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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
PARTI
DECLARATION
-------
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
-------
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
-------
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
-------
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
-------
PART 2
DECISION SUMMARY
-------
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.
-------
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
-------
'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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
;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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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)
-iitH Railroad
-X X- Fence
+ZK.
%I
DJaootn EM Team. 1998
Figure 2-8. Shallow Ground-Water Flow Map for Waste Area Group 7
18
-------
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'
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
33
-------
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
-------
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
-------
(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
-------
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
-------
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
-------
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
-------
(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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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)
-------
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)
-------
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
52
-------
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
-------
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
-------
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
-------
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)
-------
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)
-------
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)
-------
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)
-------
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
-------
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-FFCATBC
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.
-------
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
-------
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.
-------
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
-------
PART 3
RESPONSIVENESS SUMMARY
65
-------
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
-------
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
-------
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»
v-":-: ":'.;,.. :it:v,*,i,, b / t oii.p iMi-
CZD-«MftMi(eii
*iufr «r| r,( iO
1 '.)')/ 199U
jcr NOV DEC UAN FEU MAR AFJR MAY JUN JUL AUG srt' oci
-
,_
mmm
A
tn*
ZZI
\
A
i
;now
].
A
a
A
c
A
A
-------
"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
'"" ' i '' "
1'JSI/ l'J9U
JC1 NOV DEC LlAN FEB MAR AI'H MAY JUN ,IUL Allf, St 1' (1C. I
f T,ff
jnow
\
i
-------
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
-------
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
------- |