PB95-964018
EPA/ROD/R04-95/230
June 1995
EPA Superfund
Record of Decision:
USDOE Paducah Gas Diffusion Plant,
' Northeast Plume OU, Paducah, KY.
6/15/95
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DOE/OR/06-1356&D2
Record of Decision
for Interim Remedial Action
at the Northeast Plume,
Paducah Gaseous Diffusion Plant,
Paducah, Kentucky
June 1995
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CERTIFICATION
Document Identification: Record of Decision for Interim Remedial Action at the
Northeast Plume, Paducah Gaseous Diffusion Plant,
Paducah, Kentucky DOE/OR/06-1356&D2
I certify under penalty of law that I have personally examined and am familiar with the
information submitted in this application and all attachments and that, based on my inquiry
of those persons immediately responsible for obtaining the information contained in the
application, I believe that the information is true, accurate, and complete. I am aware that
there are significant penalties for submitting false information, including the possibility of
fine and imprisonment.
U. S. Department of Energy
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 Martin Marietta 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.
Page 1 of 2
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CERTIFICATION
Document Identification: Record of Decision for Interim Remedial Action at the
Northeast Plume, Paducah Gaseous Diffusion Plant,
Paducah, Kentucky DOE/OR/06-1356&D2
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.
Martin Marietta Energy Systems, Inc.
Co-Operator
c
etta Energy Systems, Ida. Date Signed
The Department of Energy has signed as "owner and operator" and Martin Marietta 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), Martin Marietta Energy Systems, Inc.'s,
representatives certify, to the best of their knowledge and belief, the truth accuracy and
completeness of the application for their respective areas of responsibility.
Page 2 of 2
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DOE/OR/06-1356&D2
Record of Decision
for Interim Remedial Action
at the Northeast Plume,
Paducah Gaseous Diffusion Plant,
Paducah, Kentucky
June 1995
Prepared by
Jacobs Engineering Group Inc.
175 Freedom Blvd. • Kevil, KY 42053
DE-AC05-93OR22028
Prepared for
U.S. Department of Energy
Environmental Management and Enrichment Facilities
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PREFACE
This Record of Decision for Interim Remedial Action at the Northeast Plume, Paducah Gaseous
Diffusion Plant, Paducah, Kentucky (DOE/OR/06-1356&D2) was prepared in
accordance with the requirements under both the Comprehensive Environmental
Response, Compensation and Liability Act, the Resource Conservation and Recovery
Act and Kentucky Revised Statutes 224.46. This work was performed under Work
Breakdown Structure 1.4.12.7.1.02.05.03 (Activity Data Sheet 5302). Publication of this
document follows the draft Federal Facility Agreement record of decision outline and
meets a Primary Document Deliverable milestone for the Paducah Gaseous Diffusion
Plant Environmental Management and Enrichment Facilities. This document provides
the United States Department of Energy, the United States Environmental Protection
Agency, and the Kentucky Department for Environmental Protection with a mechanism
for documentation of a formal decision for selecting an interim remedial action to
address the Northeast Plume.
11
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ACKNOWLEDGMENT
Jacobs Engineering Group Inc. under prime contract to the
United States Department of Energy developed this
document with the assistance of the Jacobs Environmental
Restoration Team members:
Geraghty and Miller, Inc.
Lockwood Greene Technologies, Inc.
PAI Corporation
Solutions to Environmental Problems
United Science Industries
University of Tennessee
Additional support was given to the team by Lockheed
Martin Energy Systems, Inc., a Lockheed Martin company.
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CONTENTS
PREFACE.... ....ii
ACKNOWLEDGMENT iii
TABLES vi
FIGURES vii
NOTATIONS viii
ACRONYMS AND ABBREVIATIONS viii
PART 1. DECLARATION
SITE NAME AND LOCATION
STATEMENT OF BASIS AND PURPOSE
ASSESSMENT OF THE SITE
DESCRIPTION OF SELECTED REMEDY
STATUTORY DETERMINATIONS
PART 2. DECISION SUMMARY 1
2.1 Site Name, Location, and Description ; 2
2.2 Site History and Enforcement Activities 2
2.3 Highlights of Community Participation 4
2.4 Scope and Role of Operable Unit '. 7
Response Action and the Site Management Strategy 7
Future Response Actions Associated with this Response Action 8
2.5 Summary of Site Characteristics 8
Hydrogeologic Characteristics 8
Operable Unit Characteristics 11
Contaminant Characteristics 11
2.6 Summary of Site Risks 13
2.7 Description of Alternatives 13
Alternative 1-No Action 14
Alternative 2-Hydraulic Plume Control 14
2.8 Summary of the Comparative Analysis of the Interim Alternative.... 19
Overall Protection of Human Health and the Environment 20
Compliance with Applicable or Relevant and Appropriate
Requirements ...„ 21
Long-Term Effectiveness and Permanence 21
Reduction of Contaminant Toxicity, Mobility, or Volume through
Treatment ...22
Short-Term Effectiveness 22
Implementability 22
Costs 22
State Acceptance 23
Community Acceptance 23
2.9 Selected Remedy 23
2.10 Statutory Determinations 28
Protection of Human Health and the Environment 28
Compliance with Applicable or Relevant and Appropriate
Requirements : 28
Applicable or Relevant and Appropriate Requirements for
Alternative 2—Hydraulic Plume Control 30
Chemical-specific applicable or relevant and appropriate
requirements 30
IV
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Location-specific applicable or relevant and appropriate
requirements 31
Action-specific applicable or relevant and appropriate
requirements 33
Cost effectiveness 47
Utilization of permanent solutions and alternative treatment
technologies 47
Preference for treatment as a principal element 47
2.11 Documentation of Significant Changes 47
PART 3. RESPONSIVENESS SUMMARY 48
3.1 Responsiveness Summary Introduction 49
3.2 Summary and Response to Local Community Concerns 50
3.3 Comprehensive Response to Specific Legal and
Technical Comments 50
APPENDIX
NORTHEAST PLUME INTERIM REMEDIAL DESIGN SCHEDULE
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TABLES
Table 1. Alternative 2—Cooling Towers and Treatability Studies
Cost Breakdown 24
Table 2. Alternative 2—Cooling Towers Cost Breakdown 25
Table 3. In Situ Ground Water Study Cost Breakdown 26
Table 4. Photocatalytic Oxidation Pilot Study Cost Breakdown ....27
Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and
Guidance for the Northeast Plume Hydraulic Plume Control 36
VI
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FIGURES
Figure 1. Paducah Gaseous Diffusion Plant Vicinity Map 3
Figure 2. Extent of Trichloroethene and Technetium-99 Contamination
in the RGA 5
Figure 3. Location of Former Kellogg Building and Leach Field 6
Figure 4. Schematic of Stratigraphic and Structural Relationships Near the
Paducah Gaseous Diffusion Plant 9
Figure 5. Locations of Treatment Equipment 15
Figure 6. Schematic of C-637 Water Cooling Towers 16
Figure 7. Photocatalytic Oxidation Treatment Schematic 17
Figure 8. In Situ Ground Water Treatment Schematic 18
vu
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NOTATIONS
The following list of acronyms and abbreviations is provided to assist in the review of
this document.
1,1-DCE
"Tc
235U
238U
AGO
ARAR
bgs
BMP
C.F.R.
CERCLA
CWA
DNAPL
DOE
EPA
ESA
Fed. Reg.
FWS
ft
gal
HAZMAT
HSP
HSWA
ICM
K.A.R.
K.R.S.
KDEP
km
KPDES
1
I/sec
m
MCL
rrg
mi
MW
NCP
NHPA
NWP
O&M
pCi/1
PGDP
pH
PHEA
PRAP
RCRA
ACRONYMS AND ABBREVIATIONS
1,1-dichloroethene
technetium-99
uranium-235
uranium-238
Administrative Order by Consent
applicable or relevant and appropriate requirement
below ground surface
best management practices
Code of Federal Regulations
Comprehensive Environmental Response, Compensation and Liability
Act of 1980
Clean Water Act
dense nonaqueous phase liquid
United States Department of Energy
United States Environmental Protection Agency
Endangered Species Act
Federal Register
Fish and Wildlife Service
foot (feet)
gallon(s)
hazardous materials training
health and safety plan
Hazardous and Solid Waste Amendments of 1984
interim corrective measures
Kentucky Administrative Regulations
Kentucky Revised Statutes
Kentucky Department for Environmental Protection
kilometer(s)
Kentucky Pollutant Discharge Elimination System
liter(s)
liters per second
meter(s)
maximum contaminant level
milligram(s)
mile(s)
monitoring well
National Oil and Hazardous Substances Pollution Contingency Plan
National Historic Preservation Act
nation wide permits
operation and maintenance
picoCuries per liter
Paducah Gaseous Diffusion Plant
hydrogen ion activity (inverse log)
Draft Results of the Public Health and Ecological Assessment, Phase II
proposed remedial action plan
Resource Conservation and Recovery Act of 1976
viu
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RD remedial design
RGA Regional Gravel Aquifer
ROD record of decision
SARA Superfund Amendments and Reauthorization Act of 1986
SHPO State Historic Preservation Officer
TBC to be considered
TCE trichloroethene
TV A Tennessee Valley Authority
UCRS Upper Continental Recharge System
UF6 uranium hexafluoride
U.S.C. United States Code
U.S.C.A. United States Code Annotated
USEC United States Enrichment Corporation.
VOC volatile organic compound
ug/1 micrograms per liter
IX
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PARTI
DECLARATION
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DECLARATION FOR THE RECORD OF DECISION
FOR INTERIM REMEDIAL ACTION
AT THE NORTHEAST PLUME
SITE NAME AND LOCATION
Northeast Plume
Paducah Gaseous Diffusion Plant
Paducah, Kentucky
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action for the Northeast
Plume at the Paducah Gaseous Diffusion Plant (PGDP) near Paducah, Kentucky, chosen
in accordance with the Resource Conservation and Recovery Act of 1976 (RCRA),
Kentucky Revised Statues (K.R.S.)/ the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986, and the National Oil and Hazardous
Substances Pollution Contingency Plan. This decision is based upon the administrative
record for this site.
With the participation of the Kentucky Department for Environmental Protection.
(KDEP), both the United States Environmental Protection Agency (EPA) and the United
States Department of Energy (DOE) entered into an Administrative Order by Consent
(ACO) effective November 23,1988, after the discovery of contamination in residential
wells north of the PGDP. The ACO was drafted under Sections 104 and 106 of
CERCLA. The DOE was issued a Kentucky Hazardous Waste Management Permit and
an EPA Hazardous and Solid Waste Amendments Permit July 16, 1991. The KDEP
portion of the RCRA permit was issued pursuant to Chapter 224 of the Kentucky
Revised Statutes by authority granted from the EPA to the KDEP to administer a RCRA
hazardous waste program. The EPA issued its portion of the RCRA permit pursuant to
the Hazardous and Solid Waste Amendments of 1984. Hereinafter the two permits will
be collectively referred to as the RCRA permits. The RCRA permits require the proper
treatment, storage, and disposal of waste; corrective action (i.e., cleanup); closure of
solid waste management units; and investigations of off-site contamination, including
ground water contaminated by prior activities at the PGDP. On May 31, 1994, the
PGDP was placed on the National Priorities List (effective date June 30, 1994). The
DOE is currently negotiating a Federal Facilities Agreement with the EPA and the
KDEP.
On July. 2,1993, the DOE was directed by the KDEP and the EPA to submit a workplan
to implement an interim measure at the Northeast Plume. This interim remedial action
will be initiated pursuant to the Interim Measure Provisions of PGDP's Kentucky
Hazardous Waste Permit issued by the KDEP, the Hazardous and Solid Waste
Amendments Permit issued by the EPA, and this record of decision (ROD). The
Kentucky Division of Waste Management concurs with the DOE and the EPA on the
selected interim action, in accordance with the requirements of the Kentucky Hazardous
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Waste Management Permit. The scope of this action warrants the incorporation of the
selected remedy into Kentucky's Hazardous Waste Permit. This ROD will serve as the
primary document for the modification to Kentucky's Hazardous Waste Permit. This
action will serve as a step toward comprehensively addressing the Northeast Plume.
In January 1994, the Interim Corrective Measures Workplan for the Northeast Plume was
submitted to the EPA and the Commonwealth of Kentucky. The workplan described the
investigation and provided the path forward for an interim remedial action or a final
remedial action for the contaminated ground water emanating from the northeast part of
the PGDP. However, information derived from the Groundwater Monitoring Phase IV
Investigation indicated the need to modify the workplan schedule. The rationale for this
modification includes: the discovery of multiple plumes and sources composing the
Northeast Plume including one area of acute trichloroethehe (TCE) ground water
contamination that emanates from the eastern margin of the plant and extends off DOE
property; a better definition of the plume's boundaries; and the long-term goal to
develop an efficient and cost-effective ground water strategy. Following an October 5,
1994, meeting between the DOE, the EPA, and the Commonwealth of Kentucky, the
decision was made to proceed with an interim remedial action for the high TCE
concentration ground water plume.
This action will retard the migration of the highest TCE concentration area within the
ground water plume emanating from the eastern margin of the PGDP. Ground water will
be extracted from at least one well located along Ogden Landing Road and pumped
through a pipeline to a treatment facility. The extraction well(s), pipeline, and the
treatment facility will be located on DOE property. Contaminated ground water will be
pumped at a rate, based on current ground water modeling, adequate to initiate
hydraulic control of the high TCE concentration plume which extends northeast of the
plant security fence. In addition, the extraction rate may be optimized in order to
minimize the movement of technetium-99 and other areas of acute TCE contamination
detected near the plant's eastern boundary. Concurrent with the interim remedial action
in Alternative 2 is a provision for two treatability studies which examine the following
innovative technologies: (1) photocatalytic oxidation of TCE, and (2) in situ treatment of
TCE-contaminated ground water.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances and constituents from the site, if
not addressed by implementing the response action selected in this ROD for interim
action, may present an imminent and substantial endangerment to public health,
welfare, or the environment in the future.
DESCRIPTION OF SELECTED REMEDY
The primary objective of this interim remedial action is to implement a first-phase
remedial action as an interim action to initiate hydraulic control of the high
concentration area within the Northeast Plume that extends outside the plant security
fence. Because ground water serves as a pathway for contamination to move to the
surrounding area, it has received the highest priority for undergoing prompt interim
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actions. The ground water at the PGDP will be addressed comprehensively in an
operable unit (hereinafter defined as the "Ground Water Integrator Operable Unit"). The
Northeast Plume is one part of the Ground Water Integrator Operable Unit. Final
remedial decisions for the Northeast Plume and the Ground Water Integrator Operable
Unit will be made through the remedial investigation and remedy selection process, after
the nature and extent of contamination in the ground water system(s) and the areas (i.e.,
source operable units) contributing contaminants to the ground water are more fully
understood.
The major components of the interim action remedy include:
• The contaminated ground water Will be extracted at a location in the
northern portion of the high TCE concentration area of the plume (greater
than 1,000 micrograms per liter of TCE). The contaminated ground water
will be pumped at a rate of approximately 100 gallons per minute to
initiate hydraulic control without changing ground water gradients enough
to cause adverse effects. During operation, this pumping rate may be
modified to optimize hydraulic containment, by adjusting flow from the
extraction wells, and to support subsequent actions.
• The extracted ground water will be collected and piped to a treatment
system prior to release to a Kentucky Pollutant Discharge Elimination
System permitted outfall. The treatment facility will consist of a sand
filter for removal of suspended solid materials, and utilization of the
PGDP's existing cooling towers for volatilization of contaminated ground
water. The chemicals of concern are TCE and 1,1-dichloroethene.
• Two treatability studies which include: (1) photocatalytic oxidation of
TCE-contaminated off-gas, and (2) in situ treatment of TCE-
contaminated ground water.
The KDEP and the EPA have participated in the development of this ROD, including
review and comment on the content of the document. All KDEP and EPA comments
issued to DOE have been incorporated into the ROD.
STATUTORY DETERMINATIONS
This interim action is protective of human health and the environment, complies with
federal and state applicable or relevant and appropriate requirements for the scope of
this limited action, is cost effective and is consistent with RCRA requirements. Although
this interim action is not intended to fully address the statutory mandate for
permanence and treatment to the maximum extent practicable, this interim action does
utilize treatment and, thus, is in furtherance of that statutory mandate. Subsequent
actions are planned to address the principal threats posed by the conditions at this site.
Because this remedy will result in hazardous substances and constituents remaining
onsite above health-based levels, a review will be conducted within five years after
commencement of the remedial action, and every five years thereafter, until a final
remedial alternative is selected and implemented. These reviews will be conducted to
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ensure that the selected remedy continues to provide adequate protection of human
health and the environment. Because this is an interim action ROD, review of this
operable unit and of this remedy will be ongoing as the DOE continues to develop final
remedial alternatives for the Ground Water Integrator Operable Unit.
Robert Dale Dempsey
Assistant Manager for Environmental Management
United States Department Of Energy
Da(e
Date
Jh\ John H. Hankinson, Jr.
' Regional Administrator
United States Environmental Protection Agency, Region IV
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PART 2
DECISION SUMMARY
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DECISION SUMMARY
2.1 Site Name, Location, and Description
The Paducah Gaseous Diffusion Plant (PGDP), located in western Kentucky, is an
active uranium enrichment facility owned by the United States Department of Energy
(DOE). Effective July 1, 1993, the DOE leased the plant's production facilities to the
United States Enrichment Corporation (USEC) which in turn contracted with Martin
Marietta Utility Services, Inc., to provide operation and maintenance services. Lockheed
Martin Energy Systems, Inc., manages the environmental restoration and waste
management activities for the DOE at the PGDP.
The PGDP is situated on a 1,457 hectare (3,600 acre) reservation approximately 6.4
kilometers (km) [4 miles (mi)] south of the Ohio River and about 16 km (10 mi) west of
Paducah, Kentucky (Figure 1). About 304 hectares (750 acres) of the reservation are
within a security area and buffer zone that have restricted access to the general public.
Beyond the DOE-owned buffer zone is the Western Kentucky Wildlife Management
Area which covers approximately 2,428 hectares (6,000 acres).
2.2 Site History and Enforcement Activities
Construction of the PGDP began in 1951, and operations began in 1952. The PGDP uses
gaseous diffusion to provide a physical separation process which allows for enrichment
of the uranium. Commercially produced uranium hexafluoride (UF6) is composed
primarily of uranium-238 (238U), and a small percentage of uranium-235 (235U). The
gaseous diffusion process is premised on the fact that UF6 with fissionable 235U is
slightly lighter than UF6 with 238U. Therefore, as the UF6 passes through the gaseous
diffusion plant's cascade system, separation of 235U from 238U takes place. This
separation results in enriched uranium (increased percentage of 235U). This enriched
uranium is then transported to USEC's enrichment facility in Piketon, Ohio, for further
enrichment.
The DOE is conducting cleanup activities at the PGDP. These cleanup efforts are
necessary to address contamination that has resulted from past operations at the plant.
Remedial activities are being conducted in consultation with the Kentucky Department
for Environmental Protection's (KDEP's) Division of Waste Management, the Radiation
Control Branch, and the United States Environmental Protection Agency (EPA).
In August 1988, volatile organic compounds (VOCs) and radionudides were detected in
ground water from residential wells north of the PGDP. In response to tlu's discovery,
the DOE and the EPA entered into an Administrative Order by Consent (ACO) under
Sections 104 and 106 of the Comprehensive Environmental Response, Compensation
and Liability Act of 1980 (CERCLA) (i.e., conduct a remedial investigation/feasibility
study). The DOE then implemented the PGDP Water Policy to reduce the current risk to
potential human exposure (i.e., potentially affected residence and businesses).
The CERCLA site investigations discovered trichloroethene (TCE)-contaminated ground
water within the Regional Gravel Aquifer (RGA) northeast of the plant. This plume is
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Wildlile Management Area
Paducah Gaseous Diffusion Plant (PGDP)
Department of Energy (DOE) Reservation
I | Municipality
Tennessee Valley Authority (TVA)
Ohio River
Municipal Water Supply Wells
(Kevil. KY and Metropolis. IL)
II
Missouri
Mississippi River
0123
Appioilmat* State (imtos)
. JL^ X mfen,^^
.j ._..._.._
Paducah Gaseous Diffusion Plant
Paducah. Kentucky
Figure 1. Paducah Gaseous Diffusion Plant Vicinity Map
OlJacobs ER TMm..t995
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referred to as the Northeast Plume, the DOE submitted an interim corrective measures
(ICM) workplan for the Northeast Plume to the EPA and the Commonwealth of
Kentucky in order to conduct an investigation and provide the path forward for an
interim remedial action as required by the Hazardous Waste Permit or a final remedial
action for the contaminated ground water emanating from the northeast part of the
PGDP.
Results of the Groundwater Monitoring Phase IV Investigation, published in the
Northeast Plume Preliminary Characterization Summary Report, delineated numerous
plumes in the RGA that coalesce to form the Northeast Plume. One of these plumes is a
zone of high TCE concentration [TCE concentrations exceeding 1,000 micrograms per
liter (ug/1)] that emanates from the eastern margin of the plant and extends off DOE
property (Figure 2). No technetium-99 ("Tc) contaminated ground water occurs above
the current calculated MCL of 900 pCi/1 within the portions of this plume that occur
outside the PGDP fence. Because mis TCE plume is migrating northeast toward the
eastern boundary of the area served by the PGDP Water Policy, a potential risk exists;
therefore, this interim remedial action is necessary.
One source of ground water contamination in the Northeast Plume is thought to be the
Kellogg Building leach field (Figure 3). The Groundwater Monitoring Phase IV
Investigation results indicate that this leach field may have been a significant contributor
to the zone of highest TCE-contaminated ground water emanating from the eastern
margin of the PGDP. Site investigations suggest the presence of free-phase TCE, a dense
nonaqueous phase liquid (DNAPL) in the subsurface material at the PGDP which
represents additional sources of ground water contamination.
2.3 Highlights of Community Participation
On March 12 and 13, 1995, a notice of availability was published in The Paducah Sun, a
regional newspaper, regarding the Proposed Remedial Action Plan for Interim Remedial
Action at the Northeast Plume. The Proposed Remedial Action Plan (PRAP) was released
to the public March 12, 1995. The PRAP was made available for public review at the
Paducah Public Library and the off-site Environmental Information Center located in the
West Kentucky Technology Park in Kevil, Kentucky. A public comment period was held
March 12 through April 25,1995.
Specific groups that received individual copies of the PRAP included the local PGDP
Neighborhood Council, Natural Resource Trustees, and the PGDP Environmental
Advisory Committee. An informal meeting was held with the PGDP Environmental
Advisory Committee on March 2, 1995. At this meeting, DOE personnel briefed the
Committee on the proposed action and solicited both written and verbal comments.
Phone calls and/or visits were made to various stakeholders, including neighbors and
representatives of environmental groups, to advise them of the public comment period
and briefly explain the PRAP. The PRAPs were mailed to those contacted. A response
to the comments received during the public participation period is included in the
Responsiveness Summary, which is part of this record of decision (ROD).
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A Sol Boring
K-8
EMrmttd TCE Plum* In RQA TCE i 1.000 ugA
EitlraMd TCE Plum* Soundly ti RQA i 8 wfl
EokniMd Te46 Plufm Bowidvy In RQA
_— . DOE Boundify
»- POOP FOTO*
Not*: This llgur* to tot lluMttv* purpOM* anty «nd «*
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Former,
Kellogg
Building
A Soil Boring
O Monitoring Well
Paducah Gaseous
Diffusion Plant Fence
0 2
Approximate Scale (feel)
ZjJacobs ER T»«m. 1995
Figure 3. Location of Former Kellogg Building and Leach Field
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The PRAP contained a notice of the availability for a public meeting to discuss the
Northeast Plume and proposed actions. However, no requests for a public meeting were
received.
This decision document presents the selected interim remedial action for the Northeast
Plume at the PGDP, chosen in accordance with CERCLA, as amended by the Superfund
Amendments and Reauthorization Acts of 1986 (SARA), the EPA and Commonwealth
of Kentucky permits issued under the Resource Conservation and Recovery Act (RCRA),
as amended by the Hazardous and Solid Waste Amendments of 1984 (HSWA),
Kentucky Revised Statute (K.R.S.) 224.46, and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). The decision for interim remedial action
at this site is based upon administrative record documentation.
2.4 Scope and Role of Operable Unit
Response Action and the Site Management Strategy
The PGDP presents unusually complex problems in terms of hazardous waste
management and environmental releases. The DOE's proposed strategy is to divide the
site into operable units grouped by source areas and Ground Water Integrator Operable
Units. Discrete response actions will be selected and implemented for each operable unit
to address the source areas (i.e., source operable units) and the integrator operable units
impacted by commingled releases from source operable units. Prioritization for
investigation and possible interim remedial actions has been assigned to each of the
integrator operable units and source operable units depending on their potential for
contributing to off-site contamination. Because ground water integrator units serve as
migration pathways that transport contamination from source operable units to off-site
receptors, they receive the highest priority for undergoing initial evaluation and interim
remedial actions.
Consistent with the DOE's strategy, this action is intended as an incremental step
toward addressing the Ground Water Integrator Operable Unit. The Northeast Plume
contributes to off-site ground water contamination that will continue to migrate and may
contaminate clean resources and potentially expose additional off-site receptors.
Implementation of this interim remedial action will: (1) initiate hydraulic control of the
high concentration area of TCE contamination within the Northeast Plume that is
migrating outside the eastern margin of the plant security fence, and (2) Monitor the
performance of this interim remedial action in order to track contaminant migration and
assess the system's performance prior to development of a final remedy.
This action can be implemented to monitor the performance of this interim remedial
action in order to track contaminant migration, and assess the system's performance
prior to development of the final remedy. Remedial investigations can continue to be
conducted for the remainder of the Northeast Plume and Ground Water Integrator
Operable Unit. This phased approach is consistent with EPA regulations and guidance
and in accordance with the Hazardous Waste Permit, which advises initiation of early
actions as soon as possible after a problem is identified for which an early action is
appropriate, and early actions should be coordinated with final remedies such that they
are the first phase of the overall remedial action.
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Future Response Actions Associated with this Response Action
The remedial action described by this ROD is not the final action for the Northeast
Plume. Following issuance of the ROD for this interim measure, additional remedial
investigations and/or treatability studies will be initiated to obtain data needed for
evaluating remedial alternatives to implement a final remedy which will provide
protection of human health and the environment. These remedial investigations and/or
treatability studies will be consistent with the requirements of both the draft Site
Management Plan and the draft Federal Facility Agreement being developed by the
DOE, the EPA, and the KDEP. This study may lead to a PRAP for a second interim
remedial action and/or a final action for the Northeast Plume.
Although a site investigation, public health and ecological assessment, and an
alternative evaluation were performed for the PGDP site as a whole, a final action
cannot be recommended until further characterization activities have been completed.
Before a final action can be recommended for the northeast portion of the Ground Water
Integrator Operable Unit/a baseline risk assessment must be completed, including an
ecological risk assessment. Additionally, a more complete characterization of the
Northeast Plume needs to be performed and the interaction of all source operable units
with the Ground Water Integrator Operable Unit must be better defined. Although
additional data will be needed before the selection of a final action, sufficient
information is available to support recommendation of the interim remedial action
presented in this document. This interim remedial action should not be inconsistent with
nor preclude implementation of any currently anticipated final remedy.
2.5 Summary of Site Characteristics
Hydrogeologic Characteristics
The subsurface geologic framework at the PGDP consists of Mississippian limestone
bedrock overlain by 105 meters (m) [344 feet (ft)] of unconsolidated sediments. Figure 4
presents a schematic cross section illustrating the conceptual geology at the site. The
following discussion focuses on the lithologies present in the area encompassing the
Northeast Plume.
The surficial deposits northeast of the plant consist of a 1.5 to 7.6 m (5 to 25 ft) thick
clayey silt of wind-blown origin called loess and alluvial flood deposits of sand and silt
which occur within the floodplain of Little Bayou Creek. The soils that formed in the
upper 1.2 m (4 ft) of the loess and alluvial deposits are silt loams of the Galloway,
Grenada, Henry, Loring, and Vicksburg Soil Series.
Underlying the surficial deposits to a depth ranging from 21 to 36 m (75 to 118 ft) below
ground surface (bgs) are the continental deposits of late Tertiary and Quaternary age.
These unconsolidated deposits, composed of an upward-fining sequence of gravels,
sands, silts, and clays, are divided into an upper and lower member. The upper
continental deposits consist of sand, silt, and day with occasional discontinuous gravel
lenses that range in thickness from 6 to 18 m (20 to 59 ft). The coarser textured, more
permeable lenses within the upper continental deposits have been informally grouped
into a ground water flow system referred to as the Upper Continental Recharge System
-------
SOUTH
Loess
McNMRY FORMATION
Tincatoou Fonrallon
/ tna
RuWtoZon*
NORTH
UPPER CONTINENTAL DEPOSITS
PORTERS CREEK CLAY Terrace
Slope
LOWER CONTINENTAL DEPOSITS
NOT TO SCALE
Figure 4. Schematic of Stratigraphic and Structural Relationships Near the Paducah Gaseous Diffusion Plant
(JlJacobs ER Team. 1995
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(UCRS). Ground water is found in the UCRS on both a perennial and a seasonal basis.
The ground water flow direction in the UCRS is ultimately downward into the
underlying aquifers.
The lower continental deposits consist of chert gravel and sand deposited in a high
energy, fluvial environment. Averaging 9 m (30 ft) thick, the deposits pinch out to the
south against a buried escarpment called the Porters Creek terrace (Figure 4). The base
of the deposits is an undulating, erosional surface created by scouring into the
underlying Porters Creek Clay and McNairy Formation. These channels were
subsequently filled with a complex sequence of gravel and sand. Discrete, elongate,
coarser grained, clean gravel units occur within the lower continental deposits forming
high permeability zones. One such unit, less than 305 m (1,000 ft) wide, extends about
1.6 km (1 mi) northeast of the plant along the southernmost edge of the Northeast
Plume.
Lithologies composing the lower continental deposits form a hydrogeologic unit
informally called the RGA. The RGA is the dominant ground water flow system in the
area due to its relatively high hydraulic conductivity and is the primary aquifer of
interest in this interim remedial action. Ground water recharge is by downward
percolation through the UCRS and via underflow through gravels located south of the
Porters Creek terrace. From the site, ground water flows northward toward the Ohio
River, which is the local base level for the system.
Discrete high permeability gravel units in the RGA, such as the one identified along the
southern edge of the Northeast Plume, may provide local pathways for ground water
and contaminant flow. The orientation of these pathways may help to explain the
current geometry of the Northeast Plume, because the interpreted trend of contaminant
migration contradicts the direction of apparent ground water movement derived from
potentiometric contours.
The lower continental deposits are directly underlain by the Porters Creek Clay and the
McNairy Formation at a depth ranging from 21 to 36 m (75 to 118 ft) bgs. The Porters
Creek Clay is a homogeneous clay that forms the buried terrace face along the southern
edge of the PGDP. South of the Porters Creek terrace, the Porters Creek Clay averages
26 m (85 ft) thick, and north of the terrace the clay ranges from 0 to 6 m (0 to 20 ft).
This clay is generally a low permeability barrier to ground water flow:
Interbedded and interfingering clay, silt, and fine sands, with some lignite and pyrite,
compose the Cretaceous McNairy Formation. This formation averages 68 m (223 ft) in
thickness in the Northeast Plume area. The McNairy Flow System is a hydrogeologic unit
that refers to the water-bearing sands within the McNairy Formation. Ground water
within the McNairy Flow System moves in a northerly direction toward discharge areas
along the Ohio River. Although the hydraulic conductivity of the McNairy sands is
several orders of magnitude less than that of the RGA gravels, there is a vertical
hydraulic connection between the two where they are in contact.
Directly underlying the McNairy Formation are the Cretaceous Tuscaloosa Formation
and the Mississippian rubble zone which together consist of rounded to subangular chert
and silicified limestone fragments up to 6 m (20 ft) thick (Figure 4). Bedrock beneath the
site occurs at approximately 105 m (344 ft) bgs.
10
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A three-dimensional ground water flow model was developed in July 1994 to simulate
the regional ground water flow in the vicinity of the PGDP. The DOE selected the
MODFLOW computer code, a publicly available ground water flow simulation program
developed by the United States Geological Survey. In order to simulate ground water
flow in the principal water-bearing units beneath the site on a regional scale/ the flow
model was constructed and calibrated to cover nearly 100 km2 (39 mi2). The regional
model simulates ground water flow in multiple water-bearing units consisting of the
UCRS, RGA, and the McNairy Flow System. A detailed presentation of the computer
model is presented in the Technical Memorandum for Interim remedial Action of the
Northeast Plume at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky (DOE/OR/06-
1318&D2)
Operable Unit Characteristics
The Kellogg Building leach field may have been a significant source for the high
concentration zone of ground water contamination emanating from the eastern margin of
the PGDP along the southern edge of the Northeast Plume. Located adjacent to the
plant's eastern security fence line (Figure 3), the former Kellogg Building functioned as a
pipe fabrication facility during the initial construction of the plant's cascade system. It is
believed that TCE may have been used extensively at this facility from 1951 to 1955
when the building was demolished. Drains in the former Kellogg Building are thought to
have emptied into a leach field southeast of the building. The Ground Water Monitoring
Phase IV Investigation discovered elevated concentrations of TCE in the ground water in
the vicinity of this leach field. As a result, the Kellogg Building leach field is considered a
potential source of TCE ground water contamination for the Northeast Plume.
Additional source units likely contribute to the high concentration zone of ground water
contamination emanating from the eastern margin of the PGDP along the southern edge
of the Northeast Plume. These sources are probably located inside the plant's security
fence to the southwest of the Kellogg Building leach field nearer to the origin of the high
concentration zone of TCE contamination shown on Figure 2. Identification and further
characterization of the significant source units contributing to this plume is necessary
before a final remedial action is taken.
Contaminant Characteristics
The contaminants of concern in the Northeast Plume outside the plant security fence are
TCE and 1,1-dichloroethene (1,1-DCE). Trichloroethene is the predominant contaminant
in the Northeast Plume. The Groundwater Monitoring Phase IV Investigation measured
TCE concentrations in ground water extracted from soil borings located outside the
plant security fence up to 2,856 ug/1, which exceeds the maximum contaminant level
(MCL) of 5 ug/1. A degradation product of TCE, 1,1-DCE, was detected above the
MCL of 7 ug/1 in the ground water sampled from two soil borings, D-9 and D-10,
located immediately east of the PGDP fence (Figure 2). The maximum concentration of
1,1-DCE measured was 15 ug/1.
Trichloroethene is a halogenated organic chemical used widely as a metal degreaser.
Although TCE is no longer used at the PGDP, past use and disposal practices resulted
in soil and ground water contamination. At the PGDP, the two major forms of TCE
contamination in the subsurface are: (1) dissolved phase in the ground water; and (2)
11
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free-phase product. Because it is relatively insoluble at high concentrations and has a
higher specific gravity than water, free-phase TCE is a DNAPL. When spilled, free-
phase TCE moves downward through the unsaturated zone and the aquifer under the
influence of gravity. Lateral spreading occurs as the free-phase TCE seeks out lower
capillary pressure, higher permeability pathways through heterogeneous subsurface
material. This DNAPL movement ceases when the volume of free product is insufficient
to overcome the capillary pressure of the subsurface material. Free-phase TCE,
distributed as residual blobs and ganglia, dissolves slowly into the ground water causing
continued contamination of the downgradient aquifer.
The radionuclide "Tc was introduced to the PGDP as a by-product of the reprocessing
of uranium. This radionuclide was probably introduced into the ground water from past
handling or disposal of TCE contaminated with "Tc and scrap metal contaminated
with "Tc. Ground water sampled from the RGA in four soil borings located immediately
east of the plant security fence detected "Tc contamination at concentrations up to 58
pCi/1. The extent of this "Tc contamination is shown on Figure 2 by the 30 pCi/1
isopleth, which represents the lowest concentration for which a coherent plume
boundary can be drawn. The 58 pCi/1 "Tc concentration is low with respect to the
aqueous regulatory concentration of 900 pCi/1 currently calculated from the MCL of 4
millirems per year. Since "Tc is a weak beta emitter, it has been classified by the EPA as
a Group A carcinogen (known human carcinogen).
Trichloroethene ground water contamination in the Northeast Plume outside the PGDP
security fence occurs primarily within the RGA. Isolated instances of TCE ground water
contamination occur in the McNairy Formation as well. Ground water in the RGA is
contaminated in a plume complex approximately 1.2 km (0.75 mi) wide that extends
about 2.4 km (1.5 mi) to the northeast of the plant (Figure 2). A narrow zone of high
TCE contamination, defined by the 1,000 ng/1 isopleth, occurs within the southernmost
portion of the plume complex. This high concentration zone originates within the plant,
emanates from the plant's eastern boundary in the vicinity of the Kellogg Building leach
field, and extends at least 1.6 km (1 mi) to the northeast, north of Ogden Landing Road
(Figure 2).
Both the distribution and internal stratigraphy of the RGA influence the distribution of
TCE contamination. The southeastern margin of the Northeast Plume is controlled by the
pinchout of the RGA against the Porters Creek terrace. The geometry of the high TCE
concentration zone corresponds to the trend of the coarser-grained, well-sorted gravel
unit located along the southern edge of the Northeast Plume. This gravel unit may
provide a preferred pathway for contaminant migration. The vertical distribution of
TCE within the high concentration zone varies with distance from probable source areas.
Trichloroethene concentrations increase toward the bottom of the aquifer as the distance
from source areas increases. In the vicinity of suspected source areas, such as the Kellogg
Building leach field, contamination is distributed more equally throughout the RGA.
The Groundwater Monitoring Phase IV Investigation discovered TCE-contaminated
ground water within sands of the upper part of the McNairy Formation. The frequency
and concentration of TCE decreases to the northeast of the plant. The highest
concentration reported from the McNairy Formation outside the plant security fence was
413 ng/1 from soil boring D 10 (Figure 2). The sand is laterally discontinuous, pinching
out 15.3 (50 ft) and 7.6 m (25 ft) to the east and west, respectively, of soil boring D 10.
12
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2.6 Summary of Site Risks
Based on the results of investigative activities at the Northeast Plume, the DOE, the
EPA, and the KDEP have decided that there is sufficient potential risk to the public and
environment to warrant this action. The principal goal of this interim remedial action is
to implement control measures which will mitigate migration of the contaminants.
Long-term exposure to TCE via ingestion or inhalation have produced increases in liver,
lung, and kidney tumors in mice and rats. Therefore, the EPA has classified TCE as a B2
carcinogen (probable human carcinogen). This classification is currently being reviewed
by the EPA.
A breakdown product of TCE is 1,1-DCE. The liver is the principal target organ of 1,1-
DCE toxicity. The EPA classifies 1,1-DCE as a Class C carcinogen (possible human
carcinogen).
Infiltration and downward migration of TCE may lead to ground water contamination
with ground water flow as the transport mechanism to off-site locations. The primary
routes of exposure include ingestion of contaminated ground water and dermal
absorption and inhalation through domestic uses of contaminated ground water. Other
exposure pathways, although less likely, include release of contaminated ground water
into surface water and sediment with subsequent incidental ingestion and dermal
absorption. Current data indicates that the Northeast Plume has not contaminated a
surface water body. Notwithstanding, this exposure pathway is less certain, as
significant dilution in surface water and loss of both TCE and 1,1-DCE due to
volatilization may result in concentrations in surface water and sediment that are of no
toxicological concern.
Risks associated with the off-site ground water have been reduced greatly by the
Paducah Gaseous Diffusion Plant Water Policy. The purpose of the Water Policy is to
eliminate exposure by restricting ground water use. Since municipal water is provided to
affected and potentially affected residences and businesses, there are currently no
significant risks to human health. If, in the future, the present water policy is no longer in
effect and institutional controls are ignored, area residents could be at risk from
exposure to contaminated ground water. Potential future exposures for an off-site
resident include ingestion of contaminated drinking water and inhalation of volatile
organic compounds during household water use.
The ACO states that monthly sampling of residential wells is required for those wells
potentially affected by the contaminant plume. In accordance with the ACO under
Sections 104 and 106 of CERCLA, residential wells are sampled on a routine basis for
pH, temperature, turbidity, TCE, "Tc, and gross alpha and beta activities. The ACO
will not cover future off-site residents.
2.7 Description of Alternatives
The screening and evaluation process identified one remedial alternative that will
quickly and effectively reduce risk by retarding the migration of contamination from the
Northeast Plume.
13
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Alternative 1 - No Action
Pursuant to 40 C.F.R. § 300.430(e)(6), the DOE is required to consider a no action
alternative. This alternative is useful as a baseline for comparison between potential
alternatives. Under this alternative, no further action would be taken with regard to the
Northeast Plume.
Alternative 2 - Hydraulic Plume Control
The hydraulic plume control interim remedial action consists of one or more extraction
well(s) to be placed near the north end of the high concentration area of the Northeast
Plume located near Ogden Landing Road. This action will initiate hydraulic control of
the high concentration area of the Northeast Plume and mitigate the concentrations of
TCE in the ground water. The wells are expected to be located on DOE property (Figure
5) within the high TCE concentration isopleth of the plume. Extracted ground water will
be pumped through a pipeline at approximately 6.3 liters per second (I/sec) (100
gallons per minute) to a water treatment facility. The treatment facility will consist of a
sand filter for removal of suspended solid materials, and utilization of the PGDP's
existing cooling towers for volatilization of TCE-contaminated ground water (Figure 6).
The sand filter may be located near the PGDP's eastern security fence. The cooling tower
is located on DOE property within the security fence (Figure 5). The pipeline will be
placed under existing gravel roads or within created ditches immediately adjacent to
these roads. Treated water will be discharged to a Kentucky Pollutant Discharge
Elimination System (KPDES) permitted outfall along the western boundary of the
PGDP.
Data gathered during the Northeast Plume investigations and operations will be used to
optimize the remedial action by adjusting flow rates from the extraction well(s) to
control the plume to the maximum extent possible while minimizing adverse effects.
Hydraulic plume control is consistent with the EPA's Office of Solid Waste and
Emergency Response Directive 9283.1-03 and the Hazardous Waste Permit which sets a
policy for remediation of aqueous contaminant plumes. The directive advises that the
plume should be contained early, that initiation of early actions should take place as
soon as possible after a problem is identified for which an early action is appropriate,
and that early actions should be coordinated with final remedies such that they are the
first phase of the overall remedial action. The directive further advises that remedial
actions for contaminated ground water should be implemented in a phased approach.
Two innovative pilot-plant studies will be conducted during this interim remedial action.
The studies will evaluate technology performance and cost effectiveness for potential
full-scale implementation. The two innovative pilot-treatment studies are:
(1) Photocatalytic oxidation treatment of off-gas; and
(2) In situ treatment of TCE-contaminated ground water.
Photocatalytic oxidation treatment of off-gas is an innovative technology (Figure 7).
Reduction of TCE by this technology has been demonstrated, but is unproved at the
PGDP. Site-specific information is required in order to determine an appropriate cost
estimate and design criteria of equipment for a future full-scale operation. A small side
14
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Location 01
Ketog BuHdng
Leach Field
In Situ Ground Water
Treatment Location
EMmMTCEPkm
Boundary In «OA* Snort
---- DOEBoundvy
Piopo««d Ptp» Rouli lo Tuoranl F«o«y
1000' 2000'
Not«: Thii flgum I* to MamMw purpam only and rtnuU
noi b* IfMrpvM •* pr*d» kx«fcx» e« m» plumo.
Apptortnrti Sa^» (mt)
Figure 5. Locations of Treatment Equipment
15
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Fan Rings
Onlribution Pipe
Distribution Deck
I
Cross section of
heat exchanger
lor process
rectrculation
cooling water
r- FB
- (Packing. Media)
FiO —>
(Packing Media) ~>
C-337 Process Building
IDJMCbl ER TMm. IMS
Figure 6. Schematic of C-637 Water Cooling Towers
BowdowntoC-616
andOmlalOOl
-------
Innovative Pilot Demonstration Using Photocatalytic Oxidation for Off-Gas Treatment
Operational
Data Acquisition
Scrubber
Photoreactors
Off-Gas
Off-Gas
From
In Situ
Ground Water
Treatment
Figure 7. Photocatalytic Oxidation Treatment Schematic
(BJacobt EH TMm. 1995
stream volume will be varied in order to conduct the pilot study, thus testing the
photocatalytic oxidation performance. A three-month pilot demonstration is expected.
Benefits of this technology include the following:
• Complete destruction of VOCs before discharge of off-gas;
• Low operation and maintenance (O&M) cost; and
• Compatible with in situ treatment technologies.
The in situ ground water treatment well is also an innovative treatment technology. This
technology is appropriate for demonstration at the PGDP (Figure 8). If successful, this
technology has several potential benefits, including:
• Reduction of waste generated during the remedial action;
• No contaminated water transfer to the surface; therefore, no treatment
cost, disposal, or associated permits are required;
• Less intrusive in environmentally sensitive areas within the PGDP where
logistics limit remedial alternatives;
• No regional lowering of the ground water level, thus reducing the effect on
the regional flow system;
• The entire thickness of the aquifer may be included in circulation (radius
of influence); and
• Lower cost than conventional pump and treat technology.
17
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Blower
Ambient Air
Monitoring Wells
Stripping Zone
(Bioreactor)
Ground Water
Circulation
Ground Water
Circulation
ZUieota ER Turn. 1995
Not to scale
Figure 8. In Situ Ground Water Treatment Schematic
18
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One in situ ground water treatment well is proposed for this two-year pilot study. If this
technology is determined viable for operation, wells located across the high
concentration portion of the plume can remediate contaminants which migrate to the
wells, or the wells can be located near source area(s) for mass reduction. Other
objectives include determining if the technology reduces TCE concentrations in ground
water below remedial goal objectives or MCLs, estimates of the radius of influence of the
treatment system, operating cost associated with the technology, and the time for
remediation to acceptable levels to occur. A secondary objective would be to couple this
technology with photocatalytic oxidation as the off-gas treatment, since photocatalytic
oxidation could provide complete destruction of off-gas from the well. Additional
secondary objectives include: documentation of selected aquifer characteristics that may
be affected by oxygenation and recirculation of treated ground water; documentation of
off-gas concentrations from the well bore; and documentation of other operating
parameters as needed in the design phase.
2.8 Summary of the Comparative Analysis of the Interim Alternative
This section provides the basis for determining which alternative (1) meets the threshold
criteria of overall protection of human health and the environment, and complies with
applicable or relevant and appropriate requirements (ARARs) and is consistent with the
Hazardous Waste Permit; (2) provides the best balance between effectiveness and
reduction of toxicity, mobility, or volume through treatment, implementability, and cost;
and (3) satisfies state and community acceptance criteria. Because of the limited scope
of this interim remedial action, the comparative analysis focuses on the selected remedy,
while considering the No Action Alternative under the appropriate criteria.
CERCLA requires nine criteria be used for evaluating the expected performance of
remedial actions. The nine criteria are identified below and the interim remedial action
has been evaluated on the basis of these criteria.
1. Overall protection of human health and the environment. This requires that
the 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. The EPA's goal is
to return usable ground water to its beneficial use within a time frame
that is reasonable given the particular circumstances of the site.
2. Compliance with ARARs. The alternatives must be assessed to determine if
they attain compliance with ARARs of both state and federal law.
3. Long-term effectiveness and permanence. This focuses on the magnitude and
nature of the risks associated with untreated waste and/or treatment
residuals. This criterion includes consideration of the adequacy and
reliability of any associated engineering controls, such as monitoring and
maintenance requirements.
4. Reduction of contaminant toxicity, mobility, or volume through treatment.
This includes the degree to which the alternative employs treatment to
reduce the toxicity, mobility, or volume of the contamination.
19
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5. Short-term effectiveness. This includes the effect of implementing the
alternative relative to the potential risks to the general public, potential
threat to workers, and the time required until protection is achieved.
6. Implementability. These are potential difficulties associated with
implementing the alternative. This may include the technical feasibility,
administrative feasibility, and the availability of services and materials.
7. Cost. The costs associated with the alternatives include the capital cost,
annual operation and maintenance (O&M), and the combined net present
value.
8. State acceptance.
9. Community acceptance. This includes the consideration of any formal
comments by the community to the PRAP for interim remedial action.
The criteria listed above are categorized into three groups. The first and second criterion
are threshold criteria. The chosen final alternative must meet the threshold criteria to be
eligible for selection. The five primary balancing criteria include criteria three through
seven. The last two criteria are termed the modifying criteria. The modifying criteria were
evaluated following issuance of the PRAP for public review and comment.
Overall Protection of Human Health and the Environment
Alternative 1, No Action, would not initiate hydraulic plume control. The purpose of
including the No Action Alternative is to provide a baseline to which other alternatives
can be compared. Existing controls such as ground water monitoring, alternate water
supply, and agreements on water-use restrictions would be continued. The water policy
represents only institutional controls and does not meet EPA's bias for permanent
solutions involving treatment of the contaminated media, (i.e., It does not return the
ground water to beneficial use.) These controls include:
• Public awareness programs that advise local residents of site conditions
and potential problems resulting from ground water contamination;
• An alternative water supply for residents whose wells have been
affected. Also, an action memorandum was approved by the EPA to
extend a West McCracken County Water District line to all residents
whose wells have the potential to be contaminated in the future. The
water policy requires that these residents sign an agreement not to use
their wells. Construction of the pipeline (water main) has recently been
completed; and
• The annual site environmental monitoring program.
Alternative 2, Hydraulic Plume Control, will initiate an effort toward returning the
ground water to beneficial use by controlling the high concentration area of the plume.
Future site risk will be reduced since ground water will be extracted and treated. This
20
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alternative alone is not intended to remediate the plume to MCLs; however, water that
is extracted will be treated to meet compliance concentrations.
Alternative 2 would accomplish the interim remedial action objectives of initiating
hydraulic control of the plume and initiating risk reduction along with facilitating
collection of data needed for selecting subsequent and future final remedial actions. It
would also reduce future risks associated with continued migration of the high
concentration area of the plume and resulting exposures. This alternative features
treatment of extracted ground water to meet effluent discharge limits which meets EPA's
preference for treatment, and subsequently is preceding toward the preference for a
permanent solution. Successful control of the plume in combination with existing
controls (alternate water supply, monitoring, etc.) ensures protection during the period
of the interim response. However, the risk cannot be quantified until a baseline risk
assessment has been conducted at the Northeast Plume.
Compliance with Applicable or Relevant and Appropriate Requirements
An alternative must meet this threshold criterion to be eligible .for selection. Alternative 1
would not provide compliance with ARARs since migration of ground water
contamination would not be reduced. Alternative 2 would provide compliance with
ARARs. A detailed description of ARARs for the selected remedy is presented in
Section 2.10 of this ROD.
On July 2,1993, the DOE was directed by the KDEP and the EPA to submit a workplan
to implement an interim measure at the Northeast Plume. This interim remedial action
will be initiated pursuant to the Interim Measure Provisions of PGDP's Kentucky
Hazardous Waste Management Permit issued by the KDEP, the Hazardous and Solid
Waste Amendments Permit issued by the EPA, and this ROD. The Kentucky Division of
Waste Management concurs with the DOE and the EPA on the selected interim action,
in accordance with the requirements of the Kentucky Hazardous Waste Management
Permit. The scope of this action warrants the incorporation of the selected remedy into
the Commonwealth's Hazardous Waste permit. This ROD will serve as the primary
document for the modification to the Commonwealth's Hazardous Waste permit. This
action will serve as a step toward comprehensively addressing the Northeast Plume.
In ROD documentation, the CERCLA requires that the RCRA be listed as an ARAR. By
doing this, it in no way limits, takes away, or negates the Commonwealth of Kentucky's
RCRA authority at the site.
Long-term Effectiveness and Permanence
The No Action Alternative could cause potential health and environmental impacts to
occur through a future exposure scenario. The extraction and treatment system is
intended as an interim remedial action until sufficient information can be accumulated to
formulate the final solution for this integrator operable unit. This action is intended to be
consistent and appropriate with the final remedial action. The effectiveness and
efficiency of this system will be evaluated for potential final actions.
21
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Reduction of Contaminant Toxicity, Mobility, or Volume through Treatment
Alternative 2, Hydraulic Plume Control, would reduce the mobility and volume of the
contaminated ground water, and will reduce the toxicity within the extracted and
treated water until a final action is taken. The volume of contaminant reduction will
depend upon the length of time the interim remedial action is implemented. This action
will be reviewed within five years after initiation. Construction is scheduled to be
completed within two years, with approximately three years of operation and
maintenance.
Short-Term Effectiveness
Alternative 1, No Action, would not entail new controls. Therefore, no additional
impacts to short-term human health and the environment would be encountered.
Alternative 2, Hydraulic Plume Control, will not pose a threat to either nearby
communities or the workers associated with the operation and maintenance of the
treatment system. Workers associated with the construction and operation of the source
control systems will abide by the requirements of a site-specific health and safety plan
(HSP). The HSP will be prepared as part of the bid package and submitted to the
selected contractor prior to the award of the project. Prior to implementation of this
interim remedial action, the EPA and the KDEP will be afforded the opportunity to
review the HSP. The draft HSP will be modified by the contractor to reflect pertinent
comments submitted by the regulatory agencies. Standard engineering controls would
also be implemented to mitigate any potential environmental impacts. Construction
start-up for the alternative is possible within 15 months of the signature of this interim
remedial action ROD and could be effective until a final ROD is implemented.
Implementability
Alternative 1, No Action, could be readily implemented. Additional technical and
administrative procedures would not be conducted other than those currently conducted
for the alternative water supply and ground water monitoring.
Alternative 2, Hydraulic Plume Control, is technically and administratively feasible.
Extraction wells and monitoring wells can be readily constructed using standard
equipment and technologies. Numerous services and materials for construction are
readily available, and the likelihood of competitive bids would be expected.
Administrative difficulties are not expected to be encountered when fulfilling the
necessary procedures for obtaining surface water discharge approval.
Costs
Cost estimates for each alternative are based upon the Northwest Plume Interim ROD
and contract information and are expressed in terms of 1995 dollars. The costs for
22
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Alternative 2, Hydraulic Plume Control, and the two treatability studies are listed
below:
• Present worth cost: $5,291,000;
• Capital cost: $4,851,000; and
• O&M costs (3 years combined): $1,283,000.
A cost estimate is included for the interim remedial action. The estimate is based upon
feasibility-level scoping and is intended to aid in making project evaluations. The
estimate has an expected accuracy of +50 to -30% for the proposed scope of the action.
Alternative 2—Cooling Towers and Treatability Studies Cost Breakdown can be found
in Table 1; Alternative 2—Cooling Towers Cost Breakdown, Table 2; In Situ Ground
Water Study Cost Breakdown, Table 3; and Photocatalytic Oxidation Pilot Study Cost
Breakdown, Table 4.
State Acceptance
The Northeast Plume Technical Memorandum, PRAP, and draft ROD were issued for
review and comment to both the KDEP and the EPA. The KDEP concurs with this
action, consistent with the requirements of the Commonwealth of Kentucky's Hazardous
Waste Permit.
Community Acceptance
No groups and organizations opposed this interim remedial action. Community
response to the alternatives is presented in the responsiveness summary which
addresses comments received during the public briefing and the public comment period.
2.9 Selected Remedy
Based upon the evaluation of the alternatives in regard to the nine criteria, the remedy
jointly selected by the EPA, the KDEP, and the DOE is Alternative 2, Hydraulic Plume
Control. The DOE will prepare a detailed design of the treatment unit in accordance
with the requirements of the ROD for this interim remedial action, and in accordance
with the ICM Workplan for the Northeast Plume. The ICM Workplan, pursuant to the
PGDP's Kentucky Hazardous Waste Management Permit and EPA HSWA permit, will
be approved at the same time as this ROD. The selected remedy will be included in the
Kentucky Hazardous Waste Permit by way of a permit modification, as a corrective
action requirement.
The selected remedy will consist of the following elements at a minimum:
(1) Extraction of contaminated water from a well field location on DOE
property near the northern portion of the high concentration area of the
off-site Northeast Plume;
(2) Treatment of extracted ground water contaminated with TCE and 1,1-
DCE;
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Table 1. Alternative 2—Cooling Towers and Treatability Studies Cost Breakdown*
Pro] ect Cost Item Costs ($ Thousands)6
Capital Costs
Direct Cost
Monitoring & Extraction Wells 738
Transfer Piping 186
Sand Filter Building 364
In Situ Treatability Study 493
Photocatalytic Oxidation Pilot Study 96
Waste Management 283
Misc. Support & Training 98
Construction Management 547
Direct Total Cost 2805
Indirect Cost
Engineering Expenses 851
Administration Costs 514
Contingency (Indirect & Direct) 681
Indirect Total Cost 2046
Total Capital Cost 4851
O&M Costs
O&M Costs (1st year):
Administration Costs 164
Sampling, Analysis & Operations 228
1st year O&M Costs 392
O&M Costs (2nd year)
Administration Costs 190
Sampling, Analysis & Operations 206
2nd year O&M Costs 396
O&M Costs (3rd year)
Administration Costs 97
Sampling, Analysis & Operations 145
3rd year O&M Costs 242
Total O&M Contingency 253
Total O&M Costs 1283
Total Project Cost in Escalated Dollars 6134
Present Worth Costs
Total Alternative 2 Present Worth Costs: 5291
[Per Building Life Cycle Cost Analysis
(Version 4.20-95)]
* Per Guidance Document EPA/540/G-89/004, Guidance for Conducting Remedial Investigations
and Feasibility Studies under CERCLA
b Escalated (average 3.7% escalated rate per DOE Guidance)
24
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Table 2. Alternative 2—Cooling Towers Cost Breakdown*
Project Cost Item Costs ($ Thousands)1*
Capital Costs
Direct Cost
Monitoring & Extraction Wells 738
Transfer Piping 186
Sand Filter Building 364
Waste Management 108
Misc. Support & Training 98
Construction Management 395
Direct Total Cost 1889
Indirect Cost
Engineering Expenses 629
Administration Costs 432
Contingency (Indirect & Direct) 498
Indirect Total Cost . 1559
Total Capital Cost 3448
O&M Costs
O&M Costs (1st year):
Administration Costs 90
Sampling, Analysis & Operations . 139
1st year O&M Costs 229
O&M Costs (2nd year)
Administration Costs 95
Sampling, Analysis & Operations 145
2nd year O&M Costs . 240
O&M Costs (3rd year)
Administration Costs • 97
Sampling, Analysis & Operations • 145
3rd year O&M Costs 242
Total O&M Contingency 177
Total O&M Costs 888
Total Project Cost in Escalated Dollars 4336
Present Worth Costs
Total Alternative 2 Present Worth Costs: 3791
[Per Building Life Cycle Cost Analysis
(Version 4.20-95)]
Per Guidance Document EPA/540/G-89/004, Guidance for Conducting Remedial Investigations and
Feasibility Studies under CERCLA
' Escalated (average 3.7% escalated rate per DOE Guidance)
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Table 3. In Situ Ground Water Study Cost Breakdown*
Project Cost Item Costs ($ Thousands)1*
Capital Costs
Direct Cost
Waste Management 175
In Situ Treatability Study 493
Construction Management 152
Direct Total Cost 820
Indirect Cost
Engineering Expenses 176
Administration Costs 45
Contingency (Indirect & Direct) 156
Indirect Total Cost . 377
Total Capital Cost 1197
O&M Costs
O&M Costs (1st year):
Administration Costs 61
Sampling, Analysis & Operations 58
1st year O&M Costs 119
O&M Costs (2nd year)
Administration Costs 95
Sampling, Analysis & Operations 61
2nd year O&M Costs 156
Total O&M Contingency ; 70_
Total O&M Costs 34T
Total Project Cost in Escalated Dollars 1542
Present Worth Costs
Total Alternative 2 Present Worth Costs: 1346
[Per Building Life Cycle Cost Analysis
(Version 4.20-95)]
Per Guidance Document EPA/540/G-89/004, Guidance for Conducting Remedial Investigations and
Feasibility Studies under CERCLA
Escalated (average 3.7% escalated rate per DOE Guidance)
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Table 4. Photocatalytic Oxidation Pilot Study Cost Breakdown*
Project Cost Item Costs ($ Thousands)1*
Capital Costs
Direct Cost
Photocatalytic Oxidation Pilot Study 96
Direct Total Cost 96_
Indirect Cost
Engineering Expenses . 46
Administration Costs 37
Contingency (Indirect & Direct) . 27
Indirect Total Cost 110
Total Capital Cost . 206
O&M Costs
O&M Costs (1st year):
Administration Costs 13
Sampling, Analysis & Operations 31
(3 months) O&M Costs 44_
Total O&M Contingency 6
Total O&M Costs 50
Total Project Cost in Escalated Dollars 256
Present Worth Costs
Total Alternative 2 Present Worth Costs: 227
[Per Building Life Cycle Cost Analysis
(Version 4.20-95)]
a Per Guidance Document EPA/540/G-89/004, Guidance for Conducting Remedial Investigations and
Feasibility Studies under CERCLA
b Escalated (average 3.7% escalated rate per DOE Guidance)
(3) Surface discharge; and
(4) Demonstration of two innovative pilot treatment studies.
Contaminated water will be extracted from one or more wells located near the northern
end of the high concentration area. Water will be pumped through underground piping to
the treatment unit. Water will likely be pumped to a sand filter to remove suspended
solids and then be pumped through an existing cooling tower for the removal of VOCs.
Treated water will be discharged to a KPDES permitted surface water outfall: The DOE
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will evaluate the concentrations of TCE, TCE degradation products, and "Tc in the
effluent from the treatment system and monitoring wells to ensure that this interim
remedial action is protective of both human health and the environment.
Current "Tc concentrations in the Northeast Plume outside the plant's security fence are
at levels which do not pose a potential threat to human health or the environment upon
surface discharge. Technetium-99 was detected at a maximum concentration of 58
pCi/1. However, this concentration is well below the calculated concentration allowed
for drinking water (900 pCi/1). Influent water (e.g., extracted ground water) will be
sampled for "Tc during the interim action to assure that threshold limits are not
exceeded. Routine sampling will be performed for "Tc in ground water monitoring wells.
The monitoring system will include those wells installed as part of this interim remedial
action and existing monitoring wells located upgradient of the extraction well field.
These monitoring wells should provide sufficient notification for institution of corrective
measures should signification concentrations of this radionuclide be detected.
The TCE off-gas concentrations are not expected to exceed the Commonwealth of
Kentucky air regulations (401 K.A.R. 63:022). Assuming ground water concentrations of
1,000 |ig/l, approximately 6.3xlO-* kilograms per second (0.05 pounds per hour) of TCE
will be released to the atmosphere. This level is less than the regulatory significant level,
with height correction. Therefore, no off-gas treatment is proposed.
2.10 Statutory Determinations
The DOE, the EPA, and the KDEP concur that the selected remedy will satisfy the
statutory requirements of K.R.S. 224.46-530 and CERCLA 121(b) and the Hazardous
Waste Permit for providing protection of human health and the environment, attaining
ARARs directly associated with this action, being cost effective, utilizing alternative
treatment technologies to the maximum extent practicable, and exhibiting a preference
for treatment as a principal element.
Protection of Human Health and the Environment
The interim remedial action remedy initiates protection of human health for PGDP
employees and the public through mitigation of contaminants from the Northeast Plume
until a final action is determined. The remedy also provides protection for the
environment by providing treatment of the effluent prior to discharge into the KPDES
outfall, and effective management of all residual wastes generated during
implementation of the action.
Compliance with Applicable or Relevant and Appropriate Requirements
Congress specified in the CERCLA § 121 that remedial actions for cleanup of hazardous
substances and constituents must comply with requirements, criteria, standards, or
limitations under federal or more stringent state environmental laws that are applicable
or relevant and appropriate to the hazardous substances and constituents or
circumstances at a site. Applicable or relevant and appropriate requirements are utilized
to ensure the protection of human health and the environment.
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In ROD documentation, the CERCLA requires that the RCRA be listed as an ARAR. By
doing this, it in no way limits, takes away, or negates the Commonwealth of Kentucky's
RCRA authority at the site.
The following is an explanation of the terms used throughout this document:
Applicable requirements are "those cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under federal
environmental or state environmental or facility siting laws that specifically address a
hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstance 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 or state environmental or facility siting laws that, while not
applicable to a hazardous substance, pollutant, contaminant, remedial action, location,
or other circumstance at a CERCLA site, 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).
Chemical-specific requirements are usually "health- or risk-based numerical values or
methodologies which, when applied to site-specific conditions, result in the
establishment of numerical values" (53 Fed. Reg. 51437, December 21, 1988). These
values establish the acceptable amount or concentration of a chemical that may remain
in, or be discharged to, the ambient environment.
Location-specific requirements "generally are restrictions placed upon the concentration
of hazardous substances and constituents or the conduct of activities solely because
they are in special locations" (53 Fed. Reg. 51437, December 21,1988). Some examples
of special locations include floodplains, wetlands, historic places, and sensitive
ecosystems or habitats.
Action-specific requirements "are usually technology- or activity-based requirements or
limitations on actions taken with respect to hazardous wastes or requirements to
conduct certain actions to address particular circumstances at a site" (53 Fed. Reg.
51437, December 21, 1988). Selection of a particular remedial action at a site would
invoke the appropriate action-specific ARARs that may specify particular performance
standards or technologies, as well as specific environmental levels for discharged or
residual chemicals.
Requirements under federal or state law may be either applicable or relevant and
appropriate to CERCLA cleanup actions, but not both. However, if a requirement is not
applicable it must be both relevant and appropriate for compliance to be necessary. In
the cases where both a federal and a state ARAR are available, or where two potential
ARARs address the same issue, the more stringent regulation must be selected. However,
CERCLA § 121(d)(4) provides several ARAR waiver options that may be invoked,
providing that the primary requirement of protection of human health and the
environment is met.
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The CERCLA remedial actions conducted entirely onsite, as defined in 40 C.F.R. §
300.5, must comply with the substantive provisions of laws and regulations but not
procedural or administrative requirements. Substantive requirements pertain directly to
the actions or conditions at a site, while administrative requirements pertain to
permitting, documenting, and processing regulatory review and decision making.
Response actions conducted entirely onsite are not required to obtain federal, state or
local permits. In order to ensure that CERCLA response actions proceed as rapidly as
possible, the EPA has re-affirmed this position in the final NCP (55 Fed. Reg. 8756,
March 8, 1990).
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 Superfund remedies. In
addition, ARARs do not exist for every chemical or circumstance likely to be found at a
Superfund 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 (55 Fed. Reg. 8745, March 8, 1990).
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. This other
information is to be considered (TBC) guidance and may be used when developing
CERCLA remedies. The TBC guidance generally falls within three categories: (1) health
effects information; (2) technical information on how to perform or evaluate
investigations or response actions; and (3) policy.
Response actions under the NCP will comply with the provisions for response action
worker safety and health in 29 C.F.R. 1910.120 (40 C.F.R. § 300.150). The Occupational
Safety and Health Act and its corresponding regulations are applicable to the PGDP.
These standards are designed to protect the health and safety of workers. However,
these standards must be complied with although they are not ARARs.
Applicable or Relevant and Appropriate Requirements for Alternative 2—Hydraulic
Plume Control
Chemical-specific applicable or relevant and appropriate requirements
Discharges of the treated ground water into an outfall must comply with Kentucky's
antidegradation statute. Surface waters of Kentucky must be safeguarded against the
creation of any new pollution (401 K.A.R. 5:029 § 2). Furthermore, where the quality of
surface water exceeds that which is necessary to support reproduction of fish and
wildlife, and human recreation in and on the water, the quality shall be maintained and
protected. This is an applicable standard.
Treated water discharged into an outfall, must comply with 401 K.A.R. 5:031 and
5:050. These requirements are applicable, and the substantive requirements will be
implemented. The PGDP has in place a KPDES permit (KY 0004049). This permit
incorporates Clean Water Act (CWA) requirements under Kentucky regulations and
establishes limitations for various chemicals including TCE at KPDES outfalls.
Concentrations of TCE may not exceed .081 mg/1 at. the outfall. The KPDES permit
requires the compliance point to be at the nearest accessible point after final treatment,
but prior to actual discharge to or mixture with receiving waters. Under 401 K.A.R.
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5:029, the terms "surface water" or "receiving waters" do not include ditches used for
water treatment which are under valid easement by a permitted discharger. In addition,
pursuant to 401 K.A.R. 5:070, if any chemical will be discharged through a KPDES
outfall that is not regulated by the permit, the permit must be modified to include the
chemical.
Maximum contaminant levels under the Safe Drinking Water Act (40 C.F.R. § 141) and
Kentucky Administrative Regulations (401 K.A.R. 8:250-420) would not be relevant and
appropriate to this alternative. As an interim remedial action, the scope is limited to
control of the high concentration contamination area within the Northeast Plume, so
treatment to MCLs would not be appropriate at this phase.
Location-specific applicable or relevant and appropriate requirements
Protected resources referred to in this section are present on the operable unit; however,
no adverse impacts to these resources are currently anticipated. Consequently, although
all ARARs discussed in this section are applicable, they will be met by avoidance of the
resources. However, if impacts become apparent, due to construction or other plan
modifications, additional requirements (e.g., consultation with the Fish and Wildlife
Service (FWS) or the State Historic Preservation Officer (SHPO) concerning endangered
species and cultural resources respectively, mitigation for impacts to wetlands, etc.) will
need to be addressed and/or initiated to comply with the ARARs.
Wetlands and floodplains have been identified in the area of the Northeast Plume.
Construction of the ground water treatment facility and extraction wells 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. Part 6;
Appendix A, and 10 C.F.R. Part 1022]. In addition, the facilities must not be
constructed in a 100-year floodplain (Executive Order 11988, and 10 C.F.R. 1022).
Construction in wetlands should be avoided unless there are no practicable alternatives
[40 C.F.R. § 6.302(a)]. 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
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. Part 230, and 33 C.F.R. Parts 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 or endangered 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 construction plan or other modifications, the specific
requirements of 33 C.F.R. § 330 [nation wide permits (NWP)], or 33 C.F.R. § 325
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(processing of general permits), and statutes governing discharges of dredged or fill
material into waters of the United States would become applicable.
Specific requirements of NWP 12 (Utility Line Backfill and Bedding) and general permits
that would be applicable to this project, if impacts become apparent, include but are not
limited to: (1) avoiding and minimizing impacts to the fullest extent possible, (2)
incorporation of erosion control measures and best management practices (BMPs) into
construction plans, (3) avoiding stockpiling of materials in waters of the United States
including wetlands, and (4) keeping heavy equipment out of waters of the United States
including wetlands whenever possible. If it is determined that this is not possible, heavy
equipment must be placed on mats or other measures implemented to minimize soil
disturbance. Specific requirements would be better defined once the nature and extent
of impacts and appropriate permit(s) are determined.
Under the Endangered Species Act (16 U.S.C. § 1531 et seq.)t federal agencies are
prohibited from jeopardizing threatened or endangered species or adversely modifying
habitats essential to their survival [40 C.F.R. § 6.302(h)]. All designated endangered or
threatened species or their habitats must be identified [40 C.F.R. § 6.302(h)]. Two
federally endangered or candidate species have been documented to exist in the
surrounding area: the Indiana bat and the copperbelly water snake. Sixteen additional
federally listed or candidate species have been reported from surrounding McCracken
and Ballard counties. Of these 18 species only the Indiana bat, copperbelly water snake,
Rafinesque's big-eared bat, and southeastern myotis have possible habitats present near
the treatment areas. No impacts to any of these species or their habitats are anticipated
at this time. If it becomes apparent that impacts to any of these species or their habitats
are unavoidable, due to construction plan or other modifications, formal consultation
with the FWS must be initiated pursuant to 50 C.F.R. § 402. If the consultation reveals
that the activity may jeopardize a listed species or habitat, mitigation measures should
be considered [16 U.S.C. § 1531-1544, 50 C.F.R. Part 402, 40 C.F.R. § 6.302(h), and 16
U.S.C. § 661-668]. Since the State Threatened and Endangered Species List has not been
promulgated, it is TBC guidance.
Under the National Historic Preservation Act (NHPA) (16 U.S.C. § 470), federal
agencies are required to exercise caution to ensure mat no properties that may qualify as
cultural or historic be inadvertently demolished, altered, or affected. Section 106 of the
NHPA requires a federal agency to take into account the effects of its undertaking on
properties included in or eligible for the National Register of Historic Places, and, prior
to approval of an undertaking, to offer the Advisory Council on Historic Preservation a
reasonable opportunity to comment on the undertaking (36 C.F.R. § 800). This is
accomplished by following the "Section 106 process" (36 C.F.R. § 800).
In general, the Section 106 process includes: reviewing existing information on historic
properties potentially affected by the undertaking; requesting information from local
governments, Indian tribes, public and private organizations, and other parties likely to
have knowledge of or concerns with historic properties in the area; and surveying the
area to determine the location of unknown properties or sites. If no properties are
discovered using the above methods, the agency will provide this documentation to the
SHPO and any interested parties, and no further steps are required. If historic
properties are found, the properties must be assessed to determine effects pursuant to
36 C.F.R. § 800.5. Generally, if no known sites are found through the review and
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information request process, and the area of the undertaking is undisturbed, a survey of
the area is required. However, if the area of the undertaking is within a previously
disturbed area, and the SHPO concurs, no further steps are required.
The areas chosen for the site of the extraction wells and water treatment facility were
surveyed during a study conducted by the United States Army Corps of Engineers in
1993. No historic or cultural properties were discovered during the survey.
Consequently, if the pipeline route is restricted to previously disturbed areas (i.e., under
the existing road or within adjacent created ditches) and the location of the extraction
wells and water treatment facility does not change, the Section 106 process is fulfilled
upon concurrence with the SHPO. However, if the pipeline cannot be confined to
previously disturbed areas and/or the location of the extraction wells and/or the water
treatment facility changes, a survey of the new areas may be required upon consultation
with the SHPO.
Under the Farmland Protection Policy Act (7 C.F.R. § 658), federal agencies are required
to: take into account the adverse effects of their programs on the preservation of
farmlands; consider alternatives, as appropriate, to lessen adverse impacts to
farmlands; and ensure that their programs, to the extent practicable, are compatible
with state and local government and private programs to protect farmland.
Prime farmland soils have been identified in the area of the proposed action; however,
less than 0.01 acre is presently being considered for conversion. Consequently,
consultation with the Soil Conservation Service has determined that it is not necessary
to complete Form AD 1006, the Farmland Conversion Impact Rating Form, to determine
the impact of the undertaking on prime farmland. If modifications are made to the
current plans, more prime farmland may be impacted and Form AD 1006 would need to
be completed.
Action-specific applicable or relevant and appropriate requirements
Site preparation and construction activities (i.e., extraction/monitoring wells, pipeline,
and sand filters) will be conducted in order to implement the interim remedial action.
Such construction activity could produce airborne pollutants. Particulate emission levels
resulting from earth-moving and site-grading activities may exceed the Kentucky air
quality regulations found in 401 K.A.R. 63:010 et seq. The Kentucky air quality
regulations contain general standards of performance governing fugitive dust emissions.
The regulations in 401 K.A.R. 63:010 § 3 require the use of water or chemicals, if
possible, and/or placement of asphalt or concrete on roads and material stockpiles to
control dust. Visible fugitive dust may not be discharged beyond the property line where
the dust originated. Additionally, all open bodied trucks which operate outside the
property boundary and which may emit materials that could be airborne must be
covered. This regulation would be applicable.
Storm water discharges from activities at industrial sites involving construction
operation will be regulated by the KPDES Permit (KY0004049) established under 401
K.A.R. 5:055. The PGDP is exempted from the Kentucky General Permit for Storm
Water Point Sources (KYR100000) under 401 K.A.R. 5:055 because it has an individual
KPDES Permit. Pursuant to 401 K.A.R. 5:055, the PGDP's KPDES Permit specifies that
BMPs and sediment and erosion controls be implemented at a site to control storm
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water runoff. The PGDP has developed a BMP plan pursuant to these requirements
which are applicable.
The cooling towers meet the definition of "waste water treatment facility" under 401
K.A.R. 30:010 § l(90)(t); therefore, they are exempt from RCRA regulation pursuant to
401 K.A.R. 38:010 § l(2)(b)(5). The facility will be regulated under the CWA and the
site's KPDES permit. Under 401 K.A.R. 5:005 § 7, treatment systems from industrial
wastes must be designed according to specific criteria. Also, the KPDES permit will
have to be modified to include the cooling towers as a waste source.
The Kentucky regulations, in 401 K.A.R. 5:005 § 7, specify that design criteria for any
facility, including wastewater treatment units such as the cooling tower, shall be
controlled by current engineering practices. Facilities must also protect those minimum
conditions applicable to all waters of the Commonwealth found in 401 K.A.R. 5:031 § 2.
Furthermore, facilities shall not cause those waters classified in 401 K.A.R. 5:035 to be
of lesser quality than the numeric criteria applicable to those waters in 401 K.A.R. 5:031
§§ 3 to 9. These requirements are applicable to this action.
Additionally, 401 K.A.R. 5:005 § 7 of the regulations requires that a recording flow
measuring device be installed at each large facility. As defined in 401 K.A.R. 5:005 § 8, a
"large facility" means a treatment facility with an average daily design flow of 50,000
gallons (gal) per day or more and sewer lines of more than 50,000 ft. These requirements
are applicable to this action.
The cooling tower will be used to remove VOCs from the ground water. As a modified
source it would be regulated by the requirements in 401 K.A.R. 63:022 § 3, which specify
that no owner or operator shall allow any source to exceed the allowable emission limit
determined by the formula in Appendix A of that regulation. If the owner or operator
cannot meet the allowable emission limit even after application of best available control
technology, and can demonstrate this fact to the satisfaction of the Cabinet, then best
available control technology shall be required. However, calculations by both the DOE
and the KDEP agree that the allowable emission rate will not be exceeded.
The construction of water wells is regulated by the Commonwealth of Kentucky.
Construction of water withdrawal wells will require that the wells be constructed by a
certified driller under specified design criteria (401 K.A.R. 6:310'§ 13). A permit is
required when more than 10,000 gal of water per day are pumped out of the ground
(401 K.A.R. 4:010 § 1). However, the DOE is exempt from permits and other
administrative requirements under CERCLA § 121 (c)(l), but will be required to record
and report the recovery rate. All substantive requirements of this regulation will apply.
During well installation, investigation-derived waste and personal protective equipment
could meet the definition of a characteristically hazardous waste. Operational residuals
from sand filters may also be above characteristically hazardous waste levels. A
determination will be made on any such waste as required under 401 K.A.R. 32:010 § 2.
Kentucky regulations applicable to generators of hazardous waste are detailed in 401
K.A.R. Chapter 32 et seq. It should be noted that aqueous waste associated with well
installation and operations will be treated in the cooling towers or another wastewater
treatment unit on site. This water will be exempt from the RCRA regulations as specified
in the wastewater treatment unit exemption.
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Any solid waste deemed characteristically hazardous under the RCRA could be moved
to a less than 90-day storage facility at the PGDP. Pursuant to 401 K.A.R. 32:030' § 5,
on-site accumulation of hazardous waste may occur for 90 days or less without
modifying the RCRA permit, if the waste is placed in containers that comply with 401
K.A.R. 35:180. Selected requirements for the use and management of containers holding
hazardous waste being accumulated onsite for less than 90 days are defined in 401
K.A.R. 35:180. The regulation requires that containers holding the waste be in good
condition. Also, the waste must be stored in containers lined with materials that are
compatible (401 K.A.R. 35:180 § 3). Furthermore, containers must be managed to ensure
that they are always closed during storage, except when necessary to add or remove
waste; containers are not opened, handled, or stored in any manner which may rupture
the container or cause it to leak; and the containers are labeled with the notation
"hazardous waste" and the date the accumulation begins (401 K.A.R. 35:180 § 4).
These selected requirements are applicable to the-management of hazardous waste
stored onsite for less than 90 days. However, on-site accumulation of as much as 55
gallons of hazardous waste or one quart of acutely hazardous waste may occur for more
than 90 days, provided §§ 2, 3 and 4(1) of 401 K.A.R. 35:180 are followed and the
containers are marked with the notation "hazardous waste." These requirements would
be applicable to any on-site storage of hazardous waste for less than 90 days.
Generators of hazardous waste must obtain an EPA identification number. The PGDP
has an identification number and a current RCRA Part B permit. Generators must keep a
copy of each manifest, a signed copy of the manifest returned from the designated
facility which received the waste, annual reports, and exception reports for at least three
years (401 K.A.R. 32:040 § 1). The generator must also maintain records of any test
results, waste analyses, or other determinations for at least three years from the date
that the waste was last sent to an on-site or off-site treatment storage, or disposal
facility (401 K.A.R. 32:040 § 1).
All less than 90-day accumulation areas and permitted facilities at the PGDP will go
through RCRA closure when removed from operation. Applicable requirements will be
adhered to at that time.
Pursuant to 401 K.A.R. 37:050 and 40 C.F.R. § 268.50, the storage of hazardous wastes
restricted from land disposal under 401 K.A.R. 37:030 and 40 C.F.R. § 268 is
prohibited, unless the generator stores such wastes in tanks, containers, or containment
buildings onsite solely for the purpose of accumulating such quantities Of hazardous
waste as necessary to facilitate proper recovery, treatment, or disposal. Such storage at
the PGDP must be in compliance with the requirements in 401 K.A.R. 32:030 § 5 and
401 K.A.R. Chapters 34 and/or the requirements in 40 C.F.R. § 264. Furthermore, each
container must be clearly marked with the identification of its contents, the date each
accumulation period began, and the quantity of each hazardous waste. These
regulations apply to the management of hazardous wastes prohibited from land
disposal that are stored onsite. The PGDP has a Part B permit in place which abides by
these standards. Any hazardous waste from on-site wells or treatment residuals are
included in the latest permit modification.
If wastes are shipped offsite for treatment and/or disposal, the regulations mandated in
49 C.F.R. §§ 172-179 will be applicable. Off-site shipments must comply with both the
substantive and administrative requirements of these regulations. Materials designated
35
-------
as hazardous by the Department of Transportation are listed and classified in 49 C.F.R.
§§ 172.101 and 102. Transportation, shipping requirements, package marking, labeling,
transport vehicle placarding, and shipping paper(s) requirements are set forth in 49
C.F.R. Subparts C, D, E, and F.
Additional requirements which are applicable to the transportation of hazardous
material are located in 401 K.A.R. Chapter 33. These regulations detail standards to
which persons transporting hazardous waste in the United States must adhere including
a manifest system, record keeping, and hazardous waste discharges. However, these
regulations do not apply to on-site transportation of hazardous waste by generators or
by owners or operators of permitted hazardous waste management facilities. The
regulations in 49 C.F.R. § 172 would be applicable since they apply to each person who
offers hazardous material for transportation and each carrier who transports the
material. Specifications for packaging and containers used for the transportation of
hazardous materials in commerce are included in 49 C.F.R. § 178. The PGDP abides by
all applicable regulations for off-site transportation of hazardous material.
A transporter who intends to transport hazardous waste within the Commonwealth of
Kentucky must have an EPA identification number issued by the Kentucky Natural
Resources and Environmental Protection Cabinet (401 K.A.R. 33:010). The transporter
must also register with the Cabinet by filing an application pursuant to 401 K.A.R.
33:010. Furthermore, the transporter of hazardous waste must meet the standards for
compliance with the manifest system and record keeping found in 401 K.A.R. 33:020.
These administrative requirements apply only to off-site shipments within the
Commonwealth of Kentucky. Those hazardous and/or low-level wastes requiring off-
site treatment or disposal must be sent to a facility which meets the EPA's acceptability
criteria (40 C.F.R. 300.58). Those wastes generated by the action that requires off-site
treatment or disposal will be sent to one or more of the following facilities: Envirocare of
Utah, Clive, Utah; Rollins Environmental Services, Dear Park, Texas; Rollins
Environmental Services, Baton Rouge, Louisiana; SEG, Oak Ridge, Tennessee; and TSCA
Incinerator, Oak Ridge, Tennessee. These regulations are applicable to the off site
shipment of hazardous waste.
Requirements for providing and maintaining emergency response information during
transportation and at facilities where hazardous materials are loaded for
transportation, stored incidental to transportation or otherwise handled during any
phase of transportation, are delineated in Subpart G of 49 C.F.R. § 172. However, an
exemption is allowed for small quantities under the RCRA permit. Training requirements
for hazardous materials training (HAZMAT) employees are included in Subpart H of 49
C.F.R. § 172. Training ensures that a HAZMAT employee has familiarity with Subpart
H requirements, is able to recognize and identify hazardous materials, and has
knowledge of emergency response information, self protection measures, and accident
prevention methods and procedures. Under CERCLA § 121 (e), administrative
requirements for off-site transportation will be applicable.
Table 5 provides a listing of those applicable, relevant and appropriate, and TBC
requirements as chemical-, location-, or action-specific.
36
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Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control
Actions
Requirements
Prerequisites
Federal Citation
Kentucky
Citation
CHEMICAL-SPECIFIC
Antidegradation
Treatment and
discharge of the
ground water into a
surface water body
Waters of the Commonwealth must be Discharges into waters of the
safeguarded against the creation of Commonwealth - applicable
any new pollution.
Must apply for KPDES permit
modification for increased discharge
to an outfall or to discharge a
chemical not regulated by the permit.
The discharge must comply with the
KPDES effluent limitations of
KY0004049 for an outfall.
Specifically, the discharge must not
exceed the permit limit for TCE of
0.081 mg/1 at the outfall.
LOCATION-SPECIFIC
Protection of
wetlands
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.
Point-source discharge to waters of
the Commonwealth - applicable
Point-source discharge to waters of
the Commonwealth - applicable
5:029 § 2
5:055
5:080 § 1;
5:029 § 3
Any federal action that will have an
impact on wetlands - applicable
Any action involving discharge of
dredge or fill material into wetlands
- applicable
Any federal action that will have an
impact on wetlands - applicable
10 C.F.R. § 1022;
Executive Order 11990
10 C.F.R. § 230.10;
13 U.S.C. § 1022.3(b)
10 C.F.R. § 1022.3(b)
33 C.F.R. § 330
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Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control (continued)
Actions
Requirements
Prerequisites
Federal Citation
Kentucky
Citation
GO
LOCATION-SPECIFIC (continued)
Discharge of dredged
or fill material into
navigable water
Protection of
floodplains
Protection of
threatened and
endangered species
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 also
prohibited unless there are
practicable alternatives and
practicable, appropriate mitigation
methods are available.
Discharges which cause or contribute
to violations of state water quality
standards, violate toxic effluent
standards or discharge prohibitions
or jeopardize threatened and
endangered species under the ESA.
Avoid siting or construction in any
100-year floodplains.
Avoid actions which jeopardize
threatened or endangered species or
take appropriate mitigation
measures.
Any action involving discharge of
dredged or fill material into
wetlands - applicable
Any action involving discharge of
dredged or fill material into
wetlands - applicable
Any action involving discharge of
dredged or fill material into
wetlands - applicable
Any federal action within a 100-year
floodplain - applicable
Any action which jeopardizes
threatened or endangered species or
their critical habitats - applicable
40 C.F.R. § 230.10(a)
40 C.F.R. § 230.10(c);
40 C.F.R. § 230.10(d)
40 C.F.R. § 230.10(b)
10CF.R. 1022
Executive Order 11988
16 U.S.C. § 1531-1544;
50 C.F.R. § 402;
40 C.F.R. § 6.302(h)
-------
Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control (continued) '
Actions
Requirements
Prerequisites
Federal Citation
Kentucky
Citation
w
LOCATION-SPECIFIC (continued)
Protection of cultural
resources
Ensure that no properties that may
qualify as cultural or historic be
inadvertently demolished, altered,
or destroyed.
Any federal action that will have an
impact on cultural resources -
applicable
16 U.S.C.A. § 470
Avoid or minimize impacts to cultural Any federal action that will have an 36 C.F.R. § 800
resources by following the Section 106 impact on cultural resources -
process, including consultation with applicable
the SHPO.
Protection of prime
Farmland
ACTION-SPECIFIC
Take into account agency action
impacts on prime farmland and
consider alternatives.
Site preparation and Reasonable precaution must be taken
construction activities to prevent particulate matter from
becoming airborne.
Surface water control
Implement good site planning and
BMPs to control storm water
discharges; comply with storm water
runoff requirements of.KPDES Permit
KY 0004049.
Conversion of prime farmland soils to 7 C.F.R. § 658
non-farmable areas - applicable
Handling, processing, construction,
road grading, and land clearing
activities - applicable
Construction activities at industrial 40 C.F.R. § 122;
sites involving disturbance of five 57 Fed. Reg. 41176
acres or more land - applicable if over (Sept. 9,1992)
five acres disturbed; - relevant and
appropriate if less than five acres
disturbed
401 K.A.R.
63:010 § 3
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Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control (continued)
Actions
Requirements
Prerequisites
Federal Citation
Kentucky
Citation
ACTION-SPECIFIC (continued)
Waste water
treatment facility
Water treatment
facility (modified
source)
Protection of aquatic
organisms
Exempt from RCRA under 401 K.A.R.
38:010 § l(2)(b)(5).
Designed according to specific criteria
and controlled through current
engineering practices.
Protect those minimum conditions
applicable to all waters of the
Commonwealth.
Install a recording measuring device
at each large facility.
No owner or operator shall allow any
source to exceed the allowable
emission levels determined in
Appendix A of 401 K.A.R. 63:022.
Water criteria of 401 K.A.R. 5:031
must be maintained as well as
appropriate criteria for other
designated use classifications in 401
K.A.R. 5:026.
Construction of a waste water
treatment facility-applicable
Emissions from a treatment facility
- applicable
Action affecting the existing water
quality-applicable
Construction of water Constructed by a certified driller
wells under specified design criteria.
Construction of water withdrawal
wells - applicable
38:010 §1
(2)(b)(5)
5:005 § 7
63:022
401 K.A.R.
5:031
6:310 §1
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Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control (continued)
Actions
Requirements
Prerequisites
Federal Citation
Kentucky
Citation
ACTION-SPECIFIC (continued)
Waste management Generators of waste shall determine Generation of waste material
Container storage
(onsite)
if it is hazardous.
Storage in containers for less than
90 days.
- applicable
Onsite storage of hazardous waste
-applicable
40 C.F.R. § 262.11 32:010 §2
40 C.F.R. § 262.34(a) 32:030 § 5(1)
Containers must be in good condition Storage of hazardous waste less than 40 C.F.R. § 265
35:180 § 4
and lined.
Containers must always be closed
during storage expect when necessary
to add or remove waste; containers
must not be handled in any manner
which may rupture the container or
cause it to leak; and must be labeled
with the notation "hazardous
waste."
Inspect container storage areas
weekly for deterioration.
90 days - applicable
Subpart I
40 C.F.R. § 265.174 35:180 § 5
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Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control (continued)
Actions
Requirements
Prerequisites
Kentucky
Federal Citation Citation
ACTION-SPECIFIC (continued)
Container storage
(onsite)
(continued)
ro
Closure of 90-day accumulation areas
shall minimize the need for further
maintenance; control, minimize, or
eliminate postclosure escape of
hazardous waste; and comply with
other closure requirements in 401
K.A.R. Chapter 35
All contaminated equipment,
structures, and soil shall be properly
disposed or decontaminated.
Storage in containers for more than 90
days.
Containers of hazardous waste
must be:
• Maintained in good condition;
• Compatible with hazardous
wastes to be stored; and
• Closed during storage (except to
add or remove waste).
Inspect container storage areas
weekly for deterioration.
40 C.F.R. § 262.34 35:070 § 2
40 C.F.R. § 262.37 35:070 § 5
Onsite storage - applicable
40CF.R.§ 264
40 C.F.R. § 264.171 34:180 § 2
34:180 §3
Storage of containerized RCRA
hazardous waste (listed or
characteristic) not meeting small
quantity by a generator criteria held 40 C.F.R. § 264.172
for a temporary period before
treatment, disposal, or storage
elsewhere, in a container [i.e., any
portable device (in) which a
material is stored, transported,
disposed, or handled] - Applicable to
treatment of residuals or wastes
which are RCRA hazardous wasted
40 C.F.R § 264.173
34:180
34:180 §4
40 C.F.R. § 264.174 34:180 § 5
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Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control (continued)
Actions
Requirements
Prerequisites
Federal Citation
Kentucky
Citation
ACTION-SPECIFIC (continued)
Container Storage
(onsite)
(continued)
Place containers on a sloped, crack-
free base, and protect from contact
with accumulated liquid. Provide
containment system with a capacity
of 10% of the volume containers, or,
for liquids, the volume of the largest
container, whichever is greater.
Remove spilled or leaked waste in a
timely manner to prevent overflow to
the containment system.
At closure, remove all hazardous
waste and residues from the
containment system and
decontaminate or remove all
containers, liners.
40 C.F.R. § 264.175 34:180 § 6
40 C.F.R. § 264.178 34:180 § 9
-------
Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control (continued)
Actions
Requirements
Prerequisites
Kentucky
Federal Citation Citation
40 C.F.R. § 262.34(a) 32:030 § 5(1)
• Meet operating procedures;
• Be routinely inspected;
• Response to leaks or spills.
Disposition of unfit tanks;
• Meet closure requirements;
40 C.F.R. § 265
Subpart )
35:190
ACTION-SPECIFIC (continued)
Tank storage (on site) Storage in tanks for less than 90 days. Onsite storage of hazardous waste
- applicable
Storage in tanks for less than 90 days. Onsite storage - applicable
Tanks for storage of hazardous waste
mush
• Tank integrity assessment;
• Meet design and construction
standards;
• Meet containment and release
detection requirements;
40 C.F.R. § 265.191 35:190 §2
40 C.F.R. § 265.192 35:190 § 3
40 CF.R. § 265.193 35:190 §4
40 CF.R. § 265.194 35:190 § 5
40 C.F.R. § 265.195 35:190 § 6
40 C.F.R. 264.1% 35:190 § 7
40 C.F.R. § 265.197 35:190 § 8
[except §265.197(c)] fe*Ept§8(3)]
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Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control (continued)
Actions
Requirements
Prerequisites
Federal Citation
Kentucky
Citation
ui
ACTION-SPECIFIC (continued)
Disposal of treatment Land disposal restrictions for RCRA
residuals hazardous waste may be triggered.
Hazardous waste determinations are
to be performed on treatment plant
residuals.
Transportation of
hazardous waste
(offsite)
Transporters of waste must follow
detailed standards.
Waste must be packaged and
transported in accordance with DOT
requirements including: shipping
requirements, package marking,
labeling, vehicle placarding, and
shipping papers.
Disposal of RCRA restricted waste
- applicable
Determination if a waste is RCRA
hazardous waste - applicable
Waste exhibits a RCRA hazardous
waste characteristic as defined by
Subpart C of 40 C.F.R. 261 and off-site
transportation occurs - applicable
Hazardous waste is transported
offsite - applicable
The waste is considered a RCRA
hazardous waste by characteristic or
a hazardous substance that equals or
exceeds a reportable quantity and
transportation occurs in commerce
- applicable
40 C.F.R. § 268
40 C.F.R. § 262.11
40 C.F.R. § 263
40C.F.R.§ 263
Subparts A&B
49 C.F.R. §§ 172.173,
178, and 179
Chapter 37
32:010 § 2
Chapter 33
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ON
Table 5. Applicable or Relevant and Appropriate Requirements (ARARs) and Guidance for the Northeast Plume
Hydraulic Plume Control (continued)
Actions
Requirements
Prerequisites
Federal Citation
Kentucky
Citation
ACTION-SPECIFIC (continued)
Transportation of
hazardous waste
(offsite)
(continued)
Emergency response information and
employee HAZMAT are required.
Transporter must have EPA
identification number issued by the
Kentucky Natural Resources and
Environmental Protection Cabinet.
49CF.R.§ 172
Transportation of hazardous
materials in the Commonwealth of
Kentucky - applicable
33:010
RCRA listed as an ARA is a requirement of CERCLA in ROD documentation. By doing this, it in no way limits, takes away, or negates the
Commonwealth of Kentucky's RCRA authority at the site.
-------
Cost effectiveness
The interim remedial action remedy employs a proven technology which affords overall
effectiveness proportional to its costs such that the remedy represents reasonable value.
This action will utilize a relatively inexpensive technology to initiate control of the
spread of the highly contaminated portion of the Northeast Plume.
Utilization of permanent solutions and alternative treatment technologies
The objectives for this interim remedial action are to initiate hydraulic plume control to
decrease the migration of contaminants from the high concentration zones of the
Northeast Plume, and by installing innovative technologies which may provide more
efficient and cost effective methods for addressing the plume. This action should
provide protection for human health and the environment. However, it is not intended to
fully address the principal threats to human health and the environment posed by the
northeast operable unit. This is not the final action planned for the Northeast Plume
contamination. Subsequent actions will fully address the principal threats posed by the
conditions at the PGDP. Utilization of a permanent solution will be addressed in the
final decision document for the site.
Preference for treatment as a principal element
This interim remedial action satisfies the statutory preference for treatment of the
discharged effluent as a principal element of the containment system.
2.11 Documentation Of Significant Changes
The Proposed Remedial Action Plan for Interim Remedial Action of the Northeast Plume, was
released for public comment on March 12, 1995. The PRAP identified Alternative 2,
Hydraulic Plume Control as the preferred alternative. During the public comment period
the selected remedy was further developed to decrease the project cost and time to
implementation. After several discussions with the EPA, the KDEP, and the USEC, it
was agreed that the DOE would utilize existing facilities to treat the ground water.
Therefore, the decision was made to use the existing cooling towers for volatilization of
the VOCs. This modification is consistent with the type of treatment specified in the
PRAP and will result in a comparable level of treatment. As public noticed in the PRAP,
the ground water extraction wells and pipeline will be used and the treated ground
water will be discharged to a KPDES outfall. The DOE has reviewed all written and
verbal comments submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the remedy, as it was
originally identified in the PRAP, were necessary.
During the development of the final remedial alternatives for the Ground Water
Integrator Operable Unit, including the Northeast Plume, the necessity of action
implemented under this ROD for interim remedial action will be re-evaluated. The final
ROD for the Ground Water Integrator Operable Unit may retain or replace portions or
all of the actions conducted through this ROD. However, nothing conducted pursuant to
this ROD is deemed inconsistent with likely final remedial actions.
47
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PARTS
RESPONSIVENESS SUMMARY
48
-------
'RESPONSIVENESS SUMMARY
3.1 Responsiveness Summary Introduction
The responsiveness summary has been prepared to meet the requirements of Sections
113(k)(2)(b)(iv) and 117 (b) of CERCLA, as amended by SARA, which requires, the
DOE as "lead agency" to respond "...to each of the significant comments, criticisms,
and new data submitted in written or oral presentations" on the PRAP.
The DOE has gathered information on the types and extent of contamination found,
evaluated remedial measures, and has recommended an interim remedial action to
initiate control of the contamination found in the Northeast Plume. As part of the
remedial action process, a notice of availability regarding the PRAP was published
March 12 and March 13,1995, in The Paducah Sun, a regional newspaper. The PRAP for
Interim Remedial Action of the Northeast Plume was released to the public March 12,
1995. This document was made available at the Environmental Information Center in the
West Kentucky Technology Park in Kevil, Kentucky, and at the Paducah Public Library.
A public comment period began March 12,1995, and continued until April 25,1995.
Specific groups which received individual copies of the PRAP included the local PGDP
Neighborhood Council, Natural Resource Trustees, and the PGDP Environmental
Advisory Committee. Informal meetings were held with the PGDP Neighborhood
Council April 27, 1995 and with the PGDP Environmental Advisory Committee on
April 20, 1995. At these meetings, DOE personnel briefed the groups on the proposed
action and solicited both written and verbal comments.
Telephone calls or visits were made to various stakeholders, including neighbors and
representative of environmental groups, to alert them to the public comment period and
briefly explain the PRAP. Proposed remedial action plans and/or ICMs were mailed to
those contacted.
Public participation in the CERCLA process is required by 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 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. This document summarizes both the oral and written
comments during the various informal meetings and telephone calls, and the written
comments received during the public comment period running from March 12 through
April 25, 1995.
As evidenced from the comments received during the public comment period, the
selected interim remedy specified in the ROD for interim remedial action has received
concurrence by the EPA, the KDEP and the DOE.
The Environmental Advisory Committee, a panel of local businessmen and scientists
organized and supported by Martin Marietta Energy Systems, Inc., to provide feedback
on environmental restoration at the PGDP, generally expressed concern that no imminent
49
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health hazard exists and that the pump and treatment method may not halt or even
impede the advancement of the plume's edge.
Comments received during the public comment period for the interim remedial action are
summarized below. Comments and responses have been divided into two parts and are
categorized by topic within the responsiveness summary: Part I for local community
concerns, and Part n for specific legal and technical questions. The comments below
have been paraphrased in order to effectively summarize them in this document. Copies
of the written comments are available for review at the Environmental Information
Center.
3.2 Summary and Response to Local Community Concerns
COMMENT: The pump and treat facility for the Northwest Plume has not been put into
operation. Thus, the data from the Northwest Plume is not yet available. The pump and
treat method may or may not halt or even impede the advancement of the plume edge.
We believe that no imminent health hazard exists."
RESPONSE: Pump and treat technologies have been demonstrated to provide an
effective method for containment. By addressing the high concentration areas of the
plume through containment the DOE hopes to provide protection to human health and
the environment, and decrease future costs associated with remedial actions. This
interim remedial action will mitigate the migration of the plume while on-site sources
remedies are implemented.
COMMENT: Change the present proposal to include the cooling tower treatment.
RESPONSE: The DOE will treat the extracted ground water via the cooling towers.
3.3 Comprehensive Response to Specific Legal and Technical Comments
COMMENT: Changing of the ROD to reflect removal of TCE by the use of the cooling
towers as an air TCE stripper will reduced the cost and the development of such a
useful, innovative technique would allow the Environmental Advisory Committee to
reluctantly withdraw its objection to the pump and treat proposal. The Environmental
Advisory Committee does not agree to the present proposed plan arid a ROD based on
its preferred alternative, and then modifying the ROD after it is signed. Any
modifications should be made prior to a ROD's signing.
RESPONSE: Following a detailed review of regulatory requirements, engineering
standards, PGDP operation guidelines, and comparative cost effectiveness, the DOE
decided to utilize the existing cooling towers for volatilization of the TCE contained in
the extracted ground water. This decision was reached through a cooperative effort of
several organizations including the DOE, the EPA, the KDEP, and the USEC.
50
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Appendix
Northeast Plume
Interim Remedial Design Schedule
-------
Northeast Plume Interim Remedial Design Schedule
ID
1
2
3
4
5
6
7
8
9
Name
Remedial Design
Prepare Systems Requirement
Document
Prepare Task Order
Develop 30% design
Primes/DOE/EPA/KDEP 30%
review
Develop 60% design
Primes/DOE/EPA/KDEP 60%
review
Develop 90% design
Issue Certified for Construction
Remedial Design Report
Duration
333d
60d
30d
90d
4d
56d
9d
49d
35d
Start Date
7/9/95
7/9/95
9/7/95
10/7/95
1/5/96
1/9/96
3/5/96
3/14/96
5/2/96
Finish
Date
6/5/96
9/6/95
10/6/95
1/4/96
1/8/96
3/4/96
3/13/96
5/1/96
6/5/96
Construction schedule will be submitted in the RD Report
QIM
1995
Qtr 1 | Qo 2 | Qtt J I Qu 4
~
I
K
1996
Qtrl I Ou: | QtrJ I Qtt 4
™
11
1997
Qtrl 1 QirJ 1 Qtr3 I Qu4
1
Qtrl | Qu2
Summary ^^"^"""'^ Milestone ^
Activity ^^^^^
Schedule Revised 5/22/95
-------
Distribution List
-------
U.S. DEPARTMENT OF ENERGY
Myma E. Redfield
Program Manager
US. Department of Energy
P.O. Box 1410
Paducah, KY 42001
Robert C. Edwards (2 copies)
US. Department of Energy
P.O. Box 1410
Paducah, KY 42001
Arnold Guevara (2 copies)
US. Department of Energy
19901 Germantown Road
Germantown, MD 20874
Jimmie C Hodges
US. Department of Energy
P.O. Box 1410
Paducah, KY 42001
K. Kates, AD-424
US. Department of Energy
200 Administration Road
Room 1028
Oak Ridge, TN 37830
Anthony A. Sims
US. Department of Energy
200 Administration Road
Oak Ridge, TN 37803
Terri Slack
US. Department of Energy
200 Administration Roaa
Oak Ridge, TN 37830
Robert C. Sleeman, EW-91
US. Department of Energy
200 Administration Roaa
Room 3013
Oak Ridge, TN 37830
Robertr Dale Dempsey, EW-90
Assistant Manager for
EnvironmentalManagement '
US. Department of Energy
55 Jefferson Circle Turnpike, Bldg. U
Oak Ridge, TN 37830
EEA
John H. Hankinson, Jr.
Regional Administrator
US. EPA, Region IV
345 Courtland Street, NE
Atlanta, GA 30365
Tony Able (5 copies)
US. EPA, Region IV
345 Courtland Street, NE •
Atlanta, GA 30365
FOSTER WHEELER
ENVIRONMENTAL CORP.
David Jones (2 copies)
111 Union Valley Road
Oak Ridge, TN 37830
MK-FERGUSON
David Beall (2 copies)
5735 Hobbs Road
C-730 Trailer D
Kevil, KY 52053
JACOBS ENGINEERING.
GROUP
Don Wilkes (2 copies)
Jacobs Engineering Group
175 Freedom Blvd.
Kevil, KY 42053
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
MARTIN MARIETTA ENERGY
SYSTEMS. INC.
Patricia A. Gourieux
(Letter Only)
Martin Marietta Energy Systems
761 Veterans Ave
Kevil, KY 42053
Jimmy C. Massey (Letter Only)
Martin Marietta Energy Systems
761 Veterans Ave
Kevil, KY 42053
NATURAL RESOURCE
TRUSTEES
Alex Barber
Commissioner Office
KY Dept. for Environmental
Protection
14 ReUly Road
Frankfort Office Park
Frankfort, KY 40601
James H. Lee
US. Department of Interior
Richard B. Russell Federal Bldg.
75 Spring Street, SW Suite 345
Atlanta, GA 30303
Abraham Loudermilk
Tennessee Valley Authority
400 W. Summit Hill Drive
Knoxville, TN 37902
Andrea B. Perkins
US. Department of Energy
Information Resource Center
105 Broadway
Oak Ridge, TN 37830
Allen Robison
US. Department of Interior
Fish and Wildlife Service
446 Neal Street
Cookville, TN 38501
STATE OF KENTUCKY
Caroline P. Haight
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'
Lisa Fleming/Todd Muilins
KY Division of Waste Management
4500 Clarks River Road
Paducah, KY 42003
IYA
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
U.S. ENRICHMENT
CORPORATION
David Hutcheson
US.E.C.
P.O. Box 1410
Paducah, KY 42001
U.S. GEOLOGICAL SURVEY
Martin Rose
US. Geological Survey
2301 Bradley Avenue
Louisville, KY 40217
WEST KY WILDLIFE
MANAGEMENT AREA
Charles W. Logsdon
West Kentucky Wildlife Ment Area
KY Dept. of Fish and WildEfe
Resources
10535 Ogden Landing Road
Kevil, KY 40253
JEG.0695.01
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