EPA/ROD/R04-98/017
                                    1998
EPA Superfund
     Record of Decision:
     OAK RIDGE RESERVATION (USDOE)
     EPA ID: TN1890090003
     OU37
     OAK RIDGE, TN
     01/23/1998

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541-R98-017





                                              DOE/OR/02-1486&D4
                                              Record of Decision
                                      for the K-1070-C/D Operable Unit,
                                       East Tennessee  Technology Park,
                                             Oak Ridge, Tennessee
                                           Date Issue-November 1997
                                                 Prepared by
                                                Jacobs EM Team
                                             125 Broadway Avenue
                                             Oak Ridge,  Tennessee
                                       under contract DE-AC05-930R2208
                                                 Prepared for
                                          U.S. Department of Energy
                                      Office of Environmental Management

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                                                   PREFACE

This Record of Decision for the K-1070-C/D Operable Unit, East Tennessee Technology Park, Oak
Ridge, Tennessee (DOE/OR/02-1486&D4) was prepared in accordance with reguirements under the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA)  to
present the selected remedy for the K-1070-C/D Operable Unit to the public.  This work was
performed under Work Breakdown Structure 1.4.12.4.1.01.48 (Activity Data Sheet 4300, "K-1070-C/D
G Pit and Concrete Pad").   This document provides the Environmental Restoration Program with
information about the selected remedy for the K-1070-C/D Operable Unit,  which includes
excavation of G Pit materials and placement into interim storage, treatment and disposal, and an
interim soil cover for the Concrete Pad Area.  The CERCLA remedial investigation and risk
analysis has shown that no further action is necessary for the Landfarm Area, surface water, and
sediment at the K-1070-C/D Burial Ground.  This selected remedy is different from and supersedes
the remedy presented in the document's Dl version.  This document also summarizes information
from the remedial investigation/feasibility study  (DOE/OR/01-1297&D2) and the proposed plan
(DOE/OR/02-1399&D4).

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                                      ACRONYMS AND ABBREVIATIONS
ARAR
CERCLA
CFR
CNF
DCA
DCE
DOE
DOT
EPA
ETTP
FFA
FFCAct
FR
FS
ft
g
gal
ha
ISV
km
L
LDR
LLW
m
IR
MCL
mg
mrem
NCP
NPDES
NTS
O&M
ORR
OSWER
OU
PCB
PCE
pCi
ppm
RCRA
RI
ROD
S&M
applicable or relevant and appropriate requirement
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
Code of Federal Regulations
Central Neutralization Facility
dichloroethane
dichloroethene
U.S. Department of Energy
U.S. Department of Transportation
U.S. Environmental Protection Agency
East Tennessee Technology Park  (formerly Oak Ridge K-25 Site)
Federal Facility Agreement
Federal Facility Compliance Act of 1992
Federal Register
feasibility study
foot
gram
gallon
hectare
in situ vitrification
kilometer
liter
land disposal restriction
low-level (radioactive) waste
meter
microroentgen
maximum contaminant level
milligram
millirem
National Oil and Hazardous Substances Pollution Contingency Plan
National Pollutant Discharge Elimination System
Nevada Test Site
operation and maintenance
Oak Ridge Reservation
Office of Solid Waste and Emergency Response
operable unit
polychlorinated biphenyl
tetrachloroethene
picocurie
parts per million
Resource Conservation and Recovery Act of 1976
remedial investigation
record of decision
surveillance and maintenance

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                                ACRONYMS AND ABBREVIATIONS (continued)

SARA           Superfund Amendments and Reauthorization Act of 1986
TBC            to be considered
Tc             technetium
TCA            trichloroethane
TCE            trichloroethene
TDEC           Tennessee Department of Environment and Conservation
U              uranium
USC            United States Code
"WAG            waste acceptance criteria
yd             yard

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                                             PART 1.  DECLARATION
                                            SITE NAME AND LOCATION

       U.S. Department of Energy
       K-1070-C/D Operable Unit
       East Tennessee Technology Park,  Oak Ridge Reservation
       Oak Ridge, Tennessee

                                        STATEMENT OF BASIS AND PURPOSE

       This record of decision (ROD)  presents the selected remedial action for the G Pit and the
Concrete Pad of the K-1070-C/D Operable Unit  (OU) at the East Tennessee Technology Park  (ETTP)
(formerly the Oak Ridge K-25 Site) on the U.S. Department of Energy  (DOE) Oak Ridge Reservation
(ORR) in Oak Ridge, Tennessee.  This ROD also designates no further action for the Landfarm Area
and for surface water and sediment at the K-1070-C/D OU.  The action was chosen in accordance
with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980  (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of 1986  (SARA), 42 United States
Code (USC) Section 9601 et seg. and,  to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).

       This decision is based on the Administrative Record for the K-1070-C/D OU,  including the
remedial investigation (RI)/feasibility study (FS)  (DOE 1995), the proposed plan  (DOE 1997a),
and other documents for this site.

       DOE is the lead agency for this action.  The U.S. Environmental Protection Agency (EPA)
and the Tennessee Department of Environment and Conservation  (TDEC are supportive agencies as
parties of the Federal Facility Agreement  (FFA)  for this response action.  They concur with the
selected remedy.

                                           ASSESSMENT OF THE SITE

     If actual or threatened releases of hazardous substances from this site arc not addressed
by implementing the response action selected in this ROD, the hazardous substances present
unacceptable risks to public health,  welfare, or the environment.

                                      DESCRIPTION OF THE SELECTED REMEDY

       This response action fits into the overall ORR cleanup strategy by addressing wastes and
contaminated soils at the K-1070-C/D G Pit, Concrete Pad, and Landfarm Area.  The selected
remedy mitigates a primary contaminant source to groundwater by:

       •      excavating the G Pit and backfilling it with suitable material;
       •      placing G Pit soil and  excavated waste into compliant interim storage at ETTP;
       •      conducting a written evaluation of potential ex situ treatment technologies to
              determine their applicability to the G Pit wastes;
       •      conducting a "proof-of-process" evaluation of those treatment technologies
              identified in the written evaluation to aid in the selection of the  most appropriate
              treatment technology;
       •      treating G Pit waste using the  selected technology to meet applicable waste

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              acceptance criteria (WAG)  [such as Resource Conservation and Recovery Act of 1976
              (RCRA)  land disposal restrictions (LDRs)]  for a permitted disposal facility (it is
              anticipated that this treatment will also destroy the classified components of the
              waste);  and
       •       disposing of the treated waste in a disposal facility that can lawfully accept it.

       The selected remedy also includes interim measures for areas of the OU other than the G
Pit, the Landfarm Area, and surface water and sediment.  These interim measures include the
following:

       •       placing a soil cover to prevent direct contact with and provide radiation shielding
              at the  Concrete Pad Area and
       •       maintaining institutional controls as they currently exist in the surveillance and
              maintenance (S&M)  program.

       Areas addressed by these interim actions, including the Trench Area, the North Pits Area,
the South Pits Area (exclusive of the G Pit), the K-1414 Area, and the Pits Downgradient Area,
will be reevaluated for final remedial action in the ETTP ROD.

       No further action will be taken for the Landfarm Area and for surface water and sediment
at the K-1070-C/D OU.

                                           STATUTORY DETERMINATIONS

       The selected remedy protects human health and the environment, complies with federal and
state reguirements that are legally applicable or relevant and appropriate, and is
cost-effective.  The final remedy  (G Pit excavation) uses permanent solutions and alternative
treatment technologies to the maximum extent practicable for this site and satisfies the
statutory preference for treatment to reduce toxicity,  mobility, and volume as a principal
element of the remedy.  For areas subject to interim actions, the use of permanent solutions,
alternative treatment technologies, and the preference for treatment will be addressed in the
final remedial action pursuant to the ETTP ROD.  A CERCLA 5-year review will not be reguired
after the remedial action at the G Pit because the G Pit wastes are removed.  The other areas of
the K-1070-C/D OU where hazardous substances will remain on site will be reevaluated in the
upcoming ETTP RI/FS and ROD.

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                                           PART 2.   DECISION SUMMARY

                                     SITE NAME, LOCATION, AND DESCRIPTION

       DOE ORR,  shown in Figure 2.1, is located within and adjacent to the corporate limits of
the city of Oak Ridge in East Tennessee and includes portions of Anderson and Roane Counties.
Oak Ridge is located approximately 20 km  (12.5 miles) west-northwest of Knoxville, 19 km  (12
miles) southwest of Clinton, and 16 km  (10 miles) northeast of Kingston.  ORR comprises 13,794
ha  (34,516 acres) of federally owned land and houses three major installations-Oak Ridge
National Laboratory, Oak Ridge Y-12 Plant, and ETTP.  ORR is bounded to the east, south, and
west by Clinch River (Melton Hill Lake) and by the developed portion of the city of Oak Ridge.

       ETTP encompasses approximately 688 ha (1,700 acres)  in the northwest corner of ORR in
Roane County, Tennessee.  The K-1070-C/D OU is an 8.9-ha (22-acre)  tract of land located within
the security perimeter fence on the eastern side of ETTP (Fig. 2.1).  Although portions of ETTP
are within the 100- and 500-year floodplains; of Clinch River, the  K-1070-C/D OU is not.  It is
bordered by the East Patrol Road to the north and the Burial Ground Patrol Road to the south.
The K-1070-C/D OU is divided into seven source areas:  Trench Area, Landfarm Area, Concrete Pad
Area, North Pits Area,  South Pits Area  (which includes G Pit), Pits Downgradient Area (i.e.,
area downgradient from the North and South Pits), and K-1414 Area.  These areas include soil and
buried waste, such as drums, gas centrifuge hardware, and other eguipment, and numerous
hazardous substances.  Surface water (wet weather conveyances) and  associated sediments are also
part of the K-1070-C/D OU.

                                                 SITE HISTORY

       Activities at the former K-25 Site generated many types of waste, including hazardous,
radioactive, and classified wastes that were disposed of at the K-1070-C/D OU from 1975 to 1989.

       The Trench Area was used for the disposal of classified materials generated by the Gas
Centrifuge Program and other plant operations,  including hardware and eguipment.  Low-level
radioactive, nonradioactive, hazardous, and nonhazardous materials  were also buried in the
Trench Area.  Records indicate that these materials included organic and inorganic wastes,
asbestos, solvents, uranium, heavy metals, acids, bases, glass, waste oil, capacitors containing
polychlorinated biphenyls  (PCBs), lead-acid batteries, and machine  coolant.  When the last
trench was closed, a grassy vegetative soil cover was established.

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       The North and South Pits Areas include 10 pits that were used for disposal of segregated
liguid and glass waste.  The pits typically received laboratory guantities of hazardous wastes.
Some pits also received radioactive wastes.  After disposal operations ceased, a 0.31-0.93-m
(1-3-ft)  soil cover was placed over each pit, and the site was revegetated.  The G Pit, 1 of the
10 pits,  contains classified materials and drums throughout its depth.

       The Pits Downgradient Area is a grassy hill west of the North and South Pits Areas.
Shallow groundwater underlying this area is contaminated by releases from the upgradient waste
areas.

       The K-1414 Area west of the Trench Area is the vehicle maintenance garage and fueling
facility for ETTP.  The facility has been a fuel storage facility since 1949.  In 1987, a fuel
leak was discovered.  A diesel tank and about 2,300 L  (600 gal) of diesel fuel and water were
removed.

                                     HIGHLIGHTS  OF COMMUNITY  PARTICIPATION

       DOE originally issued a proposed plan for the K-1070-C/D OU in April 1996.  Public notices
for the project were published in The Knoxville News-Sentinel, The Roane County News, and the
Oak Ridger July 15, 1996, which set a public comment period from July 15, 1996, to August 12,
1996.  One comment was received during that time; this comment and DOE's response are documented
in Part 3 of this ROD.  Following the public comment period,  DOE prepared and issued a Dl ROD
for the K-1070-C/D OU in February 1997.  However, information obtained since that time has led
DOE to conclude that the remedy detailed in the Dl ROD was unsuitable because of safety
concerns.  Therefore, in July 1997, DOE, with the concurrence of EPA and TDEC, issued a revised
proposed plan that detailed a more appropriate preferred alternative. DOE published a public
notice for the revised proposed plan in The Knoxville News-Sentinel on July 11 and 13, 1997, The
Oak Ridger and The Roane County News on July 11, 1997, The Clinton Courier-News on July 13 and
14, 1997, and The Rockwood Times on July 15, 1997, and established a new public comment period
from July 14, 1997, to August 12, 1997.  No public comments were received during this second
comment period.

                                           SCOPE AND ROLE OF THE OU

       The K-1070-C/D OU is on the eastern side of ETTP and encompasses  soil,  waste,  surface
water  (wet weather conveyances), and associated sediments at seven areas:  Trench Area, Landfarm
Area, Concrete Pad Area, North Pits Area, South Pits Area, Pits Downgradient Area(i.e., area
downgradient of the North and South Pits), and K-1414 Area.  This remedial action for the
K-1070-C/D OU fits into the overall cleanup strategy for ORR by addressing a primary contributor
to groundwater contamination  (soil and waste from the G Pit in the South Pits Area) as well as
protecting industrial workers  (from exposure to the Concrete Pad).  No further action is
recommended for surface water and sediment at the K-1070-C/D OU and for the Landfarm Area.

       Additional efforts at risk reduction, not included in this ROD, include an early action
that will intercept and treat groundwater releases from this OU and an interim action that
involves ongoing collection and treatment of water from the SW-31 Spring, located downgradient
of the OU.  Early action involves installing a system to capture contaminated groundwater in the
unconsolidated zone along the southern and western edges of the Trench Area.  This early action
is described in the engineering evaluation/cost analysis for the Mitchell Branch and the
K-1070-C/D Area trenches (DOE 1997b).

       Source characterization of the Trench, the North Pits, and the South Pits Areas, as well
as secondary sources at the Pits Downgradient and K-1414 Areas, and their impact to groundwater
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will be reevaluated in the ETTP RI and addressed in the ETTP FS.  Selection of the final remedy
addressing these components of the K-1070-C/D OU has been deferred to the ETTP ROD.

                                        SUMMARY  OF  SITE CHARACTERISTICS

       The following summarizes the RI findings (nature and extent of contamination and fate and
transport) for the G Pit, the Concrete Pad Area, the Landfarm Area, and surface water and
sediments.  Documentation supporting the ETTP ROD will present details of the North Pits Area,
the other pits in the South Pits Area, the Trench Area, the Pits Downgradient Area, and the
K-1414 Area.

G PIT

       The G Pit at the South Pits Area appears to be a primary source of contaminant release to
K-1070-C/D OU soil and groundwater, based on adjacent soil borings and source-term samples
collected from within this pit.  Data collected during the RI define the nature and extent
(lateral and vertical) of a soil contaminant plume emanating from the G Pit and extending
downgradient to the Pits Downgradient Area.  Leachate samples from the G Pit include acetone
(500 mg/L),  1,1,1-trichloroethane  (TCA)  (840 mg/L), trichloroethene  (TCE)  (220 mg/L),
1,1-dichloroethane (DCA)  (43 mg/L), and methylene chloride  (7.1 mg/L.  The concentrations of TCE
(20 percent of solubility) and 1,1-DCA  (19 percent of solubility) show the presence of
free-phase contamination, indicating that the G Pit is a continuing source of soil and
groundwater contamination.  Fate and transport modeling of releases from the G Pit area shows
that several chlorinated hydrocarbon concentrations exceeded or will exceed the groundwater
maximum contaminant levels (MCLs) specified by the Safe Drinking Water Act of 1974  [40 Code of
Federal Regulations (CFR) 141], and that maximum concentrations for all contaminants detected in
the G Pit (including volatile organic compounds, semivolatile organic compounds, and
radionuclides) have not yet peaked at the water table and will continue to increase.  Because
groundwater is not within the scope of this OU,  MCLs are not an applicable or relevant and
appropriate reguirement  (ARAR) for this action.   However, these exceedances of MCLs  (either
actual or modeled future) indicate that the G Pit is contributing to groundwater contamination
at unacceptable levels.

CONCRETE PAD AREA

       Surface soil samples [0-0.3 m (0-1 ft)]  indicate significant levels of radiological and
organic contamination.  The major contaminants are isotopes of uranium (234 U and 238 U) and
technetium  (99 Tc).  Detected levels of 234 U averaged 75.5 pCi/g, 238 U averaged 60.9 pCi/g,
and 99 Tc averaged 16.4 pCi/g. Gross alpha levels averaged 360 pCi/g, and gross beta levels
averaged 250 pCi/g.

       Because the Concrete Pad lies directly over the Trench Area, sampling the soil around the
pad was limited to prevent intrusion into the trenches.  Therefore, the lateral and vertical
extent of contamination has not been fully defined; however, contamination in the Concrete Pad
Area appears to be concentrated in a shallow, surface soil interval.  Contaminants migrating
vertically from the Concrete Pad Area may commingle with contaminants in the underlying Trench
Area; therefore, data from groundwater wells cannot discriminate between these two source areas.
Based on models of contaminant leaching, several contaminants from the Concrete Pad Area soils
could migrate to groundwater in levels above MCLs or residential risk-based levels.  These
include technetium, 1,2-dichloroethene  (DCE), tetrachloroethene  (PCE), and TCE.

LANDFARM AREA

       Confirmatory soil samples at the Landfarm Area indicate no significant contamination
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remains from landfarming activities; however, an anomalous sample concentration of PCE was
detected in this area.  This isolated occurrence of PCE is within acceptable residential and
industrial risk levels for soils; thus no unacceptable risks are associated with soil at the
Landfarm Area.

SURFACE WATER AND SEDIMENTS

        The surface waters (wet weather conveyances) in the K-1070-C/D OU do not appear to
be an off-site transport mechanism for surface soil contaminants detected at the site.
Contaminant concentrations in surface water and sediment at the K-1070-C/D area are low and at
levels that do not exceed remedial goal options developed in the RI.  Metals and radionuclides
detected in sediment at the K-1070-C/D OU were near their detection limits or background
criteria concentrations and are therefore believed to be naturally occurring.

                                             SUMMARY OF  SITE RISKS

       Following is a summary of the site risks presented in the K-1070-C/D RI for the Concrete
Pad Area, the G Pit, the Landfarm Area, and surface water and sediment.  Unacceptable risks
are assumed to exist from exposure to buried waste at the Trench Area, the North Pits Area, and
the South Pits Area.  These risks, as well as risks from exposure to secondary sources and
contaminated groundwater at the Trench, North Pits, South Pits, Concrete Pad, Pits Downgradient,
and K-1414 Areas, will be reevaluated in the ETTP RI/FS.

CONCRETE PAD AREA

       The Concrete Pad Area is the only area that poses an unacceptable health risk from future
industrial worker exposure to soil or concrete.  Soil/concrete exposure could occur through
dermal contact, ingestion, or external exposure to ionizing radiation.  Industrial risk is 2 x
10 -4, based on external exposure to 238 U in soil.

G PIT

       The G Pit is the primary source of contaminant release to groundwater in the South Pits
Area.  These contaminants include 1,1-DCE, TCE, 1,1,2-TCA, and PCE.

LANDFARM AREA

       No unacceptable risk was found at the Landfarm Area at the K-1070-C/D OU; therefore,
remedial action is unnecessary for this area.

SURFACE WATER AND SEDIMENTS

       No unacceptable risk was found for surface water and sediment at the K-1070-C/D OU;
therefore, remedial action is unnecessary for these media.

       The RI ecological risk assessment indicates that ecological risks for direct contact with
and ingestion of contaminants in surface water and surface soil at the K-1070-C/D OU are
negligible.  Therefore, remedial action to address ecological risk is unnecessary.

                                          DESCRIPTION  OF ALTERNATIVES

       Four alternatives (Alternatives 1,  2,  3, and 4) were developed and carried forward for
detailed analysis in the FS.   The primary differences among these alternatives relate to the
Concrete Pad Area and the G Pit  (see Table 2.1).
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                       Table  2.1.   Summary  of  alternatives  for  the  Concrete  Pad Area  and
                             the G  Pit  for  the K-1070-C/D OU, Oak Ridge,  Tennessee
   Alternative

        1

        2
                                                                                 G Pit
                                                                     No action
                                                                     Recycle empty drums, ISV, add
                                                                     and maintain soil cover

                                                                     Excavate and dispose of at
                                                                     Envirocare of Utah, Inc.
                                                                     Recycle empty drums, ISV, add
                                                                     and maintain soil cover

                                                                     Excavate, store temporarily,
                                                                     treat, and dispose of
          Concrete Pad Area

No action

Remove the Concrete Pad and surface
soils, dispose of at NTS

Remove the Concrete Pad and
contaminated surface soils, dispose of at
NTS

Cover the Concrete Pad with soil
Preferred alternative   Cover the Concrete Pad with soil
ISV = in situ vitrification
NTS = Nevada Test Site
OU = operable unit
       These alternatives were developed and evaluated based on the assumption that drums and
other materials in the G Pit were contained just below the surface.  The resulting preferred
alternative, documented in the April 1, 1996, proposed plan, was Alternative 4, which includes
in situ vitrification  (ISV) of the G Pit.  However, a subseguent review of G Pit information
revealed that man-made materials are likely contained throughout the depth of the G Pit,
resulting in safety concerns from the use of ISV. Because of this discovery, DOE added another
alternative, the preferred alternative delineated in the proposed plan.  This alternative is a
combination of Alternatives 3 and 4 and does not include ISV.  Details and rationale are
provided under the preferred alternative discussion in this ROD.

       The focus of all action alternatives presented here (and in the proposed plan)  is the G
Pit and the Concrete Pad.  Institutional controls to prevent exposure to waste or contaminated
groundwater at other areas of the K-1070-C/D OU  (as they currently exist under the S&M program)
were components of these alternatives as developed in the FS and are presented here as such for
consistency.  However, under the selected remedy (detailed later in this ROD), these
institutional controls are an interim measure because reevaluation of sources and contaminated
groundwater in portions of the K-1070 C/D OU have now been deferred to the ETTP RI/FS.

       Specific details on each alternative are discussed in the following paragraphs.

ALTERNATIVE 1:  NO ACTION
       For all the waste areas,  Alternative 1 would involve no remedial actions or restrictions
to reduce potential exposure.  Current controls and restrictions would no longer apply;
therefore, the site would be available for unrestricted land use.  This alternative would leave
unprotected and unattended classified waste buried in the Trench Area, which would result in
unacceptable risk to human health and the environment.  DOE is reguired by CERCLA to include
this alternative as a baseline in the RI/FS selection process for comparison with other selected
alternatives.
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ALTERNATIVE 2:  CONCRETE PAD AREA REMOVAL, G PIT ISV, AND INSTITUTIONAL CONTROLS AND MONITORING

       This alternative consists of removing the Concrete Pad and associated contaminated soils
and off-site disposal of the waste at the Nevada Test Site  (NTS); recycling any drums from the
G Pit and ISV of G Pit contaminated soils followed by the addition of a soil cover; and
maintenance of new and existing soil covers and institutional controls for the North Pits, South
Pits, and Trench Areas.  This alternative would designate waste areas as access-restricted,
inactive disposal areas.

       The Concrete Pad would be demolished using standard construction eguipment.  The waste
concrete and excavated soils, approximately 9.9 m 3  (13 yd 3) and 81.8 m 3 (107 yd 3 ),
respectively, would be placed in shipping containers and transported by truck and rail to NTS
for final disposal.  Excavated areas would be regraded using uncontaminated native soil.

       Metal drums buried near the surface of the G Pit would be excavated and sent to a metal
recycling facility for recycling.  G Pit soils would be treated in place using ISV.  ISV would
create a glass monolith, destroying the organic contaminants in the G Pit and encapsulating
inorganic and radioactive contaminants.  ISV would also prevent further migration of
contaminants into groundwater and reduce waste volume by approximately 20 percent.  The G Pit
would be backfilled and covered with uncontaminated native soil to protect treated waste.

       New and existing soil covers for the North Pits,  South Pits,  and Trench Areas would
reguire routine inspections and periodic maintenance.  Institutional controls would consist of
access and use restrictions such as fencing, deed restrictions, and administrative controls to
prevent unearthing the buried waste.  Groundwater monitoring and periodic radiological surveys
would be performed.

ALTERNATIVE 3:  CONCRETE PAD AREA AND G PIT REMOVAL, AND INSTITUTIONAL CONTROLS AND MONITORING

       This alternative involves the removal and off-site disposal of the Concrete Pad and its
associated contaminated soils and G Pit soils, drums, and wastes.  Institutional controls and
monitoring would be implemented for the North Pits, South Pits, and Trench Areas.  This
alternative would designate the waste areas as access-restricted, inactive disposal areas.

       Removal of the Concrete Pad and associated soils would occur as described for Alternative
2.  Standard construction eguipment would be used to remove soil, drums, and waste from the G
Pit. Approximately 133 m 3  (174 yd 3)  of contaminated material would be loaded onto railcars at
ETTP and transported to the Envirocare of Utah, Inc., disposal facility in Clive, Utah, for
chemical stabilization and final disposal.

       Institutional controls would be implemented as described for Alternative 2.

ALTERNATIVE 4:  CONCRETE PAD AREA SOIL COVER, G PIT ISV, AND INSTITUTIONAL CONTROLS AND
MONITORING

       This alternative involves placing a soil cover over the Concrete Pad and associated
contaminated soils; reuse/recycling of any empty G Pit drums and ISV with a soil cover for the G
Pit; maintenance of the new G Pit and Concrete Pad Area soil covers and other existing trench/
pit soil covers; and institutional controls and monitoring for the North Pits, South Pits, and
Trench Areas.  This alternative would designate the waste areas as access-restricted, inactive
disposal areas.

       A 0.61-m (2-ft)  soil cover would be placed over contaminated material at the Concrete Pad
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Area.  Risk-based modeling of the Concrete Pad Area indicated that 0.5 m  (1.64 ft) of native
soil would adequately protect the on-site worker. An earthen berm would be built at the Concrete
Pad Area to divert storm runoff.  Soil would be seeded with grass to prevent the protective
cover from eroding.

       ISV of G Pit soils,  materials reuse of any excavated drums,  institutional controls, and
monitoring would be implemented as described for Alternative 2.

       Institutional controls would be implemented as described for Alternative 2.

PREFERRED ALTERNATIVE:  CONCRETE PAD AREA SOIL COVER, G PIT REMOVAL, AND INTERIM INSTITUTIONAL
CONTROLS

       The DOE original preferred alternative for the K-1070-C/D OU was Alternative 4.  However,
it has since been discovered that man-made materials, such as drums and other containers, exist
throughout the depth of the G Pit, not just at the surface as originally thought it would be
prohibitively difficult to segregate and remove these materials, and ISV of the G Pit with these
materials present could result in unacceptable pressure and/or temperature excursions, leading
to possible contaminant migration and personnel injury.  Accordingly, DOE, with the concurrence
of TDEC and EPA, developed a new preferred alternative that combines Alternatives 3 and 4 and
presented it in the current version of the proposed plan.  Specifically, the excavation,
treatment, and disposal of material from the G Pit (Alternative 3)  and the soil cover of the
Concrete Pad  (Alternative 4)  are combined to form this remedy.  Interim storage of excavated G
Pit material, an evaluation of ex situ treatment technologies to meet classification
requirements and WAG for a permitted disposal facility, and a bench-scale test  (proof-of-process
evaluation) of those technologies that are not currently components of Alternative 3 have been
added to this alternative as presented in the current version of the proposed plan.  Existing
institutional controls at the K-1070-C/D OU would also be required until ultimate decisions for
the K-1070-C/D OU are finalized in the ETTP ROD.  No further action would be taken for the
Landfarm Area and for surface water and sediment at the K-1070-C/D OU.

       The action on G Pit would be carried out in two phases.  The first phase would include
excavation of G Pit material and placement into compliant interim storage at ETTP and a written
evaluation of ex situ treatment technologies for applicability to this material.  The G Pit
would also be backfilled during this first phase. The second phase would include interim
storage, proof-of-process,  full-scale treatment, and ultimate disposal of the G Pit wastes.

                                SUMMARY OF COMPARATIVE  ANALYSIS  OF ALTERNATIVES

       Alternatives 1, 2,  3,  and 4 were evaluated during the detailed analysis in the K-1070-C/D
FS.   The preferred alternative was partially evaluated in the FS under Alternatives 3 and 4.  A
detailed analysis of the new preferred alternative is included here.

       The alternatives were evaluated against the first seven of nine criteria developed by EPA
(EPA 1988a) to measure overall feasibility and acceptability of remedial alternatives.  The last
two criteria  (state and community acceptance) have been evaluated based on a regulatory agency
review and public comments.  The first two criteria  (overall protection of human health and the
environment and compliance with ARARs) must be met by any alternative considered for selection
in the ROD.  The next five criteria (long-term effectiveness; reduction of toxicity, mobility,
and volume through treatment; short-term effectiveness; implementability; and cost) are
considered together and represent the primary criteria upon which the analysis is based, taking
into account technical, cost, institutional, and risk concerns.
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OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

       Alternative 1 does not protect human health and the environment.  If action is not taken,
G Pit seepage will continue to contaminate groundwater, and unacceptable risk from exposure
to the Concrete Pad Area may result.  Alternatives 2, 3, 4, and the preferred alternative would
protect human health and the environment by minimizing exposure to the Concrete Pad and by
removing or treating the contents of the G Pit, which is a primary contributor to groundwater
contamination from the site.

COMPLIANCE WITH ARARs

       All the alternatives would comply with ARARs.

LONG-TERM EFFECTIVENESS AND PERMANENCE

       Alternative 1 would not be effective in the long-term because current site conditions do
not protect human health and the environment and these conditions are likely to worsen in the
future.  If removal of soil/waste is successfully implemented, the non-ISV component of
Alternative 2, Alternative 3, and the preferred alternative would be effective in the long term.

       For the Concrete Pad Area, Alternatives 2 and 3 would provide a more permanent remedy than
Alternative 4 and the preferred alternative because the pad and contaminated soils would be
removed.

       Because ISV cannot safely process the materials at the G Pit,  the ISV components of
Alternatives 2 and 4 would not be effective.

REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT

       For Alternative 3 and the preferred alternative, treatment of excavated soils from the G
Pit would reduce the mobility of contaminants but could increase the volume of waste, depending
on the treatment technology selected.

SHORT-TERM EFFECTIVENESS

       Alternatives 2, 3, and the preferred alternative are effective but present some short-term
risk to workers and the environment because they involve excavation of contaminated soils,
increasing the potential for contaminant migration during remediation.  Off-site waste transport
and disposal of waste material slightly increase risk to surrounding communities.  However,
operational controls during remediation would minimize the short-term effects of these actions
in compliance with regulatory reguirements and DOE Orders.

       Because man-made materials such as drums are now thought to be dispersed throughout the G
Pit, removing them before ISV would be prohibitively difficult.  If ISV were implemented at the
G Pit with these materials present, possible pressure and temperature excursions could
jeopardize personnel safety and increase the likelihood of contaminant migration.

IMPLEMENTABILITY

       Alternative 3,  the preferred alternative, and the non-ISV components of Alternatives 2 and
4 are technically and administratively feasible to implement.  The materials and services
reguired for excavation, treatment, and disposal are readily available.  Some additional
administrative reguirements may arise for the disposal component of Alternatives 2, 3, and the
preferred alternative because of specific regulations concerning characterization, packaging,
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transportation, and acceptance of waste for off-site disposition.

COST

       Following is a comparison of the costs developed in the FS for Alternatives 1,  2,  3,  and 4
and the newly developed costs for the preferred alternative.  These costs were developed with an
intended accuracy range of +50 to -30 percent.  Within this range of accuracy, Alternative 4 and
the preferred alternative have the lowest costs while the costs for Alternatives 2 and 3 are
higher and approximately egual.   The present-worth cost of the preferred alternative,  which was
defined as $5.7 million in the July 1997 proposed plan, has been reestimated at $5.9 million.
The difference between the $5.7 million and the $5.9 million presented here is the present value
cost of 5 years of operation and maintenance  (O&M) for the site.  This 5-year interval is used
as a temporary period until a final decision is made and action is implemented for the remaining
areas of the K-1070-C/D OU as part of the ETTP ROD and remedial action.

       Present-worth Cost (based on a 30-year present value)

       •      Alternative 1                      no cost
              Alternative 2                      $7.0 million
       •      Alternative 3                      $7.2 million
       •      Alternative 4                      $5.3 million
       •      Preferred alternative             $5.9 million

STATE ACCEPTANCE

       This criterion evaluates  whether the state agrees with, opposes, or has no comment on the
preferred alternative.  The state of Tennessee concurs with the selected remedy.

COMMUNITY ACCEPTANCE

       Community acceptance addresses the issues and concerns the public may have regarding each
of the alternatives.  The "Highlights of Community Participation" section summarizes community
participation.  The selected remedy was not modified based on public comments.  Part 3 of this
ROD presents the comment submitted during the first public comment period and a response to this
comment.  No comments were received from the second public comment period.

                                                SEIiECTED REMEDY

       DOE, with the concurrence of EPA and TDEC,  determined that the preferred alternative as
presented in the July 1997 proposed plan is the most appropriate remedy for protection of human
health and the environment at the K-1070-C/D OU.  This remedy consists of an interim soil cover
over the Concrete Pad to protect the industrial worker, and excavation, proof-of-process
examination, full-scale treatment, and disposal of the contents of the G Pit to eliminate a
primary source of groundwater contamination at the OU. This portion of the remedy will be
implemented in two phases.  No further action will be taken for the Landfarm Area and for
surface water and sediment at the K-1070-C/D OU.

       Selection of this remedy is based on the comparative analysis of the alternatives
presented in the FS and on information regarding G Pit materials obtained since publication of
the FS.   This alternative provides the best balance of trade-offs with respect to the CERCLA
criteria used to evaluate remedial alternatives.  This alternative is effective in both the
short- and long-term.  It has implementability advantages over other alternatives because waste
transport is not reguired for the Concrete Pad and because ISV is not implemented at the G Pit.
This remedy complies with ARARs, provides overall protection of human health and the
-------
environment, and is cost-effective.

       Specific details on the selected remedy follow.

Concrete Pad

       •       A soil  cover,  considered an interim measure,  will  be  placed over  the  Concrete  Pad
              Area with adequate thickness and sufficient  areal  extent  to provide protection from
              direct  exposure to ionizing radiation.  A conceptual  example of the areal  extent  of
              such a  cover is shown in Figure  2.2.   The soil  cover  will be seeded and graded to
              facilitate drainage and maintenance.   The soil  cover  will be placed over areas
              directly related to the Concrete Pad contamination.   The  soil will be placed over
              the existing plastic cover to minimize the possibility of contamination of cover
              soil.   The necessary thickness and areal  extent of the soil cover will be  confirmed
              in the  field by radiological surveys to verify  that the remediated Concrete Pad Area
              is within acceptable exposure limits of < 10  iR/hour  above background (based on a 1
              x 10 -4 risk for an industrial worker working exclusively on the  Concrete  Pad  for 9
              years).   If the survey indicates that the established exposure criteria for the
              industrial worker have not been  met,  more soil  will be added to the soil cover.   The
              soil cover will be maintained under the existing S&M  program to ensure interim
              protection until a long-term decision for the Concrete Pad Area is finalized in the
              ETTP ROD.
G Pit
              Phase I:   Soil,  debris,  and other material  from the  G Pit  will  be  removed,
              segregated,  characterized,  and temporarily  placed into classified  mixed waste
              storage at ETTP.  Standard construction equipment will be used to remove the
              materials  from the G Pit [estimated at 190  m 3  (250  yd 3)].   The basis  of  this
              estimate is a visual approximation from aerial  photographs of the  G Pit boundaries,
              approximately 6 m by 6  m (20 ft by 20  ft).   Depth is assumed to be 4.6  m (15 ft),
              based on bedrock elevation.   Characterization data obtained during the  excavation
              will be used for a written assessment  of potential treatment technologies  for the  G
              Pit wastes.   Following  excavation,  the G Pit will be backfilled and properly graded.

              Phase II:   While the G  Pit waste is in compliant classified storage at  ETTP, a
              proof-of-process evaluation will be conducted using  the ex situ treatment
              technologies identified in the first phase  of the selected remedy.   This
              proof-of-process evaluation will consist of a bench-scale  test  of  these treatment
              technologies on samples of the G Pit waste.   Results of the proof-of-process
              evaluation will be analyzed and used to select  the most appropriate waste  treatment
              technology.   Once a technology is selected,  it  will  be implemented for  full-scale
              treatment  of the G Pit  waste to satisfy applicable WAG (including  RCRA  LDRs).
              Because the G Pit waste is expected to be classified,  the  treatment process used to
              satisfy LDRs is anticipated to also destroy the classified components of the waste.
              Following successful treatment,  the waste will  be disposed of in a facility that can
              lawfully accept it.


Interim Institutional Controls
              Radiological  walkover surveys  will  be conducted on site  to confirm the  effectiveness
              of the Concrete Pad soil  cover in preventing exposure  to ionizing radiation.
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       •       Existing institutional controls in the S&M program will continue until final
              decisions are made for the K-1070-C/D OU in the ETTP ROD.   These controls include
              access restrictions and maintenance of soil covers.

       Groundwater monitoring reguirements will be determined in the ETTP RI/FS (which will
address protection of groundwater).   However, the results of ongoing monitoring for the SW-31
Spring (not included in the K-1070-C/D OU) under a separate action will be reviewed to assess
the impact of actions on the G Pit in the K-1070-C/D OU.

       The total escalated cost for  this project is $6.3 million  (Table 2.2).   The present-worth
capital cost of this project is $5.7 million.  The average annual O&M cost, escalated to the
year of inception, is $44,700.  The  present-worth cost of O&M for a 5-year period is $160,000.
            Table 2.2.   Cost estimate for the selected remedy,  K-1070-C/D OU,  Oak Ridge,  Tennessee
          Remedial project
        Capital cost ($ x 1,000)            O&M cost
                                               ($ x 1,000)
Direct a   Indirect a   Total a   Present   Annual a     Present
                                  worth b                worth b
                                                      Base actions
      Construction
      Assessment
      Interim storage
      Proof-of-process
 1,349
  400
  103
  672
      G Pit full-scale treatment  2,691
        and disposal
      Base action totals          5,215
      None
                                    NA
 275         1,624
  82          482      	
  21          124      	
 137          809
 549         3,240     	

1,064        6,279    5,700

    Contingent actions

  NA           NA       NA
                                               44.7
                                                                                 NA
                                                           160
                                                                                            NA
    a Costs are escalated (average 2.7 percent escalation rate per DOE guidance).
    b Present-worth costs for 30-year study based on Building Life-Cycle analysis (version 4.20-95).
    c The total unescalated O&M cost is divided by the number of years duration and then escalated to the
       first full year of implementation.
    DOE = U.S. Department of Energy
     NA = not applicable
     OU = operable unit
                               O&M = operation and maintenance
                                 $ = dollar
                                           STATUTORY DETERMINATIONS
       Under CERCLA Section 121,  selected remedies must be protective of human health and the
environment, comply with ARARs (unless a statutory waiver is justified and granted),  be cost-
effective, and use permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable.  In addition, CERCLA includes a
preference for remedies that use treatment that permanently and significantly reduce the
toxicity, mobility, or volume of hazardous wastes as their principal element.
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PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

       The selected remedy protects human health and the environment by providing shielding from
contaminants at the Concrete Pad Area; by preventing the continued migration of contaminants
from the G Pit; and by providing institutional controls to limit site access, regulate land
usage, and maintain the soil covers until a final decision is made in the ETTP ROD.

COMPLIANCE WITH ARARS

       The selected remedy meets all ARARs,  which are discussed here and listed in Table 2.3.

       Chemical-specific requirements set health- or risk-based concentration limits or discharge
limitations in various environmental media for specific hazardous substances, pollutants, or
contaminants for remedial activities  [53 Federal Register  (FR) 51437, December 21, 1988, and FR
8741, March 8, 1990] .   These requirements generally set protective cleanup levels for the
chemicals of concern in the designated media or else indicate a safe level of discharge that may
be incorporated when considering a specific remedial activity.

       Subpart H of 40 CFR 61 addresses atmospheric radionuclide emissions from DOE facilities
and may be applicable to airborne emissions during the K-1070-C/D OU remedial activities. EPA
has issued a final National Emission Standards for Hazardous Air Pollutants rule  (54 FR 51654,
December 15, 1989) that limits emissions of radionuclides to the ambient air from DOE facilities
to amounts that would not cause any member of the public to receive an effective dose equivalent
of 10 mrem/year or more (40 CFR 61.92).  Title 40 CFR 61.93(b)(4)(i) requires radiological
emission measurements at all release points with a potential to discharge radionuclides into the
air in quantities that could cause an effective dose equivalent in excess of I percent of the
standard  (0.1 mrem/year).   All radionuclides that could contribute > 10 percent of the standard
(1 mrem/year) for a release point shall be measured.  TDEC has codified these regulations
verbatim in Rules of the Tennessee Department of Environment and Conservation, Chapter
1200-3-11.08, effective October 15, 1995.

       DOE Orders are  not promulgated regulations; thus, they are to-be-considered (TBC) guidance
and not ARARs by EPA.   However, compliance is required at DOE facilities.  The radiation
exposure limits defined in DOE Order 5400.5, "Radiation Protection of the Public and the
Environment," February 8,  1990, are an effective dose equivalent of 100 mrem/year from all
exposure pathways and all DOE sources of radiation.  The overriding principle of the DOE Order
is that all releases of radioactive material shall be as low as reasonably achievable.  DOE has
proposed these radiation protection standards for the public and the environment for
codification at 10 CFR 834  (58 FR 16268, March 15, 1993).

       Location-specific,  requirements set restrictions on the concentration of hazardous
substances or the conduct of activities solely because they are in special locations  (55 FR
8741, March 8, 1990).   Based on current information for the K-1070-C/D OU, none of the following
factors are present:  aboveground caves, Holocene faults, wetlands, floodplains, aquatic
resources, historic sites, archaeological findings, or rare, threatened, or endangered species.
Therefore, there are no location-specific ARARs triggered for the K-1070-C/D OU.

       Performance,  design,  or other action-specific requirements set controls or restrictions on
particular kinds of activities related to the management of hazardous waste  (55 FR 8741, March
8, 1990).  Selection of a particular remedial action at a site will invoke the action-specific
ARARs that may specify particular performance standards or technologies as well as environmental
levels for discharged or residual chemicals.
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                                          Table 2.3.  Summary of ARARs for soil cover of the Concrete Pad, excavation of the G Pit, and institutional controls for the North Pits,
                                                                             South Pits, and Trench Areas, K-1070-C/D OU, Oak Ridge, Tennessee
Action
                                                      Requirement
                                                          None
                                                                                                                  Prerequisites
                                                                                                                                                           Citation
                                                                       Location-specific

                                                                       Chemical-specific
Control of radionuclide
emissions
                           Exposures to members of the public from all radiation sources released
                           into the atmosphere shall not cause an EDE to be > 10 mrem
                           (0.1 mSv)/year

                           Radiological emission measurements must be performed at all release
                           points that have a potential to discharge radionuclides into the air in
                           guantities which could cause an EDE in excess of 1 % of the standard
                           (0.1 mrem/year).  All radionuclides which could contribute > 10% of
                           the standard (1 mrem/year for the release point shall he measured

Protection of the general  DOE will carry out all DOE activities to ensure that radiation doses to
public                     individuals will be ALARA

                           Exposures to members of the public from all radiation sources shall
                           not cause an EDE to be > 100 mrem (1 mSv)/year
Surface water control
                                                                       Action-specific

                           Implement good site planning and best management practices to
                           control storm water discharges including:

                           6 document best management practices in a stormwater control plan
                             or eguivalent document

                           6 minimal clearing for grading

                           6 removal of vegetation cover only within 20 days of construction

                           6 perform weekly erosion control inspections and maintenance

                           6 control measures to detain runoff

                           6 discharges must not cause erosion
                                                                                                      None
Point source discharge of radionuclides
into the ambient air from a DOE
facility-applicable
                                                                                                      Release of radionuclides info the
                                                                                                      environment-TBC
                                                                                                      5400.5(11.la);
                                                                                                      10 CFR 834  (proposed)
Control of stormwater discharges
associated with construction activities at
industrial sites that result in a disturbance
of > 5 acres of total land area. For
those sites with < 5 acres affected-
relevant and appropriate
                                                                                                                                                       None
40 CFR 61.92;
Rules of the TDEC
1200-3-11-.08

40 CFR 61.93;
Rules of the TDEC
1200-3-11-.08
                                                 DOE Order 5400.5 (1.4)
                                                 10 CFR 834 (proposed)

                                                 DOE Order
                                                                                                                                                       40 CFR 122;
                                                                                                                                                       Rules of the TDEC
                                                                                                                                                       1200-4-10-.05
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                                                              Table 2.3. (continued)
Action

Fugitive emissions from
excavation activities
                       Requirement

Take reasonable precautions to prevent particulate matter from
becoming airborne; no visible emissions are permitted beyond property
boundary lines for more thin 5 minutes/hour or 20 minutes/day.
Potential nonpoint sources of fugitive emissions are included in the
plantwide fugitive emissions plan
        Prerequisites

Nonpoint source air emissions-
applicable
    Citation

Rules of the TDEC
1200-3-8-.01
Characterization/management
of excavated wastes, PPE and
other secondary wastes
streams generated during
remediation
A person who generates solid waste must determine whether that waste
is hazardous using various methods, including application of
knowledge or the hazardous characteristics of the waste based on
information regarding the materials or processes used

All RCRA restricted waste generated during remedial activities must
be treated to meet the LDR before land disposal
Generation of waste which is potentially
RCRA contaminated- applicable
                                                                                                          Disposal of wastes potentially
                                                                                                          contaminated with RCRA constituents-
                                                                                                          applicable
40 CFR 262.11;
Rules of the TDEC
      -11-.03(1)(b)
                                                 40 CFR 268.40;
                                                 Rules of the TDEC
                                                 1200-1-11-.10(3)(a)
                               LLW generators must characterize and segregate LLW from
                               uncontaminated waste and otherwise minimize the amount of LLW
                               generated. Subseguent management of LLW must be accordance with
                               DOE Order 5820.2A.
                                                                           Generators of LLW-TBC
                                                                                                                            DOE Order
                                                                                                                            5820.2A(III.3)
Characterization/management
of debris containing RCRA
hazardous waste
Surface contamination or a representative sample, of debris must be
characterized to determine whether it is RCRA-listed or RCRA
characteristic waste and a determination made as to whether it is waste
restricted from land disposal using TCLP or operator knowledge
                               Hazardous debris must  (1) be treated by specified technologies based
                               on the type of debris and type of contaminants before find disposal or
                               (2) be treated to meet existing treatment standards for the specific
                               waste contaminating the debris
Debris contaminated with RCRA-listed or
characteristic waste-applicable
40 CFR 262.11;
40 CFR 268.7(a);
Rules of the TDEC
1200-1-11-.03(1)(b)
Rules of the TDEC
1200-1-11-.10(1)(a)
40 CFR 268.45;
Rules of the TDEC
1200-1-11-.10(3)(a)
                               Debris treated by one of the specified extraction or destruction
                               technologies, meets the reguirements for a clean debris surface and
                               which no longer exhibits a characteristic meets the LDR treatment
                               standards and is no longer subject to LDR. Such debris may be
                               disposed of at a sanitary landfill, recycled, or reused; debris treated by
                               immobilization must be disposed of in a Subtitle C facility
                                                                                                                            40 CFR 268.45 (c);
                                                                                                                            Rules of the TDEC
                                                                                                                            1200-1-11-.10 (3) (a)
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                                                                                                  Table 2.3.  (continued)
Action
                                                      Requirement
                                                                                 Prerequisites
                                                                                                                                                              Citation
Collection, transfer to CNF
and treatment or any water
generated from
decontamination activities
On-site wastewater treatment units that are part of a wastewater
treatment facility that is subject to regulation under Section 402 or
Section 307 (b) of CWA  (i.e., are NPDES permitted) are exempt from
the reguirements of RCRA Subtitle C standards.
All tank systems, conveyance systems,
and ancillary eguipment used to store or
transport RCRA contaminated
wastewater-applicable
40 CFR 264.1(g)(6)
40 CFR 260.10;
40 CFR 270.1(c)(2)
53 FR 34079,
September 2, 1988
                                 Must meet WAG of receiving facility
                                                                                                                         DOE Order 5820.2A;
                                                                                                                         K/SS-538, February
                                                                                                                         1990  (CNF WAG)
Storage of mixed hazardous
waste
Allows storage of mixed wastes at ORR pending development of
treatment capacity
Storage of mixed waste-applicable
FFCAct Section 105;
ORR FFA
Storage of RCRA hazardous
waste in containers
Must comply with the container storage reguirements of 40 CFR
262.34 and 40 CFR 264.171-174
Storage of RCRA hazardous waste-
applicable
40 CFR 264.34;
40 CFR 264.171-178;
Rules of the TDEC
1200-1-11-.06(9)
Residual radioactivity left in
place at the Concrete Pad and
G Pit
Specific guidelines for allowable levels of residual radioactivity left in
place
Long-term management of radioactivity
left in place-TBC
DOE Order 5400.5
(IV);
10 CFR 834 (proposed)
Institutional controls
Implement institutional controls for all areas where containment is a
remedial action; such controls include, at a minimum, deed restrictions
for sale and use of the property and securing the area to prevent
human contact with hazardous substances
Containment as final remedial action for    Rules of the TDEC
hazardous substances which pose or may      1200-1-13-.08(10)
pose an unreasonable threat to the public,
health, safety or the environment-
relevant and appropriate
Transportation of waste/
treatment residuals to off-site
disposal facility
The waste must meet packaging, labeling, marking, placarding and
pretransport reguirements in accordance with DOT regulations
Transportation of hazardous and
radioactive materials above exempt
guantities-applicable
49 CFR Parts 171,  172,
173, and 177;
DOE Order 460.1 (TBC)
                                 Must meet packaging reguirements based on the maximum activity of
                                 radioactive material in a package
                                                                             Packaging of radioactive materials above
                                                                             exempt guantities for public transport-
                                                                             applicable
                                            49 CFR 173.431;
                                            49 CFR 173.433;
                                            49 CFR 173.435;
                                            49 CFR 173.41
                                 Must be marked with hazardous waste marking, generator's name and
                                 address, and the manifest docket number
                                                                             Transportation of hazardous waste in        40 CFR 262.32(b)
                                                                             containers of 110 gal or less-applicable
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                                                              Table 2.3. (continued)
Action

Transportation of waste/
treatment residuals to off-site
disposal facility  (continued)
                     Requirement

Generators must certify before shipment that waste meets WAG of
receiving facility
                                 LLW must be disposed of on site; if off-site disposal is required
                                 because lack of capacity, disposal must be to a DOE facility

                                 Off-site disposal of LLW to a commercial facility requires an
                                 exemption from the on-site disposal requirements of DOE Order
                                 5920.2A; requests for exemption must be approved by the DOE ORO
                                 field office. Must meet DOE Order and implementinq procedural
                                 requirements for off-site shipments
    Prerequisites

Waste shipped from one field
orqanization to another for disposal-
TBC

Shipments of LLW-TBC
                                                                             Shipments of LLW-TBC
    Citation

DOE Order
5820.2A(III)


DOE Order 5820.2A


DOE Order 5820.2A
ALARA = as low as reasonably achievable
ARAR = applicable or relevant and appropriate
 requirement
CFR = Code of Federal Regulations
CNF = Central Neutralization Facility
CWA = Clean Water Act of 1972
DOE = U.S. Department of Energy
DOT = U.S. Department of Transportation
EDE = effective dose equivalent
FFA = Federal Facility Agreement
FFCAct = Federal Facility Compliance Act of 1992
                                FR = Federal Register
                                > = greater than
                                gal = gallon
                                < = less than
                                LDR = land disposal restrictions
                                LLW = low-level (radioactive)  waste
                                mrem = millirem
                                mSv = milliSievert
                                NPDES = National Pollutant Discharge Elimination
                                 System
                                ORO = Oak Ridge Operations
                                ORR = Oak Ridge Reservation
           OU = operable unit
           % = percent
           PPE = personal protective equipment
           RCRA = Resource Conservation and Recovery Act
            of 1976
           TBC = to be considered
           TCLP = Toxic Characteristic Leaching Procedure
           TDEC = Tennessee Department of Environment and
            Conservation
           WAG = waste acceptance criteria
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Stormwater Runoff

       Stormwater discharges from activities at industrial sites involving construction
operations that result in the disturbance of 2 ha (5 acres) of total land or more have been
included in the final rule for the National Pollutant Discharge Elimination System (NPDES)
permits for Stormwater discharges and incorporated into the TDEC permitting regulations (40 CFR
122; Rules of the TDEC 1200-4-10-. 05).  Consultation with TDEC is required to ensure compliance
with the substantive requirements of the NPDES permitting process for Stormwater discharges
during construction activities (Rules of the TDEC 1200-4-10-. 05) .  In particular, implementation
of good site planning and best management practices to control Stormwater discharges is
required.  Stormwater discharge requirements are applicable if 2 ha  (5 acres)  or more are
disturbed; otherwise they are relevant and appropriate requirements.  Stormwater flow controls
such as berms, silt fences, hay bales, and other best management practices will be followed
during implementation of the selected remedy to comply with Stormwater runoff ARARs.

Fugitive Emissions

       Elevation of airborne particulate concentrations could  result from remediation activities.
The TDEC Air Pollution Commission has promulgated applicable requirements in Rules of the TDEC
1200-3-8.010 for the control of fugitive dust.  An operator must take reasonable precautions to
prevent particulate matter from becoming airborne.  In addition, fugitive dust may not be
emitted as a visible emission beyond property boundary lines for more than 5 minute/hour or 20
minute/day.  To ensure compliance with ETTP air permits and to meet the substantive requirements
of fugitive dust emissions, dust suppression measures  (such as water, organic agents, or foams
sprayed over the area of concern to prevent dust generation) combined with ambient air
monitoring stations are to be recommended as a best management approach for activities during
the K-1070-C/D OU remediation.

Characterization and Management of Excavated Pit Material and Secondary Waste Streams

       During remediation,  excavated pit material, personal protective equipment, and other
secondary wastes will be generated that may be contaminated with RCRA-listed or
RCRA-characteristic waste and/or low-level  (radioactive)  waste  (LLW) .  When a solid waste is
generated, it must be classified as hazardous or nonhazardous  and managed accordingly (see
Table 2.3).  DOE Order 5820.2A, "Radioactive Waste Management," requires generators of LLW to
characterize and segregate LLW to minimize the amount of LLW generated.

       Any empty containers contaminated with RCRA-listed waste that are removed from the G Pit
would be exempt from RCRA  (including the LDRs) if they meet the definition of an intact
container as specified in 40 CFR 268.2 and meet the requirements specified in 40 CFR 261.7 for
empty containers.  If the container cannot qualify as an empty intact container, any container
contaminated with RCRA-hazardous waste must be handled and managed as hazardous debris.
Treatment standards for hazardous debris are codified at 40 CFR 268.45.  All hazardous debris
and any incidental soil associated with the debris must be treated by the specified
immobilization, extraction, or destruction technologies or meet the waste-specific LDR treatment
standard for the waste contaminating the debris [40 CFR 268.45(a)].  If the debris is treated by
an extraction or destruction technology, it will no longer be  considered hazardous and need not
be managed in a RCRA Subtitle C facility provided the debris no longer exhibits a hazardous
characteristic.  To meet the LDR treatment standards for contaminated soil, a treatability
variance can be obtained under 40 CFR 268.44.  EPA has developed guidance for obtaining and
complying with a treatability variance for soil that is contaminated with RCRA hazardous wastes
for which treatment standards have already been set [EPA Office of Solid Waste and Emergency
Response  (OSWER) Directive 9347.3-06FS, July 1989].
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Wastewater from Decontamination Activities

       Any wastewater from decontamination activities at the G Pit and groundwater collected
during excavation will be transferred to the Central Neutralization Facility (CNF).   The
wastewater will be evaluated to ensure that it will meet WAG.  The wastewater may contain
RCRA-listed waste.  However, any on-site wastewater treatment units that are part of a
wastewater treatment facility subject to regulation under Clean Water Act of 1972 Sections 402
or 307(b) (i.e., are NPDES-permitted) are exempt from the reguirements of RCRA Subtitle C
standards for all tank systems, conveyance systems  (whether piped or trucked),  and ancillary
eguipment [40 CFR 264.1(g)(6); 40 CFR 260.10; 40 CFR 270.1(c)(2); 53 FR 34079,  September 2,
1988].  If the wastewater does not meet CNF WAG, it will be stored on site in compliance with 40
CFR 262.34,  40 CFR 264.171-178, and pursuant to Section 105 of the Federal Facility Compliance
Act of 1992 (FFCAct) and the FFA.

Storage of Waste Pending Transfer to Existing Permitted Storage

       Some of the excavated wastes are expected to contain RCRA-listed and/or
RCRA-characteristic waste in addition to LLW and will thus be considered mixed waste.  In
accordance with FFCAct Section 105, the FFA among Tennessee, DOE, and EPA, and approved RODs
(and implementing plans)  issued pursuant to the FFA govern the development of treatment
technologies and capacities, storage pending treatment, and ultimate treatment of LDR mixed
waste generated by ORR environmental restoration activities.  Accordingly, mixed wastes
generated under this ROD may be stored at ORR pending the development of treatment capacity for
the mixed waste in accordance with schedules set forth in the implementation plans for this ROD.

Closure of G Pit

       After removal of the waste from the G Pit,  some residual contamination will be present in
the surrounding subsurface soils.  Pursuant to RCRA, 40 CFR 264.114, at closure all contaminated
soils must be removed or the closure must comply with the closure provisions of 40 CFR 264.310,
which would be considered potentially relevant and appropriate.  This closure provision would
reguire the placement of a cap designed and constructed to have a permeability less than or
egual to any bottom liner or subsoils present.  However, EPA OSWER Directive 9234.2-04FS
discusses a hybrid clean closure that may be used when leachate from the residual contamination
will not impact groundwater above health-based levels, even though levels in the leachate and
residual contamination are above health-based levels if contamination does not pose a
direct-contact threat.  In such cases, the guidance indicates no cover would be reguired.  Using
the hybrid closure approach, the capping reguirements, while considered relevant, are not
appropriate for the closure of the G Pit.

       For the residual radioactivity left in place, the reguirements of DOE Order 5400.5 (IV)
will be TBC guidance.

Treatment, Packaging, and Trasportation of Waste Off Site for Disposal
       Removal of RCRA waste from an area of contamination at a CERCLA site and subseguent
disposal will subject the wastes to the RCRA LDRs  (53 FR 51444).   To meet the LDR treatment
reguirements,  the waste will be incinerated at the Toxic Substances Control Act of 1976
Incinerator or otherwise treated at another approved, permitted facility to meet LDRs.  Because
either option involves the use of an approved facility, there are no ARARs for this activity.
After treatment, the waste or waste residuals will be transferred to an off-site permitted
disposal facility.

       Once wastes generated from a CERCLA response action are transferred off site,  all
administrative as well as substantive provisions of all applicable reguirements must be met.
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The U.S. Department of Transportation  (DOT) Regulations for Hazardous Materials list general
reguirements for shipping and packaging in 49 CFR 172 and 173  (see Table 2.3).

       EPA and TDEC regulations governing generators and transporters of hazardous waste are
found in 40 CFR 262-263 and Rules of the TDEC 1200-1-11-.03 to .04, respectively.  Rules of the
TDEC 1200-1-11-.03  (40 CFR 262) reguires generators to ensure and document that the hazardous
waste they generate is properly identified and transported to a treatment, storage, and disposal
facility.  Specific reguirements are given for manifesting [Rules of the TDEC 1200-1-11-. 03 (3);
40 CFR 262.20-23], packaging, labeling, marking, and placarding [Rules of the TDEC
1200-1-11-.03 (4); 40 CFR 262.30-33].  Pretransport reguirements reference the DOT regulations
under 49 CFR 172, 173, 178, and 179.

       In accordance with DOE Order 5820.2A,  mixed waste is to be disposed of on the site where
it is generated, if possible, or if off-site disposal is necessary because there is no on-site
capacity, disposal must be at another DOE facility.  An off-site disposal facility holding both
a RCRA permit and a Nuclear Regulatory Commission Agreement-state permit can be used for
disposal if an exemption to DOE Order 5820.2A reguirements is approved by EM-50, in consultation
with EH-1, and the waste meets the off-site disposal facility WAG  (see Table 2.3).

       CERCLA Section 121(d)(3) provides certain reguirements for the off-site transfer of any
hazardous substance, pollutant, or contaminant generated during CERCLA response actions; such
substances must be transferred to a facility that is in compliance with RCRA and applicable
state laws.  EPA has codified this statutory reguirement at 40 CFR 300.440, which establishes
the procedures and criteria for determining whether facilities are acceptable for the off-site
receipt of waste.

Soil Cover of the Concrete Pad

       The soil covering placed over the Concrete Pad will leave residual radioactive
contamination and waste in place.  The reguirements of DOE Order 5400.5  (IV) will be considered
TBC guidance for the residual radioactivity left in place.

Institutional Controls for the North Pits, South Pits, and Trench Areas

       Institutional controls would remain in place for the North Pits,  South Pits, and Trench
Areas as an interim measure until these sources are reevaluated in the ETTP RI/FS.  The
institutional control reguirements in Rules of the TDEC 1200-1-13-.08 (10) will be relevant and
hazardous substances that pose or may pose a threat to human health and safety  (see Table 2.3).
Corresponding reguirements found in DOE Order 5400.5 are contractually binding for DOE
subcontractors.

COST EFFECTIVENESS

       Actions taken under CERCLA must consider the estimated total present-worth cost of
alternatives.  The selected remedy costs less than Alternatives 2 and 3 and is approximately the
same cost as Alternative 4.  The selected remedy is, therefore, considered cost-effective for
the protection of human health and the environment.

USE OF PERMANENT SOLUTIONS TO THE MAXIMUM EXTENT PRACTICABLE

       DOE believes the selected remedy represents the maximum extent to which permanent
solutions and alternative treatment technologies or resource recovery technologies can be used
in a cost-effective manner for the K-1070-C/D OU sources at this time.   Of the remediation
alternatives, DOE believes the selected remedy provides the best balance of trade-offs in terms
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of long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through
treatment; short-term effectiveness; implementability; and cost.  Some wastes will remain at the
site untreated.  The remaining waste's impact on future groundwater contamination will be
assessed during the ETTP RI/FS and, potentially, additional action may be taken at that time.

PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT

       The statutory preference for treatment to reduce the toxicity,  mobility,  or volume of
waste as a principal element of the selected remedy is satisfied with the action at the G Pit
because the waste will be treated subseguent to excavation.  The soil cover at the Concrete Pad
does not satisfy this preference; however, this soil cover is considered a temporary measure and
will be reevaluated in the ETTP RI/FS along with the other source areas not addressed in this
ROD.

DOCUMENTATION OF SIGNIFICANT CHANGES

       The proposed plan for the K-1070-C/D OU was released for public comment in July 1997.  No
comments were submitted during the public comment period.  Therefore,  no significant changes to
the remedy, as originally identified in the proposed plan, are necessary as a result of public
comments.  However, since the public comment period, the soil cover of the Concrete Pad and the
institutional controls, previously designated as final actions in the proposed plan, have been
redesignated as interim actions because of the reevaluation of waste,  secondary sources, and
contaminated groundwater in the upcoming ETTP ROD.
                                                  REFERENCES

DOE  (U.S. Department of Energy). 1997a. Proposed Plan for the K-25 Site K-1070-C/D Operable
       Unit,  Oak Ridge,  Tennessee,  DOE/OR/02-1399&D4.  Oak Ridge, TN.

DOE. 1997b. Engineering Evaluation/Cost Analysis for the Mitchell Branch and K-1070-C/D Area
Trenches, DOE/OR/02-1585&D1.  Oak Ridge, TN.

DOE. 1996. Proposed Plan for the K-25 Site K-1070-C/D Operable Unit,  Oak Ridge, Tennessee,
       DOE/OR/02-1399&D2.  Oak Ridge,  TN.

DOE. 1995. Phase 2 Remedial Investigation/Baseline Risk Assessment Report and Feasibility Study
       for the K-1070-C/D Classified Burial Ground at the Oak Ridge K-25 Site,  Oak Ridge,
       Tennessee,  DOE/OR/01-1297&D2&V1-V4.  Oak Ridge,  TN.

EPA  (U.S. Environmental Protection Agency). 1988a. Guidance for Conducting Remedial
       Investigations and Feasibility Studies Under CERCLA,  EPA/540/G-89/004.  Washington, DC.

EPA. 1988b. Community Relations in Superfund, A Handbook, EPA/540/R-92/009. Washington, DC.
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                                        PART  3.  RESPONSIVENESS  SUMMARY

       This responsiveness summary documents public comments to both proposed plans (D2 and D4
versions) for the K-1070-C/D OU  (DOE 1996; DOE 1997a).   These two proposed plans were issued in
April 1996 and July 1997, respectively.  The first public comment period began July 15, 1996,
and ended August 12, 1996; the second comment period began July 14, 1997, and ended August 12,
1997.  In both cases, DOE announced the availability of the proposed plan in local newspapers,
including The Knoxville News-Sentinel, The Roane County News, The Oak Ridger, The Rockwood
Times, and the Clinton Courier-News.  The public notices advised that a public meeting would be
arranged if reguested.  This document addresses all public comments received on the proposed
plan.

       This responsiveness summary serves three major purposes.   First,  it informs DOE, EPA,  and
TDEC of community concerns about the site and the community preferences regarding the proposed
remedial alternative.  Second, it demonstrates how public comments were integrated into the
decision-making process.  Finally, it allows DOE to formally respond to public comments.

       This summary is prepared pursuant to the terms of the FFA among DOE,  EPA,  and TDEC, as
well as other reguirements, including:

              CERCLA as amended by SARA, 42 USC,  Section 9601,  et seg.;
              NCP,  40 CFR 300.430; and
              Community Relations in Superfund,  A Handbook (EPA 1988b).

COMMENTS AND RESPONSES

       No public meeting was reguested after posting of each public notice.   Only one member of
the public commented on the K-1070-C/D OU proposed plan during the first public comment period.
No comments were received during the second public comment period.  This public comment and the
DOE response follows.

Comment:  Max Trisel wrote that Alteniative 4 appears to be the most appropriate and
cost-effective measure and that the proposed plan addresses the concerns for human health and
the environment for the short-term and long-term effects upon implementation.

Response:  DOE originally agreed that Alternative 4 was the most appropriate alternative.
However, recently obtained information indicates man-made materials may be contained throughout
the G Pit, not just below the surface as previously thought.  ISV of the G Pit with these
materials present could result in unacceptable pressure and/or temperature excursions, possibly
spreading contamination and leading to worker injury.  Therefore, DOE has proposed, and
subseguently selected, an alternative that combines part of Alternative 3 (excavation of the G
Pit) and part of Alternative 4  (soil cover for the Concrete Pad).

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                                                Attachment One

                                              Record of Decision
                                           K-1070-C/D Operable Unit
                                        East Tennessee Technology Park
                                  Oak  Ridge  Reservation,  Oak  Ridge,  Tennessee

Site Description - As shown in Attachment Two, the K-1070-C/D Operable Unit (OU) is an 22 acre
tract of land located on the eastern side of the East Tennessee Technology Park  (ETTP).  This OU
is divided into seven source areas:  Trench Area, Landfarm Area, Concrete Pad Area, North Pits
Area, South Pits Area (which includes G-Pit), Pits Downgradient Area  (i.e., area down gradient
from the North and South Pits),  and the K-1414 Area.  These areas include soil and buried waste,
such as drums, gas centrifuge hardware, and other eguipment,  and numerous hazardous substances.
Surface water and associated sediments are also part of the K-1070-C/D OU.  The primary
contaminants of concern addressed in this Record of Decision  (ROD) include organic compounds in
soil and groundwater, and uranium isotopes  (U-234 and U-238)  and technetium-99 in surface soils.

Selected Remedy:  The estimated present worth cost of implementing the selected remedy for 30
years is $5.9M.  The remedy includes:

       •      no action  decisions for the Landfarm Area,  and  surface water and associated
              sediments  within  the K-1070-C/D OU;
       •      existing institutional O&M (including access restrictions and maintenance of
              existing soil covers)  to control exposure concerns associated with waste left in
              place within the  Trench Area,  and the North and South Pits Areas;
       •      a soil cover,  considered an interim measure, placed over the Concrete Pad Area with
              adeguate thickness and sufficient areal extent  to provide protection from direct
              exposure to ionizing radiation;  and
       •      removal,  interim  storage,  treatment and disposal of G-Pit source materials
              (addressing 1 of  10 pits within the South Pits  Area).  After waste removal (~ 250
              cubic yards of classified mixed waste consisting of contaminated soil and debris,
              including  metal drums),  G-Pit will be backfilled and properly graded.

Contaminants of Concern:  G-Pit leachate contaminants include acetone  (500 mg/1),
1,1,1-trichloroethane (840 mg/1), trichloroethene  (220 mg/1), 1, I-dichloroethane  (43 mg/1), and
methylene chloride  (7.1 mg/1).   Concrete Pad Area contaminants include isotopes of uranium
(U-234 and U-238), and technetium-99.  No ecological risks were identified for OU surface water.

Risk Issues:  The greatest G-Pit risks were identified through the groundwater pathway  (i.e.,
future receptor using groundwater for drinking purposes).  Extreme levels of organics composing
G-Pit leachate indicate presence of free phase contamination.  Fate and transport modeling
indicate that several chlorinated hydrocarbon concentrations exceeded or will exceed MCLs for
groundwater, and that maximum conceptrations for all contaminants detected in G-Pit leachate
(including volatile organic compounds, semivolatile organic compounds and radionuclides) have
not yet peaked at the water table and will continue to increase.

The risks from the Concrete Pad Area are due to exposure  to ionizing radiation under an
industrial scenario.  Detected levels of U-234 averaged 75.5 pCi/g, U-238 averaged 60.9 pCi/g,
and Tc-99 averaged 16.4 pCi/g.   Also, gross alpha levels  averaged 360 pCi/g, and gross beta
levels averaged 250 pCi/g.  The calculated industrial risk is 2 X 10 -4, based on external
exposure to U-238 in soil.
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Implementation Issues:  Due to the classified nature of G-Pit waste, removed source materials
will have to undergo treatment to render it un-classified before final disposal.  Until a
treatment process is developed to accomplish this, G-Pit source materials will have to be placed
into classified mixed waste storage.  Treatability studies will have to be conducted to evaluate
and select a treatment process.

Additional efforts at risk reduction, not included in this ROD include an early action that will
intercept and treat groundwater releases from the K-1070-C/D OU and an interim action that
involves ongoing collection and treatment of water from the SW-31 Spring, located down gradient
of the OU.  The early action, described in a previously approved EE/CA, involves installing a
system to capture and treat contaminated groundwater in the unconsolidated zone along the
southern and western edges of the Trench Area.

Final actions for the K-1070-C/D OU  (excluding G-Pit source materials) will be evaluated in the
ETTP RI/FS.  It is anticipated that DOE will prefer to leave the remainder of K-1070-C/D OU
wastes in place under existing institutional controls.



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