cell would be discharged to
PWTP. Approximately 0.03 m (0.1 ft) of subimpoundment soil would be removed from all
impoundments (see "Project Scope and Summary of Site Characteristics") and placed in the
consolidation cell. This alternative meets all remedial action objectives and would isolate the
wastes sufficiently to protect human health and the environment. Fedeial institutional controls
at the consolidation cell site would be required indefinitely because chemical constituents in the
IML.CJE 2-12 Seixemhcr I5.
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waste would remain hazardous forever and some radioactive constituents tamer:' ;um and
plutonium) have half-lives of thousands or tens of thousands of years.
To develop the consolidation cell, the waste from Impoundments C and D would be
transferred to Impoundment B, and Impoundments C and D would be filled to provide a staging
area for remediating the large impoundments. The waste in Impoundment A would be transferred
to Impoundment B. The bottom liner of the consolidation cell .th •: ieachate collection/detection
system would be installed in the empty Impoundment A.
All the sediment in Impoundment B—which would also store waste from Impoundments
A, C, and D—would be transferred to the consolidation cell. A temporary cap would be placed
over the waste. After the waste is dewatered through the leachate collection system and no
further settlement is expected, a final cap would be installed.
The consolidation cell would be inspected and maintained on a regular basis. Institutional
controls would prohibit industrial use of the surface of the consolidation cell, although access to
the cap for recreational activities would be permissible. No activities that disturb the cap (e.g.,
underground utilities, building foundations, etc.) would be allowed. No institutional controls on
the remainder of the S'te would be needed for contamination within the scope of SIOU. Residual
contamination on the remainder of the site would be addressed in the Bethel Valley watershed
ROD.
Additional detail can be found in Section 5.2.3 of the RI/FS. Figure 2.3 is a cross section
of the consolidation cell during different phases of construction and operation.
Alternative 3 would require a CERCLA waiver from the TSCA requirement that PCB
wastes be disposed of at least 15 m (50 ft) above the high water table [40 CFR 761.75(b)(3)].
TSCA regulations do not specify the permeability of the media between the waste and the water
table. The proposed compacted clay liner for Alternative 3 would retard migration of PCBs more
effectively than most unconsolidated soils. The proposed combination of a clay liner with a
leachate collection/detection system and a geomembrane liner would provide even greater
protection. A waiver would be justified based on equivalent piotectiveness provided by the liner.
Alternative 3 would comply with all other ARARs.
(Tl»*>J707 1ML. CIE 2-13 Scfxcmber 15. IW
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flEVAIlON
If I MSU
800
STEP J CONSOLIDATED SEDIMENT, CONTAMINATED SOIL, FINAL CAP
SEE OETAii C
STEP 2 UNCONSOUUAIH) yOlMLNT IEMPORARY CAP
.SEE DEI AH D
SufffACf
coNraoi
ORfDCm,: Of'/H* nu.v
/Vt Cl 1 • I'ON I A Yf II
\
FINAL MICH
GHOUNOWAIfR
fXlStlNG HIGH
GHOUNDWAIFn
OESlGN OEIAIlS ARE PHELMMART MOD4f 1C AI lOMS 1O lUPflOVE
CQNSrnuCTAB^iTv on Et'tcnvCxcss on 10 RfDuCE COST
ARE EXPECIED OufliNC REMCOlAl DESIGN
POND 3524
Detail C
Detail
tROSIOM POOIICI'ON
VECI IAHON IATER IJ f I MMI
DRAIN MATERIAL II FT MINI
GEOMEMBRANt
ClAV INFnlRAIlON BARRiCR I] FT MINI
AMiNAlEO SOU RfCONTOuPED IOPHONAII —
POBOUj F'll I) (I MINI-
FulER FABRIC AND CEOCRiO COMPOSITE —
10 AND SO*. SCMltO-
HORIZONTAL SCALE IN FEET
VERTICAL EXAGGERATION 7X
POND 3513
SlUOGt
FH ItR fABRC
SAND »XO COUEC'ORfltACn'IE COUlCHON SISIIM
PiPf S 16 « ««NI )
CEOUIHBRANE |PR|UAR< MNfRI 1
rAND »«0 CiNIEH COllECtOO PiPC <
6 IN UlN I
C(OD°«'N
CfOMtMBIIANt IS(CONOAnv I IN- 11}
Cl AV lINf H
l|(»r.H»ll Ol IK.I.ON iT-.UM
,'. .•..'.:'.': • .'•'• •'.'•;'.'.'.' •''.'••'. .'..' .. VrT~
V"*-••-..•--•';••• •'/*.' _t '.•*/
- OMPACIEO RANDOM FKl
-CEOMEMBRANE
CONTAMINATED SURFACE SOU IIF ANTI
TAMlNAtCD SOLlOS/POROUS "U )
OEOCRiO COMPOSITE \~
F» TH FABRIC I
SfOiMlM AND SOU SlURRT
Fig. 2.3
Alternative 3 section - liner, placement of wastes.
temporary cap, and final cap
DOE ORNL. SuiUct Imoounomcnn • Olfc HiOpe Icnfei^t -
OOCUXI-"! O )»M»)0
oo
-------
ALTERNATIVE 4—CONSOLIDATION CELL WITH EX SITU
TREATMENT
Total capital cost: S33.9 million
Present value of capital cost: S25.9 million
Time to in-plement: 4 years
Annual O&M cost, years 5-30: 582,000
Present value of total O&M cost: S532.000
Alternative 4 would add an ex situ treatment step to the operations proposed for
Alternative 3. After transfer of all sediment into Impoundment B and construction of the
consolidation cell liner in the empty Impoundment A, waste would be solidified in a new
treatment facility similar to the facility described in Alternative 6. After curing in forms, the
solidified waste would be moved into the consolidation cell and the cell would be capped.
Alternative 4 was not addressed in detail in the proposed plan because it is substantially
similar to Alternative 3 with treatment (solidification) incorporated. This treatment would be
similar to the solidification process described for Alternative 6. As for Alternative 3, Alternative
4 would need a waiver from TSCA siting criteria. If wastes from Impoundments C and D are
determined to be hazardous under RCRA regulations, additional waivers could also be needed
depending on the results of engineering support studies regarding the effectiveness of the
treatment process.
ALTERNATIVE 5—OFF-SIOU CONSOLIDATION CELL
Total capital cost: $16.0 million
Present value of capital cost: S12.6 million
Time to implement: 3.5 years
Annual O&M cost, years 3.5-30: 579,000
Present value of total O&M cost: $532.000
Alternative 5 is the same as Alternative 3, except that the disposal cell would not be at the
SIOU site in the main area of ORNL. The location assumed in the FS is at ORNL near the
Process Waste Sludge Basin, one of several small impoundments with similar wastes that could
also be consolidated in the cell. Sediment would be removed from the impoundments.
IML.CJE ' 2-15 Sepiemhcr 15. IW
-------
transported by tanker truck or pipeline to the newly construc'ed disposal cell, and dewatered in
the cell as described for Alternative 3. The cap and institutional controls would also be as
described for Alternative 3.
Alternative 5 was not addressed in detail in the proposed plan because it is substantially
sim:lar to Alternative 3 except for the location of the constructed consolidation cell. Alternative 5
would neea the same waiver from TSCA siting criteria as Alternative 3.
ALTERNATIVE 6—REMOVAL, TREATMENT, AND DISPOSAL
Total capital cost: S47.4 million
Present value of capital cost: S38.7 million
Time to implement: 4 years
Annual O&M cost, years 5-9: $44,000
Present value of total O&M cost: $108,000
Alternative 6 is a two-stage process that includes removal of all sediments within SIOU,
treatment of sediment-; to meet ARARs and di^osal facility WAC, containerization of treated
wastes, and transport of all treated waste to appropriate waste disposal facilities. The process for
addressing Impoundments A and B is shown in Figure 2.4.
The first stage, remediation of Impoundments C and D, will be a stand-alone project.
Impoundments C and D will be resampled using an approved sampling plan. The sediments in
Impoundments C and D will be removed by manual pumping or dredging as described for
Alternative 3 or by other appropriate methods. Approximately 0.03 m (0.1 ft) of clay liner
below.the sediment will be excavated to ensure that the sediment has been removed. Based on
th». c-unpijng results, the waste removed from the small i.npo^.'.dments will be treated as needed
to meet WAC at Envirocare.
Current data sugjfst that PCB concentrations are > 50 ppm and, consequently, the wastes
would require either disposal by incineration c - in a permitted chemical waste landfill.
Incineration requires destruction of PCBs to < 2 ppm. If concentrations > 50 ppm are verified
during resampling, an alternate method of destruction for PCBs (rather than incineration or
disposal in a PCB- landfill) would be required because there are currently no incinerators or
chemical waste landfills that can accept waste materials that contain iv.ixed nCBs and radiological
contaminants. At present, there are no known commercial vendors who have treated PCBs to
< 2 ppm in a radioactive matrix containing transuranic elements. DOE will solicit proposals
rn>>i-W07 IML CJi: 2-16 Sepiemher 15. IW
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Remotely Opera1 d
Dredge or Vacuui i s,udge Line to Sett|ing Tanks
Setting Tankr.
Treatment Facility
Thickened Sediment to
Treatmenl Facility
Supcrnalanl Return Line
to Impoundment
Dredge Power and
Contrcl Station
Staging on Site for Curing, Transport
Trai Donation to Final Disposal
ill Nevada Test Site
Note:
Conceptual design (or removal, treatment, and
transportation of Surface Impoundments Operable
Unit sediment from Impoundments A and B. Details
of design are likely to change during remedial design.
Steps:
1. Sediment is pumped from impoundments to settling tank.
2. After settling, supernatant is decanted from tank and returned in impoundment.
3. Thickened sediment is pumped to treatment facility.
4. Cement, fly ash admixture is combined with sediment in pug mill.
5. Wet concrete-like mixture is extruded from pug mill into containers.
6. Containers are moved to staging, curing area and held until mixture solidifies.
7. Containers of solidified waste are transported to disposal site.
Fig. 2.4
Alternative 6 - Removal, Treatment, and Off-site Disposal
DOE • ORNl. Surface Impoundment! • Oak Ridge. Tennessee
DOCUMENT ID 35HJ30
0040 30'ROD
DRAWlNo ID
9M<«21COR
DRAWING OAIE
AUGUST 11.19V 1C
-------
from vendors of various PCB destruction technologies. DOE will evaluate the »endors and
technologies and select the safest and most cost-effective technology. Chemical dechlorination
is the proposed FCB destruction technology considered in the cost estimate.
EPA has proposed revisions to the regulations concerning treatment of PCB-comaminated
waste that may alter the destruction requirements. If these re\ i^ions are promulgated. DOE will
incorporate the mcdif;;d requirements intr- -emediul Jco.gn anu remeuial action planning
documents for Impoundments C and D, as required.
Costs for removal and treatment, packaging and transportation according to U.S.
Department of Transportation (DOT) requirements, and disposal at Envirocare are estimated at
$4.6 million for < 61 m3 (80 yd3) of sediment and incidental soil removed.
Impoundments C and D would be backfilled with stone and gravel to provide an area for
. 'instruction of a facility to treat the sediment from Impoundments A and B.
The second stage, remediation of Impoundments A and B, assumes that an appropriate
disposal facility will be available before waste removal activities begin. Remediation of
Impoundments A and B relies on stabilization/solidification as the representative treatment
method. A 1996 treatability study developed a recipe of dry cement, dry fly ash, and sediment
with enough water to produce a waste form that meets DOT transport requirements and NTS
WAC. The treatment facility could include settling tanks, dewatering equipment, a pug mill for
mixing dry ingredients with the sediment, a packaging station, and auxiliary equipment. The
facility would have provisions for remote operation, shielding, high-efficiency paniculate air
filtration, and other provisions necessary to control worker exposure to radiation.
After construction and testing of the treatment facility, approximately 3,500 m3 (4,600 yd3)
of sediment would be transferred from Impoundments A and 3 to the facility with a remotely
operated hydraulic J.. Jge or other appropriate equipment. Excess water at the treatment facility
would be returned to the impoundments or would be treated at PWTP. Incidental soil that may
be encountered during sediment and water remediation will be handled appropriately. DOE
anticipates that the impoundments will be excavated to an elevation of 0.03 m (0.1 ft) below the
as-built elevation of the floor of the impoundment excluding bedrock and riprap. Details of soil
removal will be developed in the remedial action work plan. Waste would be solidified into
containers meeting DOT requirements and staged on the SIOU site for curing and transport.
After curing, waste would be shipped immediately to the disposal facility. Disposal fees
are estimated based on current charges at NTS for disposal of contact-handled low-level waste
JTCO1W707 IMI. CIE 2-18 .Vpirniper 15. IW
-------
in standard containeis. Development of an on-ORR mixed uaste disposal facility is under
consideration in a separate CERCLA decision-making process. A decision on the on-ORR
facility is expected in late 1998 " " approved, the far:i: schedn'--1 'o K .onal in
2uOO. If the facility is approved and constructed, and if SIOU w?stes meet the facility's WAC,
then DOE may choose to send the waste there, rather than to NTS or another appropriate facility.
When all waste is removed and shipped, the tre~:uiviu lacility and equipment would be
decontaminated to the extent practical. Contaminated material that is not reusable would be cut
up. placed in containers, and shipped for disposal. Uncomaminated material, including the
treatment building, would be released for other use. Surface water in the impoundments would
be discharged to PWTP, the impoundments would be backfi'leo with clean soil, and the site
would be restored.
Institutional controls would not be needed at the site for SIOU contaminants but could be
needed because of other contaminant sources. Appropri.ie institutional controls for residual
contamination would remain in place unless and until superseded as appropriate by the Bethel
Valley watershed ROD. The cost estimate assumes 5 years of monitoring and controls after
remediation. Institutional controls at NTS (or other final disposal location) would be needed
indefinitely. The cost for these controls is assumed to be included in the disposal fee.
This alternative meets all remedial action objectives and ARARs.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Table 2.2 summarizes the performance of the alternatives against the nine CERCLA
criteria. The first two criteria must be met in initial screening by any alternative considered for
selection in the ROD. The next five criteria are the primary balancing criteria upon which the
analysis is based. The remaining two criteria (state and community acceptance) are based on
regulatory agency review and public comment. Following is a discussion of the evaluation of the
alternatives.
Overall Protection of Human Health and the Environment. SIOU is in the main plant
area of ORNL in proximity to numerous industrial workers and adjacent to White Oak Creek,
which is a pathway for migration of contamination. Alternative 6 offers the greatest protection
because the waste is transferred from SIOU to a secure disposal facility. The disposal facility
would have superior hydrogeologic characteristics and/or engineering controls to contain the
waste and permanent institutional controls to address hazardous wastes from many sources. If
JTOOJW'07 IML.CIE 2-19 Seplcmber 15. IW?
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Table 2.2. Evaluation of alternatives for CERCLA criteria, SIOU ORNL, Oak Ridge, Tennes*
CERCLA criteria
1 . Overall prelection of human
health and (he environment
Future RME MA
Employee on rite
Resident Clinch River
Re jidem White 0*k Own
Resident White Oik Creek
Resident on site
Human health risk discussion
; . ' : . .-. :': .• -••••:•
Ecological rtik
2. Compliance with ARARs
3 Long-term effecuyeoen
Alternative 1
No action
8 x 10'
5 x I01
5 x 10'
7 x I01
2 x 10'
Risk to human health
from migration of
contaminati >n to
groundwatcr and White
Oak Creek. If water
cover over sediment is
lost, airborne
contamination resulting in
widespread human health
risk is possible. Very
high extcnal gamma
exposures to on-sitc
recepii.is
Risk to environmental
receptors from
consumption of fish in
impoundments. Small
risk from consumption of
fish in While Oak Creek
No ARARs under
CERCLA. Not protective
as required by CERCLA
Not effective
Alternative 2
MuBflayfr cap and
fautitutiona*
controls
Total risk
< 1 x 10*
< 1 x 10*
6 x 10'
1 x 10'
1 x 10'
Protective to
receptor at White
Oak Dam. Possible
risk to human health
from migration of
contamination to
groundwater and
White Oak Creek.
Protective while
DOE maintains
institutional controls
No risk to
environmental
receptors
4 waivers required
Effective for period
of institutional
control
Alternative 3
Consolidation cell
with simple
dewatcrlng
Total risk
< 1 x 10*
< 1 x 10*
< 1 x 10*
< 1 x 10'
< 1 x 10*
Protective to
employees and to
residential
receptors at White
Oak Dam and ai
While Oak Creek.
Protective at the
site while DOE
maintains
institutional
controls
No risk to
environmental
receptors
1 waiver required
Very effective for
period of
institutional control
Alternative 4
Consolidation cell
with ex situ
treatment
Total risk
< x 10*
< x 10*
< x 10*
< x 10*
< x |0*
Protective to
employees and to
residential receptors
ai White Oak Dam
and al While Oak
Creek. Protective at
the site while DOE
maintains institutional
controls
No risk to
environmental
receptors
1 waiver required
Very effective for
period of institutional
control
Alternative 5
orrsiou
consolidation ceD
Total risk
< v |0«
< > 10*
< x 10*
< x 10'
< x 10*
Protective to all
receptor1 while DOE
maintains
institutional controls
*
No risk to
environment.)
receptors
3 waivers required
Very clfccinc for
period of
institutional control
Alternative 6
Removal,
treatment, and off-
sft* disposal
Total risk
< 1 x 10*
< 1 x 10*
*- 1 x 10*
x 10"
x Id*
Prole. • ve to all
rccepii ,s because .>f
remov;i! of source
malcr.il
No risk to
envir imental
recej s
Meets all ARARs
Very effective
K)
K)
O
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Table 2.2. (contirucd)
CERCLA crturia
4. Reduction nf roiiciry.
mobility, or volume through
treatment
S. Short-term effectiveness
6. Implemenfebllity
7. Cost efTecrivetKu: :
Capital present value
0AM present vilue
K. State accepUnce
9 Community acceptance
Alternative 1
•/ V No action
None
No increase or reduction
in short-term effects on
human health and
environment
Very easy to implement
$0
SI.X2 million
Not acceptable
No support
Alternative 2
Multilayer cap and
Institutional
controls
None
Potential for small.
adverse short-term
effects
Easy to implement
$5.28 million
$586.000
Not acceptable
Not presented
Alternative 3
Consolidation cell
with simple
dewaitring
Small reduction in
volume
Potential for
moderate, adverse
short-term effects
Somewhat difficult
to implement
$10.2 million
$554.000
Nut supported at
this lime
Significant support
Alternative 4
Consolidation cell
with ex situ
treatment
Increase in volume.
Some decrease in
monthly of most
contaminants
Potential for
moderately high.
adverse short-term
effects
Difficult in
implement
$25. 9 million
$532.000
Not supported
Not presented
Alternative 5
orr-siou
consolidLilon cell
Small reduction in
volume
Potential ft.
moderately .iigh.
adverse short-term
effects
Difficult to
implement
$12.6 million
$532,000
Not supported
Not presenied
Alternative 6
Removal,
1 realm, t, and off-
sil. ..ifpotal
Incre.ise in volume.
Some decrease in
mobility of most
contaminants
Potential for high.
adverse shon-ienn
effects
Dilficult in
implement.
lechi...-ally and
adminisinilivcly
J3X.7 million
JIOK.IXX)
Preferred alternative
SigmlK.ini support
to
NJ
ARAR = applicable or relevant ind appropriate .cquirement
Cf-RCLA = Comprehensive r-iivii<>nmental Resp.mse. Compensation, and
Liability \cl of 1980
DOI: = U.S. Department of Energy
OAM = c leration and maintenance
ORNL = )ak Ridge National Lai .miory
ORR = Oak Kiiige Reservation
RME = re.is'iiuhle maximum enposure
SIOU = Surface Impoundments Operuble Unit
WAG - waite area grouping
< = less than
f
-------
disposal is at NTS in unlined trenches, protection \vould oe ensured because of the desert
environment with low precipitation and high evapotransporation. depth to groundwater. remote
location, and existing institutional controls. If disposal is at an engineered on-ORR disposal
facility or another appropriate facility, protection would be ensured by robust design of
engineering controls and institutional controls.
Alternatives 3, ' and 5 would protect all hu...a.. ie'.eptors as long as JOE maintains
institutional controls at the disposal site. The engineering controls would be designed for long-
term protection, but they may not be as robust as the controls or environmental isolation for
Alternative 6. Alternative 2 would protect receptors at White Oak Dam, but it would require
institutional controls along White Oak Creek as well as at me SIOU site, and the engineering
controls at the site would be the least effective. Alternative 1 would not be protective in the long
term and would pose some risk to workers maintaining the impoundments. Short-term risks to
workers and the public would be lowest for Alternative 2, low fur Alternative 3, higher for
A':ernatives 4 and 5, and highest for Alternative 6. All alternatives would control risks to
workers to within acceptable levels. DOE considers the long-term protection offered by
Alternative 6 to outweigh the increased shon-term risks. Therefore, Alternative 6 is considered
to provide greatest overall protection of human health. Alternatives 2 through 6 protect
environmental receptors.
Compliance with ARARs. Alternative 6 could potentially meet all ARARs if a treatment
process is developed that can reduce PCBs to < 2 ppm. Alternatives 2, 3, 4, and 5 require a
waiver from the TSCA requirement for disposal of PCB wastes that are more than 15 m (50 ft)
above high groundwater. Alternative 5 also requires waivers for the disposal of TSCA waste
within 15 m (50 ft) of the high water table [40 CFR 761.75(b)(3)] and RCRA land disposal
restriction (LDR) requirements (40 CFR 268). If LDRs could not be met, a third waiver would
be requested on basis of the attainment of an equivalent standard of performance. Treatment for
Alternative 4 would also trigger LDRs. and waivers could potentially be required depending on
the effectiveness of'u -treatment process. Alternative 2 would ..!:o need waivers for inadvertent
intrusion requirements and monitoring in a contaminated area, elimination of free liquids from
wastes, and leaving waste in contact with groundwater.
Long-Term Effectiveness. Alternative 6 provides the best long-term effectiveness
because waste is removed from SIOU and disposed of at NTS or placed in an on-ORR or other
appropriate engineered disposal facility. Waste would be treated to reduce toxicity and mobility
b .fore disposal. The proposed off-SIOU disposal facility would offer superior containment and
better protection from inadvertent intrusion than the facilities proposed for other alternatives. The
hydrogeology at the proposed disposal facilities for Alternative 6 is more suitable than the on-
IML.CHI 2-22 S<7»ctnt
-------
SIOU disposal location for Alternatives 2. 3. and 4, which is ?.'ooui 100 m (330 ft) from White
Oak Creek and where fractured bedrock is near the base of the liner. It is also more suitable than
the Melton Valley location t ;or /iltcrnative 5 The " '•- disr^c~' f-"-ility for
. Jternative 6 would hive long-term institutional controls in place that are considered effective.
Alternatives 3-5 effectively reduce human health risl: fo below EPA targets. Alternative 2
-.'duces risks to within 'h; EPA target risk range. Alterruu.. j$ 2-6 eliminate ecological risks
during the period of institutional control. Because receptors must be prevented from intruding
into the waste and from long-term exposures (e.g., building a house with a basement penetrating
the cap), the effectiveness after institutional controls are abandoned would be reduced. In the
very long term, degradation of the engineered containment facilities would reduce long-term
effectiveness. The caps for Alternative 2, the cap and liner for Alternatives 3 and 5, and the cap,
liner, waste containers, and waste form for Alternative 4 would eventually degrade. These
containment elements would have an expected effective life on the order of a few hundred years
for Alternatives 2. 3, and 5. and of perhaps 1.000 years f<>r Alternative 4. In the long term.
Alternative 1 cannot effectively reduce risks to human health. Estimated future risks exceed the
EPA target risk range, and there is no reduction in risk to the environment for either the long or
short term.
Reduction of Toxicity, Mobility, and Volume Through Treatment. Alternative 6 would
reduce toxicity of the sediment in Impoundments C and D by treating PCBs. PCB treatment
would not significantly affect sediment volumes, but a large liquid waste stream could result
depending on the chosen PCB treatment process. The liquid waste would be treated at ORNL
before discharge at an existing permitted outfall. Stabilization/solidification of the sediment from
Impoundments A and B in Alternative 6 would increase volume but would greatly reduce mobility
of contaminants in the sediment from Impoundments A and B. Toxicity would not be affected.
Alternative 4 would treat the waste from all impoundments with stabilization/solidification, which
would increase voiume, decrease mobility, and not affer roxicity.
Alternatives 3 and 5 would dewater the sediments and treat the surface water and leachate.
This would provide a small volume reduction through treatment. No contaminants would be
destroyed, and toxicity and mobility would not be i.f:ec:eJ through treatment.
Alternatives 1 and 2 would not provide treatment of the sediments.
Short-Term Effectiveness. For all alternatives, short-term effects to workers during
construction and other remedial efforts would be controlled through compliance with Occupational
Safety and Health Administration requirements. DOT requirements and DOE Orders.
TTOCUO^O? IML-OE 2-23 Sepucmher 15. l**7
-------
Appropriate heal-in and safety plans would be developed jnd implemented. Proper adherence to
the safety requirements would provide an adequate level of protection for remediation workers.
Risk to workers would increaf - ' • rc>pe ^f'he remed ciion^ ^-">ased. ". risks for
Alternative 1 would result from continued long-term maintenance of the impoundments to stop
leaks in the berm and maintain water levels. Risks during construction for Alternative 2 would
DC small, and risks for Alternative 3 would be moderite. Alternative 4 would include
wonstruc:ion . ru! operation of a treatment facility, thu^ int..casing accident risk over that for
Alternative 3. Alternative 5 would add risks for transport of slurried waste within CRNL and
thus would be greater than Alternative 3. Risks from long-term maintenance of the caps for
Alternatives 2. 3, 4, and 5 would be very low.
Alternative 6 would include the additional risk from construction and operation of a PCB
treatment facility, a more complex stabilization/solidification treatment facility, as well as long-
haul transport of the wastes from Tennessee to Nevada.' Although risks would be controlled
through project design, safety plans, and compliance wit-i egnlations as for other alternatives.
Alternative 6 would result in the greatest worker risk, including increased worker exposure to
radiation and the potential for spills or accidents. It is the only alternative that poses risk (i.e..
from transportation accidents) to the public.
Other short-term effects (i.e., environmental effects, potential for sudden failure,
socioeconomic impact, and time until objectives are met) are small and do not significantly
differentiate between the action alternatives. The no-action alternative would continue to pose
short- and long-tenti environmental risks.
Implement ability. The maintenance actions for Alternative 1, the no action alternative,
are already in place. Continued implementation would be very easy, reasonably reliable, and
simple to monitor. Alternative 1 would pose no impediment to undertaking additional remedial
actions. Regulatory agency approval or long-term irv-l^rnentation of Alternative 1 (i.e.,
administrative implementability) would be difficult to obtain.
Engineered caps and cells proposed for Alternatives 2-5 are routinely designed and built
throughout the country. The sediment and water '•"•nd'iug and cell construction equipment,
material, and techniques for Alternatives 3-5 are readily available. The proposed in-cell
dewatering method for Alternatives 3 and 5 has not been widely used, but it is expected to be
reliable based on results of the engineering support study (Energy Systems 1996). Alternative
dewatering methods arc also available. The engineering support 'tudy also indicates that
stabilization/solidification treatment for Alternative 4 is implementable. Although regulatory'
JTUQVN'O' IMI. CJE 2-24 S
-------
agencies oppose Alternative 2 and the state prefers Alternative 6. if Alternative 2, 3. 4. or: .vere
selected and approved through the CERCLA process, there would be no other administrative
impediments (c.c .censes, pe-~-.its) to miplementa
Of the action alternatives. Alternative 2 would be easiest to construct and operate.
Comparatively, Alternative 3 would be somewhat difficult because of the requirements for waste
transfer and radiation protection. Alternatives 4 and 5 wo>.u, be :nore difficult because of the
treatment plant construction and operation or the transport of slurried waste, respectively. The
reliability of Alternatives 2, 3,4, and 5 would be similar, although Alternative 2 is not designed
to prevent groundwater intrusion into the waste. All alternatives could be readily monitored;
however, contamination from other sources in Bethel Valley could mask releases fiom on-site
disposal options (Alternatives 1-4). Equipment, technologies, and specialists are readily available
for Alternatives 1, 2, 3, and 5. and no permitted facilities are needed.
Technical iniplementability of Alternative 6 would be ilx uiosi difficult because of the
safety requirements necessary to ensure adequate containment and shielding of the highly
radioactive waste and the complexity of the two treatment systems. Treatment of mixed
radioactive and hazardous waste to reduce PCB concentrations has been done in the laboratory,
but no full-scale field demonstrations are known to have been completed. Containment of
potential airborne releases of alpha-emitting radionuclides increases the complexity of the
treatment process. After treatment for PCBs reduces concentrations sufficiently for the waste to
exit TSCA regulatory authority, the waste from Impoundments C and D is expected to meet
Envirocare WAC. If treatment does not successfully meet PCB destruction requirements, no
disposal facilities are currently available that can accept waste from Impoundments C and D.
Although complex, the proposed stabilization/solidification of sediment from
Impoundments A and B for Alternative 6 is implement able. The solidified, containerized waste
form could be safely transported according to DOT requirements and disposed of without
airborne releases of contamination. Samples of the final waste form would be taken to ensure
that the waste to be disposed of is not RCRA-characteristic hazardous waste and does not contain
PCBs at levels > C0 pom.
The availability of NTS for disposal of solid low-level radioactive waste is likely, but
administrative considerations may impede or delay shipments of waste. Although there are no
laws prohibiting shipment of low-level waste, DOE Headquarters Office of the General Counsel
has recommended suspension of waste shipments from new generators to ^TS pending resolution
of issues associated with National Environmental Policy Act of 1969 (NEPA) review of the
facility at a programmatic level. An environmental impact statement (EIS) has been prepared
rr&>k«707 IML.CJE 2-25 Scp«mtxr 15. IW
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under NEPA for NTS and for some generators on projec'-specific bases: however, not all
possible generators and their actions have been addressed. A programmatic EIS has been
releaseu . )OE 1997b). Once approved, a ROD for tb.j programmatic EIS will set forth terms
and conditions under which shipments may resume. Obtaining administrative approval for
shipment and disposal is considered difficult, but achievable.
DOE is Luii'cp.ii.. evaluating various w iste ciijpuial alternatives for e..uronnKntal
restoration wastes from the entire ORR under a separate decision-making process. This
evaluation includes consideration of a large-scale engineered disposal facility on ORR for most
low-level radioactive, hazardous, TSCA. or mixed wastes generated from cleanup activities. If
the result of this separate project is the construction of a disposal facility for the entire reservation
and the treated SIOU wastes meet the new facility's WAC. SIOU wastes may be sent to the ORR
disposal facility rather than to NTS or another appropriate facility.
Cost. According to EPA guidance, the cost for maintenance and institutional control is
estimated only until year 30 because costs beyond that time frame are not considered accurate.
However, because of the long half-lives of some of the radioactive constituents, maintenance and
controls would be needed forever for Alternatives 1-5. Table 2.2 shows present value capital
costs and operations and maintenance costs until year 30.
Alternative 6 is the most costly of all the alternatives at an estimated $38.7 million capital
cost and S 108, 000 O&M cost (present value). However, the greater cost is justified because of
the greater long-term effectiveness and protection offered by Alternative 6. It does not require
long-term annual surveillance and maintenance expenditures Its cost is primarily attributed to
the amount of handling necessary to achieve full compliance with ARARs. Removal and disposal
of the SIOU waste does allow beneficial reuse of the site and, given its location, reuse of the site
should offset some of the cost. If an ORR disposal facility for low-level waste becomes available
for SIOU waste, cost savings of up to S3. 6 million compared to disposal at NTS may result from
reductions in transpo-— :?n costs and disposal fees. There may be additional savings of over
S4 million if treatment for PCBs is not required. DOE considers Alternative 6 cost-effective.
State Acceptance. Alternative 6 meets all TDEC recommendations. In a letter to DOE
dated September 20, 1996, specifically addressing Alternatives 3 and 6, TDEC stated that
Alternative 3 is unacceptable because the long-term effectiveness of the cell is not protective for
the life of the defined risk. In addition, costly, indefinite institutional controls would be required.
Alternative 3 also promotes a strategy of maintaining small pockets of contaminated media
throughout ORR that the state will not support. The state strongly opposes Alternatives 1 and
IMI. Of. 2-26 Scprmber 15.
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I. in which waste remains in contact with groundwater. Although the state has not officially
commented on Alternatives 4 and 5, the same arguments made regarding Alternative 3 apparently
would apply.
Community Acceptance. Community acceptance addresses the issues and concerns the
public may have about each alternative. The proposed plan (DOE 1997a) presented Alternative 6
.is the preferred alternative. The "Highlights of Communi:> . _:iidpation~ section summarizes
community participation. The selected remedy is the same as the preferred alternative in the
proposed plan. The Responsiveness Summary, Part 3 of this ROD, provides comments submitted
during the public comment period and responses to these comments.
The proposed plan has also been reviewed by the EPA National Remedy Review Board.
This review organization was established as part of the EPA Superfund Administrative Reforms
in January 1996 and is comprised of technical.experts and senior managers from EPA regional
offices and headquarters. The board promotes cost-effectiveness and national consistency in
remedy selection at Superfund sites. Specific comments from the board are included in the
responsiveness summary of this ROD.
Two comnv"»ois, including the ORR Environmental Management Site Specific Advisory
Board (ORREMSSAB), supported Alternative 6. Four commentors supported Alternative 3. No
other alternatives were supported. Recommendations from the EPA National Remedy Review
Board and responses from EPA Region 4 are included in the Responsiveness Summary.
SELECTED REMEDY
DOE, with the concurrence of EPA and the state of Tennessee, has determined that the
preferred alternative (Alternative 6) presented in the proposed plan is the most appropriate
remedy for protection cf human health and the environment and for elimination of the primary
source of groundwater contamination at the SIOU. This selection is based on the comparative
analysis of the alierr-^'ivcs presented in this ROD. This alternative satisfies the two threshold
criteria and provides the best balance of trade-offs with respect to the CERCLA criteria used to
evaluate remedial alternatives. DOE considers Alternative 6 to be an acceptable remedy for the
following reasons.
• Action is needed to address these impoundments because or 'heir continuing releases
to groundwater and White Oak Creek and the risk of airborne releases if the water
cover is lost.
JTOW09-07 IML.CIE 2-27 Sefxemhcr 15. I*)?
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• TDEC and ORREMSSAB prefer Alternative t>. They are opposed to promoting a
strategy of maintaining isolated pockets of contamination requiring long-term
monitoring and in • '".:olr ?. neede.1 for A1' "s 2 3. 4. and 5.
\
• Alternative 6 is consistent with the overall national approach to radioactive wastes.
At other DOE sites, wastes are either consolidated in existing facilities (e.g.. NTS or
bnv.:o.are) or into centralized facilities on site For example. Female! and Hanford
have facilities similar to the contingency on-ORR disposal facility discussed in the
context of Alternative 6.
Alternative 6 satisfies the statutory preference for remedial actions that use treatment to
reduce toxicuy, mobility, and volume. The preferred alternative provides long-term effectiveness
and permanence over other alternatives. Specific details on the selected remedy follow.
Alternative 6, the selected remedy, offers the greatest overall protection of human health
and the environment because the waste is removed from the site. Alternative 6 meets all ARARs,
has the greatest long-term effectiveness, and meets the statutory preference for treatment of
wastes by reducing toxicity (of PCBs) and mobility (of radioactive and heavy metal contaminants)
and is preferred by the state of Tennessee. Alternative 6 does not depend on institutional controls
for long-term effectiveness (except for those already in place at NTS and Envirocare. or thosi-
existing or proposed at other appropriate off-site disposal facilities). Alternative 6 is acceptable
in meeting short-term effectiveness, impiementability, and cost effectiveness criteria.
The selected remedy meets the end-use criteria recommended by the citizens group
site-specific advisory board for ORNL, the expressed recommendations of TDEC, EPA
requirements and statutory preferences, and the goals and objectives of the DOE Accelerated
Cleanup Plan.
The materials removed from Impoundments A and o will be treated, packaged, and
shipped for disposal at NTS or another appropriate facility. If an on-ORR disposal facility with
WAC compatible with SIOU wastes is developed through a separate decision-making process, it
would serve as the contingency disposal facility fo. :\ '•• alternative. If a new on-ORR disposal
facility is available, it will likely be chosen because of reduced transportation costs and disposal
fees.
DOE will issue an RFP for removal, treatment, and disposal ~f flie sediment, water, and
incidental soil in Impoundments C and D. DOE will submit the recommended methodology to
nOOUN'07 IML.OE 2-28 iepiorhrr
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EPA and TDEC. A contract will be awarded and substantial remedial arsons will begin \...hin
15 months of approval of this ROD. The project will be completed by January 1, 2003.
STATUTORY DETERMINATIONS
Under CERCLA Section 121. selected remedies must b^ protective of human health aiid
the environment, comply with ARARs (unless a statutory waiver is justified and granted), be cost-
effective, and use permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. CERCLA includes a preference for remedies
that permanently and significantly reduce the volume, toxicity, or mobility of hazardous wastes
as their principal element.
PROTECTION OF HUMAN HEALTH AND ENVIRONMENT
The selected remedy protects human health and the environment by removing the source
sediment contaminants at the SIOU; preventing the continued migration of contaminants from the
SIOU; and designating the Bethel Valley watershed decision-making process to appropriately
address any residual contamination remaining at the site.
COMPLIANCE WITH ARARS
The selected remedy will meet all ARARs, which are summarized here and listed in
Table 2.3.
Chemical-specific requirements set health- or risk-based concentration limits or discharge
limitations in various environmental media for specific hazardous substances, pollutants, or
contaminants. These requirements generally set protective cleanup levels for the chemicals of
concern in the designated media or indicate a safe level of discharge that may be incorporated
when considering a specific remedial activity. There are no specified cleanup levels for SIOU
because the scope of the action is limited to source removal of contaminated sediments; residual
contamination of surrounding media will be addressed as part of the Bethel Valley watershed
project.
Chemical-specific ARARs for SIOU consist of limits on radionuclide emissions.
Subpart H of 40 CFR 61 addresses atmospheric radionuclide emissions fr^ni DOE facilities and
will be applicable to airborne emissions during remedial activities. EPA has issued a final
National Emission Standards for Hazardous Air Pollutants rule that limits emissions of
IML/CIE 2-29
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Table 2.3. ARARs and TBCs for remedial action at SIOU, (MR, Oak Ridgi-, Tennessee
Action
Requirement
Prerequisites
Citation
Aciion(s) that will affect such resources must
adhere to the DOE/ORO Programmatic Agreement
May 6. 1994). When alteraiion or destruction of
the resource is unavoidable, steps must be taken 10
minimize >r mitigate the impacts and to preserve
data and ecords of the resource
Any action that will impact historic or
archaeolugic resource*—applicable
National Historic Preservation Ac1
(16 USC 470a-w)
EO 11593;
36 CFR 800
DOIi/ORO Programmatic Agreement
(May 6. 1994) (TBC)
Control of radionuclide
emissions
Protection of the
Chtmical'tptciftc
Exposures to members of the public from all
radiation sources released into the atmosphere shall
not cause an EDE to be > 10 mrem
(O.I mSv)/year
Radiological emission measurements must be
performed at all release points with a potential to
discharge radionuclides into the air in quantities
that could cause an EDE in excess of I % of the
standard (0.1 mrem/year). All radionuclides that
could contribute > 10% of the standard
(I mrem/year) for the release point shall be
measured
DOE will i.ir:> out all DOE activities to ensure
that radiation doses to individuals are ALARA
Exposures to members of the public from all
radiation sources shall not cause an F.DE to be
> 100 mrem (I mSv)/year
Point source discharge of radionuclides into
the ambient air from a DOE facility-
applicable
40CFR6I.92
Rules of the TDEC 1200-3-11-.08
40CFR6I.93
Rules of the TDEC 1200-3-11-.OH
Release of radionuclid.-
environment—TBC
into the
LJOK Order M •<> <(l.4)
10CFR 834 (;-,..posed)
DOE Order 5400.3(11.1 a)
10 CI-R 834 (proposed)
Surface water control
V
•a
Actioiftptcific
Implement good site planning and best
management practices to control stormwater
discharges including:
• documentation of best management practices in
a sturmwater control plan or equivalent
Control of stormwater discharges associated
with construction activities at industrial sites
that result in a disturbance of > 5 acres of
total land area. For those sites with
< 5 acres affected—relevant and
appropriate
40CFR 122
Rules of the TO EC 1200-4-IO-.05
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Table 2.3. (continued)
Action
Requirement
PrmquWtw
Challon
l-'ugilive emissions from
excavation activities
U)
Characterization/ ma nagement
of excavated wastes. PPE and
other secondary wastes streams
generated during remediation
V
if
• minimal clearing for grading
• removal of vegetation cover only within
20 days of construction
• week! erosion control inspections and
mainh iancr
• control measures to detain runoff
• discharges that do not cause erosion
Take reasonable precautions to prevent paniculate
miner from becoming airborne; no visible
emissions are permitted beyond property boundary
lines for more than 5 minutes/hour or
20 minutes/day. Potential nonpoint sources of
fugitive emissions are included in the plant-wide
fugitive emissions plan
A person who generates solid waste must
determine whether that waste is hazardous using
various methods, including application of
knowledge of hazardous characteristics of the
waste based on information about ihe materials or
processes used
All RCRA lotricied waste generated during
remedial activities must be treated to meet LDR
before land disposal
LLW generators must characterize and segregate
LLW from uncontaminated waste and otherwise
minimize the amount of LLW generated.
Subsequent management of LLW must be
accordance with DOE Order 5820.2A
Nonpoinl source air emissions—applicable Rules of (he TDEC 1200-3-8- 01
Wastes generated during activities potentially
contaminated with RCRA-characteristic
waste—applicable lo secondary wastes
from remediation of Impoundments C and
D if further sampling indicates the wastes
are RCRA-charactu utic
Generators of LLW-TBC
40 CFR 262.11
Rules of the TDEC 1200 l-l l-.03(l)(h)
40 CPR 26H 10
Rules of'he !DLC 1200-1-1 l-.IO(3)(a)
DOE Order SR20.2A
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Table 2.3. (continued)
9
'»
Action
Requirement
Prerequisites
Citation
Treatment of RCRA-
cliaracterislic waste
Treatment of contaminated soil
,inj sediment to meet ihe
disposal requirements of
40CFR761.60pm
Storage or treatment of RCRA characteristic
waste in a lank—applicable to treatment of
Impoundments C and 0 wastes if further
sampling indicates the wastes are RCRA-
characteristic
40 CFR 268
40 CFR 268 44
40 CFR 761 60
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Table 2.3. (continued)
Action
Requirement
Prmquisitw
Citation
o
m
Closure of impoundments
Tnmxportalion to disposal
facility
Repair any corrosion, crack, or leak
At closure, remove all hazardous waste ami
hazardous waste residues from lanlcs. discharge
control equipment, and discharge confinement
structures
Remove i>r decontaminate all waste residues,
contaminated containment system components
(linen, etc.). contaminated subsoils, and structures
and manage them as hazardous wastes
The waste must meet packaging, labeling,
marking, placarding, and pretranspon
requirements in accordance with DOT regulations
Waste must meet packaging requirements based on
the maximum activity of radioactive material in a
package
Waste must be marked with hazardous waste
marking, venerator's name and address, and the
manifest > >tlet number
Shipment must be manifested according to 40 CFR
262 and 263
Generators must certify before shipment that the
waste meets the waste acceptance criteria of the
receiving facility
Closure of surface impoundments— relevant
and appropriate to closure of
Impoundments C and D if further
sampling indicates the wastes are RCRA-
characterislic
Transportation of hazardous and radioactive
materials above exempt quantities—
applicable
Packaging of radioactive materials above
e-empt quantities for public transport-
applicable
Transportation of hazardous waste in
containers of 110 gal or less—applicable to
transport of Impoundments C and D
wastes if further sampling indicates the
wastes are RCRA-characleristic
Transportation of hazardous waste for off- 40 CFR 262 Snhpan B
40 OR 264 1%
Rules of the TDI:C 1200 l-l l-.On(IO|(j!)
40 CFR 264 I97
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Table 2.3. (continued)
Aciioo
Requirement
Prmqulsltts
Citation
0
LLW must be disposed of on site: if off-silt
disposal is required due (o lack of capacity,
disposal must be to a DOE facility
Off-site disposal of LLW 10 a commercial facility
requires an exemption from the on-sile disposal
requirements of DOE Order 5820 2A; requests fur
exempli n must be approved by the DOE ORO.
Must m el DOE Order and implementing
procedural requirements for off-site shipments
Shipments of LLW-TBC
Shipmcnis of l.t.W-TBC
DOt Order 5820.2A
DOE Order 5X20.2A
10
UJ
AI.ARA = as low as reasonably achievable
AKAR = applicable or relevant and appropriate requirement
n-'R = Ctnte of Federal Regulations
DOI: = US. Department of Energy
DOT = U.S. Department of Transportation
1-1)1: = effective dose equivalent
IX) = Executive Order
> = greater than
jiul = gallon
< = less ihan
I.DR = land disposal restriction
I.I.W = low-level (...dioactivc) \>aste
nuem = millirem
mSv = millisicven
ORO = Oak Ridge Operations
ORR = Oak Ridge Reservation
% = percent
PCB - polychlorinaicd biphenyl
PPE = personal protective equipment
ppm - parts per million
RCRA = Resource Conservation and Recovery Act nl 1976
SIOU = Surface Impoundments Operable Uml
TBC = to he considered
TDEC = Tennessee Department of Environment and C'mr.ervalion
USC = United Suites Code
-------
radionuclides '.a the ambient air from DOE facilities to amounts thu would not cause any member
of the public to receive an effective dose equivalent of 10 mrem/year or more (-10 CFR 61.92).
40 CFR 61.93(b)(4)(i) requires ..j^oical emission m .e^nts Jl reieu,,. i;"'r with
potential to discharge radionuclides into the air in quantities :hat could cause an effective dose
equivalent in excess of 1 percent of the standard (0.1 mrem/year). All radionuclides that could
contribute > 10 percent of the standard (1 mrem/year) for a release point shall be measured.
TDFC has proposed an equivalent rule in Rules of the Tenness-\ ^ apartment of Environment and
Conservation, Chapter 1200-3-11. Containment and filtration of emissions as needed during
treatment will be required, and dust control measures discussed under the "Fugitive Emissions"
heading will prevent unacceptable emissions of radionuclides during remedial action at SIOU.
To-be-considered guidance from DOE Order 5400.5. "Radiation Protection of the Public
and the Environment," of February 8, 1990. limits exposures to an effective dose equivalent of
100 mrem/year from all exposure pathways and all DOE sources of radiation. The overriding
principle of the DOE Order is that all releases of radioacti"e material shall be as low as
reasonably achievable.
Location-specific requirements set restrictions on the concentration of hazardous substances
or the conduct of activities solely because they are in special locations. Based on current
information for SIOU, the only condition or resource present on or near SIOU that would trigger
location-specific ARARs is that SIOU is located within an historic district. The mitigation
requirements associated with cultural resources and consultation with the State Historic
Preservation Office have already been satisfied.
Performance, design, or other action-specific requirements set controls or restrictions on
particular kinds of activities related to the management of hazardous waste. Selection of a
particular remedial action at a site will invoke action-specific ARARs that may specify particular
performance standard* ui technologies, as well as environment?.! levels for discharged or residual
chemicals. The following text summarizes the action-specific ARARs triggered by various types
of activities anticipated during implementation of the remedial action.
Stormwater Runoff
Stormwater discharges from industrial site activities involving construction operations that
result in the disturbance of 2 ha (5 acres) of land or more have been included in the final rule for
the National Pollutant Discharge Elimination System (NPDES) permits for Stormwater discharges
and incorporated into the TDEC permitting regulations [40 CFR 122; Rules of the TDEC
1200-4-10-.05]. Stormwater discharge requirements are applicable if 2 ha (5 acres) or more are
disturbed; otherwise, they are relevant and appropriate requirements. Compliance with the
T IML Ob" 2-35 September 15. 1997
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substantive requirements of the NPDES permitting process for stormwater discharges uuring
construction activities (Rules of the TDEC 1200-4-10-.05) will be required. In particular.
implementation of good site pla-- • P"d hest management practice* to control stormwater
discharges will be required. Stormwater flow controls such as berms, silt fences, hay bales, and
other best management practices will be followed during implementation of the selected remedy
to comply with stormwater runoff ARARs.
Fugitive Emissions
Elevation of airborne paniculate concentrations could result if excavation at SIOU were
not controlled. The TDEC Air Pollution Commission has promulgated applicable requirements
in Rules of the TDEC 1200-5-8-.010, for the control of fugitive dust. An operator must take
reasonable precautions to prevent paniculate matter from becoming airborne. In addition,
fugitive dust may not be released as a visible emission beyond propeny boundary lines for more
than 5 minutes/hour or 20 minutes/day. To ensure compliance with the ORNL site aj' permit
and to meet the substantive requirements of fugitive dust en issior.s, dust suppression measures
(such as water, organic agents, or foams sprayed over the area of concern to prevent dust
generation) combined with ambient air monitoring stations shall be used as a best management
approach for activities during SIOU remediation.
Treatment of Surface Water Removed from SIOU
All waters removed from the impoundments during remedial activities will be sent to
PWTP. The water must first be tested to ensure it meets the WAC for PWTP, and if necessary.
treated before being sent to the facility. PWTP is a part of a permitted NPDES. If PWTP
cannot accept any of the water, a contingency is to use a package treatment plant consisting of
zeolite ion exchange canisters and from there transferring the water to the Nonradiological Waste
Treatment Plant. Any spent zeolite packs must be characterized, and if necessary, managed and
disposed of as a hazardous waste in accordance with 40 CFR 261, 262, and 263 or as a mixed
waste under the Commissioner's Order for the site treatir.en. plan. Section 105 of the FFA, and
DOE Order 5820.2A, "Radioactive Waste Management."
Treatment of Sediments from Impoundments C and D
Sediments and incidental soils from Impoundments C and D will be treated using an
alternate method of disposal per 40 CFR 761.60(e). An alternate method of disposal is required
because no TSCA-permitted incinerators or permitted chemical-waste landfills are currently
available that can also accept the radiological and potentially RCRA-contaminated sediments. The
alternate method of disposal has not yet been finalized; however, chemical dechlorination is the
method used in the cost estimate for the selected remedy. Treatment systems must be evaluated
OT IML.CJE 2-36 Sfpicmner 15.
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to de'eTnine the destruction efficiency for PCBs in ;he sediments. If a method other th ..i
chemical dechlorination is used, it will be reviewed and approved by EPA and TDEC with
appropr jte documentation. Protectiveness of hunun health and the environment will be
paramount in selection of the alternate method of disposal. EPA guidance requires that PCBs be
destroyed to a level of < 2 ppm to demonstrate equivalency of performance with a TSCA-
nermitted incinerator. Once destruction requirements for PCBs have been met. the sediments will
exit ". SCA regulatory authority and be eligible for disposal at 2nvir<"care as a mixed wa-te, if
all other WAC are met.
Proposed revisions to the TSCA rules, if finalized, would allow destruction to risk-based
level [proposed Sect. 761.61(c)] or disposal in a landfill that has been deemed protective
(proposed Sect. 761.62). Should methodology capable of the required efficiency be unavailable
for environmental media such as the sediments, the remaining wastes would of necessity be stored
until suitable treatment and disposal facilities are developed.
The sediments from Impoundments C and D may also be RCRA-characteristic waste. The
sediments and incidental soils must be properly characterized per 40 CFR 261. If the sediments
are a RCRA-hazardous waste, LDRs (40 CFR 268) will be legally applicable for disposal of the
wastes at an off-site facility. The sediments will then be treated to meet LDRs and any other
disposal facility WAC. Treatability variances may be required for some of the potential RCRA
constituents. If so, the EPA guidance for obtaining and complying with treatability variances for
soil contaminated with RCRA-hazardous wastes for which treatment standards have already been
set will be followed (Office of Solid Waste and Emergency Respcnse Directive 9347.3-06FS, July
1989). Tanks associated with treatment of the RCRA wastes must comply with RCRA tank
requirements in 40 CFR, Subpan J. Requirements such as secondary containment and closure
of a tank system are included here.
Stabilization of Sediments from Impoundments A and B
Stabilization of sediments and incidental soils from Impoundments A and B will involve
requirements for physically stabilizing the wastes such that the waste can pass the paint filter test
oer RCRA. Subtitle D. ;:r.H can meet WAC of NTS or ot.ier disposal facilities, in addition,
sufficient shielding of the radiological activity must be provided that all other requirements for
transportation, worker safety, public exposure limits, and disposal facility WAC are met.
li? 1ML CJi: 2-37 S*[xcmtxrr 15. IW
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Closure of Impoundments
The SIOU scope includes removal and treatment of the sediments and surface water of the
impoundments. Remediation of incidental soils is included only as necessary to support
remediation of the sediments. Contaminated subsoils surrounding the impoundments will be
addressed as pan of the Bethel Valley watershed operable unit (OU) and will be included with
ac'ions for other subsoils. Thus, requirements fcr c'osure -.vitr1 u-sre in place, while relevant.
are not appropriate.
Transportation of Waste for Disposal
Mixed or low-leve1 wastes will be generated during uie SIOU remediation. In accordance
with DOE Order 5820.2A, radioactive waste is to be disposed of on the site where it is generated
if possible; if off-site disposal is necessary because of lack of on-site capacity, disposal must be
at another DOE facility. Because disposal capabilities for the SIOU sediments currently do not
ex it nn ORR, the selected remedy includes off-site disposal of the sediments.
DOT requirements for shipping and packaging (49 CFR 172 and 175) and for transport
on a public highway (49 CFR 177) of hazardous materials will be applicable to remedial actions
at SIOU. General requirements for shipping hazardous materials are defined in 49 CFR 172,
with specific marking, labeling, and placarding regulations for radioactive materials in 49 CFR
172.510. 172.405, and 172.556, respectively.
Regulations governing transportation of hazardous materials by public highway are found
in 49 CFR 177, and specific loading and unloading requirements for radioactive materials are in
49 CFR 177.842. The number of packages in any one motor vehicle must be limited so that the
total transport index number does not exceed 50. The total transport index is the sum of the
numbers expressing the maximum radiation level in millirems per hour at 1 m (3.3 ft) from the
external surface of each package (49 CFR 173.403bb).
EPA and TDEC regulations governing generators and transporters of hazardous waste
found in 40 CFR 262-263 and Rules of the TDEC 1200-1-11-.03 to .04. are also ARAR for
remedial activities at the SIOU. Rules of the TDEC i200-l-l i-.03 (40 CFR 262) requires
generators to ensure and document that the hazardous waste they generate is properly identified
and transported to a treatment, storage, and disposal facility.
Requirements for manifesting [Rules of the TDEC 1200-1-11-.03(3); 40 CFR 262.20-23],
packaging. labeling, marking, and placarding [Rules of the TDEC 1200-1-11-.03(4); 40 CFR
262.30-33] will be followed. In addition, there are record-keeping and reporting requirements
rrouww IML.CJE 2-38 Scrxmncr is. \*K
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[Rules of the TDEC 1200-1-11-.03(5); 40 CFR 262.40-43). Pretransport requirements
referenced under DOT regulations 49 CFR 172. 173, 178. and 179 are also applicable.
In the event that an on-ORR disposal facility becomes available, the above regulations for
packaging, labeling, and transport would be relevant and appropriate rather than applicable.
Off-Site reposal of Low-Level Wastes
CERCLA Section 121(d)(3) requires that the off-site transfer of any hazardous substance,
pollutant, or contaminant generated during CERCLA response actions be to a facility that is in
compliance with RCRA and applicable state laws. EPA has established procedures and criteria
at 40 CFR 300.440 for determining whether facilities are acceptable for the receipt of off-site
waste. Per 40 CFR 300.440(a)(4), EPA will determine the acceptability of the facility selected
for disposal of CERCLA wastes. DOE will request the determination from EPA once facility
availability is apparent. Once wastes generated from a CERCLA response action -re transferred
off site, all administrative as well as substantive provisions of all applicable requirements must
be met.
An off-site facility licensed for disposal of radiological waste and approved by EPA to
accept CERCLA waste will be used for sediments from Impoundments A and B. The wastes
must also meet the acceptance criteria of the off-site disposal facility. If the sediments from
Impoundments C and D are RCRA hazardous, they would be treated to meet LDRs before
disposal. After destruction of PCBs and treatment to remove RCRA characteristics, the
sediments would be disposed of as low-level waste.
Decontamination of Equipment
Decontamination activities will include washing equipment and collecting the
decontamination water with temporary sumps connected to PWTP. The decontamination water
must meet WAC for this facility before treatment.
Institutional Controls
Institutional controls will remain in place for SIOU until superseded by the Bethel Valley
watershed ROD. No regulatory requirements specify institutional controls for CERCLA units.
For the containment and long-term management of residual contamination at inactive
hazardous waste sites-,* Rules of the TDEC 1200-l-I2-.08(3)(a)4.(iv) controls are to include, at
a minimum, deed restrictions for sale and use of the property and securing the area to prevent
human contact with hazardous substances. Also, RCRA contains general requirements for
IML/CJE 2-39 Scpcmber 15. IW
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institutional controls following closure of RCRA units (40 CFR 264.14). which are relevant and
appropriate for any RCRA waste left on site. Although residual contamination v/ill remain in the
si'rrounding media, these req-. ... '•*• . ::o: Veer: .jded ac TA" -.OU beep
removal of the sediments will not leave waste in place as defined by the scope of this action.
DOE Order 5400.5. Chapter IV, requires administrative (institutional) controls for long-
term management ,.. ureas containing residual radioactivity above guidance levels based on basic
dose limits in the DOE Order.
These and other measures mandated by health and safety standards will continue to protect
workers and the public after remedial action at SIOU is completed and pending remedial action
on the Bethel Valley watershed OU.
COST EFFECTIVENESS
Actions taken under CERCLA must consider the estimated total present-worth cost of
alternatives. Alternative 6 meets regulatory requirements, reduces risk to human health and the
environment to acceptable levels, and allows beneficial reuse of the site, which offsets some of
the cost associated with this remedy. Alternative 6 is considered a cost-effective remedy for the
protection of human health and the environment.
USE OF PERMANENT SOLUTIONS TO THE MAXIMUM EXTENT PRACTICABLE
The selected remedy represents the maximum extent to which permanent solutions can be
used in a cost-effective manner for the SIOU sources at this time. Of the remediation
alternatives, 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. The ir"p::; of any residual contamination
will be assessed in the Bethel Valley ROD; additional action could be taken pursuant to that
decision.
PREFERENCE FOR TREATMENT
CERCLA Section 121 establishes a preference for alternatives that use treatment to
permanently reduce toxicity, mobility, or volume of hazardous substances. The selected remedy
will use stabilization/solidification to reduce mobility of the contamination in the waste removed
from Impoundments A and B. If sampling results indicate that treatment of waste removed from
IML.OE 2-40 S^mhr, I!. IW
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Impoundments C and D is needed 10 meet TSCA regulations or disposal facility WAC. perman^..t
reductions of toxicity or mobility could result from implementation of the selected remedy.
The selected remedy, therefore, meets the CERCLA prefeience for treatment.
EXPLANATION OF SIGNIFIC '.NT CHANGES
The proposed plan, which was released for public comment on June 30, 1997, identified
Alternative 6 as the preferred alternative. DOE received oral comments during the public
meeting on July 15, 1997, and written comments as documented in the "Responsiveness
Summary." DOE, EPA, and TDEC reviewed the comments and determined that no significant
changes to the remedy, as originally identified in the proposed plan, were necessary.
REFERENCES
DOE (U.S. Department of Energy). 1997a. Proposed Flan for Surface Impoundments Operable
Unit. Waste Area Grouping 1, Oak Ridge National Laboratory, Oak Ridge. Tennessee,
DOE/OR702-1427&D3/R1. Oak Ridge. TN.
DOt. 1997b. Final Waste Management Programmatic Environmental Impact Statement for
Managing Treatment, Storage, and Disposal of Radioactive and Hazardous Waste,
DOE/EIS-0200-F. DOE, Office of Environmental Management, Washington, DC.
DOE. 1995. Remedial Investigation/Feasibility Study for Surface Impoundments Operable
Unit, Waste Area Grouping 1, Oak Ridge National Laboratory. Oak Ridge, Tennessee,
DOE/OR/02-1346&D2. Oak Ridge, TN.
Energy Systems (Lockheed Martin Energy Systems, Inc.). 1996. Engineering Support
Studies Report - Geo'echnical and Treatabiliry Results for the Technical Work Plan for
Surface Impoundments Operable Unit Engineering Support Studies, X-OE-791. Energy
Systems, ORNL, Environmental Restoration Program, Oak Ridge, TN.
Yu., C., A. J. Zielen, J. J. Cheng, Y. C. Yuan, and L. G. Jones. 1993. Manual for
Implementing Residual Radioactive Material Guidelines Using RESP*D. Version 5.0,
ANL/ESD/LD-2. DOE, Washington, DC.
? IML-CJE 2-41 September 15.
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PART 3. RESPONSIVENESS SUMMARY
JTIXMOW? IML.CJE Stjxcmbrr 15.
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RESPONSIVENESS SUMMARY
This responsiveness summa: c ihre^ major purposes. Fir?' c rms DOE. EPA.
2"d TDEC of community "~ncerns about the site and the community's preferences regarding the
proposed remedial alternative. Second, it demonstrates how public comments are integrated into
:w decision-making process. Finally, it allows DOE to formally ...ipond to public comments.
This responsiveness summary documents all public comments on the Proposed Plan for
the Surface Impoundments Operable Unit, Oak Ridge, Tennessee (DOE 1997a). The proposed
plan was issued in June 1997; the public comment period was June 30-July 30, 1997. DOE
announced the availability of the proposed plan in The Knoxville News-Sentinel. The Roane
County News, and The Oak Ridger June 30, 1997. A public meeting was held July 15, 1997.
Comments made during the public meeting and those received in writing during the public
v-ommeru period are addr.ssed here.
This summary is prepared pursuant to the terms of the 1992 FFA among DOE. EPA. and
TDEC, as well as other requirements, including.
• CERCLA as amended by the Super fund Amendments and Reauthorization Act of 1986
(42 USC Sect. 9601, et seq);
• NCP (40 CFR 300.430); and
• Community Relations in Super/and, A Handbook (Yu et al. 1993).
COMMUNITY PREFERENCES
DOE received 36 comments on the proposed plan. The.- j comments are summarized with
DOE's responses. DOE recorded 19 public comments at the July 15, 1997, public meeting.
Written comments we— received from the EPA National Remedy Review Board, ORR
Environmental Management Site Specific Advisory Board (ORREMSSAB), Mr. Alfred A.
Brooks, Ms. Janet L. Westbrook, and a commentor v>hose signature was illegible. Two
commentors (including ORREMSSAB) supported selection of the preferred alternative
(Alternative 6) presented in the proposed plan. Four commentors supported selection of
Alternative 3. Clarifications or modifications to alternatives were suggested by 18 of the
comments.
rn»wo7 IML/CJE 3-2 sepemher is.
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INTEGRATION OF COMMENTS
The selected remedy described in this ROD includes clarifications of the preferred
alternative based on public input. These c.edifications did not change the intern or the selection
of the preferred alternative.
ISSUES, COMMENTS, AND RESPONSES
Because many comments dealt with similar issues, the comments are categorized into the
issues identified below. The transcript of the public meeting and all written comments are
included in the Administrative Record. Comments from that meeting and written comments
received during the public comment period are either summarized below or presented in full.
DOE's response to each issue follows the statements and summaries of comments for that issue.
ISSUE 1: ALTERNATIVE 6 SHOULD BE THE SELECTED REMEDY
Comment I: ORREMSSAB, July 9, 1997.
[ORREMSSAB] is in general agreement with the preferred alternative (Alternative 6) of.
removal, treatment and disposal of surface impcundment sediments as presented in [DOE's]
proposed plan of June 30, 1997.
Alternative 1 (no action) is unacceptable because of the continued release of contaminants
'o groundwater, leakage through Impoundment B berm, migration of contaminants to surface
water, and resultant unacceptable risk to ecological receptors. The possibility of flooding of the
impoundments also remains a concern under the no action scenario. In addition, the potential risk
to human health if the water cover over the impoundment sediments is lost would be at an
unacceptable level.
Although both Alternative 3 (on-site consolidation cell) and Alternative 6 would prevent
continued releases of contaminants to groundwater. Alternative 6 is preferable because the source
material would be remove^ and this portion of the Bethel Valley area of [ORNL] would not be
restricted from future surface use. This area is desirable for future surface use as it is adjacent
to other well-developed and highly used areas of [ORNL]. Alternative 6 is also preferable to
Alternative 3 because long-term stewardship of the SIOU would not be required. It is also
desirable to create as few waste disposal areas as possible, and by transporting the impoundment
ni.tui.rt-i,- IMI. CJi: 3-3 September 15.
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sediments to either an on-site waste management facility (which would accept CERCLA wastes
from many areas on [ORR]) or [NTS], the creation of a waste disposal area solely for the
impoundment sediments would be avoided.
Comment 2: Mr. Pride, Transcript of Public Meeting, July 15, 1997.
From my own personal view I want to also favor A!tern:'ive 6. the cleanup alternative.
Some comments were made to the rem exposure [see Issue 3]. I certainly believe that the costs
probably could be improved from a personal standpoint. But even more so from Janet
fWestbrook]'s viewpoint, I think that the rem exposure is probably very, very high.
And. of course, if you do use this, there's a probability that the transport and disposal
cost to [NTS] would run S20 million-S25 million just for that. So that doesn't count the actual
work activity there. It will be contributing costs.
DOE Response: DOE agrees that Alternative 6 should be ue selected remedy. Comment
I states that, for Alternative 6. "... long-term stewardship of the SIOU would not be required."
While this is true for the wastes included in the SIOU scope, the level of cleanup or long-term
stewardship required to ..JJress the residual conta...ination in soil and groundwater on the SIOU
site will be determined in the Bethel Valley Watershed ROD. For Comment 2, please see the
response to Issue 3 regarding radiation exposures and the response to issue 4 regarding costs.
ISSUE 2: ALTERNATIVE 3 SHOULD BE THE SELECTED REMEDY
Comment 1: Ms. Westbrook, Transcript of Public Meeting, July 15, 1997; and Janet
L. Westbrook, [Written] Comments Made at the DOE Surface Impoundments Project
Public Meeting, Oak Ridge, Tennessee, July 15, 1997, with Notes Added 16 July 1997.
I am a radiological engineer, a Registered Professional Engineer, a Certified Health
Physicist, a resident of Oak Ridge, and a taxpayer. Since some of you will recognize me as
being in the rad protection organization at [ORNLJ, I must state that I am speaking for myself,
as a concerned person, and not for Lockheed Martin or ORNL.
Most of my work involves evaluating radiation work and the associated dose. The choice
of Alternative 6 over Alternative 3 disturbs me for several reasons. [See Issue 3, Comment 1;
Issue 10. Comment 2; and Issue 13. Comment 9.]
IMl CJi: 3-4 ' Scjvii'he' 15. '.•*>*
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I suggest that Alternative 3 be chosen. Then take the cost difference between the
alternatives, about S40 million. Take half of it and use it for ether projects. Take the other half.
S20 million, and invest it at, say. 8 percent for 30 years. At the end of that time vou'll have
grown the S20 million to $200 million. Then, if ORNL docs g~ awa> ..i 30 years, you can
further remediate the capped Alternative 3. It will be easier and cost less dose, because the
cesium and strontium will have decayed to half of their original values and the cobalt to about
> percent of its original value.
I made this suggestion in jest, of course, since DOE would never establish a S20 million
trust fund for the impoundments. Yet DOE is willing to spend $53 million and 36 man-rem or
more on it now. Why?
In the DOE method, as best as I could tell from the project fact sheet, each [CERCLA
evaluation] criterion was treated separately and more or less equall) (e.g., five criterion chock
marks in the criterion table might be taken to beat three check marks, even though the criteria
were in fact not of equal importance).
In an optimization study, any "trump" or veto criteria would cause an alternative to be
weeded out at once. However, DOE apparently did not realize that the state would oppose any
action that did not immobilize the waste essentially forever or else did not completely remove the
waste from the site (from the fact sheet: "TDEC stated that Alternative 3 is unacceptable because
the long-term effectiveness of the cell is not protective for the life of the defined risk . . . and also
promotes a strategy of maintaining small pockets of contaminated media throughout ORR that the
state wii; not support"). Thus it appeared that there were two options, 3 and 6, when in fact
there was only one. In that case, the money to evaluate Alternative 3 was unfortunately just
wasted.
I also did not **ve time in the meeting to go into the engineering uncertainties of the
project and this point was only lightly touched on by others. But mcae uncertainties should be
considered seriously especially since, as I did note, the company performing the remediation may
choose to deviate from the method proposed in Alternative 6 and is not required to keep under
the dose estimated. As a radiological engineer, I favor the proven technology, the tested
:echnique, over less predictably controllable methods that may result in more dose, take longer
than planned to execute, etc. I also favor a method that, once the project begins, will minimize
external impacts on schedule, e.g., that will depend on the fewest entities or organizations and
will not depend oii political decisions, such as the opening of NTS to ORNL waste, to be
completed. This is a reason to favor Alternative 3.
uT |MI. OF. ^ 3-5 Sepwinhcr I?.
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Comment 2: Mr Brooks. Transcript of Public Mutiny. Julj 15. 1°97.
I have a question on cost. Offhand comment that roughly S35 million an acre is a high
price to pay for land. I would ponu out that the [End-Use Working Giuupj aid not recommend
Alternative 6, and Alternative 3 would fully meet their criteria, which was not to leave any
-.xclusion areas, and I think, as indicated (by DOE during July 12. 1997, presentation], will be
a satisfactory recreational area.
Frankly, my own personal preference would be for [Alternative 6], but only if you can
assure me that you're not going to jeopardize some other project down the road ... [only] if we
could be assured that there is plenty of money to do the things that we have to do and something
of equal importance ... or several things of lesser importance will not be set aside under fully
endorsed Alternative 6.
But under these circumstances, since Alternative 3 docs meet ill the acceptance criteria,
and considering that land across the road certainly wouldn't go more than S10.000 an acre, then
I really can't see the need to return this ... to the pristine state ... especially since right in that
same valley you've got White Oak Creek, and on the next valley over, there will be acres of sites
that have material left, all of those contributing to White Oak Creek. Granted that this is a big
contribution, but that can be another way to lower costs.
We went through a process [East Fork Poplar Creek CERCLA decision] where EPA was
persistent on certain cleanup levels. The public was dissatisfied. It's a matter of record 'vhat
the outcome was. EPA listened to the public. I think as a pan of this process now, you have
the public with you to help you discuss it and reach what seems to be a reasonable conclusion.
I don't think the other conclusion [East Fork Poplar Creek] really factored in public opinion, and
I think now the EPA knows how intensive it can be.
Comment 3: Ms. Sigal, Transcript of Public Meeting. July 15, 1997.
[T]he [End-Use Working Group] has already provided community input on the surface
impoundments, and it's my understanding that we recommended a controlled industrial use,
uhich our definition of that term means that industrial service use is appropriate, soil should be
clean to a depth of 2 ft, shall the soil disturbance permit it, to a depth of 2 ft. No groundwater
use, no use of surface water, and federal government owner,hip. So you have the community
input for this project, and I think maybe you ought to take another look at it and maybe revisit
your alternative because 1 don't think Alternative 6 is what we had in mind when we talked about
controlled industrial use.
*
J|'«aw-i.i- IMI. CJI 3-6 Vpiirnitvr l< 1W
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Comrrtnt 4: AJfred A. Brooks, Letter to Margaret Wilson, July 17, 1997.
These comments are based 01. ...~ CERCLA Criteria, .... End-L' Working v
Community Guidelines, and the Recommendations for the End Use of Bethel Valley.
Both Alternatives 3 and 6 generally meet the above requirements; however, in the areas
of remediation worker safety and cost. Alternative 3 is more in tun- with the CERCLA criteria
and community's expressed wishes. Contrary to some public statements, the End-Use Working
Group did not endorse Alternative 6. The [End-Use Working Group's] objectives are to
recommend end uses for contaminated areas, not to recommend remediation methods.
In comparing these alternatives, consideration has been given to the fact that some of the
alleged advantages of Alternative 6 over 3 is simply the transfer of liabilities for ORR to other
sites which are only incrementally better for their accommodation. In addition, the fact that
SIOU and Melton Valley, which will contain future similar subsurface wastes, are on the White
Oak Creek is considered. The uncertainties associated with estimated costs and future budgets
have also been considered in making these judgments.
1. The additional remediation worker exposure of Alternative 6 is significant and contrary
to the Community Guidelines.
2. The cost of Alternative 6 exceeds the cost of Alternative 3 by $37 million for which
".bout [1.5] acres are restored from recreational or iite beautification use to light
building use. Given that a site needs some green areas, this is a high price to pay per
acre for the additional benefit especially with the ready availability of land near by.
A choice of Alternative 6 seems contrary to CERCLA requirements.
3. The requirement 10 reduce the PCB levels to below 2 npir. when the disposal level is
SO ppm is not cost effective especially since the sediment concentrations are only
slightly above SO ppm. DOE should request a waiver and EPA should grant it. To
enforce this regulation would incur the needless expenditure of several millions of
dollars that could be better spent on other cleanup. This would be contrary to
CERCLA's requirement for cost effectiveness.
For the above reasons, [Alternative 3] is preferable to [Alternative 6].
IJ? IMl. OH 3-7 ' S
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Comment 5: Signature Not Legible. Letter to Margaret Wilson, JuJy 20, 1997.
I disagree with the selection of Alternative 6 as the preferred alternative for remediation
of SIOIT. I believe that Alternative 3, as presented in the proposed plan, is the option that should
be the selected remedy in the [ROD] for this project.
DOE Response: O\. evaluation of the nine (. tivCL/\ criteria. Alternative 6 oners superior
performance in five criteria (overall protectiveness. compliance with ARARs. long-term
effectiveness, preference for treatment, and state acceptance). Alternative 3 is better in three
criteria (short-term effectiveness, implementability. and cost). Regarding public acceptance, the
last evaluation criterion, both alternatives have received support. Two commentors. including
ORREMSSAB, provided four comments supporting Alternative 6. Four commentors provided
16 comments supporting Alternative 3.
Remedies such as Alternative 3, which incorporates disposal at or near SIOU, can result
in small pockets of contaminated media distributed throughout ORR. The state and
ORREMSSAB oppose the formation of small pockets of contaminated media (see Issue 1,
Comment 1). The permanent requirement for maintenance and monitoring is not reflected in the
cost estimate, which assumes a 30-year project life per EPA guidance. Land use would remain
restricted in perpetuity.
Comment 1 says that the state's "veto" of Alternative 3 indicates the money spent to
evaluate it was wasted. The evaluation of all alternatives was performed according to CERCLA
guidance to develop a range of potential remedial actions. This is done to truly evaluate the
technical ramifications of varying remediation options.
Comment 1 states that the remediation contractor "is not required to keep under the dose
estimated." The estimated doses (see Issue 3, Comment 1) were prepared recently and were not
reviewed by DOE. AI! ~,*j\L contractors are required to ensure that workers are protected and
that radiation exposures are maintained ALARA (see Issue 13, Comment 9).
Commemor 1 favors "the proven technology, the tested technique, ... a method ... that
will minimize external impacts on schedule ... such as the opening of NTS to ORNL waste ...."
Although DOE agrees that these are valuable elements to strive for in the selection of an
alternative, the methods of addressing uncertainties associated with Alternative 6 are considered
reliable. See responses for Issues 7. 8. 9, 10, 11, and 13.
IM1. Ol:. 3-8 Vptcmtvr 15. :*
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Comments 1, 2. and 4 address the cost differential between Alternatives 3 and 6, and the
concern thai funding for other projects will not be available if Alternative 6 is selected. DOE
recognizes that Ainding is limited and that expenditures on SiOU may reduce funding available
for other ER projects. However, L>\JC. believes that the expenditures iuf Alternative 6 are
appropriate for remediation of the impoundments (see response to Issue 4). Furthermore, DOE
expe.ts to significantly reduce costs from those projected for Alternative 6 in the proposed plan,
based on the use of a competitive procurement process. Although Alternative 3 would remain
less costly to implement, the cost difference is not expected to apprcnch the amounts discussed
in the comments.
Comments 2. 3, and 4 address the effectiveness of Alternatives 3 and 6 in meeting the
End-Use Working Group Community Guidelines and the Recommendations for the End Use of
Bethel Valley. DOE agrees that both alternatives meet the land use recommendations as stated
in the comments. Alternative 6 is superior to Alternative 3 in meeiing the following End-Use
Working Group guidelines:
• End-use decisions for contaminated lands should not impede the continuing use and
development of ORR lands, and should allow for future employment and research
opportunities.
• Institutional controls in lieu of remedial actions should only be used in cases where
DOE has satisfied the community that further restoration is not feasible.
* End-use decisions should strive to reduce the amount of land requiring long-term
control.
Comment 4 states that "... additional remediation worker exposure of Alternative 6 is
significant and contrary to the Community Guidelines." Pltisc see response to Issue 3.
Comment 4 addresses the EPA requirement for PCB treatment for Alternative 6. Please see
response to Issue 7.
Specific responses to Comment 5 are provided under Issues 5, 6, 7, 8, 9, 10, and 12.
IML.CJi; 3-9 Sepicmhtr 15.
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ISSUE 3: RADIATION EXPOSURE TO WORKERS WILL BE HIGH FOR
ALTERNATIVE 6
Comment 1: Janet L. V -t, ,i;. f\V.ntt^n] Comments M- ' -•* the DOE Surface
Impoundments Project Public Meeting, Oak Ridge, Tennessee, July 15, 1997, with Notes
Added July 16, 1997; and Transcript of Public Meeting, July 15, 1997.
Most of iuy work involves evaluating radiation work and the associated dose. The choice
of Alternative 6 over Alternative 3 disturbs me for several reasons.
First consider the collective dose estimates. Altern?'ive "* is estimated to cost around 13
man-rem. while Alternative 6 costs 36 man-rem, nearly three times as much. Note that the
Alternative 6 estimate does not include the dose from babysitting the drums until they are shipped
to Nevada, and that the company doing the remediation is not constrained to use this method or
to keep under the dose estimates.
How much is [36] man-rem conceptually? According to a published DOE report, the
DOE complex and all of DOE in the United States, annual collective external dose ranged from
1.500 to 1,600 man-rem in the years 1990 to 1994. The 36 man-rem would increase that total
by about 2.5 percent.
The ORNL annual collective dose was between 40 and 45 man-rem for the years 1993 to
1995 and was 59 man-rem last year; the 36 man-rem for Alternative 6, if most of the work were
done over a year, would thus nearly double the typical annual collective dose for ORNL, and
would increase it by 60 percent over last year, a very high year. This would mean that ORNL's
typical contribution to the DOE collective dose would be increased to about 80 man-rem. or about
five percent of the typical total.
Second, consider the individual worker's dose. \.".. : does 36 man-rem mean when we
consider individuals? If the work is done over about a year, is that one rem to each of 36
people? Is it 2 rem to each of 18 people? Three rem to each of nine people? In each of the
years 1992 to 1994 in the DOE complex, between 40 r.nd 90 people received 1 to 2 rem of
external dose; having 36 people receiving a rem woulc :hus increase that number by 40 to 90
percent. In those years, nobody in the DOE complex got between 2 and 3 rem. And according
to the DOE report, only one person and in only one year got more than 3 rem. Obviously,
givine 36 people 1 rem or more, or fewer people more in a single operation is not typical of
work in the DOE complex.
IMI. CJi; 3-10 Wpeinhcr 15. IW
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In each of the years 1993 to 1995, ORNL': highest single dose was about 950 man-rem.
that is. just under 1 rem; in 1996 the highest dose was 1.3 rem, which only i person got.
Obviously, 36 people getting In. . . i Ceiling i rein etc.. would ' ic a huge increase
in the number of people ;r. the higher bracket at ORNL.
Possibly the collective and individual doses will be spread over more than one year. But
even so, this is a subsiantial chunk of dose to a relatively large rroup of people.
Well, third, if it is urgently necessary to remediate these impoundments, then surely it's
necessary to spend all that dose for the good of the community. As every person involved in rad
work knows, we sometimes have to give some dose to some people in order to save dose to other
people. In this case, those other people are mainly members of the public. But how much dose
to them is being saved? What is the dose to the maximally exposed member of the public if the
impoundments are unremediated? That's Alternative 1 How many people would get a dose
uver, say, 10 mrem"7 I ujn't know, as these numbers do not appear in the DOE fact sheet, only
risks; but the risks have wrapped up in them the assumptions of particular scenarios, usually very
conservative ones.
Still, the doses are presumably fairly significant, or why remediate at all? Significant, that
is, if the water is lost, if the wind is blowing in the right direction, and so forth. Then what are
the respective doses to the members of the public from Alternative 3 as compared to Alternative
6? We are not told what these are, but the risks for these two are given in the fact sheet as the
same over 30 years. Why would there then be a preference for Alternative 6?
The bottom line seems to be that the state wants the radiation to be out of there, period,
end of sentence. That is because to have it off the site and completely out of Tennessee would
leave the site pristine and available. A baby could play in the grass growing on the site. But
available for what? It makes sense to insist on cleanup for a site like K-25 which has lost its
r.ission and would be a community asset if it were made unrestricted or at least only lightly
limited industrial use. But ORNL is not something that's supposed to go away in 30 years. Its
mission is not ended yet. For example, ORNL and DOE are looking for ways to extend the
[High Flux Isotope Reactor's] life another 30 years. .' hy is it that if today we clean up the
surface impoundments to where they no longer constitute a threat to the public or worker health,
we must clean them up to pristine standards and must achieve that today? Why clean up an area
to final release criteria (which, per DOE Order 5400.5, aren't supposed to apply until the area
is actually released), until it is released? I submit that this is not justified.
IM1. OH 3-11 Scplrmher 15 l«*»7
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Also, the AL.ARA process, as described and required by 10 CFR 835 (occupational and
rad protection), DOE Order 5400.5 (protection of the public), etc., has not been applied here in
a rigorous form. Optimization proce .. as described in the » us authr ::ive rau r. ..ection
standards and reports, do not appear to be employed in the way that one would expect to see.
This is why the more costly alternative from the money and dose point of view, and the more
dubious, from the technical point of view, seems to be chosen on a single basis—tc get the
ladioactivity out of here. This is a pretty parochial view tor o ir radiologically sophisticated
community to take.
DOE Response: DOE agrees that the cumulative dose to all workers during the remedial
.-iction for the selected remedy will be higher than the dose would be if Alternative 1 (no action)
or Alternative 3 were selected. However, doses will be received over a 4-year period and annual
doses will be reduced accordingly. Controls will be maintained to ensure that no individual
worker receives a dose in excess of allowable DOE or regulatory limits. Furthermore, the
remediation contractor will be required to develop and implement remedial design and health and
s^iciy work plans will institute procedures to ensure that doses to workers implementing the
selected remedy are ALARA. Although upcoming remediation of this site and other ORR sites
to meet the goals established in the June 1997 draft Accelerating Cleanup: Focus on 2006 will
require actions that expose a larger work force to more cumulative dose, this occupational risk
is considered necessary to better manage wastes that are currently releasing contamination to
groundwater and surface water and could potentially release contamination to the atmosphere.
Because exposures of each individual worker will be maintained within acceptable limits and
ALARA for the given remediation scenario, the benefits resulting from cleanup will outweigh the
risks.
DOE agrees that current exposures are acceptable and that extraordinary events (loss of
water cover or direct hit by a tornado) would be required to disperse airborne contamination that
would expose the community to an unacceptable dose. Thes-* -vents ?.re possible, and the
resulting exposed population and internal doses received would be severe. This low-probability,
high-adverse-effect scenario is one driver for remediation. Another is the continuing release of
contamination to groundwater and to White Oak Creek.
DOE also agrees that exposures after completion of Altermtive 3 would be no greater than
exposures resulting from Alternative 6 for the time frame (30 years) considered in the comment.
CERCLA requires consideration of long-term effectiveness, which favors Alternative 6. DOE
agrees that cleanup to "prisiine" standards is not necessary today to meet DOE requirements.
However, this would allow release of the site for other beneficial uses and would eliminate the
need for future actions to address the same wastes.
JT'«J"l»"0" !Ml. CJE 3-12 SepiL-niNrr If. I»T
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In summary, although DOE agrees that worker exposure, as evaluated under the CERCLA
shon-tetin effectiveness criterion, favors Alternative 3. this alone is not sufficient to warrant
selection ./. Alternative 3 over Al; ..native 6.
ISSUE 4: COST PROJECTIONS ARE INCORRECT FOR ALTERNATIVE 6
Comment 1: Mr. Unger, Transcript of Public Me*>t:n<;, July 15, 1997.
I have a question about the cost estimate .... You said that Alternative 6 is three times
Alternative 3, yet you don't know how you're going to treat this water for PCBs or sludge for
PCBs. and you also said that there's going to be a lot of other contaminants to be treated. Will
those contaminants be treated by an off-site or by a private company, or will they go through
[ORNL's] treatment system? Does the $64 million [for Alternative 6] include the programmatic
costs, or does that include the contractors coming and taking the waste away and treating it and
(Jibpjsing of this waste.' You want to presuppose maybe letting i contractor come up with an
idea there because I can't imagine that costing $64 million to do that job. I'd like to offer to do
that job for half that right now.
Comment 2: Mr. Brooks, Transcript of Public Meeting, July 15, 1997.
A concern about cost is that the estimated cost for [Alternative 6] was between $20 million
and $30 million, and now it's gone up to $52 million. Furthermore, we have said that the
numbers that we were using in the end-use exercise were consistent with the $6 billion budget
[proposed in Congress for DOE nationwide for FY 1998].
DOE Response: The cost projection of S53.1 million present worth in the proposed plan
is based on a detailed analysis of direct costs (equipment and materials needed, actions to be
pcrformed, crew sizes needed to perform those actions, personnel protective equipment, and
productivity losses necessary to ensure adequate protection of remediation personnel) and indirect
costs (contractor profit and overhead, oversight personnel including profit and overhead, project
design and planning, and others). Contingencies were added to each line item based on the
assumed difficulty or uncertainty associated with the action. The capital and operating costs
(e.g., equipment, materials, worker salaries) are well defined and based on industry standards,
previously executed projects, and standard cost estimating procedures. The indirect costs (e.g.,
profit, overhead, inflation, discount rate) are based on the contracting methodology in place at
ORNL. The remediation contractor's costs in the estimate are on the order of half of the total
project cost.
i\i|. CJL 3-13 Sepicniher I?. :<
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The cost for treatment of PCBs and. potentially, fur RCRA hazardous materials was
estimated based on an assumed technology with adequate contingency to address any likely
treatment nic.iiod. Vendors win K* approached to propose any treatment technologies and
remediation methodologies that would meet ARARs and performance specification requirements.
Liquid wastes, pretreated by the vendor as necessary, are assumed to be discharged to the Process
W ;ste Treatment Plant at ORNL, adjacent to the SIOU site. DOE expects the selected vendor's
proposal to be 'ess than the costs used ;n the estimate.
The purpose of the cost projections in the proposed plan is to allow a comparison between
alternatives. The same team of engineers and estimators used the same methods for estimating
costs for all alternatives. The relative cost, with Alternative 6 about three times more costly than
Alternative 3. is considered accurate. Innovative contracting methodologies could significantly
reduce costs, but the relative comparison would remain the same. Pan 2 oi'this ROD shows the
revised cost estimates that reflect the M&l contracting methodology.
Disposal of treated waste from Impoundments A and B in an on-ORR disposal cell could
reduce costs by up to S3.6 million. If final revisions to EPA regulatory requirements allow (see
response to Issue 7), treatment of waste from Impoundments C and D for PCBs could be
eliminated, reducing costs by over S4 million. Even with these potential savings. Alternative 6
would be almost three times the cost of Alternative 3.
In response to Comment 2, the S20 miIlion-S30 million cost for off-SIOU disposal
previously presented to the End-Use Working Group was based on assumptions and a different
scope of work that are not considered valid in the proposed plan. Those cost estimates assumed
no treatment of waste before transport, no requirement to meet DOT containerization or transport
requirements, and stabilization of the sediment in the disposal facility at no cost. The difference
between the costs previously used and the current projections are not a significant change to the
S6 billion budget, but DOE Oak Ridge Operations will bav^ :c revise their budget before
remediation begins.
Cost was not a key factor in the selection of Alternative 6 as the selected rt;;.jdy.
Although more costly. Alternative 6 is the most app-opriate remedy for protection of human
health and the environment. To implement the remedy. DOE will select the most advantageous
contracting methodology and develop the most cost-effective design practical that meets the then-
current regulatory requirements.
n'«ui.w-ti-!M|.cjF. 3-14 Sepicmber 15.
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ISSUE 5: COST VERSUS RISK REDUCTION BENEFITS FAVORS ALTERNATIVE 3
Comment I- Signature Not LegiMe, Letter to Margaret Wilson, Ju1 20, 1997. See
AJso Issue 7, Comment 3.
The primary reason that Alternative 3 should be selected is that the projected risks are less
than i x 10* for either Alternative 6 or Alternative 3. >et ihe cost for Alternative 6.
S53.1 million (present vaiue) is 3 times or almost S37 million greater than the cost tor
Alternative 3 (S16.3 million). Selection of Alternative 6 will allow less restricted use of about
2 acres of the 6-acre SIOU site. The difference in remediation costs necessary to reduce, but not
eliminate, industrial land use restrictions comes to over $18 million per acre. Even in the main
area of ORNL. property is not worth this investment.
Although no engineered facility can be guaranteed forever, the proposed plan states that
the Alternative 3 cell will be protective as long as institutional controls are maintained. The risk
assessment in Table 1 indicates that the risk at all receptor locations is less than 1 x 10" for
Alternatives 3 and 6. In other words. Alternative 6 offers no better long-term reduction of risk
as long as institutional controls are maintained at the site for Alternative 3. Even if maintenance
is discontinued, a properly designed disposal cell will last for hundreds or even thousands of
years if no one deliberately disturbs the ccr.tainment features. This level of protection will
eliminate the risk from direct radiation from short-lived gamma emitters which will decay to
nonhazardous elements. The transuranic elements would only be hazardous if they become
airborne. Substantial erosion or intrusion would be needed to expose significant quantities of
transuranics to the atmosphere. The long-term effectiveness of Alternative 3, while not as high
as Alternative 6, is sufficient to preclude tripling the costs to ship the wastes out of Tennessee.
Although the [End-Use Working Group's] goal to reduce the number of sites requiring
lone-term institutional controls and maintenance is admirab'e, there is not enough funding
available to greenfield all currently contaminated sites. In borne cases, remediation in place is
warranted, particularly when risk reduction is the same and significant funds can be saved for
remediation of ether sites SIOU is such a case where remediation in place (Alternative 3) is
warranted and the coato for shipping waste out of my back yard (Alternative 6) is not warranted.
DOE Response: DOE agrees that risks to workers and the public are the same for
Alternatives 3 and 6, while institutional controls for Alternative 3 are effective. DOE also
recognizes that costs for Alternative 3 are much lower. In the vry long term (i.e.,
> l.uOOyears). short-lived radionuclides would have decayed awa., and risks from direct
exposure to gamma radiation would be negligible. However, if institutional controls are lost, an
rr"ntf>r IMI. or 3-15 v-jxemhei 15. i«w:
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inadvertent intruder would be subject to unacceptable risks from inhalation of long-lived alpha-
emitting transuranic radionuclides. The selection of Alternative 6 eliminates the need for
permanent institutional controls .. .usus in .he scope of this proje.
ISSUE 6: SHORT-TERM RISKS FAVORS ALTERNATIVE 3
Commert 1: Signature Not Legible, Letter to Marciret Wilson. July 2U, 1997. See
Also Issue 2, Comment 1; Issue 8, Comment 1.
[T]he short-term risk to workers for constructing and operating two treatment facilities and
transporting waste across the country must be significantly greater than the simple operations
proposed for Alternative 3. The remediation and attempted treatment of the K-25 Pond Waste
cost several times the original estimates and resulted in the death of a remediation worker, not
from radiation exposure, but from a simple industrial accident. The likelihood of such an
accident is far greater fur Alternative 6.
DOE Response: DOE agrees that short-term risks favor Alternative 3 as stated in the
above comment. However, key factors for determination of the selected remedy were long-term
effectiveness, reduction of toxicity and mobility through treatment, and state acceptance. DOE
believes the short-term risks are controllable through the use of ALARA studies, engineering,
design, and operations.
ISSUE 7: TREATMENT OF PCBS, REGULATORY ISSUES
Comment 1: Mr. Brooks, Transcript of Public Meeting, July 15, 1997.
[PCBs] are officially designated as B-2 carcinogens, evidence of cancer in test animals,
no evidence in humans. They actually are probably not f..r different than the B-l carcinogen
known as saccharine. I would suggest that the public apply coercion to EPA as to that rather
ridiculous requirement where you have to reduce something by a factor of 25 over [a disposal
facility's waste] acceptance criteria before you can dispose of it.
Comment 2: Ms. Gawarecki, Transcript of Public Meeting, July 15, 1997.
If EPA can issue waivers under CERCLA action, why cannot there be a reasonable waiver
for the TSCA issues whereas the higher PCB waste could be treated to bring it down in line with
the impoundments that have lower levels of PCBs, which some are considerably higher than
IMLXJE 3-16 September 15.
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2 ppm. You know, this is a situation where the regulations really g»t in the way of getting the
job dor.i effectively. I think that EPA needs to recognize that and work with it.
It's my understanding that.. ^ ine waste in the two b...-.ier pond. ..wt has the mgher levei.
of PCBs. Would there be a waiver available, for example, if that waste were to be pumped into
the larger ponds and then composite samples taken?
(In response to EPA presentation of EPA requirements, see r"sponse below.) Okay. Well.
be sure and send us all the house and senate bill numbers so we can write in support of this.
Thank you.
Comment 3: Signature not legible, Letter to Margaret Wilson, July 20, 1997.
Alternative 3 does not need to meet [the] unnecessary and costly PCB treatment
requirement thac does net reduce overall risk. PCB treatment is, however, required to comply
with applicable regulations for Alternative 6. If treatment does not sufficiently reduce PCB
concentrations, then the waste will remain classified as TSCA waste, there will be no disposal
facilities that can accept the waste, and the waste would have to be stored indefinitely with
associated maintenance costs and risks of releases not accounted for in the proposed plan.
DOE Response: DOE agrees that, although PCB treatment will reduce toxicity, the
contribution to overall risk from PCBs is negligible, and any of the disposal options considered
(including Alternative 3) would adequately contain the PCBs present in the was"* without
treai.iism. Howevei, if waste is removed from a site and transported off site, CERCLA will not
allow waivers from meeting any applicable regulations. If further characterization confirms
current data showing Impoundments C and D contain TSCA-reguIated waste, once the waste
leaves the site EPA cannot waive the TSCA requirements.
EPA has proposed revisions to the TSCA rules regarding treatment of PCB waste that may
offer some relief to the treatment requirements. The new rules are scheduled to be promulgated
in the first quancr of fiscal year 1998. If the new rules are promulgated before Impoundments
C and D are remediated, DOE will incorporate the modified requirements into the remedial
design and remedial action planning documents for Impoundments C and D, as required.
If the wastes from Impoundments C and D are removed and placed into Impoundments
A and B. all of the waste would be regulated under TSCA.
ijiWOT IM1. CJI: 3-17 Sepicmhcr
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If resampling Jata indicate that rhe concentration of PCBs in the waste remc ed from
Impoundments C and D is < 50 ppm, the waste would not be regulated under TSCA and the
:reatmen' '?quirei... >ould r^ ' -^"er apply
ISSUE 8: TREATMENT OF PCBs, TECHNICAL IMPLEMENTABILITY ISSUES
Comn-^nt I: Signature Not Legible, Letter to Mary-.,.. Wilson, J'jJy 20, 1997.
The technical implementability and regulatory uncertainties for Alternative 6 should
preclude its selection. Treatment of mixed waste containing gamma emitters and transuranics to
reduce PCBs to 2 ppm. as would be required for Impoundments C and D, has never been
performed full scale.
DOE Response: As noted in the comment. DOE is not aware of any fully developed
fe.->tment technologies .hat have been demonstrated u reduce PCC concentrations < 2 ppm in
sediment contaminated with fission products and transuranic elements. The activity levels of
radionuclides in Impoundments C and D are very low, thus reducing the concerns regarding
mixed waste treatment somewhat. DOE intends to solicit proposals from private industry to
propose technologies that will meet the then-current regulatory requirements (see response to
Issue 7) based on the final characterization of the waste. Based on the proposals, the remedial
design including the DOE-recommended technology will be submitted to the regulators for
approval. If necessary, a treatability study will be performed to ensure that the selected
technology will meet all regulatory and disposal facility requirements. DOE believes that the
uncertainties regarding PCB treatment can be reasonably addressed within the cost allocated to
this phase of the project and that no revisions to the preferred alternative are necessary.
ISSUE 9: TREATMENT OF RCRA HAZARDOUS WASTE, TECHNICAL ISSUES
Comment 1: Signature Not Legible, Letter to Margaret Wilson, July 20, 1997.
[I]f it is not knwn whether Impoundments C and D are RCRA hazardous, how do you
know if the waste can be treated to meet RCRA Lard Disposal Restrictions?
DOE Response: DOE agrees that if the waste in Impoundments C and D is characterized
as RCRA hazardous based on new sampling data, the waste would have to meet RCRA LDRs
before disposal. As discussed under the response to Issue 8, DOT- will request treatment
proposals from vendors based on final waste characterization results. Vendors may choose to
treat the waste on site to meet RCRA LDRs (if applicable). In addition, Envirocare will accept
rn>»«-(IT IMI. CJi: 3-18 Scpun-.her 15. |wi-
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mixed waste for treatment and disposal provided PCB and radionuclide concentrations are within
acceptable levels. After treatment by the vendor for PCBs (if necessary based on new
characterization and then-current regulations), wastes from Impoundments C and D are expected
to meet Envirocare waste acceptance criteria for treatment. As an option, Lnvirocare could then
treat the wastes, most likely using a stabilization process, to meet RCRA LDRs and other
Envirocare disposal criteria. DOE expects that the waste will pass TCLP without treatment and
uas not included addkio..J treatment costs fa' mixeu wjiir treatment. Howe.cr. even if
treatment is required, overall project costs will not significantly increase because of the small
volume of waste in Impoundments C and D. DOE believes that the uncertainties regarding waste
that may be classified as RCRA hazardous are acceptable and that no revision to the preferred
alternative is necessary.
ISSUE 10: AVAILABILITY OF DISPOSAL FACILITIES, STORAGE
Comment 1: ORREMSSAB, July 9, 1997.
On page 10 of the Proposed Plan, it is stated that "Waste would be solidified into
containers meeting DOT requirements and staged on the SIOU site for curing and transport.
After curing, waste would be immediately shipped to the disposal facility." These statements
presume that either tNTS], an on-site waste management facility, or some other facility will be
available when remediation of the impoundment begins. ORREMSSAB hopes that this is the
case. It would be undesirable to store the treated sediments in DOT containers indefinitely.
Comment 2: Janet L. Westbrook, [Written] Comments Made at the DOE Surface
Impoundments Project Public Meeting, Oak Ridge, Tennessee, July 15, 1997, with Notes
Added July 16, 1997.
If the drums of Alternative 6 are generated but cannot be shipped to NTS immediately,
then where will they t tored? Have the costs of building and maintaining a warehouse for them
for several months or years or even decades been considered?
Comment 3: Ms. Walton, Transcript of Public Meeting, July 15, 1997.
I like the NTS thing, and if it's only a DOE order [that prohibits ORNL from shipping
waste to NTS], you should be able to get them to change it. I would hope that would be a
feasible equity-type consideration with regard to the ROD that's coming out of the waste PEIS.
Because if you can't store at NTS, then possibly [Alternative 3] would be better, or we might
07 I Ml. OF. 3-19 September 15.
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need to do some more work. Because 10,000 years is a long, long time, and you don't want
to have to have institutional controls on anything that long because you cannot guarantee the long
life of the institutions.
And ... I do have one question. The funding for the NTS disposal versus the funding for
the on-site cell. Is that a wash? Do they cost the same?
Comment 4: Mr. Pride, Transcript of Public Meeting, JuJy 15, 1997.
You indicated that you would not favor going out and solidifying the Nevada option, and
I disagree with that. I think if the process is done correctly you will not have the ground
situation you have at K-25. if you use the correct process control on this. And above-ground
storage or enclosed storage certainly are going to be an alternative in here, relative to no action.
because the Nevada Test Site might not be available from the regulator standpoint.
So I very strongly disagree with no action, if Nevada i., not available. I think we should
include the possibility of the storage here either on concrete pads, as the other transuranic
contaminants are stored, or other options, and go ahead and do this and get this action done.
Comment 5: Signature Not Legible, Letter to Margaret Wilson, July 20, 1997.
[NJone of the proposed disposal facilities can currently accept the waste from
Impoundments A and B. Radionuclide concentrations are too high for Envirocare. ORR is not
on the NTS list of approved generators and the state of Nevada is fighting additional shipment
to the state. The proposed disposal facility on ORR may never be approved and built, and if it
is, may not accept wastes from SIOU. If neither facility is available to accept SIOU wastes, then
either the project would be delayed and releases to the environment would continue or the waste
v ^uid have to be stored indefinitely at great expense and rr-k akin to the K-25 Pond Waste
Management Project. Alternative 3 could be implemented immediately with none of the technical
and regulatory uncertainties.
DOE Response: DOE agrees that as of the date of this ROD, no facilities are available
that can accept treated waste from Impoundments A and B tor disposal. DOE believes that it is
highly likely that NTS will be authorized to accept waste from ORR by the time remediation of
those impoundments is scheduled to begin in FY 2000. There is also uncertainty regarding the
availability of a mixed waste disposal facility on ORR that can accept olOU wastes, but the
possibility exists that such a facility will be available.
rr-«>nw-|i- IMI. or. 3-20 Vpiemher 15. IW
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Comment 3 suggested that the administrative impediments to disposal at NTS are internal
to DOE and should be overcome. DOE agrees and expects this will occur, but the decision is
a nationwide issue that is outside the control of this project.
Comment 3 requested a comparison of disposal costs at NTS versus an on-ORR disposal
facility. The proposed plan stated that cost savings of u,> to S5.5 million would result from
disposal on ORR. This was based on expected saving k transportation, overhead, and
contingency and assumed that there would be no disposal fee a: any on-site facility. Current
DOE policy is to consider that capital construction costs for an on-site facility would be funded
separately, and that remediation projects would be assessed a fee of S200/ydJ for disposal. This
would reduce the projected savings to about S3. 6 million.
Comment 4 suggests that remediation of the impoundments should continue regardless of
the availability of disposal capacity, and that waste removed should be stored after treatment.
DOE and several commentors disagree. Such storage would require acres of enclosed storage
facilities, more robust (and more costly) containers, multiple handling and transportation
operations for the same containers, and surveillance and maintenance of the storage facilities and
waste. This would greatly increase worker risk and restrict land use for the interim period until
disposal capacity is available. Total present value costs would increase by almost S7 million.
DOE has determined that no changes to the preferred alternative are appropriate based on
the availability of disposal facilities.
ISSUE 11: EFFECTIVENESS OF DISPOSAL AT NTS, CONTINGENT DISPOSAL AT
AN ON-ORR DISPOSAL FACILITY
Comment 1: ORREMSSAB, July 9, 1997.
If it is determined that an on-siie waste managp'neii. f ':iity can be safely operated at
[ORR] and that waste acceptance criteria include the surface impoundment sediments, it would
be preferable to dispose of the impoundment sediments on-site rather than at an off-site location
because of reduced risks of transportation accidents and reduced costs.
Comment 2: Ms. Walton, Transcript of Public Meeting, July 15, 1997.
What yt>j just said [NTS is in the middle of a desert, there's no public within miles, it's
a dry atmosphere] is a very good reason not to have an on-site disposal cell. F am opposed to
that part of Alternative 6.
IML Of: 3-21 fcpiemhcr 15. !«"7
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This idea of an on-siie cell as a disposal si'e isn'i very much different from an
Alternative 3 solution. So I would be very unwilling as a taxpayer to do an Alternative 6, and
then put in an oil-site cell. Because we do have the wrong hydrology and et cetera to have a
long-term storage of this kina 01 stuu here in Oak Ridge.
Is the on-site disposal cell for a panicular class of waste, maybe small level? Because,
you know, a lot ot this stuff is lower-level stuff and this 's vc.y hi^i <»ctivit\. So I don't like that
you're mixing high activity material with low activity material, and then having low activity
material stored in on-site cells is an awful lot different than storing high activity.
Comment 3: Ms. Gawarecki, Transcript of Public Meeting, July 15, 1997.
About 10,000 years age there was an event known as a Pluvial in which all of the
enclosed basins out West and Nevada and Utah were giant lakes. So keep in mind [geologic
changes that can occur] in 10.000 years time.
DOE Response: DOE agrees with Comment 1 that on-site disposal would be preferable
to disposal at NTS if such a facility is available when needed and SIOU wastes meet the waste
acceptance criteria.
DOE understands the concern expressed in Comment 2 that disposal in Tennessee is not
as secure as disposal in Nevada based on climate, hydrogeology, and population. These issues
are being considered and analyzed in a separate CERCLA decision-making process regarding the
evaluation of waste disposal alternatives. On-ORR and off-ORR disposal are being thoroughly
reviewed, and a RI/FS and a proposed plan will be available for review by the public. These
documents will evaluate the on- and off-ORR options based on all CERCLA criteria. If the ROD
for the waste disposal alternatives selects on-ORR disposal based on analysis of CERCLA criteria
including public input, and if SIOU wa«'e meets on-ORR disposal facility's waste acceptance
criteria, it is presumed that disposal at such a facility would be safe and acceptable. Therefore,
designation of an on-ORR facility as a contingency disposal site is considered reasonable and
appropriate.
DOE recognizes the information provided in Comment 3.
JTor.W(p|ML.CIE 3-22 S«T»rn,her 15. IW
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. ISSUE 1?: LAND oSE ISSUES
Comment 1: Mr. Brooks, T<"»nscript of Public M""';ng, July 15. 1997
I have a question on cost. Offhand comment that roughly [S35 million] an acre is a high
price to pay for land. I would point out that the [End-Use Working Group] did not recommend
5 i'ernative 6, and Alternative 3 would fully meei their '...:.i. which was not to leave any
exclusion areas. I think, as indicated, [Alternative 3] will be a satisfactory recreational area.
Comment 2: Signature Not Legible, Letter to Margaret Wilson, July 20, 1997.
Alternative 3 meets land-use recommendations and guidelines established by the [End-Use
Working Group] as reported in The Oak Ridger on June 16. 1997. In particular, the [End-Use
Working Group] states that "waste should be relocated only to reduce total risks to people and
the environment." Alternatives matches this guideline much better than Alternative 6.
Recommendations for Bethel Valley Watershed land use are "... it is essential that DOE
remediation decisions achieve, at a minimum, a controlled industrial end use for the entire ORNL
Bethel Valley area. A controlled industrial use should at least provide for surface use of
contaminated lands." Alternative 3 meets this standard. [End-Use Working Group] land use
recommendations continue: "Currently, thj:; are areas where contamination results in the need
for controlled access. Reducing such areas would enhance the overall viability of the laboratory.
Remediation should result in lands that are safe for surface use by laboratory employees."
Alternative 3 meets this standard. "DOE should make the best practical use of existing
browntields while recognizing that not all land needs to be available for every use. If situations
occur where DOE cannot meet the surface use criteria due to excessive risks or costs, these
exceptions need to be discussed openly in a public forum." Alternative 3 provides the fullest
release possible for two thirds of the 6 acre site. The remaining 2 acres would be available for
surface use, proviu<.J no excavation, drilling, or structures penetrate the consolidation cell.
Alternative 3, therefore, already meets the surface use cutenon tor the entire site and exceeds
the criterion for 2/3 of the site. The extra S37 million necessary to allow building construction
on 2 acres in ORNL is not warranted given the availability of underutilized buildings at the East
Tennessee Technology h'ark. the declining missions and excess facilities at Y-12 and ORNL, and
the releases of significant acreage (for example, the Parcel A golf course and subdivisions and
the 1,000 acres at Parcel ED-1) of [ORR).
DOE Response: DOE recognizes the high cost of reducing restrictions on the small area
of land that would be permanently impacted by the consolidation cell .n Alternative 3 by shipping
the waste off site per Alternative 6. This cost is justified, in part, because of the unique nature
rinun-J-ii-: i\i|. OF 3-23 September I?. I*""1
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of the property in rhe heart of ORNL. The facility across the street is the High Temperature
Materials Laboratory'. ORNL's long-term plan is to construct an advanced materials
characterization laboratory at the site of SIOU. A consolidation cell could interfere with
development of this or other facilities in their optimal locations. In addition, the selected remedy
was determined based on all of the nine CERCLA evaluate criteria, and not just on cost and
associated land use issues.
ISSUE 13: MISCELLANEOUS ISSUES AND RESPONSES
Comment 1: ORREMSSAB, July 9, 1997.
In descriptions of the preferred alternative (Figure 4 and Page 10), there is discussion that
sediment from Ponds A and B would be removed and allowed to settle in a settling tank. After
settling, the supernatant would be decanted from the tank and returned to the impoundment.
S,;;ietime later, the impoundments would be back-filled with clean soil. There is no discussion
about what would happen to the supernatant. Would it b- treated? Would it be allowed to
percolate into soils and groundwater? The [ROD] needs to specify that any significantly
contaminated supernatant would be treated before release.
DOE Response: DOE agrees. The proposed plan states on page 7, column 1, second full
paragraph that "all water removed from the impoundments will be treated at the existing
[PWTP]." The FS provides additional detail regarding the treatment sequence and the discharge
of all water to PWTP. The description of Alternative 6 in this ROD has been modified to clarify
that surface water in the impoundments will be treated at PWTP.
Comment 2: ORREMSSAB, July 9, 1997.
In Table 1, the short-term effectiveness of the preferred alternative is described as having
the potential for ver, !.;feh, adverse short-term effects. The [ROD] needs to describe how this
potential will be avoided or mitigated.
DOE Response: The proposed plan states on page 14, paragraph 2 under "Short-term
effectiveness," that "For Alternative 6, short-term risks to remediation workers and the public
along the transportation route would be controlled to acceptable levels through compliance with
Occupational Safety and Health and DOT requirements, DOE as-low-as-reasonably-achievable
principles, and project specific health and safety plans as for Alternative 3. However, much
greater control would be needed than for Alternative 3. and more intensive handling of
radioactive waste would significantly increase worker exposure to radiation and the potential for
m»*i
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spills or other releases. Transportation of waste would increase the likelihood of accidents." The
analysis remains accurate, and the mitigation proposed will control risks to acceptable levels.
DOE req~ -ements such as spill prevention, control, c ,r,tainment, and cleanup plans; waste
management plans; operationa. .^adiness reviews; and .....er overs.0.n requirements will h^.^
mitigate risks. See also response to Issue 3 comments.
Comment J: .Mr. Jernard, Transcript of Public Meeting, July 15, 1997.
What is the maximum exposure that you expect a citizen, a nonworker, to receive over
the life of [the Alternative 3] cell?
DOE Response: Assuming that there is no failure of the engineered consolidation cell
over the life of the risk and no intrusion into the cell, no exposures to workers or the public
would result from the waste contained in the cell.
Comment 4: Ms. Greer, Transcript of Public Meeting, July 15, 1997.
Can you compare [Alternative 3J to ... [the] Y-12 ... S-3 ponds which are now a viable
... parking lot. Ms. Walton. Transcript of Public Meeting. July 15, 1997. I attended a meeting
on that recently. The problem is the cell hitting the groundwater. So that's why the state wants
them to do something better than that here because it's very hard to guarantee institutional
control for 10,000 years because institutions don't last that long.
DOE Response: A cap was placed over the S-3 ponds at the Y-12 Plant and a parking
lot was constructed on the cap. No liner was placed under the wastes at the S-3 ponds.
Significant quantities of contamination, mostly uranium, technetium, and nitrates, were released
to groundwater before the S-3 site was capped. These contaminants continue to migrate
downgradient. New releases since placement of the cap have been greatly reduced. Alternative
3 proposes removing the wastes from SIOU, constructing a liner at the former location of
Impoundment A with a double leachate collection/detection system, replacing the wastes in the
liner and constructing a cap. This would contain the wastes th*t have not already beer. '•"leased
much more effectively than the cap at the Y-12 S-3 ponds. The cap at SIOU could be used as
green space (e.g., grass and picnic tables). It is possible that a parking lot could be constructed
on the cap, but that would depend on the final configuration of the consolidation cell, the
elevations if the cap and the surrounding roads, and other considerations.
IMLCIEl 3-25 September 15. IW7
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Comment j; Ms. Gawarecki, Transcript of Public Meeting, July 15, 1997.
[If] this waste does not meet the criteria to be TRU wiste. could [it] then be treated under
the [request for proposals c J Aaste] mat was just dibC»ss. ...-r this evening?
DOE Response: There is a potential, depend;ng upon the selected technology for
treatment of TRU waste, that SIOU waste could i -' ir.aied using ih<. saj.ie technology and
equipment. Treatment of wastes other than TRU waste has not been considered in the TRU
RFPs. Many details would have to be considered to make use of the TRU facility including
schedule and availability, transportation of sludge, and cross contamination. This idea will be
considered during remedial design.
Comment 6: Ms. Gurney, Transcript of Public Meeting, July 15, 1997.
I wanted to ask a question about the cleanup criteria. We've talked about the
groundwater becoming contaminated because it had a connection with the sediments when the
groundwater levels rose. That says, to me. there's a connection through the clay. Therefore,
I'm wondering have we located the bottom, the depth of contamination, and also, if not, then
how are we calibrating our model that is going to predictably tell us what we've got to clean up?
We don't have any even source term, from what I understand, because we don't have a
good random sampling that will allow us to know that from the top to the bottom what
contamination we're dealing with throughout the pond. My question is, how can you calibrate
the model without proper sampling?
A lot of us here may know that those kinds of contaminants are not going to travel very
far through this type of matrix, and one thing that I'm wondering why it wasn't looked at is why
not look at lowering the groundwater level there just to keep that—you know, a couple of more
alternatives.
DOE Response: The prediction of the radionuclide concentration at a hypothetical
receptor location on White Oak Creek was determined for various levels of sludge removal and/or
stabilization in the impoundments by assuming the following elements:
• assessment of contaminant volumes and radionuclide concentrations from existing
sampling data:
~: IML.CJl 3-26 SffHetnber '5
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• source-term modeling to determine the leaching of hazardous constituent from the
impoundments and release to the surrounding soil, bedrock, or man-made features due
to groundwater int .1. »icn :\.c waste;
• groundwater flow and transport modeling from the impoundments to White Oak Creek
(wher? the near-surface groundwater has been fhown to discharge); and
• estimation of modeled contaminant concentrations at White Oak Creek resulting from
surface water dilution of the groundwater flux of contaminants by the Creek's flow.
Because of uncertainties associated with the hydrogeologic system underlying the surface
impoundments and the leaching characteristics of the contaminated sediment, conservative
assumptions were applied to ensure that the predicted concentrations were not underestimated.
In addition, the predicted concentrations from the model were compared with actual samples from
White Oak Creek a:id the surrounding groundwater monitoring wells, and there was good
correlation between the two results.
For source-term modeling, it is assumed that lateral groundwater flow contacts the waste
after liner failure, which releases contaminants from the sediments. Contaminant releases are
modeled using a surface rinse with a solid-to-liquid partitioning mechanism (Kp) for unstabilizeo
sludge and a matrix diffusion-controlled mechanism (effective diffusion coefficient, De) followed
by a surface rinse without partitioning for cement-stabilized sludge. Contaminated groundwater
flow in the stratigraphic units underlying the impoundments and the flow regime to White Oak
Creek were then modeled.
For groundwater transport from the impoundments to White Oak Creek, a conservative,
but realistic, scenario is assumed. Contaminated groundwater travels 30-300 ft in or around
groundwater suppression pipes and storm drain lines urri! it discharges into White Oak Creek.
To complete the transport pathway, an effective 3-in (iG-ft) soil/upper bedrock pathway is
incorporated to hydraulically connect the groundwater suppression and storm drain systems or
to represent other preferential flow paths through porous man-made features.
All radionuclides in the impoundments were modeled, and their relative impact on White
Oak Creek water quality was gauged by comparing modeling concentrations with criteria set forth
in 40 Code of Federal Regulations 141 and DOE Order 5400.5. Strontium-90, which is highly
mobile in the groundwater regime, was the only contaminant signif.rantly affecting White Oak
Creek's water quality. Therefore, this radionuclide was the only contaminant comprehensively
modeled to predict concentrations in White Oak Creek.
IML on 3-27 Stpicmtvr 15. I-WT
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The commentur suggested evaluating lowering the water table or evaluation of other
alternatives. Many other remedial technologies and alternatives were evaluated in the feasibility
study that were not presented ir J>fiil in the proposed -'-•' Lowering the •• - • - tabie was
among the technologies considered. That concept was determined to be ineffective because of
the hydrogeology at the SIOU site. The site is in a recharge area and receives groundwater from
most of the main ORNL plant area. Significant volumes of water would have to be pumped
-•oniinuo-.isly to keep the water table from encroaching «. sediment in it? current location.
This water most likely would need to be treated at great cost, l-unhermore. dewatering could
also draw water out of nearby White Oak Creek, and concentrate the contamination in the creek.
This concept was screened out of the feasibility study before development into an alternative.
Comment 7: Ms. Walton, Transcript of Public Meeting, July 15, 1997.
(Wjhen I got this I thought I had a plan and now ... I see it's called a fact sheet ....
And when I heard about the dosage I started looking through this. Well. I didn't see that
in here anywhere. Because my first reaction when I got this, I looked at it. and I looked at your
response to the state, and the EPA comment was, "Welj, this looks pretty good," and I liked it.
DOE Response: The document is a final proposed plan. All recent proposed plans issued
in Oak Ridge have been presented in the "fact sheet" format. The dosage information discussed
in Issue 3 was based on information recently prepared at ORNL that was not reviewed by DOE,
considered in the proposed plan, or placed in the Administrative Record. The commentor,
though employed at ORNL, commented as a private citizen, not on behalf of ORNL or DOE (see
Issue 13, Comment 9).
Comment 8: Mr. Kinunel, Transcript of Public Meeting, July 15, 1997.
What was the risk level associated with the contamination or the migration [of]
contamination at present?
DOE Response: The surface impoundments are in an industrial setting typical of most
national laboratories, with institutional controls such as posted areas, fencing, engineering
controls, and security features. Access to contaminated areas is restricted, and employees
entering SIOU are medically monitored. Because of these active institutional control measures.
risk levels to current human receptors are acceptable and well below EPA criteria.
/TiluiN-i|7 !M|. Oi: 3-28 September 15. IW
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Ecological risks are unacceptable only for those receptors (e.g.. fish) living in the
impoundments, and to birds and mammals thai eat those fish. Institutional controls are in place
to discourage p- ' *;on by fish-eating animals. The :lude small r"»sh fenr:~^ to prevent the
entrance and exit of frogs, snak . .artles. etc. and a gri ..k of v.; . jbove in.. ...ipoundrr.
to deter the entrance of water foul and other birds.
Comment 9: Janet L. Westbrook, [Written] Cup .^its Made &. the DOE Surface
Impoundments Project Public Meeting, Oak Ridge, Tennessee, July 15, 1997, with Notes
Added July 16, 1997.
As I noted as an aside in the meeting, I did not have time to go into the detail* of how an
optimization (ALARA) study, which is part of the ALARA process, would have been done for
a project such as this. However, such a study should have been done as pan of the feasibility
study, (i.e., ALARA methods are supposed to be applied from 'he earliest conceptualizing of the
project, not just wh n the project is about to begin. In in oprrr^mion study, the cost and dose
estimates would have been handled first, then the criteria otiier than cost and dose would have
been evaluated in a ranking system established for the purpose.
DOE Response: ALARA methods were considered in the development of every
alternative in the FS. Significant attention was given to development of methods of
accomplishment that would reduce dose to remediation workers. The cost estimates included
substantial costs associated with personal protective equipment, reductions in productivity due to
dress-out requirements, shielding, remote operations, health physics and industrial hygiene
surport, and other safety considerations. ALARA opti-nization studies will be performed, as
appropriate, during remedial design. Under CERCLA, worker dose (as evaluated under short-
term effectiveness) and cost are only two of the evaluation criteria. Determination of the selected
remedy was based on evaluation of all criteria.
/TiiUi.«-||T IMI Cjl: 3-29 ' September 15. I'M?
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C 20460
Jut 15 I9f7 office or
SCU9 WASTE AND EMERGENCY
Pt:SPOMS£
f/EMURANDUM
SUBJECT: National Remedy Review Beard Recommendations on the
Surface Impoundment Unit for the Oak Ridge National Laboratory Site
FROM: Bruce K Means, Chair
National Remedy Review Board
TO: Richard D. Green. Acting Director
Waste Management Division . --
EPA Region 4
Purpose
The National Remedy Review Board (NRRB) has completed its review of the proposed
remedial action for the Surface Impoundment Operable Unit of the Oak Ridge National
Laboratory site in Oak Ridge, Tennessee. This memorandum documents the NRRB's advisory
recommendations.
Context for NRRB Review
As you recall, the Administrator announced the NRRB as one of the October 1995
Superfund Administrative Reforms to help control remedy costs and promote consistent and
cost-effective decisions. The NRRB furthers these goals by providing a cross-regional,
management-level, "real time" review of high cost (and thus potentially controversial) proposed
response actions. The Board will review all proposed cleanup actions'where: (1) the
estimated cost of the preferred alternative exceeds $30 million, 9r (2) the preferred alternative
costs more than $10 million and is 50% more expensive than the least-costly, protective,
ARAR-compliant alternative.
The NRRB review evaluates the proposed actions for consistency with the National
Contingency Plan and relevant Superfund policy and guidance. It focuses on the nature and
complexity of the site; health and environmental risks; the range of alternatives that address site
risks; the quality and reasonableness of the cost estimates for altanra'jves; Regional.
Stcte/tribal, and other stakeholder opinions on the proposed aciicns (to the extent they are
known at the time or review); and any other relevant fade. s.
Generally, the NRRB makes "advisory recommendations" to the appropriate Regional
decision maker before the Region issues the proposed plan. The Region will then include these
recommendations in the Administrative Record for the she. While the Region is expected to give
the Board's recommendations substantial weight, other important factors, such as subsequent
public comment or technical analyses of remedial options, may influence the final Regional
decision. It is important to remember that the NRRB does net change the Agency's current
• Prr.'.w n'T. Vecuaa* O. BistO inks O" 100% P.e-r. ceo Pawr (^0% Posico-.sumeO
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NRRB Advisory Recommendations
The NRRB reviewed the site package for the Oak Ridge site and dscussed related
issues with EPA Remedial Project Manager Ec'ward Carreras on July 30. 1997. Based on this
review and discussion, the NRRB:
• Finds that the Department of Energy (DOE) proposal does not adequately demonstrate
the cost effectiveness end environmental benefits of the preferred alternative (off-site
disposal). Based on the proposed plan, other alternatives are orotective and achieve
•entedial objectives at significantly lower cost.
• Finds (hat the absence of a site wide management plan impairs the remedy selection
process for this facility. The Board understands that DOE will conduct a number of
actions at the Oak Ridge reservation. In order to enhance the cost effectiveness of
overall site remediation, the Board strongly recommends a comprehensive site-wide
waste management plan be developed expeditiously. This plan should address the
feasibility of the centralized waste management facility described as a contingency under
alternative 6 in the proposed plan. However, development of this plan should not delay
timely and appropriate action for the impoundment areas.
The NRRB appreciates the Region's efforts to work closely with the State and community
to identify the current proposed remedy. The Board members also express their appreciation to
the Region for their participation in the review process. We encourage Region 4 management
and staff to work with their Regional NRRB representative and the Region 4/10 Accelerated
Response Center at Headquarters to discuss any appropriate follow-up actions.
Please do not hesitate to give me a caV if yc" h&ve any questions at 703-603-8815.
cc: S. Luftig
T. Fields
B. Breen
E Cotsworth
J. Cunningham
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UNITED STAVES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
:,-•:: ALAEAMA STREET. S VJ
ATLANTA. GEORGIA 20202-2:0.:
MEMORANDUM
SUBJECT National Remedy Review Board Recommend ""-ions rn the
Surfl^e Impoundments Operable Unit for the
Oak RJdge National Laboratory Site
FROM Richard D Green, Acting Director
Waste Management Division
EPA Region 4
TO: Bruce K Means, Chair
National Remedy Review Board
Region 4 has received the National Remedy Review Board's (NRRB) memorandum,
dated August 15, 1997, regarding the Surface Impoundments Operable Unit of the Oak RJdge
Reservation in Oak Ridge, Tennessee The Region has carefully reviewed the NRRB's input and
has considered it in addition to other input received on this project from the Department of
Energy (DOE), the State of Tennessee, the Oak Ridge Site Specific Advisory Board (SSAB), and
other stakeholders
In brief, the NRRB found that the DOE proposal for this operable unit did not adequately
demonstrate the cost effectiveness and environmental benefits of the preferred alternative (off-site
disposal). The NRRB further recommended that DOE "expeditiously" develop a "comprehensive
site-wide management plan." However, the NRRB further noted that this comprehensive plan
should not delay timely and appropriate action for the Surface Impoundments Operable Unit.
The Region fully understands the points made by the RRi.-. The Region initially concurred
with a proposal from the DOE for an alternative that would have resulted in the construction of
an on-site waste cell within the ^erable unit. The Region's support for this alternative was based
upon an evaluation of the threshold and balancing criteria of the National Contingency Plan
(NCP). However, information was incomplete at that time c-Mcerning the NCP's modifying
criteria: state acceptance and community acceptance. The three panics to the Oak Ridge
Reservation Federal Facility Agreement (FFA) agreed to embark upon a major public outreach
effort, through the SSAB, that resulted in the formation of the "End Use Working Group," made
up of local citizens and representatives of the SSAB. The purpose of this effort was to solicit
more public input prior to the FFA parties publicly noticing a preference for a remedial
alternative.
Recycied/Recyc^SK?. Pnr.K-d v.,;r. v«-g«?iab«e O>: 8aseO Inks on 100'.. Pec. k-0 ••>.!».»' i*O-.«
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The End Use Working Group began meeting in January 1997 and produced a set of
recommendations for th" Oak Ridge Reservation Bethel Valley area including the loc°':~ ~f the
^jrface impoundments, titled "Recomrnen^._..ons for the End Use ui Contaminated Lands in the
Bethel Vaiiey Area of the Oak Ridge National Laboratory." The SSAB also produced~a~?et of
recommendations for the Surface Impoundments and issued a letter stating their concurrence with
the preferred alternative presented in the final proposed plan (off «=••..' Hi-oosal) Copies of these
lettc and recommendations were included in the remedy selection onefing package provided to
the NRRB for the July 30, 1997, review of this project.
In preparation for the release of the final proposed plan, the Region had many discussions
with the DOE and State regarding consideration of the modifying criteria (state and community
acceptance) in addition to the other remedy selection criteria. It was the determination of the
Region that the off-site disposal option, which has the support of the State and community, was
the best alternative considering all of the nine criteria for remedy selection. The DOE decided to
issue the proposed plan for formal public review with off-site disposal as the preferred alternative
The Region has reevaluated its support of the off-site disposal remedy in view of the input
received from the NRRB. However, after consideration of all of the NCP's criteria - including
Mate acceptance and community acceptance - the Region has concluded that we should reaffirm
the appropriateness of our decision that the off-site disposal remedy (with an on-site disposal
contingency should a "Centralized Waste Management Facility" be approved and constructed
under a separate action) represents the best remedy. The need for timely action, the State's
strong opposition to other alternatives, the likelihood of reductions to the total cost based upon
our experience with other DOE projects, and the support of the SSAB were all significant factors
in reaching this decision.
The Region appreciates the efforts of the RRB in their review of {his project. If you have
any questions regarding this matter, please contact Mr. Jon Johnston, Chief, Federal Facilities
Branch, at 404/562-8527, or Camilla Warren, Chief, DOE Remedial Section, at 404/562-8519.
cc: S Luftig
T. Fields
B Breen
J. Woolford
E. Cotsworth
J Cunningham
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
[ • REGION 4
ATLANTA FEDERAL CENTER
ICC ALABAMA STREET. S.W
*'"• n»c"^ ATLANTA. GEORGIA 30303-3104
SEP 2 4 ".':!
MEMORANDUM
SUBJECT: National Remedy Review Board Recommendations on the
Surface Impoundments Operable Unit for the
Oak Rjuge National Laboratory
FROM: RJchard D. Green, Acting Director ^
Waste Management Division 1
EPA Region 4
TO: Bruce K. Means, Chair
National Remedy Review Board
Tl.c purpose of this nv.-morandum is to provide additional iiuormation in response to the
National Remedy Review Board's (NRRB) August 15, 1997 recommendations concerning final
remedy selection a: the Surface Impoundments Operable Unit of the Department of Energy (DOE)
Oak Ridge Reservation (ORR), Oak Ridge Tennessee As you know, DOE, with the support of the
Tennessee Department of Environment and Conservation and EPA Region 4, has proposed a
remedial alternative for these surface impoundments involving removal, treatment, and off-site
disposal of contaminated materials, with a contingent alternative for disposal at the centralized waste
facility at ORR now under consideration, in the event that such a facility is constructed.
As indicated in our August 21, 1997 memorandum to you, Region 4's support for selecting
this remedial alternative has been based upon consideration of all nine of the remedy selection criteria
specified in the National Contingency Plan, including the modifying criteria of state and community
acceptance to be applied before final remedy selection, as required by the NCP at 40 C.F.R.
§300.430(f)(4). In supplementation of our previous memorandum, we are herein providing additional
information to clarify the basis for our conclusion that this off-site disposal remedy meets the NCP's
cos' effectiveness criterion.
Pursuant to 40 C.F.R. §300.430(f)(l)(ii)(D), cost-effectiveness is to be determined by
evaluating a remedy's lonu term effectiveness and permanence, reduction of toxicity, mobility, or
vol.jme, and short term effectiveness to determine the reneoVs overall effectiveness. Overall
effectiveness is then compared to cost. A remedy is considered to be cost effective if its costs are
proportional to its overall effectiveness.
Cost and Potential Savings
The cost for the preferred alternative presented in the proposed plan was $53.1 million in
present worth value. The DOE has since refined this estimate and the revised estimated cost is $38.7
Recycled/Recyclable « Pnnled with Vegetable OH Based Inks on 100% Rpcyciea Paper (40% Posloonsumer)
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million in present worth value. The differences in cost are due to the elimination of certain
contingency factors built into DOE's cost estimates and ^ change in overall site operations strategy
from a Management and Operations Contr-ctor approach to a Managemen* ind Integration
Contractor approach. However, in evaluating the overall cost-effectiv'eness of this estimated outlay
of S38.7 million, one must consider a number of factors which will offset this initial outlay by added
future value and/or savings which will be realized from implementatior, of this alternative
The cost of the remedial action will be partially offset by the value of rcutilization of the
specific parcel of land currently occupied by the impoundments The DOE currently has preliminary
plans for the use of that parcel for a new. research facility. Beneficial reuse of this land parcel, located
within the heavily industrialized portion of the Laboratory, will help to ensure the overall continued
economic contribution to the local and regional economy
The cost of the remedial action will be additionally offset by the continued viability and
desirability of the overalJ Laboratory for future use The Oak Ridge National Laboratory is a national
resource that has historically distinguished itself by making many significant contributions to national
research and development efforts This Laboratory' and its highly s^ iiled scientific community is a
major economic engine supporting eastern Tennessee Relocation of these waste materials will avoid
stigmatizing the Laboratory area by commingling waste disposal areas with research facilities This
will help maintain the attractiveness of the facility and thereby enhance the likelihood that it will
continue to be a national scientific resource.
Utilization of a centralized waste disposal facility (either off Oak Ridge Reservation or, under
the contingent scenario, within its boundaries) will significantly reduce overall DOE costs for
maintenance, monitoring, and other controls, when compared with the need to maintain many smaller
disposal cells. The Reservation is pursuing a strategy where CERCLA generated wastes will be
consolidated into one large (1 million yds3) modem waste management facility. The utilization of one
large facility is expected to result in a lower cost over the long term than'would numerous small and
scattered disposal cells. Significantly, such consolidation of radioactive waste, including use of both
off-site disposal and centralized on-site disposal in combination, has been key to the overall strategy
for remediation of other major DOE sites -- with the full support of EPA.
The preferred alternative also may avoid significant future costs which would be incurred for
readdressing remedial alternatives not in compliance with current Tennessee policy specifying a State
go?I that ORR radioactive wastes which require long-term institutional controls ultimately be
relocated. If maintained, this policy could cause future costs to be incurred for all disposal
alternatives except for the preferred alternative.
Long Term Effectiveness and Permanence
The preferred alternative involves the consolidation of the impoundment's waste with other
similar w?stes at the Nevada Test Site Environmental conditions at the Nevada Test Site are much
more compatible with the long term containment of radioactive wastes when compared to the
hydrogeology of eastern Tennessee. The low rainfall and deep groundwater conditions present at the
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Nevada 1 est Site make that facility more effective as a permanent disposal facility for these
radioactive wastes than presently available on-site alternatives If the Centralized Waste Management
facility, similar in construction to a large RCR/ subtitle C facility, is constructed ... 'he Reservation,
that facility will also provide greater permanence than presently available alternatives (and at a lower
cost than disposal at the Nevada Test Site).
«
Accordingly, a significant part of the increased cost associated vith the preferred alternative
is jusri ::d by the increase in prrrr^nence achieved by thir alierr.ativj. Such pecmanence ii particularly
important here because of the transuranic constituents within the surface impoundment waste
materials.
Reduction of Toxicity. Mobility, or Volume
The treatment provided under the preferred alternative will significantly reduce the mobility
of the radioactive contaminants being remediated. This reduction in mobility will enhance the
permanence of the preferred alternative over the other alternatives not including treatment. Another
enhancement to permanence will be achieved by the preferred alternative's provision for the reduction
of the toMcity through destruction of the PCBs in two of the impoundments.
These enhancements to permanence achieved through treatment, in accordance with
CERCLA's expressed preferences, also justify a portion of the preferred alternative's incremental cost.
Short Term Effectiveness
Although no pan of the cost increase associated with the preferred alternative is justified by
short-term effectiveness considerations, it should be noted that this alternative fully satisfies this
remedy selection criterion. The preferred alternative includes engineered and administrative controls
to ensure that protection of the public, workers, and environment are maintained during
implementation of the remedy, which is achieved within a reasonable time period.
Conclusion
Based on the analysis summarized above, Region 4 has concluded that the cost associated
with the preferred remedial alternative for the Surface Impoundments Operable Unit at the Oak Ridge
Natioi.u' Laboratory are proportional to this remedy's overall eflei.t'veness. Increases in cost over
otner alternatives ~ especially Considering added future value and/or savings — are justified by this
remedy's long-term effectiveness and permanence with respect to the radioactive contaminants being
remediated and the remedy's utilization of treatment which reduces the mobility and toxicity of the
wa.-'p materials in accordance with statutory preferences.
If you have any questions regarding this matter, please contact Mr. Jon Johnston, Chief,
Federal Facilities Branch, at 404/562-8527, or Camilla Warren, Chief, DOE Remedial Section, at
404/562-8519.
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cc. 3 Luftig
T. Fields
B Breen
J. Woolford
E. Cotsworth
J. Cunningham
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