PB98-964025
                              EPA 541-R98-112
                              December 1998
EPA Superfund
      Record of Decision:
      Paducah Gaseous Diffusion Plant
      (USDOE) OU 5
      Paducah, KY
      8/10/1998

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                                 DOE/OR/06-1470&D3
Record of Decision for Waste Area Groups 1 and 7
    at the Paducah Gaseous Diffusion Plant,
              Paducah, Kentucky
                February 1998
          Cleared for Public Release

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                            Department of Energy
                                Oak Ridge Operations
                                 Paducah Site Office
                                   P.O. Box 1410
                                 Paducah. KY 42001

                                      August 28, 1998

Mr. Robert H. Daniell, Director
Division of Waste Management
Kentucky Department for Environmental Protection
14 Reilly Road, Frankfort Office Park
Frankfort, Kentucky 40601

Mr. Carl R. Froede Jr., P. G.
United States Environmental Protection Agency
Region IV
DOE Remedial Section
Federal Facilities Branch
Waste Management Division
61 Forsyth Street
Atlanta, Georgia 30303

Dear Mr. Daniell and Mr. Froede:

RECORD OF DECISION FOR WASTE AREA GROUPINGS 1 AND 7 AT THE
PADUCAH GASEOUS DIFFUSION PLANT, PADUCAH, KENTUCKY, DOE/OR/06-
1470&D3

Enclosed for your information is the final Record of Decision (ROD) for Waste Area Groupings
(WAGs) 1 and 7 at the Paducah Gaseous Diffusion Plant. The ROD was signed by the
Department of Energy (DOE) February 20, 1998, and by the Environmental Protection Agency
August 10, 1998.  Concurrence with this ROD by the Kentucky Department for Environmental
Protection was received in a letter dated June 24, 1998, on the subject matter.

If you have any questions or require additional information, please call Myrna E. Redfield at
(502)441-6815.

                                      Sincerely,
                                      Jimmie C. Hodges, Site Manager
                                      Paducah Site Office

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Mr. Daniell and Mr. Froede                  2                          August 28, 1998
Enclosure

cc w/o enclosure:
R. Blumenfeld, CC-10
P. A. Gourieux, Bechtel Jacobs Company/Kevil
J. C. Massey, Bechtel Jacobs Company/Kevil
B. E. Phillips, JEG/Kevil
R. C. Sleeman, EM-91
T. Taylor, UKFFOU/Frankfort

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                                 CERTIFICATION
Document Identification:     Record of Decision for Waste Area Groups 1 and 7
                             at the Paducah Gaseous Diffusion Plant,
                             Paducah, Kentucky DOE/OR/06-1470&D3
I certify under penalty of law that I have personally examined and am familiar with the
information submitted in this application and all attachments and that, based on my inquiry of
those persons immediately responsible for obtaining the information contained hi the
application, I believe that the information is true,  accurate, and complete.  I am aware that
there are significant penalties for submitting false information, including the possibility of fine
and imprisonment.
U. S. Department of Energy
Owner and Operator
Jimmie C. Hodges, Paducah Site Manager                     Date Signed
Paducah Site Office
U.S. Department of Energy
 The Department of Energy has signed as "owner and operator" and Lockheed Martin Energy
 Systems, Inc., has signed as "co-operator" this application for the permitted facility.  The
 Department has determined that dual signatures best reflect the actual apportionment of
 responsibility under which the Department's RCRA responsibilities are for policy,
 programmatic, funding, and scheduling decisions, as well as general oversight, and the
 contractor's RCRA responsibilities are for day-to-day operations (in accordance with general
 directions given by the Department of Energy as part of its general oversight responsibility),
 including but not limited to, the following responsibilities: waste analyses and handling,
 monitoring, record keeping, reporting, and contingency planning.  For purposes of the
 certification required by 40 CFR Section 270.11(d), the Department of Energy's
 representatives certify, to the  best of their knowledge and belief, the truth accuracy and
 completeness of the application for their respective areas of responsibility.
                                        Paee 1 of 2

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                                  CERTIFICATION
Document Identification:     Record of Decision for Waste Area Groups 1 and 7
                             at the Paducah Gaseous Diffusion Plant,
                             Paducah, Kentucky DOE/OR706-1470&D3
I certify under penalty of law that I have personally examined and am familiar with the
information submitted in this application and all attachments and that, based on my inquiry of
those persons immediately responsible for obtaining the information contained in the
application, I believe that the information is true, accurate, and complete.  I am aware that
there are significant penalties for submitting false information, including the possibility of fine
and imprisonment.
Lockheed Martin Energy Systems, Inc.
Co-Operator
                                                        ((
JinttnV C. Massey, Site Manage/A                            Date Signed
Environmental Management andLEnrichment
  Facilities
Lockheed Martin Energy Systems, Inc.
 The Department of Energy has signed as "owner and operator" and Lockheed Martin Energy
 Systems, Inc., has signed as  "co-operator" this application for the permitted facility.  The
 Department has determined that dual signatures best reflect the actual apportionment of
 responsibility under which the Department's RCRA responsibilities are for policy,
 programmatic, funding, and  scheduling decisions, as well as general oversight, and the
 contractor's RCRA responsibilities are for day-to-day operations (in accordance with general
 directions given by the Department of Energy as part of its general oversight responsibility).
 including but not  limited to,  the following responsibilities,  waste analyses and handling,
 monitoring, record keeping,  reporting,  and contingency planning.  For purposes of the
 certification required by 40 CFR Section 270.11(d),  Lockheed Martin Energy  Systems.  Inc.'s.
 representatives certify, to the best of their knowledge and belief, the truth accuracy and
 completeness of the application for their respective areas of responsibility.
                                        Page 2 of 2

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                                         DOE/OR/06-1470&D3
Record of Decision for Waste Area Groups 1 and 7
     at the Paducah Gaseous Diffusion Plant,
               Paducah, Kentucky
                  February 1998
                    Prepared by
                  Jacobs EM Team
         175 Freedom Boulevard • Kevil, KY 42053
          Under Contract DE-AC05-93OR22028
                    Prepared for
           United States Department of-Energy
            Remediation Management Group

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                                 PREFACE

This Record of Decision for Waste Area Groups 1  and 7 at the Paducah Gaseous Diffusion
Plant,  Paducah, Kentucky, DOE/OR/06-1470&D3,  was  prepared in accordance with
requirements under the Comprehensive Environmental  Response, Compensation, and
Liability Act;  the Resource Conservation and Recovery Act; and Kentucky hazardous
waste s'tarutes (K.R.S. 224.46-520 and K.R.S. 224.46-530). This document was prepared
under Work  Breakdown  Structure 7.1.04.06.02  (Activity Data Sheet  5304). This
document follows the outline for records of decision contained in  the draft Federal
Facility Agreement being negotiated for the Paducah Gaseous Diffusion Plant (PGDP)
among the United States Department of Energy (DOE), the United States Environmental
Protection Agency (EPA), and the Kentucky Department for Environmental Protection
(KDEP). Publication of this document meets a primary document deliverable milestone
for the PGDP's  Environmental  Management Program. This  document provides  the
record of information and rationale that the EPA, the KDEP, and the DOE utilized in
the selection  of  preferred remedial actions/corrective measures at the  Waste Area
Groups 1 and 7 solid waste management units. Information provided in this document
forms the basis for the development of the remedies selected for this project.

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                             CONTENTS

PREFACE	ii
TABLES	vi
FIGURES	vi
ACRONYMS AND ABBREVIATIONS	vii

PART 1.  DECLARATION
         SITE NAME AND LOCATION
         STATEMENT OF BASIS AND PURPOSE
         ASSESSMENT OF THE SITE
         DESCRIPTION OF SELECTED REMEDY
         STATUTORY DETERMINATION

PART 2.  DECISION SUMMARY
         2.1   SITE NAME, LOCATION, AND DESCRIPTION	1
         2.2   SITE HISTORY AND ENFORCEMENT ACnvmES	4
               2.2.1  Waste Area Group 1	4
                     2.2.1.1  Solid Waste Management Unit 100: the Fire
                             Training Area	4
                     2.2.1.2  Solid Waste Management Unit 136: the C-740
                             Trichloroethene Spill Site	4
               2.2.2  Waste Area Group 7	6
                     2.2.2.1  Solid Waste Management Units 130 through 134:
                             the C-611 Underground Storage Tanks	6
                     2.2.2.2  Solid Waste Management Unit 8: the C-746-K
                             Sanitary Landfill	6
         2.3   HIGHLIGHTS OF COMMUNITY PARTICIPATION	9
         2.4   SCOPE AND ROLE OF THE OPERABLE UNITS	10
         2.5   SUMMARY OF SITE CHARACTERISTICS	10
               2.5.1   Hydrogeologic Characteristics of the Paducah Gaseous
                      Diffusion Plant Area	10
                      2.5.1.1  Regional surface-water hydrology	10
                      2.5.1.2  Regional geology	12
                      2.5.1.3  Regional ground-water hydrology	12
               2.5.2   Hydrogeology of Waste Area Groups 1 and 7	14
                      2.5.2.1  Solid Waste Management Unit 100	14
                      2.5.2.2  Solid Waste Management Unit 136	15
                      2.5.2.3  Solid Waste Management Units
                             130 through 134	16
                      2.5.2.4  Solid Waste Management Unit 8	17
               2.5.3  Operable Unit Characteristics	21
                      2.5.3.1  Solid Waste Management Unit 100	21
                      2.5.3.2  Solid Waste Management Unit 136	22
                      2.5.3.3  Solid Waste Management Units
                              130 through 134	22
                      2.5.3.4  Solid Waste Management Unit 8	23
               2.5.4  Contaminant Characteristics	25
          2.6  SUMMARY OF SITE RISKS	25
               2.6.1  Human Health Risk Assessment	28
               2.6.2  Ecological Risk Assessment	30
               2.6.3  Remedial Action Objectives	30
                                    111

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2.7   DESCRIPTION OF ALTERNATIVES	30
      2.7.1   Description of Alternatives for Solid Waste Management
             Unit 8 (C-746-K Sanitary Landfill)	30
             2.7.1.1  Alternative 1 — No Action	31
             2.7.1.2  Alternative 2 — Upgradient Subsurface Barrier	31
             2.7.1.3  Alternative 3 — Downgradient Leachate
                    Collection System	32
             2.7.1.4  Alternative 4 — Full Perimeter Subsurface
                    Barrier	32
             2.7.1.5  Alternatives — Constructed Wetland
                    Treatment System	33
             2.7.1.6  Alternative 6 — Limited Action	34
      2.7.2   Description of Alternatives for Solid Waste Management
             Units 100, 130 through 134, and 136	34
2.8   SUMMARY OF THE COMPARATIVE ANALYSIS OF
      ALTERNATIVES	35
      2.8.1   Overall Protection of Human Health and the
             Environment	.36
      2.8.2   Compliance with Applicable or Relevant and
             Appropriate Requirements	36
             2.8.2.1 Solid Waste Management Unit 8	36
             2.8.2.2 Solid Waste Management Units 100,130
                    through 134, and 136	37
      2.8.3   Long-Term Effectiveness and Permanence	37
      2.8.4   Reduction of Contaminant Toxicity, Mobility, or Volume	38
      2.8.5   Short-Term Effectiveness	38
      2.8.6   Implementability	38
      2.8.7   Cost	38
      2.8.8   State Acceptance	39
      2.8.9   Community Acceptance	39
 2.9   SELECTED REMEDY	39
      2.9.1   Statutory Determination	42
      2.9.2   Protection of Human Health and the Environment	43
 2.10  COMPLIANCE WITH APPLICABLE OR RELEVANT AND
      APPROPRIATE REQUIREMENTS	43
      2.10.1  Introduction to Applicable or Relevant and Appropriate
             Requirements and To Be Considered Information	43
      2.10.2  Relationship Between the Scope of the Selected Remedial
             Action, Regulatory Authorities, and Applicable or
             Relevant and Appropriate Requirements	45
      2.10.3  Chemical-Specific Applicable or Relevant and
             Appropriate Requirements	46
             2.10.3.1 Leachate discharges	46
             2.10.3.2 Radiation protection of the public and
                     environment	47
             2.10.3.3 Radionuclide emission standard	47
      2.10.4 Location-Specific Applicable or Relevant and
             Appropriate Requirements	47
                           IV

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              2.10.5  Action-Specific Applicable or Relevant and Appropriate
                     Requirements	52
                      2.10.5.1  Solid waste management unit corrective action ....52
                      2.10.5.2  Environmental performance standards	52
                      2.10.5.3  Ground-water protection	52
                      2.10.5.4  Ground-water monitoring plan	53
                      2.10.5.5  Design requirements for ground-water
                              monitoring systems	53
                      2.10.5.6  Monitoring well construction	53
                      2.10.5.7  On-site activities	54
                      2.10.5.8  Deed notice	54
                      2.10.5.9  Hazardous waste determination	54
                      2.10.5.10 Radioactive waste determination	55
                      2.10.5.11 Construction along streams	55
              2.10.6   Applicable or Relevant and Appropriate Requirements
                      and To Be Considered Information for Solid Waste
                      Management Units 100,130 through 134, and 136	55
         2.11 COST EFFECTIVENESS	55
         2.12 UTILIZATION OF PERMANENT SOLUTIONS AND
              ALTERNATIVE TREATMENT TECHNOLOGIES	64
         2.13 PREFERENCE FOR TREATMENT AS A PRINCIPAL
              ELEMENT	64
         2.14 DOCUMENTATION OF SIGNIFICANT CHANGES	64

PART 3.  RESPONSIVENESS SUMMARY
         3.1  RESPONSIVENESS SUMMARY INTRODUCTION	66
         3.2  COMMUNITY PREFERENCES/INTEGRATION OF
              COMMENTS	66
APPENDIX A   Schedule

APPENDIX B   Letter from the Division of Water

APPENDIX C   Solid Waste Management Unit 100 Exposure Assessment

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                             TABLES

Table 2-1.    Summary of Risks at Solid Waste Management Unit 8	29
Table 2-2.    Preliminary Cost Estimates	'.	39
Table 2-3.    Chemical-Specific Applicable or Relevant and Appropriate
             Requirements and To Be Considered Information for Solid Waste
             Management Unit 8 of Waste Area Group 7	48
Table 2-4.    Location-Specific Applicable or Relevant and Appropriate
             Requirements and To Be Considered Information for Solid Waste
             Management Unit 8 of Waste Area Group 7	50
Table 2-5.  .  Action-Specific Applicable or Relevant and Appropriate
             Requirements and To Be Considered Information at Solid Waste
             Management Unit 8 of Waste Area Group 7	56
Table 2-6.    Applicable or Relevant and Appropriate Requirements and To Be
             Considered Information for Solid Waste Management Unit 100 of
             Waste Area Group 1	62
Table 2-7.    Action-Specific Applicable or Relevant and Appropriate
             Requirements for Solid Waste Management Units 130
             through 134 and 136 of Waste Area Groups 1 and 7	63


                             FIGURES

Figure 2-1.    Paducah Gaseous Diffusion Plant Vicinity  Map	2
Figure 2-2.    Locations of Solid Waste Management Units in Waste Area
             Groups 1 and 7	3
Figure 2-3.    Solid Waste Management Units 100 and 136 Sample Location Map	5
Figure 2-4.    Solid Waste Management Units 130 through 134 Sample
             Location Map	7
Figure 2-5.    Solid Waste Management Unit 8 Sample Location Map	8
Figure 2-6.    Surface-Water Features in the Vicinity of the Paducah Gaseous
             Diffusion Plant	11
Figure 2-7.    Schematic of Stratigraphic and Structural Relationships near the
             Paducah Gaseous Diffusion Plant	13
Figure 2-8.    Shallow Ground-Water Row Map for Waste Area Group 7	18
Figure 2-9.    Solid Waste Management Unit 8 Cross Section B-B'	19
Figure 2-10.  Conceptual Site Model for Solid Waste Management Unit 8 of
             Waste Area Group 7	26
Figure 2-11.  Contaminant Pathways from Solid Waste Management Unit 8	27
Figure 2-12.  Approximate Location of Proposed Institutional Controls	41
                                     VI

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                ACRONYMS AND ABBREVIATIONS
"
The following list of acronyms and abbreviations is provided to assist in the review of
this document.

            neprunium-237
            plutonium-238
            technetium-99
            thorium-228
            thorium-230
            thorium-232
            uranium-234
            uranium-235
            uranium-238
            as low as reasonably achievable
            above mean sea level
            administrative record
            applicable or relevant and appropriate requirement
            below land surface
            Code of Federal Regulations
            Comprehensive Environmental Response, Compensation, and
             Liability Act
             centimeter(s)
             chemical of concern
             United States Army Corps of Engineers
             chemical of potential concern
             chemical of potential ecological concern
             Comprehensive Site Operable Unit
             Clean Water Act
             dichloroethane
             dichloroethene
             United States Department of Defense
             United States Department of Energy
             excess lifetime cancer risk
             United States Environmental Protection Agency
             Federal Register
             Federal Facility Agreement
             Federal Facility Compliance Act
             feasibility study
             foot/feet
             fire training area
             gram(s)
             gallon(s)
             gallons per minute
             Groundwater Protection Program Plan
             high-density polyethylene
             hazard index
             Hazardous and Solid Waste Amendments
             qualifier indicating estimated value
             Kentucky Administrative Regulations
             Kentucky Revised Statutes
             Kentucky Department for Environmental Protection
             Kentucky Department for Environmental Protection, Division of Water
 Th
ALARA
amsl
AR
ARAR
bis
C.F.R.
CERCLA

cm
COG
COE
COPC
COPEC
CSOU
CWA
DCA
DCE
DOD
DOE
ELCR
EPA
Fed. Reg.
FFA
FFCA
FS
ft
FTA
g
gal
gpm
GPPP
HOPE
HI
HSWA
J
K.A.R.
K.R.S.
KDEP
 KDOW
                                    Vll

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kg           kilogram(s)
km          kilometer(s)
KOW        Kentucky Ordnance Works
KPDES      Kentucky Pollutant Discharge Elimination System
1            liter
LDR         land disposal restriction
LMES       Lockheed Martin Energy Systems, Inc.
m           meter(s)
rrg          milligram(s)
mgd         million gallons per day
mil          thousandths of an inch
mrem        millirem
MW         monitoring well
NCP        National Oil and Hazardous Substances Pollution Contingency Plan
NOV        Notice of Violation
NWP        nationwide permit
O&M        operation and maintenance
OU         operable unit
PAH        polycyclic aromatic hydrocarbon
PCB         polychlorinated biphenyl
pCi         picocurie(s)
PGDP       Paducah Gaseous Diffusion Plant
pH         logarithm of the reciprocal of the hydrogen-ion concentration
PPE         personal protective equipment
 PRAP        proposed remedial action plan
 PRP          potentially responsible party
 RCRA        Resource Conservation and Recovery Act
 RFI          Resource Conservation and Recovery Act facility investigation
 RGA         Regional Gravel Aquifer
 RI           remedial investigation
 ROD         record of decision
 SAP         Sampling and Analysis Plan
 SARA        Superfund Amendments and Reauthorization Act
 sec          second
 SSAB        Site Specific Advisory Board
 SWMU       solid waste management unit
 T&E         threatened and endangered
 TBC         to be considered
 TCA         trichloroethane
 TCE         txichloroethene
 TNT         trinitrotoluene
 Tu,          acute toxicity
 U.S.C.A.     United States Code Annotated
 UCRS       Upper Continental Recharge System
 USEC       United States Enrichment Corporation
 UST         underground storage tank
 VOC        volatile organic compound
 WAG        waste area group
 WTP        water treatment plant
 yd          yard(s)
 yr           year(s)
 ug          microgram(s)
 urnhos       micromhos: the reciprocal of resistivity
                                     vui

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   PARTI




DECLARATION

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        DECLARATION FOR THE RECORD OF DECISION
                 FOR WASTE AREA GROUPS 1 AND 7

SITE NAME AND LOCATION

Waste Area Groups 1 and 7
Paducah Gaseous Diffusion Plant
United States Department of Energy
Paducah, Kentucky

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) presents the final remedial action decisions selected for
soils and sediments in each of the solid waste management units (SWMUs) of Waste
Area Groups (WAGs) 1 and 7 at the Paducah Gaseous Diffusion Plant (PGDP)  near
Paducah, Kentucky. Waste Area Group 1 consists of SWMUs 100 and 136. Waste Area
Group 7 consists of SWMUs 8 and 130 through 134. All SWMUs are located on United
States Department of Energy (DOE) property. Waste Area Group 1 is located within the
boundaries of the plant security fence. Solid Waste Management Units 130 through 134
also are located within the plant security fence. Solid Waste Management Unit  8 is
located to  the southwest of the PGDP facility,  beyond the boundaries of the plant
security fence.

By mutual consent among the United States Environmental Protection Agency (EPA),
the Kentucky Department  for Environmental Protection  (KDEP), the United States
Department of Defense (DOD), the United States Army Corps of Engineers (COE), and
the DOE, it was agreed mat the evaluation and implementation of any remedial actions
required for the Kentucky Ordnance Works (KOW)  SWMUs [SWMU 94 (KOW Sewage
Treatment Plant),  SWMU 95 (KOW Burn Area), and SWMU 157 (KOW Toluene  Spill
Site)], formerly included in WAGs 1 and 7, would be the responsibility of the DOD and
conducted on behalf of the DOD by the COE. Correspondence outlining the agreed upon
responsibilities of the DOE, the COE, and the DOD was submitted to the EPA and the
KDEP April 5, 1996.  Due to  the agreements reached among these entities,  remedial
technologies for the KOW SWMUs are not discussed further in this ROD and will be
evaluated as part of the WAG 10 investigation by the COE. Additionally,  by written
mutual consent, the EPA, the KDEP, and the DOE agreed that an evaluation of remedial
alternatives for SWMU 38,  the C-615 Sewage Treatment Plant, would be deferred until
the unit ceases operation.  Consequently, no remedial actions are discussed for  these
SWMUs in this ROD.

The remedies selected for each of the WAGs 1 and 7 SWMUs are intended to address
the contaminants of concern  presently identified and will serve as a  step  toward
comprehensively addressing contamination found across the PGDP  site. These actions
are not intended to  address remediation  of any existing or future surface- or ground-
water contamination at this site.

The DOE will evaluate the necessity for surface- and/or ground-water remedial actions
 for the SWMUs  in WAGs 1  and 7  separately  from  this action during site-wide,
 comprehensive evaluations of surface- and ground-water contamination at this site. As
 part of the comprehensive evaluations, the DOE, the EPA, and the KDEP will determine
 whether implementing surface- and ground-water remedial actions at  SWMU 8 is
 necessary  to protect human health and  the environment. Through the comprehensive
 evaluations for surface water (WAGs  18  and 25) and ground water (WAG  26), known

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also as  the  Comprehensive Site  Operable Units  (CSOUs),  the  remedial  action
alternatives for the surface water and ground water at the PGDP, including at WAGs 1
and 7, will be selected. Through the CSOU process, all data on the surface and ground
water at WAGs 1 and 7 and at the other PGDP SWMUs will be evaluated. Finally, all
risks to human health and the environment from the surface and ground water at the
PGDP, and all legally applicable or relevant and appropriate requirements, also will be
evaluated.

This ROD was prepared based on the administrative record (AR) for these WAGs. The
AR includes documentation of the rationale for undertaking the remedial actions at
WAGs 1 and 7. Major documents included in the AR are as follows: the Feasibility Study
for Waste Area Groups 1 and 7 and Kentucky Ordnance Works Solid Waste Management Units
94, 95, and 157 at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/06-
1416&D2; the Proposed Remedial Action Plan for Waste Area Groups 1 and 7 at the Paducah
Gaseous Diffusion Plant,  Paducah, Kentucky, DOE/OR/06-1428&D4;  and the Resource
Conservation and Recovery Act Facility Investigation/Remedial Investigation Report for Waste
Area  Groupings  1  and  1  at  Paducah  Gaseous Diffusion  Plant, Paducah,  Kentucky,
DOE/OR/07-1404&D2.

The remedial  actions identified in this  ROD were selected in accordance  with the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),
as amended by the Superfund Amendments and  Reauthorization  Act,  the Resource
Conservation and Recovery Act (RCRA), as amended by the Hazardous  and Solid
Waste Amendments (HSWA), and K.R.S. Chapter 224, subchapter 46. The ROD was
prepared in accordance with a hazardous waste  management permit issued  by  the
KDEP pursuant to K.R.S. Chapter 224, subchapter 46, and a permit for corrective action
issued by the EPA pursuant to the  HSWA. Both permits bear the same permit number,
KY8-890-008-982, and, throughout this document, are collectively  referred to as  the
RCRA permits.  Once the ROD is  signed, the permit will be modified to  reflect  the
selected remedies of these SWMUs.

The ROD also was prepared in accordance with a draft  Federal Facility  Agreement
(FFA) that currently is being negotiated among the DOE, the EPA,  and the KDEP. A
draft of the FFA agreed  to by all three entities was made available for public review and
comment April 19,1997. The FFA, when issued, will coordinate the requirements of the
CERCLA and the RCRA permits.

 The remedial actions will be implemented pursuant to the PGDP's RCRA permits, this
 ROD, and the draft FFA. The Commonwealth of Kentucky concurs with the DOE  on,
 and the EPA approves,  the selected remedial actions. The selected remedial actions will
 address the contaminants of concern in the soils and sediments  of WAGs 1 and 7 and
 will serve as a step toward comprehensively addressing contamination found across the
 PGDP site.

 ASSESSMENT OF THE SITE

 Actual or threatened releases from this site,  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.

 Risks for industrial workers slightly exceed EPA thresholds at SWMUs  8 and  100
 [please refer  to  the Feasibility Study (FS) in the WAGs 1 and 7 AR for more  detail
 regarding risk thresholds]; however, these risks are due to direct contact with surface
 water and sediments contaminated with metals. As discussed  in the FS for WAGs 1

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and 7, DOE/OR/06-1416&D2, the direct contact exposure pathway is associated with
numerous uncertainties (such as conservative assumptions associated  with absorption
of metals) and, therefore, is not used as the sole pathway in making remedial decisions
(refer to the FS for a more detailed discussion of the uncertainties associated  with the
risk assessment). Additional evaluation of potential risks at SWMU 100 indicate there
are  no  unacceptable  risks  to current   industrial  workers  based  upon  exposure
assumptions adjusted to reflect the actual time workers spend  at the unit (primarily to
perform upkeep activities). Additionally, it is reasonable to assume that these exposure
assumptions will remain the same in the future. Consequently, no further action, outside
of maintaining  institutional  controls,  is  warranted  at  SWMU  100.  Currently,
contaminated surface water will be addressed on a site-wide basis during the surface-
water CSOU investigation (WAGs 18 and 25).

While contaminant conditions at SWMUs 8 and 100 are similar, there also is a risk that
a human or animal could come into direct contact with acidic leachate being released
from SWMU 8 into sediments above the water level in the creeks. These risks, when
combined with the Notice of  Violation  issued by  the  Kentucky  Department  for
Environmental Protection, Division of Water (KDOW), indicate that  limited action is
necessary at SWMU 8 to protect human healthsand animals.

At SWMUs 130 through 134 and the soils of SWMU 136, risks and hazard indices for
human health and animals do not exceed threshold values; therefore, these units require
no further action. Any contaminated ground water associated  with SWMU 136 will be
evaluated as part of the ground water CSOU (WAG 26).

DESCRIPTION OF SELECTED REMEDY

The primary purpose of the remedies described within this document  are to reduce the
risks that could  pose a threat to human health  and the environment associated with
direct contact to acidic  leachate at  SWMU 8. The evaluation  of human health and
ecological risks posed by these units was conducted as part of the remedial investigation
performed at this site.

The remedial action at SWMU 8 consists of a  deed  notice and  restrictions and  the
installation of riprap and  signs. The current surface-water  monitoring program will
continue as directed by the KDOW.  Additional ground-water monitoring wells will be
installed, as needed.

Since SWMUs 130 through 134 and 136 do  not present an unacceptable risk to human
health and the environment, no further remedial action will be performed at these units.
Additionally,  since there are no risks to industrial workers at SWMU 100 based upon
actual exposures at  the unit, no further action (outside of  maintaining institutional
 controls) is warranted. However, since contamination will remain at SWMUs 8 and 100,
 and in order  to evaluate the reliability of controls in providing  protection, five-year
 reviews will be conducted for these SWMUs under the CERCLA.

 All  work on the WAGs 1 and 7 project has been conducted by mutual agreement among
 the DOE, the EPA, and the KDEP. Further, the EPA and the KDEP have participated  in
 the development of this ROD, including review and comment on the document's content.

 STATUTORY DETERMINATION

 The remedial actions  described herein are protective  of  human health  and  the
 environment, comply with federal and state requirements that are legally applicable  or

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relevant and appropriate to the WAGs 1 and 7 SWMUs, and are cost effective. The
selected remedies for the WAGs 1 and 7 SWMUs do not satisfy the CERCLA § 121(b)
[42 U.S.C.A.  § 9621(b)]  statutory  preference for having, as  a principal element,
treatment that results in a permanent and significant reduction of toxicity, mobility, or
volume because risk analysis indicates  that  such remedies are not necessary. The
selected remedies do, however, satisfy the CERCLA § I21(b) statutory  preference for
using  permanent solutions  and  alternative  treatment technologies  to  the  extent
practicable. The limited actions selected for SWMUs 8 and 100, and the No  Further
Action decisions selected  for SWMUs 130  through 134  and  136,  are viewed  as
permanent and final decisions.

Since contamination will remain at SWMUs  8 and  100 above levels that allow for
unlimited use and unrestricted exposure under the industrial land-use scenario, five-year
reviews will be conducted pursuant to CERCLA § 121(c) [42 U.S.C.A. § 9621(c)] and
40 C.F.R. § 300.430(f)(4)(ii)]. Five-year CERCLA reviews will not be conducted at
SWMUs 130 through 134  and 136  because  the selected remedial actions allow for
unlimited use and unrestricted exposure.
                                                    Date:
 Rodney R. Nelson
 Assistant Manager for Environmental Management
 United States Department of Energy
                                                    Date:
 Richard D. Green
-Acting.Director, Waste Management Division
 United States Environmental Protection Agency, Region 4

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      PART 2




DECISION SUMMARY

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2.1    SITE NAME, LOCATION, AND DESCRIPTION

The Paducah Gaseous Diffusion  Plant  (PGDP)  is located in western  Kentucky,
approximately 16.1 km (10 miles) west of Paducah and  about 6.44 km (4 miles) south
of the Ohio River (Figure 2-1). It is an uranium enrichment facility that supplies nuclear
fuel for commercial reactors. The plant, owned by the  United States Department of
Energy (DOE), began operations in 1952 and became fully operational in 1955.

The Energy  Policy Act of 1992 transferred operation of the DOE's uranium enrichment
facilities to  the United States Enrichment Corporation (USEC). Effective July 1, 1993,
Martin Marietta Utility Services, Inc., (now Lockheed  Martin Utility Services, Inc.)
contracted with the USEC to provide operation and maintenance (O&M) services. The
DOE contracted with Martin Marietta Energy Systems, Inc., [now Lockheed Martin
Energy Systems,  Inc., (LMES)] to  provide environmental restoration and  waste
management services for the PGDP under the DOE's Environmental  Management
Program.

This Record of Decision (ROD) addresses eight solid waste management units (SWMUs)
in Waste Area Groups (WAGs)  1 and 7 at the PGDP. This ROD does not address three
Kentucky Ordnance Works  (KOW)  SWMUs  formerly used  by  the  United  States
Department of  Defense  (DOD),  which were grouped with  WAGs  1 and  7 for
environmental investigation purposes.  However, the current draft  of the  PGDP  Site
Management  Plan,  DOE/OR/07-1207&D3,  places the three  SWMUs  [SWMU  94
(Sewage Treatment Plant), SWMU 95 (Bum Area), and SWMU 157 (Toluene Spill Site)]
into WAG 10. The United States Army Corps of Engineers (COE), on behalf of the DOD,
has  committed  verbally to remediate  these  three  sites, and  the  United  States
Environmental  Protection  Agency  (EPA)  and  the  Kentucky   Department  for
Environmental Protection (KDEP) have agreed to allow the COE to proceed with the
cleanup. However, in a letter to the DOE dated May 23,  1996, (Appendix B), the KDEP
also indicated that the DOE ultimately would be responsible for the cleanup of the KOW
SWMUs should the COE fail to meet Kentucky cleanup standards.

In addition to the three KOW SWMUs, this ROD does not address SWMU 38 (the C-615
Sewage Treatment Plant), formerly included in WAG 1. The KDEP, the EPA, and the
DOE have agreed to defer evaluation of remedial alternatives for SWMU 38 until the unit
ceases operation. For this reason, SWMU  38 will be evaluated at a later date as part  of
WAG 29.

Finally, this ROD does not address remediation of surface or ground water at each of the
SWMUs. Any  risks to human health or the  environment present at the site due  to
contaminated surface  or ground  water  will be addressed  as   part  of  the  two
Comprehensive Site Operable Unit (CSOU) evaluations conducted for WAGs 18 and 25
(i.e., surface water) and WAG 26 (i.e., ground water).

The locations of the SWMUs in WAGs  1 and 7 are  shown in Figure 2-2. The  eight
SWMUs addressed in this ROD are as follows:

       •   WAG 1

           — SWMU 100, the Fire Training Area (FTA); and

           — SWMU 136, the  C-740 Trichloroethene (TCE) Spill Site.

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                 OhioRlvvr
                                                                                                         LEGEND
                                ••  Wildlife Management Area
                                ••  Paducah Gaseous Diffusion Plant (PGDP)
                                iJM^jJI  Department of Energy (DOE) Reservation
                                ED  Municipality
                                      Tennessee Valley Authority (TVA)
                                        01    2	3
                                                                                                                                               ft

     Missouri

Mississippi flimr
                                                                                                                       Paducah Gaseous Diffusion Plant
                                                                                                                             Paducah. Kentucky
                                     Figure 2-1. Pnducah
ffusion Plant Vicinity Map
                                                                                                                                      fflJnobi EM Turn. 1006

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      'I   ^
      «-,.-    . 1
                                                         PADUCAH
                                                         GASEOUS DIFFUSION
                                                         PLANT
                                                               SWMU8
                                                               Sanitary
                                                                Landfill
                                                                  SWMU= Solid Waste
                                                                         Management Unit
                                                                   UST = Underground
                                                                         Storage Tank
                                                                   WAG = Waste Area Group
                                                                   TCE = Trichloroethene
                                                                   X - Fence
                                                                         Surface Water
                                                                 I - 1 - h Railroad
                                                                	WAG Boundary
                                                                  Appronmau ScaM (Feet)
                                                                                OJacoes EM Turn. 1996
Figure 2-2. Locations of Solid Waste Management Units in Waste Area Groups 1 and 7
                                          3

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      •   WAG 7

          — SWMU  130, a 2,082-liter (550-gal) gasoline underground storage tank
             (UST) located adjacent to the C-611 Water Treatment Plant (WTP);

          — SWMU  131, a 189-liter (50-gaI) UST reportedly located adjacent to  the
             C-611 WTP;

          — SWMU  132, a 7,571-liter (2,000-gal) fuel oil UST located adjacent to the
             C-611 WTP;

          — SWMU  133, a diesel fuel UST of unknown capacity located adjacent to
             the C-611 WTP;

          — SWMU 134, a 3,785-liter (1,000-gal) diesel fuel UST located adjacent to
             the C-611 WTP; and

          — SWMU 8, the C-746-K Sanitary Landfill.

2.2   SITE HISTORY AND ENFORCEMENT ACTIVITIES

Following are descriptions of events  and  legal actions pertaining to the SWMUs
addressed in this ROD. Also, brief descriptions of the units themselves are provided.

2.2.1  Waste Area Group 1

Waste Area Group 1 is located within the plant security fence in the southwestern corner
of the PGDP (Figure 2-2). It includes two units that will be addressed  by this document:
SWMU 100 (the FTA) and SWMU 136 (the C-740 TCE Spill Site).

2.2.1.1 Solid Waste Management Unit 100: the Fire Training Area

The FTA is located in the southwest comer  of the PGDP, immediately west of Fourth
Street (Figure 2-3). It consists of one large rectangular surface burn area, two circular bum
pan areas, one circular electric pump area, an elevated and bermed fuel tank area, and
two square burn area  depressions. The bum areas are unlined and are not bermed. The
FTA  has  been used since 1982 for staging fire training exercises involving waste  oils,
fuels, and other combustible liquids. Combustible liquids were not burned in the unlined
areas after 1987. Fire training exercises continue to be conducted in the vicinity, but, in
order to  prevent any  negative impacts to the environment, no burning is conducted in
unlined areas and combustible liquids are no longer used.

2.2.1.2 Solid Waste Management Unit 136: the C-740 Trichloroethene Spill Site

The TCE Spill Site is  a small rectangular area, approximately 5mx2m(15ftx6 ft),
located in the southwest corner of the PGDP within the plant security fence (Figure 2-2).
It is situated at the northwest comer of a concrete pad at the northeastern edge of the
C-740 Material Yard (Figure 2-3). The C-740 Material Yard is an active storage yard that
has been used since the early  1970s for storing various scrap metals  and drums. A 208-
liter (55-gal) drum stored on the concrete pad  leaked TCE onto the pad  and into the
gravel and soil adjacent to the western edge of the pad in May 1990. In October  1990,
soils  contaminated with TCE were excavated from a 5 m x 2 m (15  ft x 6 ft)  area, to a
depth of 1 m (3 ft). Soil samples collected from the base of the excavation pit were found
to have TCE concentrations as high as 21,000 ug/kg, indicating that TCE-contaminated

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cn
                                                            lO-SCVSW-OOl
                       //&'T\
                                             Bum   |
                                10-SCVSW-OOS j   A,M
                                                           10-SD/SW-002
                                                               10-SCVSB-001
                                                                     '  I/
                                                                       r
        Mentoring Well/Ground     --370-- Topographic Contour
        Water Sample            	Drainage Ditch
      A Surface Water Sample
      O RQA Monitoring Well
      O Soil Borings - RI/RFI       ~*~
      • Soil Borings - Phase II SI    *~~l
Wetlands
Fence
Railroad
                                                             tO-SO-013
                                    +*—x-
                                                                       (\
                                                                                      s
                                                                                        ,--»»->N
                                                                                                  \
                                                                                                  A
                                                              \
                                                              A
                                                                \
                                                                I
                                                                /
                                                                /
                                                               •y
                                                              /
                                                                                                 >'
                                                    C-740
                                                Metal and Drum
                                                 Storage Area

                                                      f^'\
                                                                                                                                      MW 325 (V
                                                                                                                                      O 36-SOSB-003 /'
                                                                         ;  ',
                                                                                                                MW3260)
                                                                              -K	N—  X   X--*-  XXX	M-
                                                                                                                            -372	
                                                                                                       C-743
                                    Figure 2-3. Solid Waste Management Units 100 and 136 Sample Location Map
                                                                                                                                          DJicobi EM Teim. 1998

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soils had not been completely removed. However, as further discussed in Section 2.5.3.2,
subsequent sampling conducted in  1994  as part  of  the Resource Conservation  and
Recovery Act (RCRA) facility investigation (RFI) indicates that no  measurable residual
TCE soil contamination remains at SWMU 136.

2.2.2   Waste Area Group 7

Waste Area Group 7 consists of SWMUs  130 through 134 (the five C-611  USTs) and
SWMU 8 (the C-746-K Sanitary Landfill). It is located outside the plant security fence
near the southwest comer of the PGDP (Figure 2-2). All of the SWMUs in WAG 7 are
inactive units.

2.2.2.1 Solid Waste Management  Units  130 through 134:  the  C-611 Underground
       Storage Tanks

The C-611 USTs  (SWMUs 130 through 134)  are located  southwest of the PGDP
security-fenced area in the vicinity of the C-611 WTP, west of Bayou Creek (Figure 2-4).
The C-611 WTP was built about 1942 as part of the KOW and later was expanded to
support operations at the  PGDP. All five  USTs located in the vicinity of the WTP
currently are inactive. With the exception of  SWMU 133, which is of unknown size, the
C-611 USTs range in capacity from 189 to  7,571  liters  (50 to 2,000  gal).  Two of the
USTs (SWMUs 130 and 131) were reportedly used for  gasoline storage from 1942 to
1945  in support of KOW operations. However, efforts to locate  the SWMU 131  UST
during the Resource Conservation and Recovery Act  facility investigation/remedial
investigation (RFI/RI) were unsuccessful, so it is  possible that it never existed. Solid
Waste Management Unit 132 was used for fuel oil storage from approximately 1942 to
1955, initially as  part of the KOW, and later in support of PGDP  activities. It was
abandoned in  place by filling the  tank with sand. The dates of operation of the
remaining two USTs (SWMUs 133 and 134) are unknown; both were reportedly used for
diesel storage and are known to have been  removed from service by 1975.  The SWMU
133 tank was abandoned in place filling the tank with grout.

2.2.2.2 Solid Waste Management Unit 8: the O746-K Sanitary Landfill

The C-746-K Sanitary Landfill (SWMU 8) is located southwest of the PGDP fenced
security area, approximately 200 m (656  ft) southeast of the C-611 WTP (Figure 2-5).
The landfill is roughly rectangular in shape and measures approximately 152 m x 213 m
(500  ft x 700  ft). It is situated immediately west of Bayou  Creek and  north of an
unnamed tributary of Bayou Creek. The ground surface is vegetated and slopes  in a
radial fashion from a maximum elevation of 119 m (392 ft) amsl near the center of the
western half of the landfill to  a low of approximately 110 m (360  ft)  amsl near Bayou
Creek at the eastern edge of the landfill. Drainage ditches located along the  western and
northern edges of the landfill flow to  the south into the unnamed tributary and to the
east into Bayou Creek, respectively.

Records indicate that the PGDP used the landfill between 1951 and 1981 for disposal of
fly ash from the  plant's coal  combustion  boilers, uncontaminated combustible plant
 waste, and potentially radiologically contaminated plant waste. According to the
Hydrohgic Investigation — Existing Sanitary Landfill Closure, Union Carbide Corporation,
 Gaseous Diffusion Plant, Paducah, Kentucky,  conducted by Wehran  Engineering in 1981,
 the fly ash was disposed in trenches excavated 2 to  3 m (5  to 10 ft) bis. During
 operations, trenches were cut in the fly ash and used for burning trash. This practice
 ceased in 1967, after which waste was buried without burning.  The waste, containing

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                         Treatment
                          Lagoon
  Treatment
   Lagoon
                                   SWMU 132
                                    2,000-GaJ
                                   UST Fuel Oil
                               WATER TREATMENT
                                      PLANT
Fenced
Grassy
 Area
           SWMU 130
          550-GaJ UST
            Gasoline
          Monitoring Well/Ground-Water Sample

          UST Sample
    O     Soil Borings - Existing Site Investigation

    O     Soil Borings - RF1/RI
 *	X-  Fence
, - -370 "   Topographic Contour

          Paved Area
           o-       ya      ear
                          a
            Approximate Scale (Feel)
                                                                                     O J»ooM EM Turn. 1996
    Figure 2-4. Solid Waste Management Units 130 through 134 Sample Location Map

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                                                                                                                                                 V
                                                                                                                                        oa-so/sw-oov^S
                                                                                                                                           08-LE-003*
oo
           e
           A
           ff
Approximate Extent of Fill
KOW Yellow Water Line
Approximate 100 Year
Flood Elevation
Fence
Creek         ^jro"™lt Sc**
Wetlands
Mentoring Well
Soil Boring
Test Pit (Wehran)
Plugged and
Abandoned Well (Wehran)
Location of Former Manhole
RFI/RI Leachate Sample Point
RFI/RI Surface
Water Sample Point
PGDP Stream Sampling Point
PGOP Seep Sampling Point
                                                                                               SWMU8
                                                                                          Sanitary Landfill
                                                         08-SB-003
                                                                                                                                          TP-9/MW 36
                                                                                                                                           {A
                                 MW183
                                 MW184
                                                                                 08-LE-001
                                                                                                         OS-LE-002^
                                                                                                  TP-2/MW 30
             \
TP-1/MW28
                                                                                                                                              /
            V
            08-SD/SW-003
                                                                                           SD/SW-002
                                                                                       746K-1
 C746K-GA1
~C746K-GA3
            o
         08-SB-008
                             Moditwd from Sh«Ms 7 «nd 9 ol lh« 1994 COE Wellind InvMllgitlon (COE, 1994)
                             •nd ImpicU to Well«ndi. FloodpUlnt. «nd Endanggfed or ThiaalMwd Spaclei (SAIC. 1993)
                              BlJacotuEM F»im. 1998
                                            Figure 2-5. Solid Waste Management Unit 8 Sample Location Map

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primarily office waste with some construction debris and kitchen waste, was placed in
trenches excavated within the fly ash and covered, when necessary, with additional fly
ash or soil fill. In addition to these materials, sludge from the C-615 Sewage Treatment
Plant may have been buried at the unit, as it was reportedly used as fill material. Soil
boring information indicates that up to 9 m (28 ft) of fly ash and trash were placed in
the landfill. The landfill was closed in 1982 and covered with a 15- to 30-cm (6- to 12-
inch) clay cap and a 46-cm (18-inch)  vegetative cover.

On January 30,  1992,  the PGDP personnel discovered leachate in a  ditch on the
southwest side of the landfill. Sampling immediately was conducted at five leachate
seep locations around the  landfill. Volatile organic compounds (VOCs)  [TCE; 1,1-
dichloroethene (DCE); 1,1-dichloroethane (DCA); and trans-l,2-DCE]  and  metals
(aluminum, iron, manganese, and zinc) were detected above background levels  in the
leachate samples. Low levels of radionuclides [technetiurn-99 ("Tc)  and uranium] also
were detected in some leachate samples. The leachate was acidic (the pH ranged from
2.3 to 5.5), and the particulate matter in the leachate  was generally orange to yellow in
color. The precipitation of dissolved metals (primarily iron and aluminum) from the
leachate was thought to be  causing  the orange to yellow staining observed at various
points  along the creek banks. This  condition was deemed in noncompliance with the
water quality provisions of 401 K.A.R. 5:031. The provisions of 401 K.A.R. 5:031 that
posed  an  issue at the landfill  were those that prohibit  discharges  that produce
"objectionable color" in waters of the Commonwealth of Kentucky. On September 15,
1992, the KDEP issued a Notice of Violation (NOV) to the PGDP for "unpermitted
seepage areas from C-746-K Sanitary Landfill into waters of the Commonwealth."

As a result of the NOV, and with the approval of the KDEP and the EPA, the DOE
immediately undertook an interim corrective action to address the seeps. To prevent any
further release of solids to the unnamed tributary, a sandbag dam with a liner was
installed in the drainage ditch southwest of the landfill. The interim action also repaired
the subsidence of the  existing landfill cap by recontouring the cap to promote surface-
water runoff. Since the landfill cap  repair was completed in October 1992, the landfill
and the adjacent creeks have been inspected regularly to determine  if the  interim
measures have been effective in reducing seepage into the creeks. In addition, a surface-
water monitoring program was initiated at the landfill to monitor contaminant levels in
the leachate and adjacent creeks. Through the monitoring program, samples are collected
quarterly at suspected seep source sites on the banks of Bayou Creek and the unnamed
tributary and locations upstream and downstream of the landfill (Figure 2-5).

2.3   HIGHLIGHTS OF COMMUNITY PARTICIPATION

The DOE issued the Proposed Remedial Action Plan for Waste Area Groups 1 and 7 at the
Paducah Gaseous Diffusion Plant,  Paducah, Kentucky,  DOE/OR/06-1428&D2,  June 25,
 1996, and held a public comment period from June 25, 1996, until August 9, 1996.  A
public meeting was held July 23,  1996,  at the LMES facility in Kevil, Kentucky, to brief
 the public on the remedial alternatives under consideration at that time. At the meeting,
DOE personnel also  answered  questions from  the public  on a  proposed wetland
 alternative at  the landfill and solicited both written and verbal comments. The DOE
 received oral comments during the public meeting and written comments during the 45-
 day public comment period. These comments,  and  formal DOE responses to these
 comments, are provided in the Responsiveness Summary, which is presented in Part 3 of
 this ROD.

 In response to comments from the public, the EPA, and the Commonwealth of Kentucky,
 changes were made to the Proposed Remedial Action Plan (PRAP). The revised PRAP

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Proposed Remedial Action Plan for Waste Area Groups 1 and 7 at the  Paducah  Gaseous
Diffusion Plant, Paducah, Kentucky, DOE/OR/06-1428&D4, was issued to the public
after a Notice of Availability announcing the 45-day public review period was published
in The Paducah Sun, December 22, 1996. During the public comment period (December
23, 1996, through February 5, 1997), the PRAP was made available for public review at
the Paducah Public Library  and the off-site DOE  Environmental Information Center
located in the West Kentucky Technology Park in Kevil, Kentucky. Specific groups that
received individual copies of the PRAP included the local PGDP Neighborhood Council,
Natural Resource Trustees, the Site  Specific  Advisory Board (SSAB), and the PGDP
Environmental Advisory Committee. The PRAP is part  of the Administrative Record
(AR)  File,  as required by the National Oil and Hazardous  Substances Pollution
Contingency Plan (NCP) [40 C.F.R. § 300.825(a)(2)].

A public meeting was held January 16, 1997, to  discuss  the changes in the PRAP. No
objections were expressed at  this meeting. Upon request from the public, the comment
period was extended 30 days. A response to the comments received during the public
participation period for this version of the PRAP is presented in the Responsiveness
Summary, which is presented in Part 3 of this ROD.

2.4    SCOPE AND ROLE OF THE OPERABLE UNITS

The PGDP presents unusually complex  problems  in  terms of hazardous waste
management and environmental releases. The DOE's proposed strategy is to divide the
site into operable units (OUs)  grouped by  source areas, and CSOUs,  one each for
ground water  and  surface  water.  Discrete response actions  will  be  selected and
implemented for each source area OU, as well as the CSOUs,  which are impacted by
commingled releases from the source area OUs. Prioritization for investigation and
possible remedial action has been assigned to each of the CSOUs (ground-water and
surface-water OUs) and source area OUs depending on their potential for contributing
to off-site contamination. As a suspected source of off-site contamination, SWMU  8
was a high priority for remediation.

2.5    SUMMARY OF SITE CHARACTERISTICS

Following are  hydrological and geological  descriptions of the  PGDP and individual
SWMUs.

2.5.1  Hydrogeologic Characteristics of the Paducah Gaseous Diffusion Plant Area

The sources for the following information are the Report of the Paducah Gaseous  Diffusion
Plant Ground-water Investigation Phase III,  KY/E-150, and the  Draft Northeast Plume
Preliminary Characterization Summary Report, DOE/OR/07-1339&D2.

2.5.1.1 Regional surface-water hydrology

The PGDP is located in the western portion of the Ohio River Basin (Figure 2-6). A local
 drainage divide causes the  plant's  surface water  to flow to the east and  northeast
 toward Little Bayou Creek  or to the west and northwest toward Bayou Creek. Both
 Bayou and Little Bayou creeks are perennial streams that discharge into the Ohio River.
 The SWMUs within WAGs 1 and 7 are located within the Bayou Creek watershed.

 Bayou  Creek flows northward along the western boundary of  the  plant,  from
 approximately 4 km (2.5 miles) south of the plant to the Ohio River.  Little Bayou Creek
 originates within DOE property and flows northward along the eastern boundary of  the


                                      10

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     ;1
   LEGEND
    ——  Department of Energy Boundary
    	Surface Water
    f^J" D  Swamp or Marsh
     —«—  Paducah Gaseous
           Diffusion Plant Fence
      O013  Effluent Outfall
               0   1SOO  3000   45OC
               Approximate Scale (leet)
  ModitiM Ifcxn KY/SUB/138-»r777CP-Oiri»S1/1
                                                                                   DJacoes EW Team. 1996
Figure 2-6.  Surface-Water Features in the Vicinity of the Paducah Gaseous Diffusion Plant
                                               11

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plant. Little Bayou Creek joins Bayou Creek in a marsh located approximately 4.8 km
(3 miles) north of the PGDP; ultimate discharge is into the Ohio River. Other surface-
water bodies located in  the area  surrounding  the  PGDP  include the  Ohio  River,
Metropolis Lake, Crawford Lake, numerous  small  ponds, gravel pits,  and settling
basins.

At the PGDP, man-made  drainage ditches receive storm water and effluent from the
plant. These waters are routed through outfalls and eventually discharge into Bayou and
Little Bayou creeks. The majority of the flow in these creeks can be attributed to effluent
water from  the plant. The 18  Kentucky Pollutant Discharge   Elimination System
(KPDES)-permitted outfalls have  a combined  average daily flow of 18.5  million liters
per day (4.88 mgd) and are monitored by the PGDP.

2.5.1.2 Regional geology

The stratigraphic sequence in the region consists of Cretaceous, Tertiary, and Quaternary
sediments  unconformably overlying Paleozoic bedrock.  At  the PGDP,  Paleozoic
limestone bedrock is present at a depth of approximately 104 m (340 ft). The sequence
of unconsolidated sediments overlying the bedrock consists of the following strata,  in
order of decreasing depth: the Tuscaloosa Formation, the McNairy Formation, the
Porters Creek Clay, the Eocene Sands, the continental deposits,  and surficial loess
and/or alluvium. Figure 2-7 illustrates the  relationships between the geologic horizons
present in the vicinity of the PGDP.

The principal geologic feature in the PGDP area is the Porters Creek Clay Terrace, a large,
low-angle,  subsurface terrace trending approximately east-west  across the southern
portions of the plant. The  terrace slope is located south of WAG 1 but directly underlies
portions of the WAG 7 area. This terrace is believed to be the result of the erosion of  the
Porters Creek Clay by the ancestral Tennessee River. As  a result of the erosion,  the
Porters Creek Clay is mainly absent from the PGDP area north of the terrace.

South of the Porters Creek Clay Terrace slope, the Porters Creek Clay is  unconformably
overlaid by  either the Eocene Sands or the continental deposits.  South of the terrace
slope, the  principal gravel facies within the continental deposits  are Miocene-Pliocene
gravels, referred to as terrace gravel deposits. The  terrace gravel deposits are  present
overlying the Eocene Sands or, where the Eocene Sands are absent,  directly on the upper
surface of the Porters Creek Clay in the WAGs 1 and 7 area. North of the terrace slope,
the McNairy Formation is directly  overlaid  by continental deposits. The continental
deposits are informally subdivided into the Lower Continental Deposits, consisting of
chert gravel  in a matrix of sand  and silt;  and the Upper  Continental Deposits, which
consist of thin, interbedded layers of clayey silt, sand, and occasional gravel.

2.5.1.3 Regional ground-water hydrology

Several water-bearing zones are  present in the PGDP area. South of the slope of  the
Porters Creek Clay Terrace, the principal water-bearing  units, in order of  increasing
depth,  are the terrace gravel, the Eocene Sands, and the McNairy Formation. However,
the Eocene Sands were not encountered beneath any of the SWMUs within WAGs 1 and
7 and will not be discussed further. The primary water-bearing units north of the buried
 terrace are the Regional Gravel Aquifer (RGA), the Upper  Continental Recharge System
 (UCRS), and the McNairy Formation.
                                      12

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 SOUTH
                          C-746-K
                       Sanitary Landfill
                         (SWMU 8)
   DOE
  POOP
Fenced Area
          Loess
Teitace
Gravels

Eocene
 Sand
                                                                             NORTH
                                               UPPER CONTINENTAL OEPOSfTS
                                               LOWER CONTINENTAL DEPOSITS
                                      TCxVn^^rS^^
                                       J-L7~i .,_L  MISSISSIPPIAN LIMESTONE
                                      TrQVoJI^&^

                                                                                                                  NOT TO SCALE
         Figure 2-7. Schematic of Stratigraphic and Structural Relationships near the Padueah Gaseous Diffusion Plant
                                                                                                               BJ Jacobs EM I tarn. 1996

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The RGA, defined as the uppermost aquifer at the PGDP, is present north of the Porters
Creek Clay Terrace. The RGA consists of the lower gravel and sand facies  of  the
continental deposits and also  includes the sands of the upper part  of the  McNairy
Formation where they are present directly below the RGA. The  unit ranges in thickness
from 3 to  12 m (10 to 40 ft) and pinches out at the base of the Porters Creek Clay Terrace
slope. According to  the 1990 Phase n and 1992 Phase ffl aquifer test reports conducted
by the Terran Corporation, the hydraulic conductivity values determined by  aquifer
pump tests for the  RGA range from 1.87 x 10'2 to 4.23 x  10'1  cm/sec (5.297 x 101 to
1.093 x 103 ft/day). Ground-water velocity within the RGA is estimated to range from 61
to 122 m/yr (200 to 400 ft/yr) to the north-northeast, toward the Ohio River, as noted in
the Remedial Investigation (RI) Addendum for Waste Area  Grouping 22, Burial Grounds, at
the Paducah Gaseous  Diffusion Plant, Paducah, Kentucky, DOE/OR/07-1141&D1.  Recharge
to the RGA is primarily via infiltration from  the  Upper  Continental Deposits and
underflow from the  Terrace Gravel.

The UCRS is present north of the Porters Creek Clay Terrace and consists of the Upper
Continental Deposits and overlying loess. It includes sand and  gravel lenses as well as
the  less  permeable clay and silt matrix of  the Upper  Continental Deposits.  The
permeable lenses are relatively discontinuous laterally; hence, the flow  direction  in this
unit is primarily vertical. A predominantly clay  layer of  varying thickness separates the
UCRS sands and gravels from the underlying RGA in most areas of the plant's grounds.
Immediately south of the Porters Creek Clay Terrace slope, the principal water-bearing
unit within the continental deposits is the Terrace Gravel. The Terrace Gravel consist of
interbedded gravel, sand, silt, and clay. Hydraulic conductivity values for the Terrace
Gravel, determined from slug tests, range from 1 x 10"6 to 1.4 x 10"3 cm/sec (2.8  x 10"3 to
4.0 ft/day).

The Porters Creek Terrace  slope is  located south  of  the  three SWMUs in  WAG 1
(SWMUs 38, 100,  and 136) but directly underlies portions of the WAG  7 area. The
amount of ground-water flow over the slope has not yet been determined, but ground-
water modeling conducted in support of  the  WAGs 1 and 7 Feasibility Study (FS)
indicates that there  is some degree of hydraulic connection between the RGA north of the
terrace slope and  the Terrace Gravel south of the  terrace  slope.  The  amount  of
connection is expected to vary as a function of the continuity of the shallow sand and
gravel lenses over  the terrace slope. In those areas of the slope where the permeable
lenses are relatively continuous, such as where streams have  deposited alluvium, the
Terrace Gravel  would be  expected  to transmit ground  water laterally along  the
impermeable surface of the Porters Creek Clay to the continental deposits (including the
 RGA) north of the slope as well as to the alluvial deposits of nearby streams.

 2.5.2   Hydrogeology of Waste Area Groups 1 and 7

 Unless otherwise noted, the information presented in  this section is  derived from the
 Resource Conservation and Recovery Act Facility  Investigation/Remedial Investigation Report
for Waste Area Groupings 1 and 7 at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky,
 DOE/OR/07-1404&D2, and from the Feasibility Study for Waste Area Groups 1  and 7 and
 Kentucky Ordnance  Works Solid  Waste Management Units 94, 95, and 157 at the  Paducah
 Gaseous Diffusion Plant, Paducah, Kentucky, DOE/OR/06-1416&D2.

 2.5.2.1 Solid Waste Management Unit 100

 Following are surface-water, surface-feature, and hydrogeologic descriptions for SWMU
 100.
                                      14

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Surface features and surface water.

The  ground  surface at  SWMU  100  is  relatively  flat,  ranging  in  elevation  from
approximately 113  to  114 m (370 to 375  ft) amsl. Most  of  the ground surface is
grass-covered, with the exception of the eastern part of the unit occupied by Fourth
Street and  a  paved driveway. There  are  two drainage ditches at the site, a north-
northeastern flowing drainage ditch located next to the railroad tracks at the western
edge of the unit and a north flowing drainage ditch on the eastern edge  of  the unit
adjacent to Fourth Street. A document issued by CDM Federal Programs Corporation in
August 1994,  Investigation of Sensitive Ecological Resources Inside the Paducah Gaseous
Diffusion Plant, 716-0003-FR-BBRY, reports that wetlands have been identified in these
drainage ditches. Runoff from the unit flows to the ditches and  discharges  via KPDES
Outfall 016 to Bayou  Creek, which is located approximately 305  m  (1,000 ft)  to
the west.

Hydrogeology.

Eleven soil borings and two  ground-water monitoring wells (MWs)  were installed at
SWMU 100 for the RFI/RI. The locations of these borings and monitoring wells, as well
as the three soil borings (H216, H353, and H354) installed at SWMU 100 for the Phase H
Site Investigation, are shown in Figure 2-3.

The following lithologies were encountered beneath the unit, in order of increasing depth:
fill material, loess deposits, and the Continental Deposits. The uppermost water-bearing
unit at this SWMU consists  of about 8 m (25 ft) of sand and gravel in the Upper
Continental Deposits. There is a day  aquitard near the base of the Upper Continental
Deposits that is 2.9-m (9.5-ft) thick  and occurs between approximately  17 to 19  m
(54 to 63 ft) bis. The RGA is present at depths between 19 and 31 m (63 and 103 ft) bis.
It consists of 1.2 m (4 ft) of sand overlying 11 m (35 ft) of sandy, pebble- to cobble-sized
chert gravel.

The Porters Creek Clay may occur beneath this unit.  Although SWMU 100 is located
north of the Porters Creek Clay Terrace, it may overlie the extreme northern edge of the
terrace slope where a thin layer of the day is present. A stiff  formation  (possibly the
Porters Creek Clay) was encountered in MW 330 at a depth of 31 m (103 ft) bis, but no
lithologic sample was obtained.

According to water-level measurements collected July 15, 1994, in UCRS MW 315, the
depth of shallow ground water at SWMU 100 is 2.45 m (8.04 ft) bis [111.9  m (367.22 ft)
amsl]. The depth to water in MW 330, which is screened in the RGA, was approximately
 12.8 m (42.1 ft) bis [101.3 m  (332.3 ft) amsl].

 2.5.2.2 Solid Waste Management Unit 136

 Following are surface-water,  surface-feature, and hydrogeologic descriptions for SWMU
 136.

 Surface features and  surface water.

 The  ground  surface  at  SWMU 136  is fairly  level and ranges  in  elevation from
 approximately 113 to 114 m (371 to 374  ft)  amsl. A 53-cm  (21-inch) thick layer of
 compacted gravel  covers the ground surface west and south of the pad, and  plastic
 sheeting covers the excavated spill area. Two shallow depressions are located to the
                                       15

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south and  southwest in the C-740  Material Yard. The nearest surface-water body  is
Bayou Creek, which is located approximately 457 m (1,500  ft) southwest of the unit.
Runoff from SWMU 136 discharges  to Bayou Creek via KPDES Outfall 008.

Hydrogeology.

Solid Waste Management Unit 136  is located north of the Porters Creek Clay Terrace
where the Porters Creek Clay is absent. Five soil borings and three monitoring wells were
drilled at SWMU 136 (Figure 2-3). None of the soil borings or  monitoring wells at this
unit were drilled to the depth of the McNairy Formation.

The following lithologies were encountered beneath the unit, in order of increasing depth:
gravel and sand fill material, loess, and the continental deposits. The Upper Continental
Deposits, consisting of up to 15 m (50 ft) of interbedded gravel, sand,  clay, and silt, are
present between 4 to 20 m (13.5 to 65 ft) bis. An 8-m (25-ft) thick aquitard, consisting  of
clay interbedded with thin silt and sand  lenses, was encountered at the base of the
Upper Continental Deposits at  SWMU 136. Lower Continental Deposits are present
beneath the unit at depths between  20 to 27 m (65 and 90 ft) bis.

According to water-level measurements  collected July 15, 1994, the depth to  the UCRS
piezometric surface at SWMU 136  is approximately 1 m (3.29  ft) bis at MW 304.  This
well was screened from approximately 5 to 8 m (16 to 26 ft) bis. The depth to water in
the two upper RGA wells (MWs 325 and 326) was approximately 12.5 m (41 ft) bis,  or
101 m (332 ft) amsl.

2.5.2.3 Solid Waste Management Units 130 through 134

All of the C-611 USTs were found at depths less than 6 m (20 ft) bis, with the exception
of the UST at SWMU 131, which could not be located.

Surface features and surface water.

The ground surface in the vicinity of the C-611 WTP gently  slopes to the south and east
and ranges in elevation from 112.8 to 121.9 m (370 to 400 ft) amsl. Surface features  at
the unit include the C-611-H WTP Building, the C-611-C Building to the south, a storage
shed to the east, and a  transformer to the west. In addition,  four treatment lagoons are
located immediately north of the C-611 WTP. The area  immediately surrounding the
buildings  is mainly gravel-covered, except the  asphalt-  or concrete-paved  areas  at
SWMUs 130 and 131, and the fenced, grass-covered area situated near SWMU 131. No
 surface water, floodplains, or wetlands have been identified within the boundaries  of
 the C-611 UST area. Bayou Creek is located approximately 370 m (1,200 ft) east of the
 area and  the  unnamed tributary  of Bayou Creek is located  approximately 300  m
 (1,000 ft) south of the area. Surface runoff from the C-611 UST area is discharged via
 KPDES Outfall 006 to Bayou Creek.

 Hydrogeology.

 The USTs overlie the  Porters Creek Clay Terrace at the  approximate location of the
 terrace slope, where the slope  dips relatively steeply to  the north-northeast at  an
 approximate gradient of 0.11 ft/ft.  In this area, the continental deposits have not been
 differentiated  into upper and  lower members and  are  informally referred to as the
 Terrace Gravel or the Terrace Slope Gravels. Five soil borings and two monitoring wells
 were drilled at SWMUs 130 through 134 (Figure 2-4).
                                       16

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The following lithologies were encountered beneath the units,  in order of  increasing
depth: fill material (composed of gravel and sand), loess, the continental deposits, and
the Porters Creek Clay. The continental deposits (consisting of interlensing gravely clay;
sandy gravel; and silry, clayey gravel) are present at these units from 5 m (17 ft)  bis to
below 14.9 m (49 ft) bis. The Porters Creek Clay was encountered, though not fully
penetrated, in three soil borings at the units. The depth to the top of the clay varies from
4 m (13  ft)  bis in the westernmost boring at SWMU 130 to 10 m (34 ft) bis in  the
south-eastern boring at SWMU 134.

The two  monitoring wells installed  at SWMUs  130 through 134 were completed in the
Terrace Gravel.  According to water-level measurements collected July 15,  1994,  the
depths to shallow ground water were approximately 2.3 m (7.5 ft) bis  at MW 318  and
2.8 m (9.32  ft) bis at MW 317.  Contouring of  the water levels  at WAG 7 (Figure  2-8)
indicates the ground-water flow direction is to the east, toward Bayou Creek.

2.5.2.4 Solid Waste Management Unit 8

Following are descriptions  of the  surface-water  and  hydrogeologic conditions at
SWMUS.

Surface water.

Drainage ditches located along the western and  northern edges of the landfill flow to the
south into the unnamed tributary  and to the  east into Bayou  Creek,  respectively. A
portion of the 100-year floodplain of Bayou Creek and the unnamed tributary is located
within the boundary of SWMU 8. Wetlands were identified in the vicinity of SWMU 8
and are shown in Figure 2-5.

Hydrogeology.

Wehran Engineering drilled 10 soil borings at  the landfill in 1980.  Five of these were
completed as piezometers (MWs 23  through 27) screened in the Porters Creek Clay. In
addition, 10 test pits were excavated in and around the landfill, and polyvinylchloride
plastic well points were installed  in  the backfill.  As  part of  the Phase  n  Site
Investigation, a soil boring (MW 183) and a monitoring well (MW 184)  were installed in
the Terrace  Gravel at the landfill in 1991.  For the RFI/PJ, nine soil borings were drilled
and four shallow monitoring wells (MWs 300  through 303) were installed around the
perimeter of the landfill. None of the soil borings or monitoring wells at this unit  fully
penetrated the Porters Creek Clay.  Figure 2-5 shows the locations of the sampling points
 at SWMU 8.

 A cross section illustrating the geology at the landfill site is presented in Figure 2-9. The
 Porters Creek Clay Terrace slope dips relatively steeply to the north-northeast beneath
 the northeastern  comer  of  the landfill.  The  following lithologies were encountered
 beneath the unit, in order of increasing depth.

        •  Landfill cap material occurs in the  upper 0.6 to 0.9  m (2.0  to 3.0 ft) of the
           landfill. A 15- to 30-cm (6- to  12-inch) clay cap  and a 46-cm (18-inch)  layer
           of subsoil and topsoil were placed on the landfill in 1982, and additional soil
           was  added when the cap was repaired in 1992. A thin layer of stiff, highly
           plastic white clay that fits  the description of the original clay cap  was
           encountered  in soil borings   8-SB-002  and  8-SB-002A.   Results  of  soil
                                      17

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174.7 •   M-O401
                                     LEGEND
          Approximate Extent of Fill

	  Surface Water

          Contour of Shallow
• - 365' - •  Ground-Water Elevation
          (Contour Interval = 5  ft)

   »•*"••   Monitoring Well or Soil Boring

    in    Shallow Ground-Water
          Elevations (ft amsl. July *94)


                        •nTT"-
                        •u Sc*tt (FMt)
                                                                        -i—i—t—H Railroad

                                                                        -X	X- Fence
                                                                                •+ZK.
                                                                                  %I
                                                                             DJaootn EM Team. 1998

   Figure 2-8. Shallow Ground-Water Flow Map for Waste Area Group 7
                                       18

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Efevilton
             B
                                                                                        B'
375 O •

970 O

>lfi O
                                                                                                                                                       El»v«tlon
                                                                                                                                                       (ft •mtl)
                                     B-7
           8-SB-004
                                                                                                                             Loess/Alluvium
                                                                        Btyou      95-SB-003
                                                                        Cr**k  -
       • tO O

       .(50
             LEGEND
             |    | Fill (fly ash. rubbish mixed w/soil)

             HH Loess/Alluvium (sand, sill, clay, gravel)
             i	1 Continental deposits: Interbedded sand,
             '	' gravel, clay, and silt (Terrace Gravel)
             |    | Porters Creek Clay
                    Horlionbl Scab in Feel
                    0             100            T
Log Symbols
     Gravel
I    I No Sample
     Fill
                    Verlicnl Exnggernlicm SX
F.^'-l Clay, Gravel, Silt & Sand
|™| Sand. Sill, and Clay
HAV| Sand and Gravel
h-.:iClay
|""~| Sand
                                                         Shallow water level (approximate, based on
                                                         July 1994 levels in surrounding monitoring wells)
                                                                                                  36B O

                                                                                                  3«3O,O

                                                                                                 • 3&S O
                                                      Line of
                                                  Cross Section
                                                                                                                                                   BJJntobitM I tain. 1946
                                         Figure 2-9. Solid Waste Management Unit 8 Cross Section B-B'

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          permeability testing on samples collected from the soils (vegetative cover)
          overlying the landfill cap range from an average hydraulic conductivity of
          1.18 x ID'7 to 3.54 x 10*cm/sec (3.34 x 10" to 1.00 x 101 ft/day).

       •   Fill material, composed of fly ash mixed with soil and assorted rubbish, is
          found beneath the clay and vegetative cap to a maximum observed thickness
          of 8.5 m (28 ft). In general, fly ash primarily consists of silt-sized particles of
          amorphous glass with quartz, mullite (aluminum silicate), various iron oxides
          such as hematite and magnetite, and lime  according  to the Hydrogeologic
          Assessment of the C-746-K Landfill and Vicinity, KY/ER-24.

       •   Loess and alluvial deposits are present in some areas underlying the landfill
          and range in thickness from 0 to 2 m (0 to 8 ft).

       •   Continental deposits consisting of up to 10 m (33 ft) of Terrace Gravel overlie
          the Porters  Creek  Clay Terrace at  the  landfill. The  continental  deposits
          consist  of clayey silt containing coarse  gravel and sand lenses and are
          difficult to distinguish from younger alluvial deposits near the creeks.

       •   The Porters Creek Clay underlies the landfill at varying depths. The depth to
          the top of the day varies from 3.0 m (10  ft) bis in 8-SB-004 to 12.6 m
          (41.5 ft) bis in 8-SB-006. The Porters Creek Clay has been described as a
          dark, greenish gray to black clay containing varying amounts of silt and fine
          sand and displaying fine, hairline fractures. Results of tests conducted by
          Wehran Engineering in 1981  indicate that the hydraulic conductivity of the
          Porters Creek Clay ranges from 5.5 x 10* to 1.3 x 10"7 cm/sec (1.56 x  10"s to
          3.68 x 10-1 ft/day) at the landfill.

The UCRS and the RGA are  not present at SWMU  8. Ground water occurs under
shallow,  unconfined conditions in the Terrace Gravel, loess, and alluvium overlying the
Porters Creek Clay Terrace. Monthly ground-water levels measured at the landfill since
1980  indicate  that  ground-water levels vary seasonally,  with the  maximum levels
typically occurring during winter and spring. Ground-water mounding occurs beneath the
northwestern portion of the unit. Data  collected in June 1992 indicate that the shallow
water levels rise to about 115  m (377 ft) amsl  beneath the western part of the landfill,
indicating that the lower 2 to 3 m (5 to  10 ft) of waste at the landfill is below the water
table during certain times of the year. According to water-level measurements collected
July 12,  1995,  the depths  to shallow ground water range from approximately 1.6  m
(5.4 ft) bis at MW 300 to 3.5 m (11.5 ft) bis at MW 303. Figure 2-8 presents a map of
the piezometric surface at the landfill.

Underflow enters the landfill from the west within the Terrace Gravel, flows laterally to
the east, and discharges into the creeks, with some unquantified amount potentially
flowing into the RGA  north of the terrace as recharge. North of the terrace slope, the
predominant ground-water flow direction within the RGA is north-northeast. Ground-
water flow modeling conducted for the FS at SWMU 8 was  used to help define the
probable shallow ground-water flow  conditions at the landfill  and  to address the
uncertainties regarding potential contaminant migration from SWMU 8 over the terrace
slope  into the RGA.  According  to  the modeling results, under current (no  action)
conditions, approximately 0.66 I/sec (10.4 gpm) of the shallow ground water emanating
from the landfill discharges to the creeks. This represents most of the shallow  ground
water flowing through the landfill, with the remainder of  the  flow, approximately
0.007 I/sec (0.10 gpm), discharging over the terrace slope into deeper layers. The results
                                      20

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of this modeling and the presence of the seeps in the surrounding surface water indicate
that most of the shallow ground water  at the landfill  discharges to the surrounding
creeks.

All available data have been used to describe the expected conditions at the C-746-K
Sanitary Landfill. However, a degree of uncertainty remains concerning some of the site
conditions at SWMU 8. These uncertainties include the degree of hydraulic connection
between  the Terrace Gravel and  the RGA over  the  terrace slope  and  detailed
information concerning the waste types  and volumes at the landfill.  An additional
uncertainty is the exact  location and condition of the KOW yellow-water line, an
underground sewer line consisting of a 30.5-cm (12-inch) diameter vitrified clay pipe.
The yellow-water line was used from 1942 to 1945 to transport yellow water, an acidic
and   trinitrotoluene  (TNT)-contaminated  waste   water,   from  the  KOW   TNT
manufacturing area  to a discharge point on Bayou Creek. Maps of the KOW area
indicate that sections of the KOW yellow-water line underlie the northern portion of the
landfill site (Figure 2-5). The uncertainties are discussed in the FS and were considered
during the development of the remedial alternatives for SWMU 8.

2.5.3   Operable Unit Characteristics

Following is a summary of the sampling results for the individual SWMUs.

2.5.3.1 Solid Waste Management Unit 100

Low levels of contamination were found in soil, sediment, surface-water, and ground-
water samples collected at SWMU 100 (the FT A).  Organic compounds detected at this
unit include VOCs (toluene, xylene, and benzene) and polycyclic aromatic hydrocarbons
(PAHs) commonly associated with waste oils and diesel fuels. They were detected  at
low concentrations in soil samples down to a depth of 4.6 m (15  ft) bis. However, no
organic compounds were detected in ground-water, surface-water, or sediment samples
indicating that these media are not impacted by organic contaminants migrating from
SWMU 100. Twelve metals (aluminum, barium, cadmium, chromium, copper, iron, lead,
magnesium, manganese, nickel,  vanadium,  and  zinc) were detected at  elevated
concentrations in ground-water, surface-water, and sediment samples from the unit. Of
these 12 metals, only three (barium,  manganese, and  vanadium) also  were detected
above background  levels in surface  and subsurface soils  at the unit. This limited
occurrence of metals in the soils at the  unit indicates that SWMU  100  likely is  not a
significant source of metals contamination.

Radionuclides ("Tc, uranium, and  thorium) were detected in soil, sediment, surface-
water, and ground-water samples from SWMU 100. Their widespread occurrence and
low activities indicate their presence likely is related to plant activities rather than past
activities at this SWMU.

The areal extent of impacted soils  at SWMU 100 has been estimated as approximately
 720 mj (7,750  ft2) according to the WAGs  1  and 7 FS, DOE/OR/06-1416&D2. The
 horizontal extent of organic and inorganic contamination in soils is restricted to depths
 above 4.6 m (15 ft) and 7.6 m (25 ft)  bis, respectively. The limited extent and low
 concentrations of organics and metals contamination at this unit may represent residual
 contamination from the waste oils or fuels burned at the unit.
                                     21

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2.5.3.2 Solid Waste Management Unit 136

Results of the RI conducted at SWMU 136,  the TCE Spill Site, indicate that  several
organic contaminants are present above background levels in soil and ground water a t
the unit. Soil samples from SWMU 136 were found to contain low levels of VOCs [TCE,
1,1-DCE, 1,1,1-trichloroethane (TCA), and 1,2-DCA] and several PAHs.  Ground-water
samples at the unit also contained organic contaminants. The maximum concentration of
TCE in ground water was detected in a UCRS hydraulic probe sample collected from
soil boring 36-SB-004 at  442 ug/1. The highest TCE concentration observed in the RGA
wells at the unit (110  ug/1) was detected in a sample from a downgradient well (MW
325). Another organic compound detected in the ground-water samples was 1,1,1-TCA,
(4,472 ug/1), which was detected  in a UCRS temporary well sample, but was not
detected at concentrations above 5 ug/1 in samples from the adjacent UCRS monitoring
well (MW 304).

Soil and ground-water samples were also found to contain metals and radionudides at
levels above background. Four metals [antimony (1.7 mg/kg), chromium (29 mg/kg),
barium (439 mg/kg), and mercury (3.2 mg/kg)]  were detected  above  background
concentrations in soils at the unit. Several metals were detected above background levels
in ground water. Samples from UCRS MW 304  contained iron, manganese, silver, zinc,
sodium,  and  aluminum above  background concentrations.  Ground-water  samples
collected from the RGA wells contained barium, manganese, and zinc above background
levels. The  radionuclide **Tc was found  above background  values in the samples
collected from all three monitoring wells at the unit. The levels of "Tc ranged from 1.27
to 12.21 pCi/1.

The observed contamination in soil and ground water at the unit indicates that the spill
site is a likely source of organic contamination. Trichloroethene and other chlorinated
hydrocarbons have migrated below the water table at the unit into the UCRS and the
RGA, leaving residual contamination in the  surface and subsurface soils  at  the unit.
However, the low concentrations of TCE detected in ground-water samples at the unit
do not indicate the presence of dense nonaqueous phase liquid. The areal extent of the
organic and metals contamination at  the  unit has been estimated as  approximately
17.7 m2 (190 ft2) according to the WAGs 1 and 7 FS, DOE/OR/06-1416&D2.

2.5.3.3 Solid Waste Management Units 130 through 134

A sample was collected from the tank residuals of both SWMUs 130 and 134. The
location of  SWMU 131  could not be determined, and SWMUs 132 and 133 had been
filled with sand and grout, respectively. Both samples contained lead, benzene, toluene,
ethylbenzene, and xylene as well as other VOCs and PAHs associated  with petroleum
 products. Low levels of lead, VOCs, and PAHs also were detected in soil samples from
 the C-611  UST  area.  The only VOC detected was  1,4-dichlorobenzene  (3  ug/1), which
was  detected in  ground-water  samples collected from MW 317, the downgradient
 (eastern) shallow monitor well. The only PAH detected was naphthalene (70 ug/1), and
 it was found in the well upgradient of the site (MW 318). Lead, the only  metal for which
 analysis was completed in the two monitoring wells, was not detected in ground water.

 Low  levels of  radionudides,  induding  uranium-235  ("'U),   uranium-238  (^U),
 neprunium-237 (a7Np),  thorium-228 (22*Th), thorium-232 (a2Th), **Tc, and plutonium-238
 ( Pu), were detected  in  soil and ground-water  samples collected in the area.  No
 radionudides were detected above background levels in the UST liquids.  The presence of
 these radionudides in soils and ground water is likely unrelated to any of the USTs, but
 the presence more likely is the result of  plant-wide activities.  The organic  and lead


                                      22

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contamination observed at SWMUs 130, 132,133, and 134 appears to be limited in areal
extent [35.3 m: (380 ft3)] and may be indicative of past  gasoline, diesel, or fuel-oil spills
in the area.

2.5.3.4 Solid  Waste Management Unit 8

Soil, ground-water, surface-water, sediment, and leachate  sampling was conducted at
the landfill for the RFI/RI. Eight soil borings and four shallow ground-water monitoring
wells, MWs 300 through 303, were installed around the perimeter of the landfill. Five
surface-water samples,  seven sediment samples, and three leachate  samples were
collected during the RFI/RI from the locations shown in Figure 2-5.

Results of the RI conducted  at the  landfill indicate that low levels of various organic
compounds, metals, and radionudides are likely leaching from the wastes buried in the
landfill into the nearby streams and to ground water. Leachate samples collected from
two shallow  holes on the bank of the unnamed tributary south of the landfill indicate
that the pH of the leachate ranges  from 2.3 to 3.4 prior to mixing with stream water.
Where  the acidic  leachate  from  the  landfill  enters the creeks,  the pH rises to
approximately 6, indicating that the leachate only slightly lowers the stream pH when
they mix. The low pH causes dissolved metals, particularly iron and aluminum, to form
a precipitate. The precipitation of iron and aluminum oxy-hydroxides is the suspected
cause of the  orange to yellow staining observed seasonally at various seep sites  at the
landfill. The staining is most intense during dry periods (late summer to early fall) when
stream flow is low.  Specific conductance values for the stream  samples are  also
typically higher during the dry season and range up to approximately 2,000 fimhos/cm.
The measured hardness for surface-water samples at  the landfill varies from 36 to
1,085 mg/1 calcium carbonate  (CaCO3). The detailed results of the  sampling  can be
found in the  RFI/RI for WAGs 1 and 7.

Inorganics.

Numerous metals (including aluminum, antimony, beryllium,  chromium, cobalt, iron,
magnesium,  manganese, selenium, thallium, and vanadium) were  detected  above
background  levels in soils  at the unit.  The metals aluminum, beryllium, cobalt, iron,
magnesium, manganese, nickel, and zinc also were detected above background levels in
all  four monitoring wells.  (The concentrations of these metals were lower  in  the
 upgradient well, MW 302,  than in the downgradient  wells.) Many metals (aluminum,
beryllium, calcium, cobalt, iron, magnesium, manganese, mercury, nickel, sodium, and
 zinc) also were detected above background levels in  the leachate samples, indicating
 that the landfill likely is one source of the metals. Surface-water samples collected for
 the RFI/RI contained numerous metals  at  concentrations above background levels;
 however,  according to the United States  Geological  Survey report,  Study  and
 Interpretation of the  Chemical Characteristics of Natural  Water, only two, antimony and
 cadmium, were present at  concentrations above those typical of natural waters. The
 elevated antimony concentration was detected in an  upstream surface-water sample
 and, therefore, likely is not due to the landfill. Cadmium was detected in surface-water
 sample 08-SW-003, as well as in some leachate samples, at  concentrations higher than
 the expected range for natural waters. This suggests that the landfill is a probable source
 of the elevated cadmium levels. Although several metals were detected in sediment
 samples from SWMU 8, the only metal detected above  background levels was iron
 (47.3 mg/kg). The extent of the metals contamination in surface water appears limited
 to the areas  upgradient of sampling location 08-SW-003.
                                      23

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The cause of the acidic pH of the landfill leachate has not been firmly established. A
study by the  Illinois State Geological Survey  indicates that  low pH, under  some
conditions, is due to the presence of high concentrations of sulfate in the fly ash. The pH
of the leachate is low enough to cause the dissolution of metals. The source of some of
the metals detected at elevated levels in ground water and leachate samples at  the
landfill is likely due to the fly ash. However, the elevated levels of iron and manganese
also may be a result of the interaction of the acidic pH with the Terrace Gravel deposits,
which often have a dark brown coating, or patina, of iron and/or manganese oxides in
the PGDP area.

Radionuclides.

Low levels of the radionuclides, "Tc, a5U, uranium-234 (^U), 2MU/ a6Th, thorium-230
(^h), ^'Th, and *7Np were detected levels in soils. The radionuclides a7Np, ^Pu, "Tc,
2UTh, ^Th, ^U, ^U, and ^U were detected above background levels in the leachate
samples from SWMU 8. The highest activities were detected at a seep on the northern
bank of the unnamed tributary, south of the landfill. Surface-water samples from two
locations at SWMU 8 contained radionuclides: ^'^U (0.45 pCi/1), ^U (0.31 pCi/1),
and ^U (0.2 pCi/1) at  08-SW-003  and 2M/2JIU  (0.32 pCi/1) at 08-SW-005. Very low
levels of radionuclides were  detected  in  the  downgradient shallow ground-water
samples from  MWs  300,  301, and 303.  (No radionuclides  were detected  above
background levels  in the upgradient well,  MW  302.)  The contaminated  rubbish
reportedly disposed in the landfill is a potential source of these contaminants.

Organics.

Very low levels of VOCs were detected in the surface and subsurface soil samples  at the
landfill. Benzene (21 jig/kg) was detected in surface and subsurface soils at soil  boring
08-SB-001 at the northeastern edge of the landfill. A possible source of the benzene, as
indicated by old photographs, was the bulldozers parked in the area  during landfill
operations. Additional  VOCs,  including 1,2-DCE,  carbon tetrachloride, and toluene,
were detected but at concentrations below the quantitation  limit. Numerous PAHs were
detected in shallow soils but, with the exception of the PAHs detected in 08-SB-001, the
concentrations of the PAHs were less than the quantitation limit. The  surface-soil
sample at soil  boring 08-SB-001 had a total PAH concentration of 9,160  Jig/kg. Two
polychlorinated biphenyls (PCBs)  were detected  at  the landfill:  (1) Aroclor-1254,
detected from the 1.52  to 3.05  m (5.0 to 10.0  ft) bis intervals in SB-006  at a
concentration of  2,082  Hg/kg;  and (2) Aroclor-1260,  detected in the surface soils at
08-SB-004  at  a  concentration of 183  Hg/kg. Although these appear  to  be isolated
occurrences of PCBs  at the  landfill,  PCBs  are  still considered potential landfill
 contaminants.

 The  VOCs TCE (27 ug/1);  1,1-DCA  (23 ng/1); 1,1-DCE (18 ug/1); and 1,2-DCE
 (330 ug/1)  were detected in MW 300 during RFI/RI sampling  activities. Two of these
 VOCs (1,1-DCA  and 1,2-DCE) also were detected in MW  301. Additional sampling of
 MWs 300 through 303 was conducted in March  1995 and results indicated  the presence
 of cis-l,2-DCE (790 ug/1); 1,1-DCE (72  ug/1); 1,1-DCA (61 ug/1); and TCE  (52 ug/1).
 Two of the leachate samples contained the organic compounds TCE; 1,2-DCA;  xylene;
 1,1-DCE; and  1,2-DCE. No organic compounds were detected  in the sediment samples
 or surface-water samples collected  during the RFI/RI at the unit. However, one organic
 [cis-l,2-DCE  (9  Hg/1)] has been detected in a  surface-water sample collected from
 PGDP stream sampling point C-746-K-3A, located southeast of the landfill within the
 unnamed tributary. The presence of VOCs in the ground-water and leachate samples
 indicate they likely are leaching from the landfill.


                                       24

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2.5.4   Contaminant Characteristics

The conceptual site model presented in Figure 2-10 illustrates source area contamination,
primary and secondary contaminated media, transport pathways, exposure pathways,
and receptors that may be associated with releases of contamination  from SWMU 8.
The  source  at  SWMU 8  consists of fly  ash;  uncontaminated,  combustible  waste;
potentially-contaminated  rubbish; and  trash.  From  the  source   at  SWMU  8,
contamination has migrated to primary contaminated media, soil and  shallow  ground
water, via  infiltration,  leaching,  erosion,  and runoff. From the  primary  media,
contaminants  are migrating  to  sediments  adjacent  to  SWMU  8,  a  secondary
contaminated medium. Migration pathways also may transport contaminants to other
secondary contaminated media  including air, leachate, soil, surface water,  and deep
ground water. As illustrated in the  conceptual site model, contamination from SWMU 8
is migrating primarily through the release of leachate at seeps next  to  the unnamed
tributary. The environmental exposure contaminant pathways  of potential concern are
illustrated in Figure 2-11.

Ground water is included in the  conceptual site model to identify it as a  contaminated
medium. However, receptors and  exposure pathways are not identified in the model
since the preferential pathway of contaminant transport from the unit is via the shallow
ground-water system to the surface. Additionally, while the remedial action taken does
not impact ground water, any future remedial action, if necessary, will be undertaken as
part  of the ground water CSOU. Air is included in the model to  identify  it  as  a
secondary contaminated medium; however, there are no receptors or exposure pathways
identified, since SWMU 8 is outdoors and the likelihood of exposure to contamination
via the air pathway outdoors is minimal.

Potential current exposure to contaminants in the source or  other primary media  at
SWMU 8 is limited since the unit is capped.  However, potential risks to industrial
workers exist at  SWMU 8 through direct contact  with the  secondary  contaminated
medium (sediments). Additionally, there is a potential for humans or animals to  come
into direct contact with acidic leachate being released from the landfill into sediments
above the water level in the creeks (Figure 2-10 is based on risk assessment results and
does not include potential risks to any receptor that may come into direct contact with
the acidic leachate). The selected remedial action for SWMU 8  is intended to reduce the
potential for direct contact with contaminated sediments and acidic leachate associated
with the unit, thereby reducing associated risks. The risks addressed by the  selected
remedy are discussed in the following section.

2,6     SUMMARY OF SITE RISKS

Solid Waste Management Unit  38 is an operating facility, therefore,  an evaluation of
 remedial options for the unit will be deferred until it ceases operation. At SWMUs 130
through 134 and the soils of SWMU 136,  risks and hazard indices  (His) for human
 health and  animals do  not exceed threshold  values; therefore, these units require  no
 further action. Any contaminated ground water associated with SWMU  136 will  be
 evaluated as part of the ground water CSOU (WAG 26).

 Risks for industrial  workers  slightly exceed EPA  thresholds at  SWMUs  8  and 100
 (please refer to  the FS  in the WAGs  1  and  7  AR for more detail  regarding risk
 thresholds); however, these risks are due  to  direct contact with surface water and
 sediments contaminated with  metals.  As  discussed in the  FS for  WAGs 1 and  7,
 DOE/OR/06-1416&D2,  the direct  contact  exposure pathway  is  associated  with


                                      25

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  Sources
  Primary
  Release
Mechanism
   Primary
Contaminated
   Media
Secondary
  Release
Mechanism
 Secondary
Contaminated
    Media
  Potential Receptor and
Exposure Routes/Pathways


Infiltration

Erosion



^
^

w



Soil


Ground
Water













•




















•


Percolation
Wind-Generated Dust
Volatilization
Erosion
Runoff
Leaching







































>_



^
r




>—


*-



>_
*



>_



Ground
Water


• Air




Onil







Surface
Water







>_
•



>^




w.
^






>.



>^


Current
Industrial
Worker

N/A



M/A



-Inhalation
-Ingestion
•Extornnl
Exposure
•Ingestion
-Inhalation
-Dermal






M/A


Future
Industrial
Worker

KI/A



NJ/A



-Inhalation
-Ingestion
-External
Exposure
-Inhalation
-Ingestion
-Dermal






N/A


Intruder/
Infrequent
Recreational
User
1


N/A


M/A




N/A


-Inhalation
-Ingestion
•Dermal
-External
Exposure





-Dcrmnl


Ecological


N/A


M/A



•Inhalation
•Ingestion
•f:xlem,il
Exposum
-Inhalation
•Ingestion







N/A


N'A-Nnl Applu nllln
                 Figure 2-10. Cnnccptu.il Site Model for Solid Waslc Management Unit, 8 of W.isle Aren Clroup 7

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KJ
SJ
                                                                 Clay Cap
                                 Precipitation produces infiltration and runoff.
                                                             Infiltration leaches
                                                             contaminants from
                                                                the waste.
                  TS Ground-Water
                      Underflow
                       -
                                            . -^•' v -•--. •~T/  ' . ""?•'  :J Leachate Seeps /••  -TT.  •   -r-

                                                                              '' •  •' :^4...\.   ',•-•'  ."="'''.'.'•'•;•  _^''.  ."^.   Hydraulic connection
                                                                             •'• •  •  .  "~U-J.' •  • ;   "•""•"." U^i.'  •  • •  •    between Terrace Gravels:
                                                                                                                          and RGA Is unknown.
                       Not to Scale   :'  .' —. ;.   --- '. • •'. ,'r—.• .'•  '.—. '.'  •.'. '^-.- .'•
                       Sill and Clny
Silty Gravel with Occasional Clay
                                                                                          Lnndnil Material
Relative Hydraulic
  Conductivities
K1 >K2>K3>K4
       (Modilied from DOE/OR/07-1404&D2)
                                                                                                                                                     Team. 199B
                                      Figure 2-11. Contaminant Pathways from Solid Waste Management Unit 8

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numerous uncertainties (such as conservative assumptions associated with absorption
of metals). This uncertainty  causes  an overestimation  of  risks.  For  example, only
dissolved metals are variably absorbed through the skin. The RI assumed that the total
concentration of metals  (including both dissolved  and suspended is available  for
absorption). Therefore, the dermal pathway typically should not be used as the sole
pathway in making remedial decisions (refer to the FS for a more detailed discussion of
the uncertainties associated  with the  risk  assessment).  Additional evaluation of
potential risks are considered in the following paragraphs.

As discussed in Appendix C, actual exposures to workers in the ditches at SWMU 100
(approximately 2 days/yr for 8 hours/day, for 25  years) are significantly less than the
default exposures used  in the  baseline risk assessment  (i.e., 250  days/yr for 8
hours/day for 25 years). This exposure is consistent with very limited activities such as
those associated with periodic  maintenance of drainage ditches  (i.e., weed eating).
Under this assumption, cancer risk to industrial  workers potentially exposed to
contaminated sediments  and surface water at rates consistent with actual  exposure
rates  at  SWMU 100 approach  de minimus (i.e.,  IxlO"6) at 2x10* (which  means 2
additional  cancers out of a population  of  1,000,000  could occur following  prolonged
exposure). Further, the maximum concentrations of the primary contaminant (beryllium)
in the two ditches surrounding SWMU 100 (called SWMU lOOa and SWMU lOOb in the
RI report), contributing most to the above risk estimate, are below or only slightly exceed
the natural background level for beryllium (0.83 mg/kg in SWMU lOOa and 0.64 mg/kg
in SWMU lOOb, compared to a background level of .67 mg/kg). These concentrations do
not indicate gross contamination related  to activities associated with the PGDP. Finally,
since these areas are ditches, activities at SWMU 100 are expected to remain consistent
with  the actual exposure rate in the future. Consequently, no further action,  outside of
maintaining institutional  controls, is required to protect  workers at  SWMU  100.
Currently contaminated surface water will be addressed on a site-wide basis  during the
surface-water CSOU investigation.

While contaminant conditions at SWMUs 8 and 100 are similar, there also is  a risk that
a human or animal could come into  direct contact with acidic leachate being released
from SWMU 8 into sediments above the water level in the creeks. These risks, when
combined  with the NOV issued by the  Kentucky Department  for  Environmental
Protection, Division of Water (KDOW), indicate that  limited action  is necessary at
SWMU 8 to protect human health and animals.

2.6.1  Human Health Risk Assessment

As previously discussed, SWMU 100 does not require action, other than maintaining
land use and  activity patterns. Therefore, this section summarizes risk information
relative  to SWMU  8 that does  require  some form  of remedial action  to address
contamination.

Data from the site investigation are evaluated in the human health risk assessment. To
identify chemicals of potential concern  (COPCs),  all constituents detected in the
surrounding sediments,  soils, surface water,  and ground water  are evaluated  using
established guidelines. From this data,  COPCs have been identified including metals,
organic compounds, and radionuclides.
                                      28

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The potential  for human contact with  contaminants is evaluated in the exposure
assessment. Since PGDP security limits access by the general public to SWMU 8 with
signs and a security patrol and the area is anticipated  to remain industrialized in the
future, exposure is most appropriately characterized under an industrial scenario.  For
this scenario,  the primary exposure  pathway is dermal  absorption  as a result of
industrial workers coming into direct contact with contaminated sediments in the creeks
for extended periods of time (8 hours/day, 250 days/year, for 25 years). Since SWMU
8 is located outside the main industrial  plant, a revised  exposure rate (i.e., an actual
exposure rate as for SWMU 100) is not considered. Potential future releases from the
unit to ground water are evaluated using predictive models to estimate leaching.

The toxicity  assessment  evaluates adverse  effects to  human  health  resulting from
exposure to chemicals of concern (COCs). Chemicals of concern in sediment at SWMU 8
are antimony, arsenic, beryllium, iron, manganese, and vanadium. Arsenic and beryllium
exhibit characteristics of carcinogens  and noncarcinogens and may cause cancer  and
various other adverse effects through  prolonged exposure. Antimony, iron, manganese,
and vanadium are noncarcinogens, but may cause various adverse health effects through
prolonged exposure.

The risk characterization indicates  that under current conditions, only  SWMU  8
warrants  an  action.  Table 2-1  provides  a summary  of  carcinogenic  risks  and
noncarcinogenic His at SWMU 8 and  the exposure pathways of concern. The risks and
His for sediment for both the current and future worker  exceed EPA threshold values
(please refer to the FS in  the WAGs  1 and 7  AR  for more detail regarding  risk
thresholds). The COCs identified for sediment are those that contribute most of the risks
and His for a pathway of concern.

          Table 2-1. Summary of Risks at Solid Waste Management Unit 8
Exposure Pathways
Sediment
Dermal Absorption
Sum of Pathways
Surface-Water
DennaJ Absorption
Sediment
Dermal Absorption
Sum of Pathways
Current Industrial Worker
Future Industrial Worker
Excess Lifetime Cancer Risk
3x10"
3x10*
3x10"
3x10"
Chronic Hazard Index
1
5
7
1
5
7
                                      29

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2.6.2  Ecological Risk Assessment

The screening ecological risk assessment for SWMU 8 indicates that current ecological
impacts in Bayou Creek are minimal. No analytes exceed benchmark values (please refer
to the RI included in the WAGs 1 and 7 AR for more information regarding ecological
benchmarks)  used to assess potential impacts to aquatic species in surface water;
however,  sediments in Bayou  Creek contain elevated  concentrations  of arsenic,
chromium, and manganese.

While concentrations of  these analytes  exceed benchmark levels, adverse impacts
appear to be very low, which may indicate a level of sediment contamination that can be
tolerated  by most  benthic  organisms. The leachate  in  Bayou  Creek also exceeds
terrestrial benchmarks for  the ingestion of surface water, but this calculation assumed
100% ingestion from the seeps. Risks associated with Bayou Creek should decrease as
remedial actions are taken to prevent direct contact with the leachate and contaminated
sediments. Analyte concentrations in  sediments also  should  decrease as  less-
contaminated sediments  are  deposited. Also, since  contaminant concentrations in
landfill soils exceed terrestrial benchmarks, the current landfill cap should be maintained
in order to protect terrestrial wildlife from exposure.

Uncertainties are  associated with the screening ecological risk assessment for SWMU 8.
While evaluation  may suggest adverse impacts to ecological receptors, no measurable
effects are seen in the field. Screening assessments are considered final assessments only
when they indicate  that there are no potential hazards to ecological receptors. However,
any cumulative effects of small losses or contamination of terrestrial habitat will be more
fully assessed on a facility-wide basis in the PGDP baseline ecological risk assessment
for the surface-water CSOU.

2.6.3  Remedial Action Objectives

Results of the risk analysis indicate that SWMU 8  poses an  unacceptable risk to
industrial workers and animals via  direct contact with acidic leachate emanating from
the unit. The remedial action objectives for this unit are to control the release of COCs
from the unit,  limit direct contact by humans, and reduce overall risks  to ecological
receptors. The  action implemented at  SWMU 8 will satisfy these objectives by limiting
human and animal exposure to contaminated sediments and acidic leachate associated
with the unit. The reduction of human risks will be accomplished by posting warning
signs and by placing a deed notice and restrictions on the SWMU  8 property.  The
reduction of ecological risks will be accomplished by installing riprap over exposed
acidic leachate seeps.

2.7    DESCRIPTION OF ALTERNATIVES

The following paragraphs present a description of the alternatives evaluated for each of
the SWMUs of concern in WAGs 1 and 7.

2.7.1  Description of Alternatives for Solid Waste  Management Unit 8 (C-746-K
       Sanitary Landfill)

The following subsections provide descriptions of individual alternatives evaluated for
SWMU 8.
                                      30

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2.7.1.1 Alternative 1 — No Action

Pursuant to 40 C.F.R. § 300.430(e)  of the NCP, the DOE is required to consider a no
action alternative. This alternative serves as a baseline to which the other alternatives
are compared. Under this alternative, current institutional actions (i.e., existing ground-
and  surface-water monitoring, landfill  cap  maintenance,  etc.)  would be continued;
however, no further remedial actions would be conducted at this SWMU.

This  alternative would  not include implementation of any treatment technologies,
contaminant  containment, institutional  controls,  or storage of wastes  or residual
materials. Costs associated with this alternative include the preparation  of five-year
review reports, mandated by Comprehensive Environmental Response, Compensation,
and  Liability Act  (CERCLA)  § 121(c)  [42 U.S.C.A. 9621(c)], at those sites where
contamination remains at levels that allow for unlimited use and unrestricted exposure.

2.7.1.2 Alternative 2 — Upgradient Subsurface Barrier

This alternative consists of the installing a subsurface barrier upgradient of the landfill in
order to divert uncontaminated ground water from landfill wastes. In addition, a deed
notice and restrictions would  be placed upon the landfill property to restrict future
land use.

Since hydrogeologjc data from the Hydrogeologic Assessment of the C-746-K Landfill and
Vicinity suggests that the current ground-water table saturates up to 1.2 m (4 ft) of the
landfill wastes,  implementation of subsurface barrier  technology would  result  in  a
reduction of the volume of landfill leachate generated. In addition, diversion of ground
water around the landfill may decrease contaminant transport through the ground-water
migration pathway. The subsurface barrier design calls for approximately 427 m (1,400
linear ft) of 60  mil  (0.15 cm or 0.06 inch)  high-density polyethylene (HDPE)  sheeting
installed to a maximum depth of 9.1 m (30 ft). The wall would be  anchored  into the
Porters Creek Clay unit, which has a permeability on the order of 10"* cm/sec (2.55  x
10's  ft/day). Low-permeability slurries,  such as a bentonite slurry, would be placed at
the lower 0.6-m (2-ft) interval at the bottom of the excavation to alleviate  the potential
for ground water to flow under the barrier wall.

Most of the residual soil generated  from trenching would be used as  trench  backfill.
Remaining trench soil generated from the trenching would require treatment, storage, or
disposal, as the potential exists that these residual materials may be contaminated with
landfill wastes. Current estimates indicate 222 m3 (290 yd3) of soil generated from trench
excavation would require management as a  nonhazardous waste.

In addition to constructing a subsurface barrier, a deed notice and restrictions would be
placed in the chain of title to restrict the  use of the property. Institution of a deed notice
and  restrictions would  supplement containment actions  in  achieving a  reduction of
contaminant exposure pathways for potential receptors by restricting land application
 (e.g., farming and residential  use) and  prohibiting destruction  of existing and  future
contaminant containment controls (e.g., existing landfill cap and upgradient barrier).
Current DOE administrative controls, including requirements for work permits, would be
continued. Current  surface-water  monitoring and landfill cap maintenance activities
 would be continued. The existing ground-water monitoring program may be modified, if
 required, to include the installation of additional monitoring wells  as  part  of this
 remedial action. The DOE would conduct reviews of the action no less than once every
 five years, since contaminants would remain in the unit. Estimated costs and a summary
 of the detailed evaluation of this alternative are presented in Section 2.8 of this ROD.


                                      31

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2.7.1.3 Alternative 3 — Downgradient Leachate Collection System x^"

This alternative consists of the installation of a downgradient leachate collection system,
composed of a French drain system located downgradient of the landfill, and a filter for
treatment of the collected leachate. Construction of a leachate collection system would
reduce the migration of leachate escaping from the landfill by accumulation, treatment,
and subsequent discharge to surface water. The leachate collection system would consist
of approximately 427 m (1,400 linear ft) of trench excavated to a depth of 7.3 m (24 ft)
bis. Perforated HDPE pipe would be embedded in a column of gravel (nonreactive river
stone or pea gravel), wrapped by a  layer of filter fabric,  and then backfilled with a
1.2-m (4-ft)  thick layer of clay at the top of the trench to minimize infiltration. Two
1.2-m (4-ft) polyethylene manhole sumps would be installed to collect the leachate. The
perforated laterals would be welded to the manholes to transport leachate to the sumps.
Leachate would be  removed  from the sumps using submersible  pumps which are
activated by leachate elevation.

The leachate would then be pumped through a dual-stage  filter to  remove particulate
matter. The filter stages would consist of a limestone stage to buffer the leachate and
precipitate the metals, and a packed-sand stage to remove the particulate  matter prior
to discharge. Treated leachate would be discharged to Bayou Creek. Discharge would be
monitored to meet the substantive requirements of a KPDES-permitted outfall.

Current estimates indicate  633 m3 (827  yd3) of soil generated from trench excavation
likely may be contaminated with landfill wastes; therefore, this material would require
management as a nonhazardous waste. Any remaining uncontaminated trench residuals
would be spread on SWMU 8 and seeded.

In  addition to the construction of a leachate collection  system, a deed notice and
restrictions  would be  placed in the chain of title to restrict the use of the property.
Institution of a deed notice and restrictions would supplement containment actions in
achieving reduction of contaminant  exposure pathways  for potential  receptors by
restricting land application (e.g., farming and residential) and prohibiting destruction of
existing and future  contaminant containment controls  (e.g.,  existing landfill cap and
leachate collection system). Current DOE administrative controls, including requirements
for work permits, would be continued. Current surface-water monitoring and landfill
cap maintenance activities would be  continued. The existing ground-water monitoring
program may be modified, if required, to include  installation of additional monitoring
wells as part of this remedial action. The DOE would conduct reviews of the action no
less than once every five years, since contaminants would remain in the unit. Estimated
costs  and a summary of the detailed evaluation of this  alternative are  presented in
Section 2.8  of this ROD.

 2.7.1.4 Alternative 4 — Full Perimeter Subsurface Barrier

 This alternative consists of the installation of a full perimeter subsurface barrier and two
 RGA monitoring wells downgradient  of the landfill. Since  hydrogeologic data from the
 Hydrogeologic Assessment of the C-746-K Landfill and Vicinity suggests that the current
 ground-water table saturates up to 1.2  m (4 ft)  of the landfill wastes,  implementing
 subsurface barrier technology would result in a reduction  of  the volume of  landfill
 leachate generated. In addition, the diversion of ground water around the landfill may
 decrease contaminant transport through the ground-water migration pathway. The
 subsurface barrier wall would be installed to a depth of 6.1  m (20 ft) on the western
 portion of the landfill, and 9.1 m (30  ft)  on the eastern portion of the landfill to tie the


                                       32

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bottom of the wall into the confining clay layer underlying the landfill. Approximately
823 m (2,700 linear ft) of subsurface barrier would be necessary to fully encompass the
wastes.  The wall would be anchored into the Porters Creek Clay  unit, which has  a
permeability on the order of 1 x 10"' cm/s (2.5 x 10s ft/day). Low-permeability slurries,
such as  a bentonite slurry, would be placed at the lower  0.6-m (2-ft)  interval at the
bottom of the excavation to alleviate the potential for ground water to flow under the
barrier wall.

Most of  the residual soil generated from trenching would  be used as trench  backfill.
Remaining trench soil generated  from the trenching would  require disposal,  as the
potential  exists  that these residual  materials  could  be contaminated with landfill
wastes.  Current estimates indicate that 621 m3 (812 yd3) of soil generated from trench
excavation would require management as a nonhazardous waste.

The current ground-water monitoring program would be expanded  to include the two
new RGA ground-water monitoring wells; sampling and analytical event frequency and
parameters for these two new wells are anticipated to be the same as for the ground-
water monitoring wells currently used for environmental assessment at the site.

In addition to the construction of a  subsurface barrier, a deed notice and restrictions
would be placed in the chain of title to restrict the use of the property. Instituting a deed
notice and restrictions would supplement containment actions in achieving a reduction
of  contaminant  exposure  pathways  for  potential   receptors by restricting  land
application (e.g., fanning and residential) and prohibiting destruction of existing and
future contaminant containment controls (e.g., existing landfill cap and full-perimeter
barrier). Current DOE administrative controls, including requirements for work permits,
would be continued. Current  surface-water  monitoring and landfill  cap maintenance
activities would be continued. The existing  ground-water monitoring program may be
modified, if required, to include the installation of additional monitoring wells as part of
this remedial action. The DOE would conduct reviews  of the action no less than once
every five years, since contaminants would remain in the unit. Estimated costs and  a
summary of the detailed evaluation  of this alternative  are presented in Section 2.8  of
this ROD.

2.7.1.5 Alternative 5 — Constructed Wetland Treatment System

This alternative  consists  of installing  a  constructed  wetland  treatment system
downgradient of the landfill within the channels of the adjacent creeks to intercept and
 treat landfill leachate. The wetland treatment system would consist of a sheet-pile wall
 constructed beyond the northern and western embankments of the adjacent creeks  which
 would contain the wetland treatment system. This downgradient location would allow
 the treatment system passively to intercept  and treat the landfill leachate. The base of
 the treatment  system would be contoured,  and  soil amendments  (e.g., mushroom
 compost, organic material, and limestone) to buffer pH would be installed as a wetland
 substrate. Wetland substrate would be built-up within the containment wall so that
 seepage from the bank of the landfill to the wetland system would remain subsurface,
 and initial treatment would occur during flow through the reactive substrate.

 The wetland treatment system would be seeded with  native  wetland  vegetation;
 volunteer vegetation also would be allowed to  emerge  within the  treatment system.  In
 order to maintain hydrologic  connection between the creeks and the wetland, "weep"
 holes would be cut intermittently in the sheet piling above  the elevation of the wetland.
 A weir would be placed at the downgradient end of the wetland to allow discharge from
 any impounded water within the wetland  system. Discharge would be monitored  to


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evaluate compliance with the substantive requirements of a KPDES outfall. In addition
to constructing a wetland treatment system within the creek, the opposing channel bank
will be cut and filled, as necessary, to straighten the channel and minimize erosion. No
residual materials would be generated from such bank work, as any excavated material
would be used as fill material within the channel.

In addition to the installation of a constructed wetland treatment system, a deed notice
and restrictions would be placed in the chain of title to restrict the use of the property.
Institution of a deed notice and restrictions would supplement treatment actions in
achieving a reduction of contaminant  exposure pathways  for  potential  receptors  by
restricting land application (e.g., farming and residential) and prohibiting destruction of
existing and future contaminant containment controls (e.g., existing landfill cap and
constructed wetland). Additionally, warning signs will be posted notifying the public of
the potential risks at the site.

This alternative would be implemented as a full-scale treatabiliry study for the first two
years of operation. As such, the treatment system would  be  monitored for  specific
parameters at a set frequency to determine its effectiveness. Current ground-water
monitoring may be modified, if required,  to  include  the  installation of additional
monitoring wells as part of this remedial action. The current surface-water sampling and
analysis program would be modified from quarterly monitoring at five  locations to
monthly monitoring at one location at  the effluent point of the treatment  system, and
one  in-stream location  downgradient of the treatment system within Bayou Creek.
Current DOE administrative controls, including requirements for work permits, would be
continued. The DOE would conduct reviews of the action no less than once every five
years, since contaminants would remain in the unit Estimated costs and a summary of
the detailed evaluation of this alternative are presented in Section 2.8 of this ROD.

2.7.1.6 Alternative 6 — Limited Action

This alternative consists of placing riprap  along the northern bank  of  the unnamed
tributary at any visible leachate seep locations to minimize the potential  for exposure,
and along the western bank of Bayou Creek to reduce erosion during high flow events.
Signs warning workers and trespassers of the potential risks to human health would be
installed along the creek and  at  the entrance to the landfill site. Institutional controls,
including  ground-water  and surface-water monitoring, would continue. Additional
ground-water monitoring wells would be installed, as needed.

In addition to installing signs and placing riprap within the creek channel, a deed notice
and restrictions would be placed in the chain of title to restrict the use of the property.
Instituting a  deed notice and restrictions would supplement institutional controls in
achieving a reduction  of contaminant exposure pathways  for potential  receptors by
restricting land use (e.g., farming and residential) and prohibiting destruction of existing
and future contaminant containment controls (i.e., the existing landfill cap). Estimated
costs and a  summary of the detailed evaluation of  this alternative  are  presented in
 Section 2.8 of this ROD.

 2.7.2 Description of Alternatives for Solid Waste  Management  Units 100,  130
       through 134, and 136

 Risks under the industrial land use scenario for human receptors at  SWMU  100 are
 associated with many uncertainties, and remediating environmental media at  this  unit
 would not be practicable for this reason.  Currently, institutional controls enacted at the
 PGDP include security fencing  and patrols to  prevent unknowing and  unauthorized


                                      34

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entry to  the plant and  risk management procedures to prevent worker exposure to
contaminated media. A  risk management evaluation indicated that these institutional
controls reduced exposure potential to acceptable levels for plant workers (see the risk
evaluation provided as  Appendix C). Therefore,  the  remedy  for this  unit  is  the
continuation of plant institutional controls.

The risk analysis indicated that no unacceptable risks exist for all use scenarios for
human receptors at SWMUs 130 through 134 and for the soils of SWMU 136.  Potential
risks for the ecological receptors are limited since all these SWMUs are located within a
fenced industrial  area,  and  habitat  for terrestrial wildlife  and  plants  is  limited.
Therefore, no further action will be required for SWMUs 130 through 134 and 136.

Since contamination will remain in place at SWMU 100 and  in order to evaluate the
reliability of controls in  providing protection, five-year reviews will be  required at  this
unit as mandated by CERCLA § 121(c) [42  U.S.C.A. § 9621 (c)]. No five-year reviews
will be conducted for the remaining SWMUs as  the risk assessment concludes  no
residual risks exist at these sites.

2.8    SUMMARY OF  THE COMPARATIVE ANALYSIS OF ALTERNATIVES

This section provides the basis for  determining which alternative: (1) meets the threshold
criteria of overall protection of human health and the environment, and compliance with
applicable or  relevant and appropriate requirements (ARARs); (2)  provides the best
balance between effectiveness and reduction of  toxicity, mobility, or  volume through
treatment, implementability, and  cost; (3)  satisfies state and community  acceptance;
and (4) is consistent with the Kentucky Hazardous Waste Management Permit.

Nine criteria are required by the CERCLA for evaluating the expected performance  of
remedial actions.  The remedial alternatives have been evaluated based on  the  nine
criteria, which are identified in the following list.

       (1)    Overall protection of human  health  and  the environment. This  threshold
              criterion requires that the remedial alternative adequately protect human
              health and the environment,  in both the short and long  term. Protection
              must  be  demonstrated by  the elimination,  reduction, or  control  of
              unacceptable risks.

       (2)    Compliance with ARARs.  This  threshold criterion  requires that  the
              alternatives be assessed to  determine  if they  attain compliance with
              ARARs of both federal and state law.

        (3)    Long-term effectiveness and permanence. This primary balancing criterion
              focuses on the magnitude of residual risk and the adequacy and reliability
              of  controls used  to  manage  remaining  waste  (untreated  waste  and
               treatment residuals) over the long term (i.e., after remedial objectives are
               met). Remedial actions  that  afford the highest  degree of long-term
              effectiveness and permanence are those that leave little or no waste at the
               site,  make  long-term  maintenance and  monitoring unnecessary, and
               minimize the need for institutional controls.

        (4)     Reduction of contaminant toxicity,  mobility, or volume through treatment.
               This primary balancing criterion is used to evaluate the degree to which
               the alternative employs recycling or treatment to  reduce  the  toxicity,
               mobility, or volume of the contamination.


                                       35

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      (5)    Short-term  effectiveness. This primary  balancing  criterion is used  to
             evaluate the effect of implementing the alternative relative to the potential
             risks  to  the general  public, potential  threat  to  workers, potential
             environmental impacts, and the time required until protection is achieved.

      (6)    Implementability. This primary balancing criterion is used  to evaluate
             potential difficulties associated with implementing the  alternative. This
             may include technical feasibility,  adminis era rive feasibility, and  the
             availability of services and materials.

      (7)    Cost. This primary balancing criterion is used to evaluate the estimated
             costs  of the alternatives. Expenditures include the capital cost, annual
             O&M, and the combined net present value of capital and O&M costs.

      (8)    State  acceptance. This modifying  criterion requires  consideration  and
             incorporation of any comments on the  ROD from the Commonwealth of
             Kentucky.

      (9)    Community acceptance. This modifying criterion provides  for consideration
             of any formal comments from the community on the PRAP.

2.8.1  Overall Protection of Human Health and the Environment

An alternative must meet this threshold criterion to be eligible for selection. As discussed
in Section 2.6, this final action is necessary to address potential risks posed by SWMU
8. Alternative 1 does not meet this criterion since it does not address  the risks at these
units. Alternative 2 would meet this criterion because it reduces the release of COCs  and
chemicals of potential ecological  concern (COPECs)  to  surface water via leachate
seepage. Alternatives 3 and 4 would meet this criterion by preventing the  migration of
COCs and COPECs into Bayou Creek and the unnamed tributary. Alternative 5 would
meet  this criterion by limiting direct contact with the waste and by  eliminating the
release of COCs and COPECs  into Bayou Creek and  the unnamed  tributary. Finally,
Alternative  6 would meet  this criterion by Limiting direct contact  with contaminated
sediments and acidic leachate associated with the unit.

2.8.2  Compliance with Applicable or Relevant and Appropriate Requirements

An alternative must meet the CERCLA threshold criterion of complying with ARARs, or
be waived, to be eligible for selection as a remedial action. The remainder of this section
describes how well each of the alternatives addressed in this ROD meets this criterion.
No ARAR  will  be  waived  for any  alternative addressed in this ROD. However,
consistent with the deferral of the potential remedial actions  for the surface water and
ground water at  WAGs 1  and 7  to the CSOUs for surface  water and ground water,
respectively, the ARARs for the remediation of these water bodies will be addressed in
the CSOUs. A detailed description of  ARARs for the  selected remedy is  presented in
Section 2.10 of this ROD.

2.8.2.1 Solid Waste Management Unit 8

For SWMU 8, Alternatives 2 (Upgradient Subsurface Barrier), 3 (Leachate Control), 5
 (Constructed Wetland), and 6 (Limited Action) would meet all chemical-, action-, and
 location-specific ARARs.  Alternative 4 (Full-Perimeter Subsurface Barrier) would not
 meet all action-specific ARARs, as the alternative would result in an increased flow of


                                      36

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contaminants to the RGA. This would run counter to the intent of 401 K.A.R. 5:037,
which is to prevent the pollution of ground water. Finally, Alternative 1 (no action) was
not evaluated for ARARs compliance  because the  action  does not meet the first
threshold criterion of protecting human health and the environment.

The FS for WAGs 1  and 7 stated that Alternative 2 would not meet chemical-specific
ARARs. The statement was made because Alternative 2 would not prevent all leachate
from reaching Bayou Creek and its unnamed tributary.  Since the 1992 NOV from the
KDEP (discussed further in Section 2.2.2.2 of this ROD)  indicated that it considered the
leachate to be violating Kentucky standards for protecting the environment, the DOE
concluded that the alternative would not meet chemical-specific ARARs. However, as is
further discussed in Section 2.10.1.1  of this ROD, the KDEP does not now consider the
leachate to be harming the creeks.

2.8.2.2 Solid Waste Management Units 100, 130 through 134, and 136

Pursuant to  the CERCLA guidance document, ARARs Q's &  As, EPA Office of Solid
Waste  and Emergency Response, 9234.2-01 FS, May 1989, an evaluation of compliance
with ARARs for a No Further Action decision is not required to be included  in a ROD.
This is because a no action decision may only be made when the site being evaluated has
been determined to be protective of human health and the environment. Since it has been
determined that SWMUs 130 through 134 and 136 are already protective  of human
health and the environment; no action will be undertaken at these SWMUs, and ARARs
compliance evaluations for the SWMUs are not included in this ROD.

Since the continuation of controls is necessary at SWMU 100 to protect human health
and the environment adequately under an industrial land-use setting, the SWMU must
undergo an  ARARs analysis.  As is further discussed  in Section 2.10.4,  the selected
remedy for SWMU 100 meets all ARARs.

2.8.3  Long-Term Effectiveness and Permanence

Alternatives 2,3, 4, 5, and 6 are designed to limit exposure to site-related contaminants
in the soil and from leachate generated by the landfill. Alternative 1 would produce the
greatest residual risk since no action would be taken.

Alternatives 2, 3, 4, 5, and 6 would provide adequate reliability and controls  if properly
designed and installed. Alternative 5 may require maintenance of the wetland treatment
system if significant hydrologic events at the unit were to erode the system. Since no
action is involved, Alternative 1 would produce the least reliability and control.

The deed notice and restrictions that would be implemented as part of Alternatives 2, 3,
4, 5, and 6 would limit how the DOE or any successive owner of the SWMU  8 property
could  use the land. Additionally, under  Alternative  6,  the  DOE would post  and
 maintain warning signs around the landfill to inform workers and any trespassers of the
 potential risks posed by the site.

 Long-term monitoring of surface and ground water is required for all the alternatives. As
 mandated by the CERCLA, five-year reviews are required for Alternatives 1, 2, 3,  4, 5,
 and 6 because untreated waste would remain onsite.
                                     37

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2.8.4   Reduction of Contaminant Toxicity, Mobility, or Volume

Alternative 5 achieves a reduction of toxicity, mobility, and volume of contamination by
treatment in a wetland. Alternative 3 would reduce the volume, mobility, and toxicity of
contaminants by capturing  and  treating  the  landfill leachate reaching the creeks.
Alternatives 2 and  4 would reduce the mobility and volume of the landfill  leachate;
however. Alternative 4 increases the mobility and volume of contaminants reaching the
RGA. Alternatives 2, 4, and  6 do  not include treatment. While Alternative 6  does not
provide a reduction of the toxicity, mobility,  or volume of the contaminants, it reduces
the exposure potential by limiting site use and exposure potential.

2.8.5   Short-Term Effectiveness

Negative impacts to community protection are not anticipated for Alternatives 2, 3, 4, 5,
or 6. Alternatives  2, 3,  4, 5, and 6 may pose minimal  risks to workers during
implementation. The probability of an accident would be rather low due primarily to the
short lengths of time involved in construction activities. In considering exposure routes,
consistent with the baseline risk assessment for a future excavation worker, short-term
risks are not expected to exceed acceptable limits for Alternatives 2, 3, 4, 5, or 6.

Alternatives 2, 3, and  4 would not pose  unacceptable environmental impacts during
implementation  since best management  practices would be  enacted  and  sensitive
resource areas would be avoided. Wetlands associated with the unnamed tributary and
Bayou Creek for Alternatives 5 and  6  could be disturbed during construction; this
disturbance would  be permissible under Nationwide Permit (NWP) 38  (Cleanup of
Hazardous and  Toxic Wastes).

Since no action is involved, Alternative 1 would not require any time to complete. For
Alternatives 3, 5, and 6, remedial action objectives would be achieved subsequent to
construction activities.  For Alternatives 2 and 4, a decrease in the volume of leachate
generated by the landfill  would occur subsequent to diverting ground-water flow; a
reduction in the volume of leachate generated would require draining of the  saturated
wastes.

2.8.6  Implementability

Alternatives 2, 3, 4, 5, and 6 would require readily available services and materials and
would be technically and administratively feasible to implement. No permits would be
required for Alternatives 2, 3, 4,5, and 6. Alternative 5 would require coordination with
 the COE due to construction activities within  wetlands associated  with  the unnamed
 tributary and Bayou Creek; less than one  acre of wetlands would be  impacted by
 implementation of this alternative. This  disturbance is permissible under  NWP 38.
 Additionally, for Alternatives 3, 5, and 6 the  substantive  requirements of the KPDES
 program would have to be met.

 2.8.7   Cost

 Estimated capital,  30-year O&M, and total  contingency costs  for each alternative are
 presented in Table 2-2.  The total cost  and  30-year present worth values for each
 alternative also are presented in the table.
                                      38

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                     Table 2-2. Preliminary Cost Estimates
($ in Thousands)
Remedial
Alternative
Capital Cost
O&M Cost
Contingency Cost
Total Cost
Present Worth*
1
$0
$48
$12
$60
$22
2
$1,909
$48
$489
$2,446
$2,405
3
$3,140
$2,827
$1,493
$7,460
$5,203
4
$2,521
$805
$831
$4,157
$3,527
5
$2,322
$637
$443
$3,402
$2,951
6
$340
$60
$6
$406
$350
 •Present worth assumes a 7% discount rate.
2.8.8   State Acceptance

The remedial action described herein will be conducted in compliance with the PGDP
Hazardous Waste  Management Permit, KY8-890-008-982,  issued by  the KDEP, and
with federal environmental requirements. The DOE has issued the WAGs 1 and 7 RI, FS,
PRAP, and this ROD  to  the KDEP  and the EPA for review. Pursuant to Section
121(e)(2) [42 U.S.C.A § 9621(e)(2)] and the draft FFA, the EPA must approve the ROD
prior to its implementation and the KDEP may provide its concurrence.

2.8.9  Community Acceptance

As further discussed in Section 2.3 and the Responsiveness Summary of Section 3 of this
ROD, the public has been provided the opportunity to comment on the selected remedial
action, and it has done so. No member of the public stated opposition to the selected
remedial action; however, public comments on the effectiveness, cost, and compliance
with the CERCLA  were received. All comments from the public were considered in the
selection of the remedial action. A summary of the public's comments and the DOE's
responses to them are contained in the Responsiveness Summary.

2.9    SELECTED REMEDY

Based upon the evaluation of the alternatives utilizing the nine CERCLA criteria, the
remedy for SWMU 8 that best meets the threshold, balancing, and modifying criteria for
the scope and objectives is Alternative 6, limited action. This  remedial action provides
for overall protection of human health and the environment, complies with ARARs,
poses no additional risks to the community during implementation and is cost effective.
Impacts to workers and sensitive resources are limited during implementation.

The selected remedy for SWMU 8 will consist of the following elements, at a minimum.

       (1)    Install warning signs. Signs will be posted at the entrance to the landfill
              site and  along the creeks, visible at any access point to the landfill, that
              clearly state the potential risks to human health  posed by the leachate
              seeps and  contaminated sediments in the creeks. The signs will be
              designed to be  resistant  to  the elements. Figure 2-12  depicts  the
              approximate locations of the signs at the landfill site.
                                     39

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      (2)    Place riprap. Riprap will be placed along the creek banks at the apparent
            seep locations along the unnamed tributary and Bayou Creek to minimize
            erosion. The riprap will be sized appropriately to reduce the potential to
            be displaced during high flow events.

      (3)    Institute a deed notice and restrictions. A deed notice and restrictions
            will be placed in the chain of title to the deed of the property to inform
            potential buyers and/or users of the potential risks to human health and
            the  environment  posed  by  the  leachate seeps  and  the  controls
            implemented at the site to minimize potential exposure. Additionally, the
            deed restrictions legally will bind  the buyer to restricted  uses of the
            property.

      (4)    Continue the existing surface-water monitoring program. As part of the
            interim corrective measures taken at SWMU 8, surface-water monitoring
            includes four sampling points along Bayou Creek and  the unnamed
            tributary adjacent to  the landfill (Figure 2-12).  Samples are collected at
            various periods ranging from once per week to once per quarter and are
            reported to the EPA and the KDEP on a semiannual basis. The surface-
            water parameters tested for include aluminum, arsenic, barium, cadmium,
            gross alpha and beta, hardness, hexavalent chromium, pH, and iron. (For
            more information on surface-water sampling at SWMU 8,  see the C-746-
            K Sanitary Landfill semiannual reports available to the public through the
            DOE Environmental Information Center, 175 Freedom Boulevard, Kevil,
            Kentucky 42053.)

            Also, as part of the interim corrective measures taken at SWMU 8, DOE
            will continue to monitor four sampling points along Bayou Creek and the
            unnamed tributary adjacent to the landfill. Further interim actions will be
            implemented if monitoring indicates that additional remedial  activity is
            necessary. These measures will continue until such  time as  the Division of
             Water implements a  discharge permit that allows for monitoring  of
             landfill discharges and protection  of the environment afforded by the
             permit conditions. At that  time,  criteria set  forth in the permit for
             monitoring will be adhered to, and current monitoring practices will be
             discontinued.

       (5)    Modify the ground-water monitoring program. Ground-water  monitoring
             at the C-746-K Sanitary Landfill currently includes quarterly sampling of
             five shallow ground-water wells located around the periphery  of the unit
             (MWs 300  through 303 and MW 184).  The results  of the ground-water
             sampling conducted at the unit are  reported  in the  C-746-K Sanitary
             Landfill  Semiannual Reports, which are issued in accordance with the
             Interim Corrective Measures Workplan for the C-746-K Sanitary Landfill.

In support of the limited action remedy, the following modifications to the ground-water
monitoring program at the landfill will be implemented.

          Monitoring Well 303 no longer will be monitored and a replacement well, MW
          303A,  will  be installed.  Monitoring  Well 303 was not screened at the
          appropriate depth to  sample the lower portion of the  Terrace Gravel
          deposits. The new well will be located in the vicinity of MW 303 and will be
          screened to the base of the Terrace Gravel deposits. Initially,  samples will be
          collected  from the new monitoring well on a quarterly basis in order to


                                      40

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                                                                               MW 303A
                                                                                  MW303
                                                                                  (PnpoMd lot \
                                                                                  AlMiidonninl) ii'
                                                C-746-K
                                           Sanitary Landfill
                                                                                          MW164
                                                                                          (PropOMd (or
                                                                                         Atwndonmcni)
   Approximate Location
   ol Proposed Riprap
_, Topographic Contour
   5 ft interval
Approximate Location ol
Proposed Signs
Approximate Location ol
Replacement Well lor MW 303
Mentoring Well
                                      MW 300\ ^-»

                                                Riprap
                                                                                            Approximate
Approximate
Extent ol Fill
                                         C746K-GA1
                                         C746K-GA3
Extent of Fill
                               Figure 2-12. Approximate Location of Proposed Institutional Controls
                                                                                                                    BIJicuOi tM I •wn.

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       •   discern seasonal variations in contaminant  levels. In accordance with the
          Sampling and Analysis Plan (SAP) Addendum, KY/ER-2, the new well will
          be monitored  for the  parameters  established under  the  environmental
          surveillance (new monitoring well) program. The parameters analyzed  and
          frequency sampled will be reevaluated after one year and  any necessary
          modifications  will be  documented in the annual  update  to the  SAP
          Addendum.

       •   Monitoring Well 184 no longer will be monitored. This well was installed in
          1991 in support of the Phase n Site Investigation. There are two reasons for
          ceasing the monitoring of MW 184:  (1) the well is usually dry, and (2) the
          sampling is unnecessary due to the four high-quality  wells (MWs 300, 301,
          302, and 303A) that will be monitored at the landfill.

The ground-water monitoring results will be reported to the EPA and the KDEP in the
PGDP  semiannual reports prepared  by the DOE  management and   the operating
contractor. If ground-water monitoring detects contamination, an assessment will be
conducted to determine if an interim remedial action is necessary. The  final  remedial
action for the landfill's impact to the Ground Water Integrator Unit will be selected and
implemented as  part  of WAG  26, which  is  the Ground  Water  Integrator Unit
investigation. The RI/FS workplan for WAG 26 is due to the regulatory agencies May 15,
2007.

In addition to those actions outlined in the preceding  paragraphs, the current landfill
cap maintenance program will be continued. The DOE will prepare a detailed design for
this remedial action in accordance with the requirements specified in the Declaration of
this ROD. During design and  construction activities, some changes may be made to the
remedy, as described here, as a result of the design and  construction processes. Changes
such as these modifications can result from the engineering design process.

This action will provide overall protection of human health and the environment. It also
can be implemented in compliance with ARARs. Potential human and animal  exposure
to contaminated sediments and the acidic landfill leachate will be reduced as a result of
implementation of this remedial action. As shown in Table 2-2,  the total estimated cost
for Alternative 6, limited action, is $406,000.

2.9.1  Statutory Determination

The remedial  actions,  described  herein  are protective of human  health  and the
environment, are cost effective and comply with federal and state requirements that are
legally applicable or relevant and appropriate to the WAGs  1 and 7 SWMUs. The
selected  remedies for the WAGs 1 and 7 SWMUs do not satisfy the CERCLA § 121(b)
[42  U.S.C.A.  §  9621(b)]  statutory preference  for having, as a  principal  element,
treatment that results in a  permanent and significant reduction of toxiciry, mobility, or
volume,  because risk  analysis indicates that such  remedies  are  not  necessary. The
selected remedies do, however, satisfy the CERCLA § 121(b)  statutory preference for
 using  permanent  solutions  and alternative  treatment technologies   to  the extent
 practicable.

 Since  contamination will remain  at  SWMUs 8 and 100 above levels  that  allow for
 unlimited use  and  unrestricted exposure under the industrial  land-use setting of the
 affected properties, five-year reviews will be conducted pursuant to CERCLA § 121 (c)
 [42 U.S.C.A. § 9621(c)]  and 40 C.F.R. § 300.430(f)(4)(ii). Five-year CERCLA  reviews
 will not be conducted at SWMUs  130 through 134 and 136 because the selected


                                      42

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remedial actions allow for unlimited use and unrestricted exposure. Finally, because the
remedial action decision for SWMU 38  is being deferred, five-year reviews  for the
SVVMU are not herein addressed.

2.9.2  Protection of Human Health and the Environment

The selected action at SWMU 8 protects PGDP employees and the public by  posting
warning signs and plant security patrols of the landfill area. The limited action  remedy
also will reduce  risks to humans and animals through Limiting leachate  exposure  by
placing riprap over acidic leachate being released above the water level in the creeks and
by restricting future land use.

Continuation of controls at SWMU 100 protects the  public  by ensuring  that  current
exposure  assumptions  are  maintained in  the  future through  institutional controls,
including the PGDP perimeter security fence.

2.10   COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
       REQUIREMENTS

This section of the ROD discusses the concepts of ARARs and to be considered (TBC)
information, as created by the  CERCLA,  and  how  the selected remedial action  is
expected to fare against the ARARs and TBC information.

2.10.1 Introduction to Applicable or Relevant and  Appropriate Requirements and
       To Be Considered Information

Congress specified in CERCLA § 121 (42 U.S.C. A. § 9621) that remedial actions for the
cleanup of hazardous substances  must  comply with  the  requirements,  criteria,
standards, or limitations under federal or more stringent state environmental laws that
are legally applicable or relevant and appropriate  to  the hazardous substances  or
circumstances at a site. The EPA defines and  explains ARARs using two categories.
First, the EPA  categorizes ARARs as  being  either "applicable"  or "relevant and
appropriate" to a site. The terms and conditions pertinent to this category are  detailed
in the following paragraphs.

        •  "Applicable" requirements are  those  cleanup  standards, standards  of
          control,  and  other  substantive  requirements,  criteria,  or limitations
          promulgated under federal environmental, state  environmental,  or facility
          siting laws  that  specifically  address a  hazardous  substance,  pollutant,
          contaminant, remedial action, location, or other circumstance found at a
           CERCLA site (40 C.F.R. § 300.5).

        •   "Relevant and  appropriate" requirements are  those cleanup standards,
           standards  of control, and other  substantive  requirements, criteria,  or
           limitations promulgated under federal environmental, state environmental, or
           facility siting laws that address problems or situations sufficiently similar to
           those encountered at  the CERCLA site that their use is well  suited to  the
           particular site (40 C.F.R. § 300.5).

        •  Requirements under federal or state law may be either applicable or relevant
           and appropriate to CERCLA cleanup actions, but not both. If a requirement
           is not applicable, it must be both relevant and appropriate  in order for it to
           be an ARAR. In cases where both a federal and a  state ARAR  are available,
           or where two potential ARARs  address the same issue, the more  stringent


                                     43

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          regulation must be selected. However, in cases where the implementation of a
          federal environmental program has been delegated by the EPA to a state,  it
          would be the analogous state regulations which would be considered ARARs.

      •   Other information that does  not meet  the definition of an ARAR may be
          necessary to determine what is protective or may be useful in developing
          CERCLA remedies. In addition, ARARs do not exist for every chemical or
          circumstance that may be found at a CERCLA site.  Therefore, the EPA
          believes it may be necessary, when determining cleanup  requirements or
          designing a remedy, to consult reliable information that would not otherwise
          be considered a potential ARAR. Criteria or guidance developed by the EPA,
          other federal agencies, or states  may  assist  in determining, for example,
          health-based levels for a particular contaminant or the  appropriate method
          for conducting an action  for which there are no ARARs. The  CERCLA
          categorizes this other information as TBC. The TBC information may be used
          as guidance when developing CERCLA remedies. Materials considered TBC
          information  generally fall  within  three  categories:   (1)  health  effects
          information, (2)  technical information on  how to perform  or  evaluate
          investigations or response actions, and (3) policy. A possible fourth category
          for TBC information is proposed regulations, when they are noncontroversial
          and likely to be promulgated  as drafted.

The second EPA categorization for ARARs is based on whether the ARARs are specific
to the chemical(s) present at the site (i.e., chemical-specific), the remedial action being
evaluated (i.e., action-specific), or the location of the site (i.e., location-specific).  The
terms and conditions pertinent to this  second category are detailed  in the following
paragraphs.

       •   "Chemical-specific" ARARs  usually are  health-  or  risk-based  numerical
          values or methodologies  which, when applied  to site-specific  conditions,
          result in the establishment of numerical values. These values establish the
          acceptable amount or concentration of  a chemical that  may remain in, or be
          discharged to, the ambient environment [53 Fed. Reg. 51437 (December 21,
          1988)].

       •   "Action-specific"  ARARs  usually  are   technology-  or activity-based
          requirements or  limitations placed  on  the remedial action being evaluated.
          Selection of a  particular remedial action at a site will trigger action-specific
          ARARs which specify appropriate technologies and performance standards
          [53 Fed. Reg. 51437 (December 21, 1988)].

       •  "Location-specific"  ARARs generally  are  restrictions  placed on   the
          concentration of hazardous  substances or the conduct of activities solely
          because they occur in special locations. Some examples of special locations
          include floodplains,  wetlands, historic places, and sensitive ecosystems or
          habitats [53 Fed. Reg. 51437  (December 21, 1988)].

 Examples of chemical-, action-, and  location-specific ARARs:

       •  Chemical-specific ARARs — Maximum contaminant levels, KPDES effluent
           limits, etc.;

       •   Action-specific ARARs — Performance and design standards; and
                                     44

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      •   Location-specific ARARs —  Preservation  of  historic  sites,  regulations
          pertaining to activities within or near wetlands or floodplains, etc.

As  discussed in the preamble to the NCP, potentially responsible parries  (PRPs)
conducting remedial actions, or portions of remedial actions, entirely onsite, as defined
in 40 C.F.R. § 300.5, must comply with the substantive portions of ARARs but not the
procedural or administrative requirements [53 Fed. Reg. 51443 (December 21,  1988)].
Substantive requirements pertain directly to  the actions  or conditions at a site, while
administrative requirements (e.g., permit applications) are paperwork requirements that
could delay remedial action implementation.

The CERCLA § 121(d)(4) [42  U.S.C.A. § 9621(d)(4)]  provides several  ARAR waiver
options  that may be invoked, provided  that human health and  the environment are
protected. Finally, under CERCLA § 121(e) [42 U.S.C.A.  § 9621(e)],  PRPs (such as the
DOE) are not required to obtain federal, state, or local permits in order to conduct
on-site response actions.

In addition to ARARs and TBC information, the EPA has addressed  other standards
pertinent to CERCLA cleanups. In the NCP,  at  40  C.F.R. § 300.150,  the EPA has
addressed the relationship of  ARARs to  worker protection standards. The EPA states
that CERCLA response actions must comply  with the worker protection standards and
requirements of the Occupational Safety and Health Act of  1970 (29 U.S.C  §§651
through 678) and analogous state laws; however,  the standards and requirements are
not ARARs  [55 Fed. Reg. 8680 (March 8,1990)].

Likewise, the DOE, in Order 5480.4,  Environmental  Safety and Health  Standards,
establishes  general requirements for  environmental  protection, safety,  and  health
standards for the DOE and  DOE contractor operations. The Order addresses DOE
activities  during the design, construction, operation, modification  (if  any),  and
decommissioning phases of the remedial action.

Finally, in 10 C.F.R. §  835, the DOE sets forth occupational standards for radiation
protection at its facilities. Pursuant to this  regulation, exposure of general employees
from DOE  activities,  other than planned  special  exposure or emergency exposure
situations, are to be controlled so that the following annual radiation dose limits are not
exceeded: a total effective dose equivalent of 5 rem; the sum of the deep dose equivalent
for external exposures  and the committed dose to any organ  or tissue,  other than the
lens of  the eye, of 50 rem; an eye lense dose equivalent of 15  rem; and a shallow dose
equivalent of 50 rem to the skin or any extremity.

2.10.2  Relationship  Between  the  Scope  of the  Selected  Remedial  Action,
        Regulatory Authorities,  and  Applicable  or Relevant  and Appropriate
        Requirements

The remedial actions identified in this ROD are intended to  protect human health  by
 minimizing  exposure to acidic leachate  seeping from the landfill banks into adjacent
 surface-water bodies.  These  actions are not intended to address remediation of any
 existing or  future surface- or ground-water contamination  at this site.  The DOE will
 evaluate  the necessity for surface- and/or  ground-water remedial actions for  the
 SWMUs in WAGs 1 and 7 separately from  this action during site-wide, comprehensive
 evaluations of surface- and ground-water contamination at this site.

 As part of the comprehensive evaluations, the DOE,  the EPA, and  the KDEP will
 determine whether implementing surface- and ground-water remedial actions at SWMU


                                      45

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8 is necessary to protect human health and the environment. Through the comprehensive
evaluations for surface water (WAGs 18 and 25) and ground water (WAG 26), known
also as the CSOUs,  the remedial action alternatives for the surface water and ground
water at the PGDP,  including at WAGs 1 and 7, will be selected. Through the CSOU
process, all data on the surface and ground water at WAGs 1 and 7, and at the other
PGDP SWMUs will be evaluated. Finally, all risks to human health and the environment
from the surface and ground water at the  PGDP, and  all  legally ARARs also will be
evaluated.

While CERCLA § 121(d)(2)(A) [42 U.S.C.A. § 9621(d)(2)(A)j requires that the RCRA
(42 U.S.C.A. §§ 6901 to 6992k) and  other environmental laws be evaluated as ARARs,
this, in no way, limits or negates the Commonwealth of Kentucky's authority pursuant
to K.R.S.  Chapter 224,  subchapter 46 and the PGDP Kentucky Hazardous Waste
Management Permit, KY8-890-008-928.  This subchapter  provides the KDEP  with
statutory authority to regulate hazardous waste in Kentucky.

The chemical-,  action-, and location-specific ARARs  and TBC  information  for  the
selected remedial actions are described in the following paragraphs.

2.10.3 Chemical-Specific Applicable or Relevant and Appropriate Requirements

The following discussion describes the chemical-specific ARARs and TBC information
for the selected remedial action. All chemical-specific ARARs  will be met  through
implementation of the selected remedial action.

2.10.3.1 Leachate discharges

Since discharges of  leachate from the C-746-K Sanitary  Landfill into waters of the
Commonwealth have been documented, the substantive requirements applicable to point
source discharges under the Clean Water Act (CWA) (33 U.S.C.A. §§ 1251 to 1387) are
legally applicable to the site under the CERCLA. The EPA has authorized the KDEP to
operate its KPDES  program in lieu of  the CWA.  The  KPDES program  must  be
administered consistently with CWA requirements. Typically, at non-CERCLA sites, the
KDEP issues a KPDES permit to regulate point source discharges. Such KPDES permits
contain effluent discharge limits  to ensure compliance with the water quality criteria
found in 401 K.A.R. Chapter 5.

However, because the PGDP is a CERCLA site,  the  permit exemption of CERCLA
§ 121(e)(l) [42 U.S.C.A. § 9621(e)(l)] applies. This provision of the CERCLA exempts
portions  of  remedial  actions  conducted  onsite from having  to  comply  with
administrative requirements, such as the acquisition of a KPDES permit. The provision
is written into  the CERCLA not to  lessen  the burden of any substantive environmental
requirements, but to reduce paperwork requirements that Congress believed potentially
could delay the implementation of remedial measures. Thus, even though the acquisition
 of a KPDES permit is not being incorporated as part of the  remedial action, the remedial
 action still will comply with the substantive requirements of the KPDES program.

 The substantive requirements of the KPDES program are contained in various sections of
 401 K.A.R. §§ 5:031, 5:065, and 5:070. Additionally, 401 K.A.R 5:029 § 2 is the KDEP's
 nondegradarion policy for surface waters. The policy states that current uses of surface
 water must be  protected. The substantive  requirements of  the KPDES program and the
 KDEP's nondegradation policy are applicable requirements under the CERCLA. These
 requirements are discussed in the following text.
                                     46

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The KDEP regulation 401 K.A.R. 5:031 § 2 contains the minimum water quality criteria
for all surface waters in the Commonwealth. The KDEP regulation 401 K.A.R. 5:031  §
4(1) contains the water quality criteria for surface waters, including Bayou Creek, which
are suitable for warm-water aquatic species. Pursuant to 401 K.A.R. 5:065 § (2)(4),
point source discharges from the C-746-K Sanitary Landfill cannot result in violations of
the applicable water quality criteria within the stream. After consultation with the EPA
and the KDEP,  the DOE has determined that discharges from the landfill currently are
not violating substantive  KPDES standards  (see Appendix B).  Thus, the  DOE has
concluded that  the  selected  remedial action will meet all water quality ARARs for
surface waters.

The  requirement  that  CERCLA  actions   comply  with environmental  monitoring
requirements is  contained in the preamble to the NCP at 55 Fed.  Reg. 8757  (March 8,
1990). As part of the remedial action, and pursuant to 401  K.A.R. 5:065 §  l(12)(d) and
5:070 § 3, instream monitoring of Bayou Creek  will  be  conducted  to  document
compliance with  KPDES  requirements.  The monitoring  of  Bayou  Creek  is  further
discussed in Section 2.9 of this ROD. The monitoring will continue, as described, in
Section 2.9 unless and until the DOE  and the KDEP agree to a modification, or a court
of competent jurisdiction so orders.

2.10.3.2 Radiation protection of the public and the environment

The DOE Order 5400.5 applies to radiation exposure to the general public from all DOE
activities,  including routine  activities,  remedial  actions,  and naturally occurring
radionuclides released by DOE processes and operations  and is TBC information. The
DOE Order 5400.5  limits radiation exposure  to  members of the  public to  a total
effective dose equivalent of less than 100 mrem/yr, or 5 mrem/yr to any organ. The
Order also specifies derived concentration guidelines for inhaled  radionuclides and
mandates that  DOE personnel and contractors  strive to ensure that radiation doses to
members  of the public are as low as reasonably achievable (ALARA) below  the
appropriate limits.

2.10.3.3 Radionuclide emission standard

On-site activities involved with the construction and/or implementation of the remedial
action could produce airborne pollutants.  It is not expected that any  radionudide
emissions would result from these activities; however, if radionuclide emissions were to
occur, emission standards for DOE facilities would apply.  Federal regulation 40 C.F.R. §
61.92 promulgated pursuant to the Clean Air Act of 1970,  as amended by the Clean Air
Act of 1990, [42 U.S.C.A. §§ 7401  to 7671(q)]  sets a total emission standard for
radionuclides, other than radon, from DOE facilities. The regulation requires the DOE to
ensure  that emissions from its facilities do not exceed those amounts that would cause
 any member of the public to receive, in any given year, an effective dose equivalent of 10
 mrem/yr. The  regulation is an applicable requirement for the remediation of SWMU 8.

The chemical-specific ARARs and TBC  information for the selected  remedial action are
 contained in Table 2-3.

 2.10.4  Location-Specific Applicable or Relevant and Appropriate Requirements

 The following  discussion describes the location-specific ARARs  and TBC information
 for the selected remedial action. All  location-specific ARARs will be met  through
 implementation of the selected remedial action.
                                      47

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   Table 2-3. Chemical-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                                for Solid Waste Management Unit 8 of Waste Area Group 7
   Medium
                                     Requirements
                                                    Prerequisites
  Federal Citation
 Kentucky
 Citation
401 K.A.R.
Leachate
discharges
                       Current uses of surface water must be
                       protected.
                                         Discharges or releases into waters of
                                         the Commonwealth — Applicable.
                    5:02'J § 1
                Discharges must not exceed discharge limits
                set pursuant to the KPDES program.
                                                                Discharges or releases into waters of
                                                                the Commonwealth — Applicable.
                                                                                                 5:031 §§ 2
                                                                                                 and 4(1)
                                                                                                 5:065 § 2(4)
               Discharges must be monitored to document
               compliance with the KPDES program.
                                                                Discharges or releases into waters of
                                                                the Commonwealth — Applicable.
                                                                                                5:065 § l(12)(d)
                                                                                                5:070 § 3
                                                        Exposure of the general public from
                                                        any source of radiation exposure at a
                                                        DOE facility — TBC on a facility-
                                                        wide basis.

                                                        Release of radioactive material from
                                                        DOE activities — TBC.
oo
       Radionuclides
       — all exposure
       pathways
General public must not receive an effective
dose equivalent greater than 100 mrem/yr,
or 5 mrem/yr to any organ from all exposure
modes.

All releases of radioactive material must be
ALARA.
DOE Order 5400.5
                                                                                                   DOE Order 5400.5
               Emissions from DOE facilities shall not
               cause members of the public to receive, in
               any year, an effective dose equivalent
               greater than 10 mrem/yr.
                                                                Emissions of radionuclides other than
                                                                radon from DOE facilities
                                                                — Applicable on a facility-wide
                                                                basis.
                                                                            40C.F.R.  §61.92

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Wetlands and a 100-year floodplain have been identified in the vicinity of SWMU 8.
Construction activities must avoid or minimize adverse impacts on wetlands and act to
preserve and  enhance their natural and beneficial values [Executive Order 11990; 40
C.F.R. § 6.302(a); 40  C.F.R. § 6, Appendix  A; and 10 C.F.R. §  1022].  In addition,
construction  activities must  minimize potential  harm  to the  100-year  floodplain
(Executive Order 11988 and 10 C.F.R. Part 1022).

The DOE will avoid, to the extent possible, the long- and short-term adverse impacts
associated with the occupancy and modification of floodplains and wetlands [10 C.F.R.
1022.3(a)]. The DOE will  undertake a careful evaluation of  the potential effects  of any
DOE action conducted in a floodplain [10 C.F.R. 1022.3(c)]. Construction in wetlands
should be avoided unless there are no practicable alternatives [40 C.F.R. § 6.302(a)J.
Degradation or destruction of wetlands must be avoided  to  the  extent possible  [40
C.F.R. § 230.10 and 33 U.S.C. § 1344(b)(l)].. Considerations about the protection of
wetlands must be incorporated into planning, regulating, and decision making [10 C.F.R.
§ 1022.3(b)]. Any action involving the discharge of dredged or fill material into wetlands
must be avoided to the extent possible (13 U.S.C. § 1344, 40 C.F.R. § 230, and 33 C.F.R.
§§ 320 to 330).

Discharges of dredged or fill material for which there are practicable alternatives with
fewer adverse impacts   or  those  which  would  cause or contribute to significant
degradation are prohibited  [40 C.F.R. §  230.10(a)].  Discharges  are also prohibited
unless there are no practicable alternatives, and practicable, appropriate mitigation
methods are available (40 C.F.R. § 230.10(d)].  Further, 40 C.F.R. § 230.10(b) prohibits
discharges  that cause or contribute to violations of  state water quality standards,
violate  toxic  effluent standards  or  discharge prohibitions (33  U.S.C.  § 1317),  or
jeopardize threatened and endangered (T&E) species or their critical habitat under the
Endangered Species Act (16 U.S.C. § 1531, et seq.). If it becomes apparent that impacts
to wetlands are unavoidable, due to the construction plan or other modifications, the
specific requirements of 61 Fed. Reg. 65920  NWPs or 33 C.F.R. § 325 (Processing of
General Permits), and statutes governing discharges of dredged  or fill material  into
waters of the United States  would become applicable. The  NWP applicable to the
selected remedy is NWP 38.

Nationwide Permit 38 is applicable to this  project. Nationwide  permits  are  permits
authorized by the COE on a nationwide basis for activities deemed to  have little to no
adverse effects on waters of the United States. Specific requirements applicable to all
NWPs  must  be  followed.  These  requirements are defined  in  61 Fed.  Reg.  65920
(December, 13 1996). However, notification is not required for CERCLA  actions and,
consequently, not required for this action [61 Fed. Reg. 65905-65906 (December 13,
1996)].

As required by 401 K.A.R. 4:060, activities or structures exempted by 401  K.A.R. 4:020,
which include activities  authorized by the  COE  NWP,  may  be placed within  the
 regulatory floodway limit of a stream only if they are not of such  nature as to result in
 increases in flood elevations. Riprap and MW 303-A will be placed within the 100-year
 floodplain. The ARARs for floodplains will  be met  as long as construction equipment
 remains on the bank and  the original contours are reconstructed as much as practicable,
 thereby  eliminating any  possible flood elevation changes. If construction plans are
 modified,  those  ARARs listed  in Table  2-4  for wetlands  may become applicable.
 Consequently, if construction plans change, or different remedial actions are chosen in
 the future, the action  would require reevaluation for location-specific ARARs.
                                      49

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           Table 2-4. Location-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                                         for Solid Waste Management Unit 8 of Waste Area Group 7
                 Actions
           Requirements
         Prerequisites
 Federal Citation
 Kentucky
 Citation
401 K.A.R.
        Protection of wetlands
en
o
 Avoid or minimize adverse impacts
 on wetlands to preserve and enhance
 their natural and beneficial values.
                                  Avoid degradation or destruction of
                                  wetlands to the extent possible.
 Incorporate considerations about
 protection of wetlands into
 planning, regulating, and decision
 making.
Any federal action that will
have an impact on wetlands
— Applicable if avoidance is
not met

Any action involving discharge
of dredged or fill material into
wetlands — Applicable if
avoidance is not met.

Any federal action that will
have an impact on wetlands
— Applicable if avoidance is
not met
 10 C.F.R. § 1022;
 Executive Order
 11990
                                                                   40 C.F.R. § 230.10;
                                                                   13 U.S.C. §
                                                                   1022.3(b)
10 C.F.R. §
1022.3(b);
33 C.F.R. § 330
61 Fed. Reg. 65920
        Discharge of dredged or
        fill material into
        navigable water
Discharges for which there are
practicable alternatives with fewer
adverse impacts or those which
would cause or contribute to
significant degradation are
prohibited.

Significant degradation is
prohibited unless appropriate steps
are taken to minimize impacts on
the aquatic ecosystem.
Any action involving discharge
of dredged or fill material into
wetlands — Applicable if
avoidance is not met.
                                                                    Any action involving discharge
                                                                    of dredged or fill material into
                                                                    wetlands — Applicable if
                                                                    avoidance is not met.
40 C.F.R. §
230.10(a)
                               40 C.F.R. §
                               230.10(c)and(d)

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   Table 2-4. Location-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                           for Solid Waste Management Unit 8 of Waste Area Group 7 (Continued)
         Actions
           Requirements
         Prerequisites
 Federal Citation
 Kentucky
 Citation
401 K.A.R.
Discharge of dredged or
fill material into
navigable water
(continued)
Discharges which cause or
contribute to violations of state
water quality standards, violate
toxic effluent standards or discharge
prohibitions, or jeopardize species
under the Endangered Species Act.
Any action involving discharge
of dredged or fill material into
wetlands — Applicable if
avoidance is not met.
40 C.F.R. §
230.10(b)
Protection of floodplains
Avoid construction in any 100-year
floodplain.
Any federal action within a
100-year floodplain
— Applicable.
10 C.F.R. § 1022
Executive Order
11988
                          Avoid activities or structures
                          within the regulatory flood way
                          limits of a stream if they result in
                          an increase in flood elevations.
                                   Any action within the
                                   regulatory floodway limits
                                   — Applicable.
                                                  4:060 § 4(2)

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2.10.5  Action-Specific Applicable or Relevant and Appropriate Requirements

The following discussion describes the action-specific ARARs and TBC information for
the selected  remedial  action.  All  action-specific  ARARs  will  be met  through
implementation of the selected remedial action.

2.10.5.1 Solid waste management unit corrective action

The regulations  that apply  to the cleanup of SWMUs are ARARs for the selected
remedial action. Pursuant to the RCRA [42  U.S.C.A.  §§  6901 through 6992(k)  and
K.R.S.  Chapter 224, subchapter 46] the regulations that apply are 40 C.F.R.  § 264.101
and 401 K.A.R. 34:060 § 12. These laws and regulations do not contain specific cleanup
standards. Rather, the regulations require that the corrective action measures taken must
result in the protection of human health and the  environment. These regulations are
applicable requirements under the CERCLA.

2.10.5.2 Environmental performance standards

The environmental performance standards of 401 K.A.R. 47:030 set minimum  numeric
and narrative criteria for all solid waste sites and facilities located in Kentucky. The
standards establish minimum criteria for the protection of the environment Included are
standards for floodplains (§ 2), wetlands (§  13), endangered species (§ 3), air (§ 10),
surface water (§ 4), ground water (§§  5  and 6), and food chain crops  (§  7). The
standards also contain provisions to ensure  safety (§ 11),  prevent the site or facility
from becoming a public nuisance (§ 12), and restrict practices related to the disposal of
PCBs  (§ 8) and disease carrying vectors (§  9). Finally, Section 14 of the regulation
requires that no solid waste site or facility violates any provision of K.R.S. Chapter 224.
Except for the provisions related to the contamination of surface water and ground
water (§§ 4 through 6), the standards, which first took  effect in 1990, are relevant and
appropriate to the C-746-K  Sanitary Landfill, which dosed in 1982. The surface-water
and ground-water contamination provisions are  not relevant and  appropriate  because
any deanup of the surface water and ground water at or adjacent to SWMU 8 would be
beyond the scope of the selected remedial action.

2.10.5.3 Ground-water protection

As required by 401  K.A.R 5:037,  any  person  conducting certain  waste-handling
activities must implement practices  to prevent the pollution of  ground  water.  The
regulation is  an applicable requirement under the CERCLA; thus, the  substantive
 provisions of the regulation are ARARs even though ground-water remediation is beyond
 the scope of the remedial action.

 Section 3(7)  of the regulation states  that ground-water protection practices may be
 incorporated  by other federal, state,  and local regulatory programs that  contain  the
 following three  standards: (1)  management and  design  standards;  (2)   mandatory
 monitoring for ground-water pollution or methods of detecting discharges, spills, or
 releases  to ground water; and  (3) specific corrective  action  criteria.  Through  the
 CERCLA, the  RCRA, Kentucky's hazardous waste  management program,  and  the
 PGDP Groundwater Protection Program Plan (GPPP) (MMES, KY/ER-2 Rev. 1, January
 1992), the three standards will be met by the selected remedial action. First, the design
 parameters for the remedial action technology have been reviewed by the EPA and the
 KDEP. Second, the CERCLA, the RCRA, and the KDEP's hazardous waste programs
 require ground-water monitoring to evaluate the effectiveness of the remedial action and
 the GPPP defines how the KDOW will  implement such monitoring. Finally, the specific


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corrective action criteria for ground water will be addressed by the ground water CSOU
for the PGDP and incorporated into a ROD and/or the PGDP RCRA Permits.

2.10.5.4 Ground-water monitoring plan

Section 4 of 401 K.A.R. 48:300 requires a ground-water monitoring plan which contains:
(a) the number, location, and depth of proposed monitoring points; (b) preoperational
data  showing existing  ground-water  quality; and (c) a  ground-water SAP. The
provisions of Section 4, which first took effect in 1990, are relevant and appropriate for
the selected  remedial action at the C-746-K Sanitary Landfill, which closed in 1982.
Moreover, the  provisions of Section 4 have and  will continue to be complied with
through  the RFI Workplan,  interim  corrective measures at  the SWMU,  and the
semiannual reporting on the unit that  the DOE provides to the KDEP and  the EPA.
Documentation on these activities may be obtained through the Administrative Record
for the Cleanup of the PGDP, 175 Freedom Boulevard, Kevil, Kentucky 42053, (502)
462-2550.

2.10.5.5 Design requirements for ground-water monitoring systems

Section 5 of  401  K.A.R.  48:300  contains  design requirements for ground-water
monitoring systems. Section 5 requires a reference or background well and at least three
monitoring wells  at a point hydraulically downgradient  from where the waste was
disposed. Like Section 4, Section 5 of  the regulation also is relevant  and appropriate,
and documentation on the ground-water monitoring program at the C-746-K  Sanitary
Landfill can be obtained through the AR

2.10.5.6 Monitoring well construction

Ground-water monitoring well construction requirements of 401  K.A.R 48:300  § 6 are
relevant and appropriate requirements  under the CERCLA because a ground-water
monitoring well will be installed as part of the remedial action. The well, tentatively
planned as  MW 303A,  will  be used to determine whether  any contaminants from
SWMU 8 are entering the Terrace Gravel. Monitoring Well 303A  will become part of the
existing  ground-water monitoring program discussed  more fully in Section  2.9  of
this ROD.

The following is a discussion of each  legally applicable  requirement of 401  K.A.R.
48:300 § 6.

        •  Precautions must  be taken  during the  drilling and  construction  of  the
          monitoring well to  avoid introducing contaminants into the borehole. Only
          potable water will be used in drilling the well and drilling muds will not  be
           used [401 K.A.R. 48:300 § 6(1)].

        • All equipment to be placed into the boring will  be  decontaminated prior to
           use at the site [401 K.A.R. 48:300 § 6(2)].

        •  Monitoring wells must be cased  to maintain the integrity of the monitoring
           well  borehole; have a minimum diameter of four  inches, unless otherwise
           approved  by the  KDEP;  have screens and  appropriate gravel  or sand
           packing; protrude  at least one foot above the ground; be four inches smaller
           than the outside diameter of the drill hole; produce an annular space above
           the sampling depth that is sealed  to prevent contamination of samples and
                                      53

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           the ground water; and if the casing is plastic, be threaded and gasket sealed,
           unless otherwise approved by the KDEP [401 K.A.R. 48:300 § 6(3)].

       •   The monitoring well casing must be enclosed in a protective cover that: (1)
           includes a protective barrier; (2) is installed into firm rock; (3) is grouted and
           placed with a cement collar below the frost line; (4) is numbered and painted
           in a highly visible color; (5)  protrudes at least one inch higher above grade
           than the monitoring well casing; (6) has a locked cap; and (7) is made of steel
           or any other material of equivalent strength [401 K.A.R. 48:300 § 6(4)].

       •   The monitoring well must have a concrete pad extending two feet around the
           well and be sloped away from the well [401 K.A.R. 48:300 § 6(5)].

.2.10.5.7  On-site activities

 On-site excavation  activities may produce airborne  pollutants.  Parriculate emission
 levels from earth-moving and site-grading activities are not expected to exceed Kentucky
 Division of Air  Quality regulations for fugitive dust emissions,  found in 401  K.A.R.
 63:010. The following provisions of this regulation are applicable under the CERCLA.

 A requirement of 401 K.A.R. 63:010 § 3 is  that reasonable precautions  be taken  to
 prevent particulate matter from, becoming airborne. Such precautions include the use of
 water or chemicals, if possible, and/or placement of asphalt or concrete on roads and
 material stockpiles to control dust [401 K.A.R. 63:010 § 3(l)(b)]. Visible fugitive dust
 must not be discharged beyond the property line where the dust originated [401 K.A.R.
 63:010 §  3(2)].  Additionally, all open4>odied trucks that operate outside the property
 boundary and that may emit materials that could be airborne must be covered [401
 K.A.R. 63:010 § 4(1)].

 2.10.5.8   Deed notice

 As  part of the  remedial action for SWMU  8, the DOE will file a notice  and deed
 restrictions with McCracken County,  Kentucky, authorities to restrict the uses of the
 property and to let prospective purchasers and others know that the property was used
 for waste disposal activities.

 In so doing, the DOE will be complying with 401 K.A.R 48:170 § 3(5) which requires the
 filing only of the deed notice. The regulation, which first took effect in 1990,  is relevant
 and appropriate for the action being taken at the landfill, which closed in 1982.

 2.10.5.9   Hazardous waste determination

 Soils excavated during the construction of the selected remedy are expected to be laid
 across the base of the landfill and seeded or used as on-site backfill material so as not
 to invoke any land disposal or storage concerns [55 Fed. Reg. 8759 (March 8, 1990)].
 However, in the unlikely event that any excavated soil is to be transported beyond
 SWMU 8 boundaries,  a  determination of whether the soil is  hazardous will be made
 pursuant to 40  C.F.R. § 262.11 and 401 K.A.R. 32:010  § 2. If the soil to be transported
 is determined to be hazardous, RCRA Subtitle C and analogous state requirements for
 the management   of  hazardous waste  would  be  complied  with  as  applicable
 requirements under the CERCLA
                                       54

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2.10.5.10 Radioactive waste determination

Pursuant to DOE Order 5820.2A, in the unlikely event any soil is transported beyond
SVVMU 8 boundaries, the soil would be tested to determine if it is radioactive. The DOE
Order 5820.2A establishes internal policies, guidelines, and requirements under which
the DOE manages its  radioactive  and  mixed  (hazardous  and radioactive) waste.
Subsequent management of radioactive soil would be conducted in accordance with the
DOE order and the Land Disposal  Restriction (LDR)  Federal  Facility  Compliance
Agreement (FFCA) entered into between the DOE and the EPA Region IV June 30,  1992.
Subsequent management of mixed waste  would  be conducted in accordance with the
DOE Order, the LDR-FFCA, Subtitle C of RCRA, and K.R.S. Chapter 224,  subchapter
46. The Order ensures  that radioactive and mixed  wastes  are managed in a manner
which assures the health and  safety of  the public,  the  DOE and its contractor
employees, and  the environment.  The  Order  requires  that  external exposures  to
radioactive material released into surface water, ground water, soil, plants, and animals
do not result in an effective dose equivalent which exceeds 25 mrem/yr to any member
of the public. As an internal order, it is TBC information under the CERCLA.

2.10.5.11 Construction along streams

Construction materials used in or along either Bayou Creek or the unnamed tributary will
be stable and inert, free from pollutants and floatable objects, and meet all  appropriate
engineering standards, pursuant to 401 K.A.R. 4:060 § 7. The regulation is an applicable
requirement under the CERCLA. The action-specific  ARARs  and TBC  information for
the selected remedial action are contained in Table 2-5.

2.10.6    Applicable or Relevant  and  Appropriate  Requirements and  To Be
         Considered  Information for Solid Waste  Management  Units 100, 130
         through 134, and 136

Under the CERCLA guidance document, ARARs  Q's & A's, EPA Office of  Solid Waste
and Emergency Response, 9234.2-01FS, May 1989, an ARARs compliance evaluation is
not required for a no action decision because the site already is protective of human
health and the environment. Thus, an ARARs analysis for SWMUs 130 through 134 and
136 is not provided because the SWMUs already are protective of human health and the
environment.

Tables 2-6 and 2-7, respectively, contain the chemical- and action-specific  ARARs and
TBC information for SWMU  100,  which has  as  its  selected  remedial  action, the
continuation of controls. There  are no location-specific  ARARs for SWMU  100. The
continuation of controls at SWMU 100 would meet all chemical- and action-specific
ARARs.

2.11      COST EFFECTIVENESS

The preferred alternative will provide overall effectiveness in reducing the  potential for
exposure by limiting future land use at the site and limiting exposure to landfill leachate
by covering visible seeps with riprap. This preferred remedial action represents the least
expensive remedial alternative evaluated that achieves  all remedial action objectives.
Selection of this remedy provides the greatest cost efficiency for the DOE.
                                     55

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           Table 2-5. Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                                       at Solid Waste Management Unit 8 of Waste Area Group 7
            Actions
            Requirements
        Prerequisites
 Federal Citation
     Kentucky
     Citation
    401 K.A.R.
        SWMU corrective
        action
Protect human health and the
environment.
Release of hazardous waste or
constituents from a SWMU
— Applicable.
40 C.F.R. §
264.101
34:060 §12
        Environmental
        performance
        standards
Meet minimum requirements for the
protection of the environment.
Any solid waste site or facility
— Applicable.
                  47:030 §§ 2, 3, and 7
                  through 14
        Ground-water
        protection
Implement practices to ensure protection
of ground water.
en
Waste-handling  activities
which, have the potential  to
alter ground-water
characteristics
— Applicable. However,
substantive requirements are
incorporated into the
CERCLA, RCRA, and
Kentucky hazardous waste
management programs, and the
PGDPGPPP.
                  5:037 § 3(7)

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    Table 2-5. Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                           at Solid Waste Management Unit 8 of Waste Area Group 7 (Continued)
      Actions
             Requirements
         Prerequisites
Federal Citation
 Kentucky
 Citation
401 K.A.R.
 Ground-water
 monitoring plan
 A ground-water monitoring plan must
 include

   •  The number, location, and depth
      of proposed monitoring points;

   •  Preoperational data showing
      existing ground-water quality;
      and

   •  A ground-water sampling and
      analysis plan.
 Ownership or operation of a
 solid waste site or facility
 — Relevant and Appropriate.
 (Note: Compliance with this
 ARAR has already been
 achieved through prior
 submittals.)
                  48:300 § 4


                  48:300 §4(1)


                  48:300 § 4(2)


                  48:300 § 4(3)
Design
requirements for
ground-water
monitoring system
The ground-water quality monitoring
system must consist of

   •  At least one reference or
      background monitoring well; and

   •  At least three downgradient
      monitoring wells.
Ownership or operation of a
solid waste site or facility
— Relevant and Appropriate.
                 48:300 § 5


                 48:300 § 5(1)


                 48:300 § 5(2)
Ground-water
monitoring well
construction
Monitoring well must be constructed with

  •   Precautions to avoid introducing
      contaminants into the borehole;

  •   Potable water; and

  •   Decontaminated equipment.
Ownership or operation of a
solid waste site or facility
— Relevant  and Appropriate.
                 48:300 § 6


                 48:300 §6(1)


                 48:300 §6(1)

                 48:300 § 6(2)

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           Table 2-5. Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                                 at Solid Waste Management Unit 8 of Waste Area Group 7 (Continued)
            Actions
             Requirements
Prerequisites
Federal Citation
 Kentucky
 Citation
401 K.A.R.
oo
        Ground-water
        monitoring well
        construction
        (continued)
Monitoring well casing must

   •   Maintain the integrity of the
       monitoring well borehole;

   •   Have a minimum diameter of 4
       inches;

   •   Have screens and appropriate
       gravel or sand packing;

   •   Protrude at least one foot above
       the ground;

   •   Be 4 inches smaller than the
       outside diameter of the drill hole;

   •   Produce an annular space above
       the sampling depth to prevent
      contamination of samples and the
      ground water; and

   •   Be threaded and gasket sealed (if
      plastic).
                                       48:300 § 6(3)

                                       48:300 § 6(3)(a)


                                       48:300 § 6(3)(b)


                                       48:300 § 6(3)(c)


                                       48:300 § 6(3)(d)


                                       48:300 § 6(3)(e)


                                       48:300 § 6(3)(f)
                                                                                                               48:300 § 6(3)(B)

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           Table 2-5. Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                                  at Solid Waste Management Unit 8 of Waste Area Group 7 (Continued)
            Actions
              Requirements
Prerequisites
Federal Citation
 Kentucky
 Citation
401 K.A.R.
\o
        Ground-water
        monitoring well
        construction
        (continued)
 Monitoring well casing must be enclosed in
 a protective cover that

    •   Includes a protective barrier;

    •   Is installed into firm rock;

    •   Is grouted and placed with a
        cement collar below the frost line;

    •   Is numbered and painted in a
        highly visible color;

    •   Protrudes at least one inch higher
        above the monitoring well casing;

    •   Has a locked cap; and

    •   Is made of steel or a material of
       equivalent strength.

The monitoring well must have a concrete
pad extending two feet around the well
and be sloped away from the well.
                                        48:300 § 6(4)


                                        48:300 § 6(4)(a)

                                        48:300 § 6(4)(b)

                                        48:300 § 6(4)(c))


                                        48:300 § 6(4)(d)


                                        48:300 § 6(4)(e)


                                        48:300 § 6(4)(f)

                                        48:300 § 6(4)(g)


                                        48:300 § 6(5)

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    Table 2-5. Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                          at Solid Waste Management Unit 8 of Waste Area Group 7 (Continued)
     Actions
              Requirements
       Prerequisites
 Federal Citation
      Kentucky
      Citation
     401 K.A.R.
 On-site activities
 Precaution must be taken to prevent
 particulate matter from becoming
 airborne.

 Such precautions may include:

   •  Using water or a chemical to control
      dust;

   •  Placing asphalt or concrete on roads
      and material stockpiles to control
      dust;

   •  Ensuring that no visible fugitive
     dust is emitted beyond the property
     line; and

   • Ensuring that all open-bodied trucks
     are covered if any materials in the
     truck could become airborne.
                                                63:010
Hazardous waste
determination
A hazardous waste determination must be
made for excavated soil being transported
beyond SWMU boundaries. If the soil is
determined to be hazardous, other RCRA
Subtitle C requirements would be
applicable.
Generation of waste
— Applicable.
40C.F.R. §262.11
32:010 § 2

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     Table 2-5..Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                           at Solid Waste Management Unit 8 of Waste Area Group 7 (Continued)
        Actions
            Requirements
       Prerequisites
 Federal Citation
     Kentucky
     Citation
    401 K.A.R.
  Radioactive
  waste determination
 A radioactive waste determination
 must be made for excavated soil being
 transported beyond SWMU boundaries.
 If the soil  is determined to be
 radioactive, or contain mixed waste,
 the soil will be managed according to
 appropriate  standards.
Generation of waste:
RCRA —Applicable;
K.R.S. 224 — Applicable;
DOE Order 5820.2A— TBC;
and LDR-FFCA—TBC
42 U.S.C.A. §§
6921 through
6939(e); DOE
Order 5820.2A
LDR-FFCA
K.R.S.  Chapter
224, subchapter 46
  Construction along
  streams
Construction materials used in or along
either Bayou Creek or the unnamed
tributary must be stable and inert, free
from pollutants and floatable objects,
and must meet all appropriate
engineering standards.
Use of construction
materials in stream
construction projects
— Applicable.
                         4:060 § 7
 Deed notice and
 restrictions
Provide notice to prospective
purchasers of the property that waste
is buried on site. Restrict uses of the
property so that the landfill cap and
riprap along the stream banks are not
disturbed.
Implementation of the
remedial action — Relevant
and appropriate.
                      34:070 § 10(2)
Pursuant to the CERCLA, the RCRA is listed as an ARAR in this ROD. This in no way limits or negates the Commonwealth of Kentucky's
h a /.a rdous waste management authority pursuant to K.R.S. Chapter 224, subchapter 46.	

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Table 2-6. Applicable or Relevant and Appropriate Requirements and To Be Considered Information
                 for Solid Waste Management Unit 100 of Waste Area Group 1
Contaminant/Medium
Requirements
Prerequisites
Federal
Citation
Kentucky
Citation
401 K.A.R.
CHEMICAL-SPECIFIC
Radionuclides — all
exposure pathways
General public must not receive an
effective dose equivalent greater
than 100 mrem/yr, or 5 mrem/yr to
any organ from all exposure modes.
All releases of radioactive
material must be ALARA.
Emissions from DOE facilities
shall not cause members of the
public to receive, in any year, an
effective dose equivalent greater
than 10 mrem/yr.
Exposure of the general public
from any source of radiation
exposure at a DOE facility
— TBC on a facility-wide basis.
Release of radioactive material
from DOE activities — TBC.
Emissions of radionuclides other
than radon from DOE facilities
— Applicable on a facility-wide
basis.
DOE Order
5400.5
DOE Order
5400.5
40 C.F.R. §61.92


LOCATION-SPECIFIC
None
ACTION-SPECIFIC
SWMU corrective action
Protect human health and the
environment.
Release of hazardous waste or
constituents from a SWMU
— Applicable.
40 C.F.R. §
264.101
34:060 § 12

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o\
OJ
                           Table 2-7. Action-Specific Applicable or Relevant and Appropriate Requirements

                      for Solid Waste Management Units 130 through 134 and 136 of Waste Area Groups 1 and 7
Actions
SWMU corrective
action
Requirements
Protect human health and the
environment.
Prerequisites
Release of hazardous waste or
constituents from a SWMU
— Applicable.
Federal Citation
40 C.F.R. §
264.101
Kentucky
Citation
401 K.A.R.
34:060 §12
      Pursuant to the CERCLA, the RCRA is listed as an ARAR in this ROD. This in no way limits or negates the Commonwealth of

      Kentucky's RCRA authority at the site.	

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2.12      UTILIZATION OF PERMANENT SOLUTIONS  AND  ALTERNATIVE
          TREATMENT TECHNOLOGIES

The objectives for this remedial action are to limit exposure to the landfill  leachate  by
covering visible seep locations with riprap, limiting nature land use, and preventing
destruction of current containment measures (i.e., the existing landfill cap) by placing a
deed notice and restrictions on the  property. The effectiveness of the remedial action
will be assessed through ground-water and surface-water monitoring. Implementing this
remedial action is intended to be the final action taken at  this site, as it provides  an
acceptable level of protection from  potential exposure to contaminants present in the
landfill leachate. Should monitoring conducted at this site indicate an unacceptable risk
to human health or environment in the future, implementing additional  remedial actions
will be assessed.

2.13   PREFERENCE FOR TREATMENT AS A PRINCIPAL  ELEMENT

The CERCLA statutory  preference for treatment is not adhered to by  the selected
remedial action because treatment  of the leachate was not deemed necessary or cost
effective. This action does satisfy  the statutory  requirement for protection of human
health and the environment.

2.14   DOCUMENTATION OF SIGNIFICANT CHANGES

No significant changes were made.
                                      64

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         PART 3




RESPONSIVENESS SUMMARY
            65

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 3.1    RESPONSIVENESS SUMMARY INTRODUCTION

 This responsiveness summary has been prepared to meet the requirements of Sections
 113(k)(2)(B)(iv)  and 117(b)  of the CERCLA,  as  amended by the  Superfund
 Amendments and  Reauthorization Act  of  1986  (SARA). These CERCLA  provisions
 require the DOE, as  "lead agency," to respond "to each of the significant comments,
 criticisms, and new data submitted in written or oral presentations" on the WAGs 1 and
 7PRAP.

 The DOE has gathered  information on the types and extent of contamination  found,
 evaluated remedial measures, and recommended remedial actions that  will minimize
 direct contact with contaminated soil and mitigate migration of contaminants through
 surface and ground water. As  part of the remedial action  process,  a  Notice  of
 Availability regarding the PRAP  was published  in The Paducah Sun, a major regional
 newspaper of general circulation. The Proposed Remedial Action Plan for Waste Area  Groups
 1 and 7  at  the Paducah Gaseous Diffusion Plant,  Paducah, Kentucky, DOE/OR/06-
 1428&D2, was released to the general public June 24, 1996.  This document was made
 available to the public at the Environmental Information Center in the West Kentucky
 Technology Park in  Kevil, Kentucky, and  at the Paducah  Public Library. A 45-day
 public comment period began June 25,1996, and continued through August 9, 1996. The
 PRAP also contained information which provided the opportunity for a public meeting
 to be held, if requested. Specific groups which received individual copies of the WAGs 1
 and 7 PRAP  included the local  PGDP Neighborhood Council, the Natural  Resource
 Trustees, the SSAB, and the PGDP Environmental Advisory Committee.

 In response to comments from the public, the EPA, and the Commonwealth of Kentucky,
 changes were made to the PRAP. The revised PRAP (Proposed Remedial Action Plan for
 Waste Area  Groups 1 and 7 at the Paducah Gaseous Diffusion Plant, Paducah,  Kentucky,
 DOE/OR/06-1428&D4) was issued to the public  after  a  Notice of Availability
 announcing the 45-day public  review period was published  in  The  Paducah Sun
 December 22, 1996. During the  public comment period (December 23,  1996, through
 February 5, 1997), the  PRAP  was made available for public review at the Paducah
 Public Library and the  off-site DOE  Environmental Information Center located in the
 West Kentucky Technology Park  in Kevil, Kentucky. The review period was extended 30
 days to March 7, 1997, due to public request. Specific groups which received individual
 copies of the PRAP included the local PGDP Neighborhood Council, Natural Resource
 Trustees, the SSAB, and the PGDP Environmental Advisory Committee.

 3.2    COMMUNITY PREFERENCES/INTEGRATION OF COMMENTS

 Public participation in  the CERCLA process  is  required  by  the SARA. Comments
 received from the public are considered in the selection of the remedial  action  for the
 site. The responsiveness summary serves two purposes: (1) to  provide the DOE with
 information about the  community preferences  and concerns regarding the remedial
 alternatives, and  (2) to show members of the community how their comments were
 incorporated into the decision-making  process.  The following are comments received
 from the public on the  WAGs 1  and  7 PRAP during the public comment periods. The
 first comment and response refers to the first PRAP and the remaining comments and
- responses refer to the second PRAP.
                                      66

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Comment:    I wish to comment on the proposed remedial action plan for SWMU 8.
             The alternatives listed do show some promise, but I wish there was a
             more substantial solution. I understand that funds are limited  for this
             project. I think Alternative 3, the leachate collection system would be the
             most reliable long term solution. I understand the cost is higher than the
             proposed Alternative 5 wetland treatment system at half the cost. I have
             concerns the wetland treatment system will not work. The fact  that the
             wetland is to be evaluated over a two-year period suggests doubt of its
             effectiveness. It's  a 3.5 million dollar bet  which translated [into] still
             higher costs if the problem is not solved. I believe that removing the source
             of the contamination is the only solution.

Response:   In response to this comment, informal public comments, and comments
             from the EPA and KDEP, the proposed alternative was reevaluated and
             changed to the current proposed alternative. Risks to human health and
             uncertainties in performance of the wetland alternative were evaluated,
             and  it was  determined that  costs  for  implementation and  were  not
             commensurate with  the risks posed at the site. Based upon this same
             rationale, invasive technologies (i.e., excavation) also were screened from
             further consideration. The current remedy was selected based upon its
             ability  to  maintain overall  protection  of  human health   and  the
             environment, comply with ARARs,  pose  no  additional  risks to  the
             community, and provide cost-effectiveness in remedy selection.

Comment:   Is it possible for certain members of the public to be added to  a mailing
             list to receive documents published by the United States Department of
             Energy? This will further facilitate the public participation process.

Response:   The DOE publishes a Notice of Availability for documents available for
              public review and notices of public meetings for PRAPs in The Paducah
              Sun.  The DOE  also provides  45-day  public comment  period  which
              provides citizens time  to review each FS and  PRAP.  Additionally, all
              reports which document the remedial action process are available to the
              public in the AR  located  in the Jacobs Technical Center at  175  Freedom
              Boulevard, Kevil, Kentucky. The telephone number for the AR is (502)
              462-2550 and the facsimile number is (502)  462-2551. The DOE also has
              established a SSAB to  keep the  public involved in the decision-making
              process at the PGDP.  In addition to these mechanisms, the DOE  will
              strive in future document releases to ensure public notice is sufficient to
              provide ample review time. However, due to cost and concerns that DOE
              would not be treating all members of the public equally if DOE were to
              selectively distribute the  documents, including to  members of the public
              on a DOE mailing list, this is not the practice of DOE at this time.

 Comment:    The public is extremely concerned about the leachate from the landfill. We
              don't agree that allowing  this  leaching to  continue  complies with
              CERCLA. It is an uncontrolled release that is prohibited by CERCLA.
                                      67

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Response:    The CERCLA does not prohibit uncontrolled  releases  when  they  meet
             CWA requirements and are not hairming the environment [42 U.S.C.A. §
             9621(b)(l),  (d)(l),  and (d)(2)(A)(ii)j.  The EPA  and  the  KDEP  have
             agreed that a  limited action would meet  all  CERCLA  and CWA
             requirements because landfill  discharges are not harming Bayou Creek or
             the unnamed tributary or violating ARARs. Also, the creek and  ground
             water in the vicinity of the landfill will continue to be monitored with  the
             results reported to the  KDEP. This process will ensure that further action
             would be  evaluated  if the  landfill  began  releasing significant  new
             discharges.

Comment:    There are organics, metals,  and radionuclides  in the leachate. These
             contaminants are entering the creek and traveling to the river. This  must
             be having a negative, long-term, cumulative impact on the wildlife in and
             around the creek and  those  humans utilizing  the water from the  river
             downstream. It is these cumulative effects from all of the  discharges at
             the plant, including air, water, land, and waste storage, which pose  the
             most serious risk to human health and the environment. Yet, it is  those
             cumulative effects from the entire situation at the site which has  never
             been given a hard look by the agency.

Response:   The  WAGs 1 and  7 investigation indicates that risks associated  with
             SWMU 8 (the C-746-K Sanitary Landfill) in the creeks are not  present
             above unacceptable levels. Additionally, the screening ecological risk
             assessment indicates  that  there are minimal   impacts  to ecological
             receptors in the creeks. The KDOW also has indicated that the landfill is
             having no adverse impacts on the creeks. Cumulative impacts  will be
             evaluated thoroughly on a site-wide basis after completion of individual
             SWMU investigations. The sitewide approach for addressing cumulative
             risks has been approved by the EPA and KDEP. Finally, as discussed in
             the  previous comment response,  the creek  and ground  water in  the
             vicinity of  the  landfill will  continue to be monitored with  the results
             reported to the KDEP. This process will ensure that further  action would
             be evaluated if the landfill began releasing significant new discharges.

 Comment:   Commercial landfills now have to install leachate collection systems. This
             leachate is then removed  and treated. While not perfect  and  without
             problems, this system is preferable to allowing the contaminants into the
             environment uncontrolled.

 Response:   The  landfill was  closed  before leachate  control  systems  became
             mandatory for landfills.  Additionally, the RI and FS  indicate that  the
             risks associated with the landfill leachate  do not warrant  a  remedial
              alternative such as a  leachate collection system. A limited  action  will
              meet the CERCLA's  requirements, which  include  being  protective of
             human health and the  environment.
                                     68

-------
Comment:    The no action alternative for the other sites (in addition to SWMU 8) in
             the proposal is questionable. These areas need to be blocked off from the
             public, and runoff from the  area needs to be controlled. The  five-year
             review is too long of a period for reviewing the environmental effects of
             such uncontrolled releases of contaminants. There needs to be ongoing
             review, including attempts to find  out what is in the  landfill  which is
             causing radionuclides, organics, and metals to be released  uncontrolled
             into the environment.

Response:   With the exception of SWMU 38, which has been deferred until the unit
             ceases operation, and the KOW SWMUs, for which the  DOD has agreed
             to accept responsibility, the remaining SVVMUs within WAGs 1 and 7 do
             not present an unacceptable risk. The DOE, KDEP, and  EPA have agreed
             that risk levels present at these, units require no additional  action. With
             regard to the landfill, as  stated previously, surface-water and ground-
             water monitoring will continue, over the next 30 years and beyond if
             necessary, to ensure protection of human health and the environment.

Comment:   The risk assessments which purportedly were done in conjunction with
             this proposal should be issued to the public in draft form and subjected
             to public view. Why should the public accept conclusionary statements in
             a summary that there is no unacceptable risk? Show us your calculations
             and let us comment on them.

Response:   The baseline  risk assessment for WAGs 1  and 7  was  performed in
             accordance with KDEP and  EPA Region 4 guidance. The DOE presents
             the results of the baseline risk assessment in the Resource Conservation and
             Recovery Act Facility Investigation/Remedial Investigation Report for Waste
             Area Groups 1  and 7 at  the Paducah Gaseous Diffusion  Plant,  Paducah
             Kentucky, DOE/OR/07-1404&D2.  Further, risk  management  decisions
             and  a summary  of the baseline risk assessment are included in the
             Feasibility Study for Waste Area Groups 1  and 7 and Kentucky Ordnance
              Works Solid Waste Management Units 94,  95, and  157 at the Paducah
              Gaseous Diffusion Plant, Paducah,  Kentucky, DOE/OR/06-1416&D2.  The
              public has access to these documents through the AR  and the Paducah
              Public Library.

Comment:    Exactly how can doing next to nothing cost $400,000? What exactly is
              that money being spent on? What accounts is the money being drawn
              from, and how  does the money match up with the requests submitted in
              the outyear budget requests when made for these WAGs.

Response:    The Limited action being taken through the ROD will be in place over the
              next 30 years and the $400,000 reflects that fact. The $400,000 is the
              total  cost  of the project,  which  includes  installing rip-rap,  posting
              warning signs,  placing a  deed notice  and restrictions  on the landfill
              property,  and  maintaining  the  landfill over the  30-year time frame.
              Additionally, two existing wells will be abandoned and replaced with a
              new well to the base of the terrace gravel. The new well will provide more
              information about whether SWMU 8 is contaminating ground water
              beneath the unit. The money for this action is coming from a line  item
              account in the DOE Paducah budget.
                                       69

-------
APPENDIX A



  Schedule

-------
D.u . t»
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jcr NOV DEC UAN FEU MAR AFJR MAY JUN JUL AUG srt' oci
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-------
"ou« -1
v":;,:-:.;>- :;;::l7f..:M WAGS i & 7 - JANUARY SCHEDULE
1 1« 1 w ) 1 "• t- ttUtl
< UK* O t* ^ U J /
Activity Description Start Finish Our
U10406R400 EPA/KDHM REVIEW ORAFI REMEDIAL DESIGN 3I7APR97 a16M«Y97 30
U10406R500 ASSESS HOOD DAMAGE IMPACIS 10 110 a17MAY97 a!9JUN97 34
010406R505 SUBMII till DESCRIBING FLOOD DAMAGE a30JUN97 a?OJUN97 1
IMPACIS 10 MO
I)10406n5l0 EPA/KOWM REVIEW K COMMENIS ON IMPACIS a?1JUN97 a?BJUL97 38
Lin ON HI)
010406R599 1SSUI IINAI CfC REMEDIAL DESIGN 10 a?9JUL97 0
[PA/KOWM ID?)
010406R699 EPA APPROVE CFC DESIGNlDl H/IMI'ACIS MR at6JUl97 0
ADDENDUM!
0104060700 KOHM APPROVE CFC DESIGN (01 N/IMPACIS LIR a?BJUL97 0
ADDENDUM)
or to 01 01. w .0?
VffOUl AC 11 ON
0104061000 REMEDIAL ACTION - SIARI a?9JUL97 0
0104061002 REMEDIAL ACIION IMREMENIAIION a?9JUL97 30MAR98 ?45
0104061004 HIP RAP INSIALLAIION a?9JUL97 8l?AUG97 15
0104061006 DEED RESIHICIIONS «18AUG97 13FEB98 1BO
0104061008 HARNING SIGNS a!8AUG97 13FE898 180
0104061009 CM NELL INSIALLAIION S ABANOONMENI a30JAN98 30MAR9B 60
0104061050 REMEDIAL ACIION - FINISH 30MAR98 0
07.10.01.01.10.03
oosr coNsraucr/ON REPORT
D10406N200 POS1 CONSTRUCIION |PC| REPORT 8010CI97 30SEP98 365
010406H300 PREPARE POST CONSIHUCHON flEPORI a010CI97 ?9APfl98 ?11
010406H3P9 ISSUE ORAFI POSI CONSIRUCHON REPORI 10 29APR98 0
DOE (001
010406H350 OOE REVIEW DRAFI POSI CONSIRUCIION 30APR98 39MA1T98 30
REPORI
010406H35I OOCUMENI REVISION 31MAY98 I2JUN98 13
D10406H360 CONSOL IDAI ION £ RESOLD! ION DRAFI PC 31MAY98 05JUN9B 6
REPORT CO^MNIS
010406H370 DflAFT- RE MEDIAL POSI CONSIRUCIION 05JUN9B 0
COMMENIS HESOLVEO
010406H3BO INCORPORAIE POSI CONSIRUCHON MEPORI 06JUN98 I?JUN9B 7
COMMENIS
H10406H399 ISSUE ORAFI PC REPORI 10 EPA/KOHM (Oil 15JUN9B 0
010406H400 EPA/KOHM REVIEW ORAF I POSI CONS II1UC 1 1 ON 16JUN9B 15AUG9B b1
OEPOfll
DI0406H500 INCORPORAIE EPA/KDHH COMMENTS 16AUG90 31AUG90 16
DI0406Hb99 ISSUE FINAL I'C HEt'OHl 10 EPA/KOHM HK'I 31AUG9B 0
D1l)40liHliOO II>A/KI)WM IUVIIN 1 INAI I'OSI CONSIIlllCI ION 01SIP9II 30SH'9fl M
llll'lllll
1 t?
-------
>< • i> ti • i n *• «r> »
'-".'( W I » « A \l 1 >
1 . -MB ' • » • ) 1 '• 1. li'./il
»Ct ivtly Oesrripl ion
WAGS 1 & 7 - JANUARY SCHEDULE
Start funsn Dur
D10406HR99 EPA/KOHH APPROVE FINAL POS1 CONSIHUL'I ION 30SEP98 0
flEPOfl
OI040BH999 PROJEC! COMPLE1E 30SfP98 0
Of. tO 01.01 30
MG /_/ - OUtYCARS
D104063000 HAG IS7 - TY99 010CI98 30SEC99 365
, i
1 f. •'.)«.•) Ml
HH-l'i MIJI i: •. •, /I 'iiM-i' 1 t_- ( i-
CZJ-i'u 	 en
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JC1 NOV DEC LlAN FEB MAR AI'H MAY JUN ,IUL Allf, St 1' (1C. I




































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-------
          APPENDIX B



Letter from the Division of Water

-------
JAMCS E.
PAUL 6. PAT-TON
                                COMMONWEALTH OF KENTUCKY
                NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CAOINET
                         DEPARTMENT POR ENVIRONMENTAL PROTECTION
                                     FKAN«.r.(JRT OfflCC PAftK
                                         14 RciLt-r Ro
                                              KY 40601
                                     September 11, 1996
    Jimmio C.  Hodges, Site Manager
    Paducah Site  Office
    United States Departmont of Energy
    P.O.  Box 1410
    Paducah,  Kentucky 42001
                                       Re:   C-746-K Landfill
                                             KPDES  Permit  No.:   KYOOO<049
                                             Paducah Oasaous Diffuoion  Plant
                                             Paducah,  McCracken County
    Doar Mr.  Hodges:
          The UK-Federal Facilities Oversight  Unit of  the  Division of Waste Management,  the
    US  Department of Energy and Water Qualicy  and  Field Operations Branches of the Division
    of  Hater have had several discussions regarding  the  1992  Division of  Water  Notice of
    Violation for unpormicted discharge and iron staining  from  the referenced facility.  To
    data the current monitoring program has not  revealed an adverse impact  oh either  Big
    Bayou Creek or the unnamed tributary  as  a result of thin  seepage from  the  landfill.
    Therefore,  it ie the consensus of the aforemencioned parties that the current monitoring
    program should be continued in lieu of the installation of  treatment.   However,  should
    the monitoring program reveal at  a  future date degradation of either  stream's water
    quality then additional  actions  may  be necessary.

          Should you have any quoeuions concerning thle  matter, please  contact mo at (502)
    S64-222S. extension 472.

                                        Since
                                              Jranch
                                                 of Water
    LJS:jo
          Division of Water Files
          Paducah Regional Office
          Tuso Taylor

-------
         APPENDIX C

Solid Waste Management Unit  100
      Exposure Assessment

-------
  EVALUATION OF EXPOSURE AT SOLID WASTE MANAGEMENT UNIT 100

Solid Waste Management Unit (SWMU)  100  (the Fire Training Area) is  located within
the Paducah Gaseous  Diffusion Plant's (PGDF's) perimeter security  t'ence which  is
identified in the Site  Management  Flan. Paduc.ifi  C-.i^ous Diffaficn Plant. Paducak,
Kentucky. DOE/OR/07-1207&D3, (SMP) as a secured industrial area. Consequently, it
is appropriate to evaluate risks to current and nature industrial  workers based on the
amount of time they actually would be in contact with contaminated media at  SWMU
100 (i.e., surface water and sediments).

Default  exposure   assumptions for  an  industrial worker  assume   contact  with
contaminated media for 250 days/yr for 25  years  as documented in a  United States
Environmental  Protection  Agency (EPA) document, Supplemental  Guidance to RAGS:
Region 4 Bulletins, Human Health Risk Assessment. Actual exposures to current industrial
workers at  SWMU 100 are significantly  less. Actual exposures  at the unit are due  to
grass mowing, weed-eating, ground-water sampling, and routine inspections according
to information provided by Lockheed Martin Energy Systems, Inc. While each  activity
likely is performed  by  a different individual, all activities combined only account for
approximately  10 hours of exposure for the entire year. To be conservative, 2 days/yr
were used as the actual exposure at the  unit for the 25 year time frame [note: all  other
factors cancel  in the equation and are not presented  in the  attached tables]. The
resultant excess lifetime cancer risk (ELCR) and hazard  index (HI) risks are well below
EPA risk assessment guidance for determining scenarios of concern (i.e., a 1  x 10"4 ELCR
and an HI of 1) and are very near de minimus (i.e., 1 x 10'*)  with an ELCR of 2  x 10"* at
SWMU lOOa  and  lOOb.  Consequently, there are  no  unacceptable risks to  current
industrial workers at SWMU 100; however, risks to future industrial workers also must
be evaluated.

Further evaluation of the ELCR and HI risks at  SWMU 100 indicate a  risk to a future
industrial worker  (albeit  highly uncertain)  exposed to surface-water  and sediment
contamination  for  more than 75 days/yr at SWMU  lOOa,  and  for  more than 130
days/yr at SWMU lOOb. Activities in the future  are anticipated  to be similar to current
ones.  The  reason  for  this is  that   the risks  at  SWMU  100 are  from contaminated
sediments  and surface water  in the drainage ditches surrounding the  unit. The SMP
identities the PGDP as future industrial facility; therefore, only existing upkeep activities
reasonably can be  expected  to  occur in the future, which indicates the site-specific
exposure frequency (2 days/yr) would be appropriate  under future  industrial use.
Additionally, institutional controls (i.e., the perimeter security fence, patrol by security)
ensure that exposures are limited  to industrial workers and provide safeguards (i.e.,
 personal protective equipment) to limit exposures to an  industrial worker. Therefore, no
 further action is required  to address the current contamination found  at  SWMU 100.
 However,  it should be noted that this decision does not mean that current actions do not
 need to be maintained. Most importantly, this decision rests upon the observation that
 SWMU 100 and the surrounding area will remain industrialized in the foreseeable future
 and  that SWMU  lOOa and  lOOb   remain in operation as drainage ditches  at  which
 upkeep activities  performed do  not  exceed aforementioned  exposure  times.  These
 observations are consistent with the expected nature use of the area as  described in the
 feasibility srudv and the SMP.
                                        C-l

-------

Chemical
Sediment
Ingestion
Dermal Absorption
Inhalation
External Exposure
Sum of Pathways


Chemical
Surface Water
Dermal Absorption
Sediment
Ingestion
Dermal Absorption
Inhalation
Sum of Pathways

Default
ELCR*
7.00E-06
3.00E-03
2.00E-08
l.OOE-06
3E-03


Default
m*
4.00E-00

3.00E-01
4.82E+01
2.00E-02
5E+01
SWMU lOOa
CARCINOGENS
Default Exposure**
(days/yr)
250
250
250
250

SWMU lOOa NON-
CARCINOGENS
Default Exposure**
(days/yr)
250

250
250
250


Actual Exposure
(days/yr)
2
2
2
2



Actual Exposure
(days/yr)
2

2
2
2


Actual
ELCR
5.60E-08
2.40E-05
1.60E-10
8.00E-09
2E-05


Actual
HI
3.20E-02

2.40E-03
3.86E-01
1.60E-04^
4E-01 "
* rrom the FS report
*• Based on EPA guidance
Equation used to complete
the table:
Where:
                      ARH = (E. (Ea x RHd)/Ed
                         ARH = Actual ELCR (risk) or HI
                                 (hazard) based on actual
                                 exposures
                            Ea = Actual exposure frequency (i.e.,
                                 2 days/yr)
                          RHd = ELCR or HI value from the FS
                                 (based on default exposure
                                 assumptions)
                            Ed = EPA's default exposure
                                 assumption  (i.e., 250 days/yr)
                                            C-2

-------
Chemical
Surface Water
Dermal Absorption
Sediment
Ingestion
Dermal Absorption
Inhalation
External Exposure
PATHWAY


Chemical
Surface Water
Dermal Absorption
Sediment
Ingestion
Dermal Absorption
Inhalation
PATHWAY SUM
Default
ELCR*
2.00E-06

6.00E-06
2.00E-03
2.00E-08
8.00E-07
2E-03


Default
HI*
3.00E-01

2.00E-01
2.69E+01
8.00E-03
3E+01
SWMU lOOb CARCINOGENS
Default Exposure**
(days/yr)
250

250
250
250
250

SWMU lOOb NON-
CARCINOGENS
Default Exposure**
(days/yr)
250

250
250
250

Actual Exposure
(days/yr)
2

2
2
2
2



Actual Exposure
(days/yr)
2

2
2
2

Actual
ELCR
1.60E-08

4.80E-08
1.60E-05
1.60E-10
6.40E-09
2E-05


Actual
HI
2.40E-03

1.60E-03
2.15E-01
6.40E-05
2E-01
* FromtheFS report
** Based on EPA guidance
Equation used to complete
the table:
Where:
                        ARH = (Ea x RHd)/Ed
                        ARH = Actual ELCR (risk) or HI (hazard)
                               based on actual exposures
                          Ea = Actual exposure frequency (i.e., 2
                               days/yr)
                         RHd = ELCR or HI value from the FS (based
                               on default exposure assumptions)
                          Ed = EPA's default exposure assumption
                               (i.e., 250 days/yr)
                                            C-3

-------
DISTRIBUTION

-------
    The distribution sheet that is included in this signed Record of Decision has become
obsolete since the signing of this Record of Decision. We have included this current revised
                       version by which we now distribute documents.


                                      DISTRIBUTION
U.S. DEPARTMENT OF ENERGY
Myma Redfield
U.S. Department of Energy
P.O. Box 1410
Paducah, KY 42001

Nancy Games, CC-10
(Letter only)
U.S. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

Gary Hartman
(Letter only)
U.S. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

Jimmie C. Hodges (3 copies)
U.S. Department of Energy
P.O. Box 1410
Paducah, KY 42001

K. Kates, AD-424
(Letter only)
U.S. Department of Energy
Chirm I Building
167 Mitchell Road
Oak Ridge, TN 37830

Robert L. Nace
(Letter only)
EM-423 Quince Orchard
U.S. Department of Energy
19901 Germantown Road
Germantown, MD 20874-1290

Robert C. Sleeman, EW-91
 (Letter only)
U.S. Department of Energy
 FederalOffice Building
200 Administration Road
 Oak Ridge, TN 37830

 Don Williams
 EM-42/Cloverleaf Building
 U.S. Department of Energy
 19901 Germantown Road
 Germantown, MD 20874-1290

 U.S. ENVIRONMENTAL
 PROTECTION  AGENCY
 Carl R. Froede, Jr. (3 copies)
 U.S. EPA, Region 4
 61 Forsyth Street
 Atlanta, GA 30303

 IACOBS ENGINEERING
 GROUP INC.
 Bruce E. Phillips
 Jacobs Engineering Group Inc.
 175 Freedom Boulevard
 Kevil, KY  42053
SYSTEMATIC MANAGEMENT
SYSTEMS
VV. F. Redrield
U.S. Department of Energy Site Office
5600 Hobbs Road
West Paducah, KY 42086

KENTUCKY DEPARTMENT OF
FISH AND WILDLIFE
Wayne Davis
Environmental Section Chief
KY Department of Fish and Wildlife
Resources
#1 Game Farm Road
Frankfort, KY 40601

BECHTEL JACOBS
COMPANY LLC
Patricia A. Gourieux
(Letter only)
Bechtel Jacobs Company LLC
761 Veterans Avenue
Kevil,  KY 42053

Jimmy C. Massey
(Letter only)
Bechtel Jacobs Company LLC
761 Veterans Avenue
Kevil,  KY 42053

NATURAL RESOURCE
TRUSTEES
Alex Barber
Commissioner's Office
KY Dept. for Environmental
Protection
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Abraham Loudermilk
Tennessee Valley Authority
400 W. Summit Hill Drive
Knoxville, TN 37902

Andrea B. Perkins
 U.S. Department of Energy
 FederalOffice Building
200 Administration Road
 Oak Ridge, TN 37830

 Allen Robison
 U.S- Department of Interior
 Fish and Wildlife Service
 446 Neal Street
 Cookville, TN 38501

 STATE  OF KENTUCKY
 Robert H. Daniell, Director
 Division of Waste Management
 KY Dept. for Environmental
 Protection
 14 Reilly Road
 Frankfort Office Park
 Frankfort, KY 40601
Steve Hampson
Cabinet for Human Resources
Radiation Control Laboratory
100 Sower Boulevard
Suite 108
Frankfort, KY 40601

Todd Mullins
KY Division of Waste Management
U.S. Department of Enerey Site Office
5600 Hobbs Road
West Paducah, KY 42086

Tuss Taylor (3 copies)
UK/KDEP
18 Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Dr. John A. Volpe
Radiation Control Branch
Cabinet for Human Resources
275 East Main Street
Mail Stop HS2E-D
Frankfort, KY 40621

TVA
TeTWhitaker
(Letter only)
Plant Manager
Shawnee Fossil Plant
7900 Metropolis Lake Road
West Paducah, KY 42086

U.S. ENRICHMENT
CORPORATION
T. Michael Taimi
(Letter only)
U.S. Enrichment Corporation
2 Democracy Center
6903 Rockledge Drive
Bethesda, MD 20817

U.S. GEOLOGICAL SURVEY
Tom Mesko
U.S. Geological Survey
9818 Bluegrass Parkway
 Louisville, KY 40299-1906

 WEST KY WILDLIFE
 MANAGEMENT AREA
 W. D. Hendricks
 West Kentucky Wildlife
 Management Area
 Kentucky Department of Fish
 and Wildlife
 10535 Ogden Landing Road
 Kevil, KY 42053

 SITE SPECIFIC ADVISORY
 BOARD
 Site Specific Advisory Board
 Information Age Park Resource Center
 2000 McCracken Boulevard
 Paducah, KY 42001
  JEG.0197.2r

-------
                                       DISTRIBUTION
U.S. DEPARTMENT OF ENERGY
Carlos Alvarado
U.S. Department of Energy
P.O. Box 1410
Paducah, KY 42001

N'ancv Cames, CC-10
U.S. Department of Energy
FederalOffice Building
200 Administration Road
Oak Ridge, TN 37830

Jimmie C. Hodges (3 copies)
U.S. Department of Energy
P.O. Box 1410
Paducah, KY 42001

Paul A. Hermann
U.S. Department of Energy
FederalOffice Building
200 Administration Road
Oak Ridge, TN  37830

K. Kates, AD-424
US. Department of Energy
Chinn 1 Building
167 Mitchell Road
Oak Ridge, TN  37830

Anthony A. Sims, CE-524
U.S. Department of Energy
Maxima Building
107 Union Valley Road
Oak Ridge, TN  37830

Robert C. Sleeman, EW-91
US. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN  37830

D.M. Drucker
EM-421
Quince Orchard
U.S. Department of Energy
19901 Germantown Road
Germantown, MD 20874-1290

 EPA
CarlR. Froede, Jr. (5 copies)
US. EPA, Region 4
61 Forsyth Street
 Atlanta, GA 30303

 JACOBS ENGINEERING
 GROUP INCT
 Don J. Wilkes (2 copies)
 Jacobs Engineering Group Inc.
 175 Freedom Blvd.
 Kevil,  KY 42053

 SYSTEMATIC MANAGEMENT
 SYSTEMS
 W. F. Redfield
 US. Department of Energy Site Office
 5600 Hobbs Road
 West Paducah, KY 42086
KENTUCKY DEPARTMENT OF
FISH AND WILDLIFE
Wavne Davis
Environmental Section Chief
KY Department of Fish and Wildlife
Resources
#1 Game Farm Road
Frankfort,  KY 40601

LOCKHEED MARTIN ENERGY
SYSTEMS, INC.
Patricia A. Gourieux (3 copies)
Lockheed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053

Jimmy C. Massey
Lockheed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053

K. L. Holt (2 copies)
Lockheed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053

D.H. Shanks
Lockheed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053

NATURAL RESOURCE
TRUSTEES
Alex Barber
Commissioner's Office
KY Dept for Environmental
Protection
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Abraham Loudermilk
Tennessee Valley Authority
400 W. Summit Hill Drive
Knoxville, TN 37902

Andrea B. Perkins
U.S. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

Allen Robison
 U.S. Department of Interior
 Fish and Wildlife Service
 446 Neal Street
 Cookville, TN 38501

 STATE OF KENTUCKY
 Robert H. Daniell, Director
 Division of Waste Management
 KY Dept. for Environmental
 Protection
 14 Reilly Road
 Frankfort Office Park
 Frankfort, KY 40601

 Tuss Taylor (4 copies)
 UK/KDEP
 18 Reilly Road
 Frankfort Office Park
 Frankfort, KY 40601
Todd Mullins
KY Division of Waste Management
U.S. Department of Energy Site Office
5600 Hobbs Road
West Paducah, KY 42086

Steve Hampson
Cabinet for Human Resources
Radiation Control Laboratory
100 Sower Boulevard
Suite 108
Frankfort, KY 40601

Dr. John A. Volpe
Radiation Control Branch
Cabinet for Human Resources
275 East Main Street
Mail Stop HS2E-D
Frankfort, KY 40621

TVA
Ted Whitaker
Plant Manager
Shavmee Fossil Plant
7900 Metropolis Lake Road
West Paducah, KY 42086

Janet Watts
Manager of Environmental Affairs
5D Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801

Barry Walton
Office of General Council WT-10A
400 W. Summit Hill Dr.
Knoxville, TN 37902

U.S. ENRICHMENT
CORPORATION
David Hutcheson
U.S.E.C.
P.O. Box 1410
Paducah, KY 42001

U.S. GEOLOGICAL SURVEY
Tom Mesko
U.S. Geological Survey
9818 Bluegrass Parkway
Louisville, KY 40299-1906

WEST KY WILDLIFE
MANAGEMENT AREA
Charles W. Logsdon
West Kentucky Wildlife
 Management Area
 Kentucky Department of Fish
 and Wildlife
 10535 Ogden Landing Road
 Kevil, KY 42053
  JEG.0197.27

-------
DISTRIBUTION

-------
    The distribution sheet that is included in this signed Record of Decision has become
obsolete since the signing of this Record of Decision. We have included this current revised
                        version by which we now distribute documents.


                                      DISTRIBUTION
U.S. DEPARTMENT OF ENERGY   SYSTEMATIC MANAGEMENT
Myrna Redrield
L'.S. Department of Energv
P.O. Box UIO
Paducah, KY 42001

Nancy Games, CC-10
(Letter only)
U.S. Department of Energy
Federalpffice Building
200 Administration Road
Oak Ridge, TN 37830

Gary Hartman
(Letter only)
U.S. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

Jimmie C. Hodges (3 copies)
U.S. Department of Energv
P.O. Box 1410
Paducah, KY 42001

K. Kates, AD-424
(Letter only)
U.S. Department of Energy
Chinn I Building
167 Mitchell Road
Oak Ridge, TN 37830

Robert L. Nace
(Letter only)
EM-423 Quince Orchard
U.S. Department of Energy
19901 Germantown Road
Germantown, MD 20874-1290

Robert C. Sleeman, EW-91
(Letter only)
U.S. Department of Energy
FederalOffice Building
200 Administration Road
Oak Ridge, TN 37830

Don Williams
EM-42/Cloverleaf Building
 U.S. Department of Energv
 19901 Germantown Road
 Germantown, MD 20874-1290

 U.S.  ENVIRONMENTAL
 PROTECTION AGENCY
 Carl R. Froede, jr. (3 copies)
 U.S. EPA, Region 4
 61 Forsyth Street
 Atlanta, GA 30303

 JACOBS ENGINEERING
 GROUP  INC.
 Bruce E. Phillips
 Jacobs Engineering Group Inc.
 175 Freedom Boulevard
 Kevil, KY 42053
SYSTEMS
VV.F.Redneld
U.S. Department of Energy Site Office
5600 Hobbs Road
West Paducah, KY 42086

KENTUCKY DEPARTMENT OF
FISH AND WILDLIFE
Wayne Davis
Environmental Section Chief
KY Department of Fish and Wildlife
Resources
#1 Game Farm Road
Frankfort, KY 40601

BECHTEL JACOBS
COMPANY LLC
Patricia A. Gourieux
(Letter only)
Bechtel Jacobs Company LLC
761 Veterans Avenue
Kevil, KY 42053
Jimmy C. Massey
(Letter only)
Bechtel Jacobs Company
761 Veterans Avenue
Kevil, KY 42053
LLC
NATURAL RESOURCE
TRUSTEES
Alex Barber
Commissioner's Office
KY Dept. for Environmental
Protection
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Abraham Loudermilk
Tennessee Valley Authority
400 W. Summit Hill Drive
Knoxville, TN 37902

Andrea B. Perkins
U.S. Department of Energy
FederalOffice Building
200 Administration Road
Oak Ridge, TN 37830

Allen Robison
U.S. Department of Interior
 Fish and Wildlife Service
446 Neal Street
Cookville, TN 38501

 STATE OF KENTUCKY
 Robert H. Daniell, Director
 Division of Waste Management
 KY Dept. for Environmental
 Protection
 14 Reilly Road
 Frankfort Office Park
 Frankfort, KY 40601
Steve Hampson
Cabinet for Human Resources
Radiation Control Laboratory
100 Sower Boule%-ard
Suite 108
Frankfort, KY 40601

Todd Mullins
KY Division of Waste Management
U.S. Department of Energy bite Office
5600 Hobbs Road
West Paducah, KY 42086

Tuss Taylor (3 copies)
UK/KDEP
IS Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Dr. John A. Volpe
Radiation Control Branch
Cabinet for Human Resources
275 East Main Street
Mail Stop HS2E-D
Frankfort, KY 40621

TVA
Ted Whitaker
(Letter only)
Plant Manager
Shawnee Fossil Plant
7900 Metropolis Lake Road
West Paducah, KY 42086

U.S. ENRICHMENT
CORPORATION
T. Michael Taimi
(Letter only)
U.S. Enrichment Corporation
2 Democracy Center
6903 Rockledge Drive
Bethesda, MD 20817

U.S. GEOLOGICAL  SURVEY
Tom Mesko
U.S. Geological Survey
9818 Bluegrass Parkway
Louisville, KY 40299-1006

WEST KY WILDLIFE
MANAGEMENT AREA
W. D. Hendricks
West Kentucky Wildlife
Management Area
Kentucky Department of Fish
and Wildlife
 10535 Ogden Landing Road
Kevil, KY 42053

 SITE SPECIFIC ADVISORY
 BOARD
Site Specific Advisory Board
 Information Age Park Resource Center
 2000 McCracken Boulevard
 Paducah, KY 42001
 SEC 0197.27

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                                       DISTRIBUTION
U.S. DEPARTMENT OF ENERGY
Carlos Alvarado
U.S. Department of Energy
P.O. Box 1410
Paducah, KY 42001

Nancv Carries, CC-10
U.S. Department of Energy
FederaiOffice Building
200 Administration Road
Oak Ridge, TN 37830

Jimmie C. Hodges (3 copies)
U.S. Department of Energy
P.O. Box 1410
Paducah, KY 42001

Paul A. Hermann
U.S. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN  37830

K. Kates, AD-424
US. Department of Energy
Chinn [Building
167 Mitchell Road
Oak Ridge, TN  37830

Anthony A. Sims, CE-524
US. Department of Energy
Maxima Building
107 Union Valley Road
Oak Ridge, TN  37830

Robert C. Sleeman, EW-91
U.S. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN  37830

D.M. Drucker
EM-421
Quince Orchard
U.S. Department of Energy
19901 Germantown Road
Germantown, MD 20874-1290

 EPA
Carl R. Froede, Jr. (5 copies)
 U.S. EPA, Region 4
61 Forsyth Street
 Atlanta, GA 30303

 JACOBS ENGINEERING
 GROUP  1NCT
 Don J. Wilkes (2 copies)
 Jacobs Engineering Group Inc.
 175 Freedom Blvd!
 Kevil, KY 42053

 SYSTEMATIC MANAGEMENT
 SYSTEMS
 W. F. Redfield
 US. Department of Energy Site Office
 5600 Hobbs Road
 West Paducah, KY 42086
KENTUCKY DEPARTMENT OF
FISH AND WILDLIFE
Wayne Davis
Environmental Section Chief
KY Department of Fish and Wildlife
Resources
#1 Game Farm Road
Frankfort, KY 40601

LOCKHEED MARTIN ENERGY
SYSTEMS, INC.
Patricia A. Gourieux (3 copies)
Lockheed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053

Jimmy C. Massey
Lockneed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053

K. L. Holt (2 copies)
Lockheed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053

D.H. Shanks
Lockheed Martin Energy Systems
761 Veterans Ave.
Kevil, KY 42053

NATURAL RESOURCE
TRUSTEES'
Alex Barber
Commissioner's Office
KY Dept for Environmental
Protection
14 Reilly Road
Frankfort Office Park
Frankfort, KY 40601

Abraham Loudermilk
Tennessee Valley Authority
400 W. Summit Hill Drive
Knoxville, TN 37902

Andrea B. Perkins
U.S. Department of Energy
Federal Office Building
200 Administration Road
Oak Ridge, TN 37830

 Allen Robison
 US. Department of Interior
 Fish and Wildlife Service
 446 Neal Street
 Cookville, TN 38501

 STATE OF KENTUCKY
 Robert H. Daniell, Director
 Division of Waste Management
 KY Dept. for Environmental
 Protection
 14 Reilly Road
 Frankfort Office Park
 Frankfort, KY 40601

 Tuss Taylor (4 copies)
 UK/KDEP
 18 Reilly Road
 Frankfort Office Park
 Frankfort, KY 40601
Todd Mullins
KY Division of Waste Management
U.S. Department of Energy Site Office
5600 Hobbs Road
West Paducah, KY 42086

Steve Hampson
Cabinet for Human Resources
Radiation Control Laboratory
100 Sower Boulevard
Suite 108
Frankfort, KY 40601

Dr. John A. Volpe
Radiation Control Branch
Cabinet for Human Resources
275 East Main Street
Mail Stop HS2E-D
Frankfort, KY 40621

JVA
Ted Whitaker
Plant Manager
Shawnee Fossil Plant
7900 Metropolis Lake Road
West Paducah, KY 42086

Janet Watts
Manager of Environmental Affairs
5D Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801

Barry Walton
Office of General Council WT-10A
400 W. Summit Hill Dr.
Knoxville, TN 37902

U.S. ENRICHMENT
CORPORATION
David Hutcheson
U.S.E.C.
P.O. Box 1410
Paducah, KY 42001

U.S. GEOLOGICAL SURVEY
Tom Mesko
U.S. Geological Survey
9818 Bluegrass Parkway
Louisville, KY 40299-1906

 WEST KY WILDLIFE
 MANAGEMENTrAREA
 Charles W. Logsdon
 West Kentucky Wildlife
 Management Area
 Kentucky Department of Fish
 and Wildlife
 10535 Ogden Landing Road
 Kevil, KY 42053
  JEG.0197.27

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