Superfund Record of Decision Oak Ridge Reservation USDOE South Campus Facility Tennessee


                                    EPA/ROD/R04-96/247
                                    1996
EPA Superfund
     Record of Decision:
     OAK RIDGE RESERVATION (USDOE)
     EPA ID: TN1890090003
     OU27
     OAK RIDGE, TN
     12/28/1995

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Record of Decision for Oak Ridge Associated Universities
                 South Campus Facility
                  Oak Ridge, Tennessee

                Date Issued-December 1995

               Prepared by Jacobs ER Team
                  125 Broadway Avenue
                  Oak Ridge,  Tennessee
            under contract DE-AC05-930R22028

          Prepared for U.S. Department of Energy
 Office  of Environmental Restoration and Waste Management

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PREFACE

The Record of Decision for Oak Ridge Associated Universities South Campus Facility Oak Ridge,
Tennessee  (DOE/OR/02-1383&D3) was prepared in accordance with reguirements under the
Comprehensive Environmental Response, Compensation, and Liability Act and documents the selected
remedy.  This work was performed under Work Breakdown Structure 1.4.12.5.1.01 (Activity Data
Sheet 8390 "Oak Ridge Associated Universities").  Publication of this document meets a Federal
Facility Agreement milestone of November 26, 1995.  This document provides the Environmental
Restoration Program with information about the no action remedy selected for the Oak Ridge
Associated Universities South Campus Facility.  While called "no action," this alternative
actually entails periodic sampling and placement of a statement in the property title notifying
potential owners of the contamination.  Information in this document summarizes information from
the remedial investigation/feasibility study  (DOE/OR/02- 1274&D2, VI and V2)  and the proposed
plan  (DOE/OR/02-1310&D3).

ACRONYMS AND ABBREVIATIONS

bgs           below ground surface
CERCLA        Comprehensive Environmental  Response,  Compensation,  and Liability Act of 1980
DOE           U.S.  Department of Energy
EPA           U.S.  Environmental Protection Agency
ER            environmental restoration
FS            feasibility  study
ft            foot
gpm           gallons per  minute
km            kilometer
L             liter
m             meter
•             microgram
MW            monitoring well
ORAU          Oak Ridge Associated Universities
ORISE         Oak Ridge Institute for Science and Education
ORR           Oak Ridge Reservation
RI            remedial investigation
ROD           record of decision
TCE           trichloroethene
TDEC          Tennessee Department of Environment and Conservation
Y-12          Plant Oak Ridge Y-12 Plant

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PART 1. DECLARATION

SITE NAME AND LOCATION

U.S. Department of Energy Oak Ridge Reservation Oak Ridge Associated Universities South Campus
Facility Oak Ridge, Tennessee

STATEMENT OF BASIS AND PURPOSE

This record of decision (ROD) presents the selected remedial action for the Oak Ridge
Reservation (ORR) Oak Ridge Associated Universities (ORAU) South Campus Facility in Oak Ridge,
Tennessee. 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, 42 United States Code Section 9601 et seg., and to the extent
practicable, the National Oil and Hazardous Substance Contingency Plan (40 Code of Federal
Regulations 300).

This decision is based on the administrative record for ORAU South Campus Facility, including
the remedial investigation (RI)/feasibility study (FS) report (DOE 1995a), the proposed plant
(DOE 1995b), and other documents contained in the administrative record file for this site.

This document is issued by the U.S. Department of Energy (DOE), Region IV of the U.S.
Environmental Protection Agency (EPA) , and the Tennessee Department of Environment and
Conservation (TDEC). DOE is the lead agency for site activities. EPA and TDEC are supportive
agencies as parties of the Federal Facility Agreement for this response action and concur with
the selected remedy.

DESCRIPTION OF THE SELECTED REMEDY

This response action fits into the overall ORR cleanup strategy by addressing soil and
groundwater contaminated with trichloroethene (TCE) at the ORAU South Campus Facility. Because
the site poses no unacceptable current or future risk to humans or the environment provide the
TCE-contaminated groundwater is not used as a drinking water source, DOE has selected a no
action remedy for the site. The no action alternative includes periodic sampling to ensure that
natural attenuation in the zone of contamination continues as expected. In addition, a
statement will be placed in the property title notifying potential owners of the contamination.
The monitoring and the title statement will provide, at a minimal cost, institutional controls
that help ensure the site continues to pose no unacceptable risk.

DECLARATION STATEMENT

The no action alternative is adeguate to ensure protection of human health and the environment
as directed by CERCLA Section 121(b). However, 5-year reviews are reguired by CERCLA Section
121(c) because hazardous constituents will remain on site. The reviews will be conducted every
5 years until natural attenuation in the zone of contamination decreases TCE concentrations
below regulatory levels of concern.

APPROVALS

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PART 2. DECISION SUMMARY

SITE LOCATION AND DESCRIPTION

The ORR ORAU South Campus Facility is southeast of the Oak Ridge Y-12 Plant (Y-12 Plant) at the
intersection of Pumphouse Road and Bethel Valley Road on the eastern edge of ORR, approximately
32 km (20 miles) west of Knoxville, Tennessee (Fig. 1). The facility was an experimental
station consisting of pasture area, several buildings, and wastewater treatment facilities.
Buildings in the northwest area of South Campus Facility are still used, primarily as office and
storage space. Hay is harvested from the pasture areas.

Following is a brief description of several aspects of the site. More site description details
are found in the RI/FS (DOE 1995a).

In general, the site slopes southeastward toward Scarboro Creek embayment. The topography in the
developed northwestern corner of the site has been modified by the installation of roads,
buildings, and associated drainage control ditches and storm drain/sewer systems.

Riparian wetlands, ranging in width from about 1.5-9 m (5-30 ft), flank the entire length of
Scarboro Creek. Emergent and wet meadow wetlands are found at the mouth of Scarboro Creek at
Scarboro Creek embayment. None of the wetlands will be affected.

Scarboro Cemetery, on the western border of South Campus Facility, is the only known cultural
resource on the site and will not be affected.

South Campus Facility is within the city limits of Oak Ridge, Tennessee. Oak Ridge has a
population of 27,310. Industrial, residential, and office expansion of Oak Ridge has occurred in
several directions, including toward South Campus Facility. Future growth in the area is
expected.

Groundwater in the unconsolidated zone mimics the local topography and flows to Scarboro Creek
embayment. Deeper groundwater flows in the strike direction of the bedrock.

SITE HISTORY

On November 21, 1989, EPA placed ORR on the National Priorities List under CERCLA. On January 1,
1992, a Federal Facility Agreement was implemented by DOE, EPA, and TDEC.

The agreement provides a procedural framework and schedule for evaluating, prioritizing, and
managing areas of contamination on ORR. The agreement specifies that CERCLA procedures be
followed to evaluate and remediate contamination problems.

Originally, the Oak Ridge Institute for Nuclear Studies operated South Campus Facility. In 1966,
the Oak Ridge Institute for Nuclear Studies became ORAU. In 1975, the name of the facility was
changed to the Comparative Animal Research Laboratory. ORAU assumed control of the laboratory
in 1981. Since its formation in 1992, the Oak Ridge Institute for Science and Education (ORISE)
has managed South Campus Facility. In 1993, ORAU South Campus Facility was renames
ORISE-Scarboro Operations Site. For consistency with previous CERCLA documentation, the site is
referred to as South Campus Facility in this document.

South Campus Facility was originally an experimental station where radionuclide effects on
animals were studied. Activities and buildings at South Campus Facility either supported

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research on exposed animals or managed those animals before and after exposing them to
radiation.  South Campus Facility included pasture, barns, laboratories,  mechanical buildings,
surgical and necropsy rooms, carpentry shops, a steam power plant, storage areas,  and wastewater
treatment facilities and ponds.  Potential contamination at South campus Facility was
investigated because operations at these facilities may have resulted in the release of chemical
and/or radioactive substances to the environment.  Buildings in the northwest area of South
Campus Facility are still used as office and storage space.  Hay is harvested from the pasture
areas.  DOE intends to maintain control of this site for the foreseeable future.

ORISE still used the structures at the site.  When the structures are no longer necessary,
acceptance into the decontamination and decommissioning program will be considered if
remediation is necessary.

Since 1988, the following investigative activities have been performed at South Campus Facility:

       •      1988-five underground storage tanks and associated contaminated soil removed  and
              treated;

       •      1988-89-groundwater monitoring wells installed and sampled;

       •      1989-scoping survey written and existing data reviewed;

              1991-CERCLA site inspection conducted;

              1993-CERCLA RI performed;  and

       •      1994-1995-groundwater monitored guarterly.

Using information from earlier studies and the RI field work, and RI report and an FS were
developed concurrently and presented in a single document. The RI characterized contamination of
the soil, groundwater,  and surface water at South Campus Facility and concluded that the site
poses no unacceptable current or future risk to human health or the environment.  The FS
presented the relative benefits of a range of potential remediation alternatives such that, in
the event an unacceptable risk to human health or the environment was found, an appropriate
remedial alternative could be selected and implemented.  The proposed plan then presented DOE's
determination that no action was necessary and solicited public comment on the determination.
The "Responsiveness Summary" documents public comments received and DOE's response to the
comments. The ROD documents the selected remedy for South Campus Facility.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI/FS and proposed plan were released for public comment May 27, 1995. The notice of the
availability of these two documents was published in The Oak Ridger and the Knoxville
News-Sentinel newspapers May 17 and 24,  1995. The administrative record file contains all the
documentation DOE considered in selecting the remedial action for South Campus Facility.  The
administrative record file is available at the Information Resource Center, 105 Broadway Avenue,
Oak Ridge, Tennessee 37830.  A 30-day public comment period for the RI/FS and the proposed  plan
began May 27, 1995.  The public was informed that a public meeting would be held,  if reguested.
No meeting was reguested, and the public comment period ended June 26,  1995.  Two comments  were
received during the public comment period.  They are addressed in the "Responsiveness Summary"
of this document.

ORR SCOPE AND ROLE OF SOUTH CAMPUS FACILITY WITHIN THE STRATEGY

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The goals of the ORR Environmental Restoration (ER) Program are to achieve compliance with
environmental regulations that protect human health and the environment, and to reduce risks to
human health and the environment that are results of contaminated, inactive disposal sites. Some
of the operable units under the overall ER Program are on the ORR but not within the boundaries
of the Y-12 Plant, Oak Ridge K-25 Site, or Oak Ridge National Laboratory. ORAU is responsible
for two such operable units: South Campus Facility (the subject of this document) and Freels
Bend Area.

All for the buildings remaining on the South Campus Facility are actively used by ORAU, now
called ORISE, in support of their Oak Ridge Operations. All of the out-buildings, other than
the main barn, have been demolished. There are no plans to demolish any buildings on the main
campus.

This ROD addressed the area outside of the buildings. Future CERCLA activities may be conducted
at this site in association with facility decontamination and decommissioning activities.

SITE CHARACTERISTICS

During the RI, soil, surface water, sediment, and groundwater were sampled and analyzed for
contamination. Most compounds were near background levels. In addition, many chemicals were
detected in a few samples. TCE was detected in soil and groundwater just east of a mechanical
building in a 2,025 m2 (22,400-ft2) area approximately 1.6 m (5 ft) deep (Fig.2). No historical
or facility operations records document the release of TCE or suggest the original source of the
TCE. The nearby mechanical building has been used as a maintenance garage. TCE is an effective
degreaser and may have been used at the maintenance garage. Detected groundwater TCE
concentrations ranged from 380 to 1,400 • g/L. TCE concentrations up to 3 • g/L were detected in
the shallow bedrock well at a depth of 23 ft bgs. Laboratory analysis has detected degradation
products of TCE at the site, indicating that local environmental factors naturally degrade TCE.
Due to the low estimated overall guantity of TCE, its ability to naturally degrade, and the slow
rate of migration, TCE is not likely to emerge into surface water at concentrations above
regulatory limits (DOE 1995a).

Benzene was detected at low levels in the groundwater from one monitoring well. The well
intercepted a bedding plane directly down-dip from the former location of the underground
storage tanks that were removed in 1988. The location suggests the benzene is residual from the
underground storage tanks.

Surface water at the site consists of Scarboro Creek, intermittent streams, drainage ditches,
storm sewers, swine water ponds, and Scarboro Creek embayment. All of the features drain into
Scarboro Creek embayment and eventually into Melton Hill Lake. Shallow groundwater emerges as
wet weather springs near the embayment.

Groundwater at South Campus Facility is not currently used at the facility or at any nearby
locations, and there is little potential for future residential use of South Campus Facility
groundwater. Municipal water serves, and is expected to continue to serve, the site, further
reducing the need for future residential groundwater use. DOE does not plan to relinguish
control of South Campus Facility; conseguently, residential development is not likely with the
next 20 years. In addition, groundwater wells in the immediate vicinity of the TCE
contamination could not be relied upon to meet minimum reguirements for residential use (DOE
1995a). Therefore, the domestic use of groundwater at the site is an incomplete exposure
pathway.

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SUMMARY OF SITE RISKS

As part of the RI (DOE 1995a), a baseline risk assessment concluded that no unacceptable risk
to human health or the environment is posed by contaminants identified in the sampling and
analysis at South Campus Facility if groundwater within the TCE zone is not used as a drinking
water source. The results are summarized in this section.

HUMAN HEALTH RISK ASSESSMENT

The human health risk assessment evaluated the potential for increased cases of cancer and other
illnesses. Cancer risk is an estimate of the incremental increase in the probability that an
exposed individual could develop cancer, based on an assumed freguency of exposure projected
over a lifetime. Non-cancer risk for each contaminant of concern is estimated by dividing a
calculated daily intake rate by the intake rate indicated in toxicity studies to cause adverse
health effects.
The assessment of human health risk considered chemical and radiological contaminants across a
range of conservative current and future exposure scenarios. Current users included outdoor
maintenance workers and hay harvesters. Hypothetical future users included a full-time worker,
recreational visitors, and residents.

At South Campus Facility, no current or future scenarios evaluated had unacceptable risk levels.
The domestic use of groundwater at the site would result in unacceptable risk. However, as
discussed in the Site Characteristics section, DOE has determined that this is an incomplete
exposure pathway.

Table 1 summarizes the human health chemical risks at South Campus Facility.

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                            Table 1.   Summary of chemical carcinogenic risks and non-carcinogenic hazard indices
                                               for South Campus Facility, Oak Ridge, Tennessee

Receptor                                 Media                Location                   Carcinogenic         Non-Carcinogenic
                                                                                                risk hazard index

Current full-time employee               Soil                 Throughout  SCF             5 X 10-6             0.0004
                                         Soil                 Main Campus                9 X 10-6             0.001

Maintenance worker                       Soil                 Drainage Ditch             5 X 10-6             0.01
                                         Sediment             Drainage Ditch             3 X 10-5             0.02

Current/future adult                     Soil                 Throughout  SCF             8 X 10-6             0.0004

recreational user                        Sediment             Scarboro Creek             3 X 10-5             0.001
                                         Soil                 Drainage Ditch             8 X 10-6             0.0009
                                         Sediment             Drainage Ditch             4 X 10-5             0.001

Future adult resident                    Soil                 Throughout  SCF             8 X 10-5             0.0005

Future child resident                    Soil                 Throughout  SCF             3 X 10-5             0.01

Reference:  DOE 1995a

SCF= South Campus Facility

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According to EPA guidance, a total pathway risk that exceeds 1 X 10-4 or a hazard index that
exceeds 1 indicates a level of concern in terms of exposure to a given medium. The risk
assessment (DOE 1995a) concluded that surface water at South Campus Facility contains no
contaminants of potential concern. Groundwater in the TCE area used as a drinking water
source would result in a carcinogenic risk of 4 X 10-3 and a hazard index of 19. However,
groundwater in the TCE area is not considered a drinking water source. Therefore, South
Campus Facility has no unacceptable risk.

ECOLOGICAL RISK ASSESSMENT

The ecological risk assessment evaluated the potential environmental effects of site
contaminants on wildlife expected to be present at South Campus Facility. The contaminants
of concern for this remedial action determination, TCE and benzene in groundwater, do not
present an unacceptable risk to wildlife or plants.

DESCRIPTION OF THE NO ACTION ALTERNATIVE

South Campus Facility poses no unacceptable risk to humans or the environment. Therefore, no
remedial action is necessary to ensure protection of human health and the environment as
directed by CERCLA Section 121(b). Pursuant to EPA Office of Solid Waste and Emergency
Response Directive 9234.2-01/FS-4 (EPA 1994), there are no applicable or relevant and
appropriate reguirements for a no action alternative. The no action alternative includes
periodic sampling to ensure that evaluations completed in support of the RI are accurate and
that natural attenuation in the zone of contamination continues as expected. A notice of the
contamination will be recorded with respect to the contaminated parcel in Anderson County
property records. The monitoring and title statement will provide, at a minimal cost, an
additional level of assurance that the site poses no unacceptable risk. A 5-year review is
reguired by CERCLA Section 121(c) because hazardous constituents will remain on site. The
reviews will be conducted every 5 years until natural attenuation in the zone of
contamination decreases TCE concentrations below regulatory levels of concern. A description
of planned sampling activities follows.

The sampling locations are indicated in Figure 2. MW-19 is about 10 m (30 ft) east of the
northeastern corner of the mechanical building. It is the monitoring well in which the
highest concentrations of TCE were found during the RI and guarterly groundwater monitoring.
MW-19 is screened in the unconsolidated zone (< 10 ft bgs). MW-43a, MW-43b, and MW-43c
comprise a well cluster in the bedrock approximately 53 m (1790 ft) downgradient (i.e., plant
south) of MW-19. MW-43a is screened 13-23 ft bgs, MW-43b 55-65 ft bgs, and MW-43c 165-175 ft
bgs. Collection of groundwater from these locations will document the decrease in TCE
concentrations, is likely to show the maximum TCE concentration in the area at any given
time, and will indicate the direction of TCE migration. Surface water will be collected from
a ditch approximately 55 m (180 ft) downgradient of the MW-43 well cluster. Sampling of the
surface water in the ditch must occur during the rainy season (i.e., January or February);
otherwise, the ditch might be dry. The surface water sample will show whether an
unacceptable level of TCE is emerging from the ground and flowing into Scarboro Creek
embayment.

Samples will be collected from the five locations described previously once every 2 years as
long as TCE contamination above acceptable levels is present. The first sampling event will
occur during the rainy season closest to and within 2 years of the signing of this ROD.

The 5-year review will consider the results of the RI, the guarterly groundwater monitoring
program, and the 2-year sampling events to assess the rate of TCE degradation.

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The cost estimate for the no action alternative is presented in Table 2. Five-year and
30-year escalated (i.e., accounting for inflation) cost estimates are presented.  The actual
cost will depend on the time required for natural degradation to decrease TCE concentrations
below regulatory levels of concern.
                               Table 2.   Estimated 5-year and 30-year costs
                              for South Campus Facility, Oak Ridge, Tennessee

Line item                   5-year  cost  ($)             30-year cost ($)

Deed restriction            4,000                        4,000
Sampling                    5,000                       37,000
Analysis                    3,000                       27,000
OREIS integration           4,000                       33,000
5-year review(s)            2,000                       13,000
Overhead                    2,000                       16,000
Contingency                 7,000                       45,000

Total cost                  27,000                      175,000

OREIS = Oak Ridge Environmental Information System


EXPLANATION OF SIGNIFICANT CHANGES

The proposed plan for South Campus Facility was released for public comment in May 1995.  The
proposed plan identified the no action alternative as the preferred alternative.  DOE
received two comments during the public comment period.  DOE, EPA, and TDEC reviewed the
comments and determined that no significant changes to the remedy, as originally identified
in the proposed plan, were necessary.

REFERENCES

DOE  (U.S. Department of Energy).  1995a.  Remedial Investigation/Feasibility Study, South
Campus Facility, Oak Ridge, Tennessee, DOE/OR/02-1274/D2&V1 and V2, Oak Ridge, TN.

DOE.  1995b.  Proposed Plan for South Campus Facility, DOE/OR/02-1310&D3.   Oak Ridge, TN.

EPA  (U.S. Environmental Protection Agency).   June 1994.  Office of Solid Waste and Emergency
Response Directive 9234.2-01/FS-4,  "ARARs Q's and A's."

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                                      PART 3.   RESPONSIVENESS SUMMARY

RESPONSIVENESS SUMMARY

This "Responsiveness Summary" documents the formal public comments on the Proposed Plan for
South Campus Facility (DOE/OR/02-1310&D3)  and the DOE response to the comments. Two comments
were submitted in writing during the 30-day public comment period that began May 27, 1995,
and ended June 26, 1995.

The no action alternative presented in the proposed plan is now the selected remedy for South
Campus Facility.  This decision is based on the administrative record for South Campus
Facility, including the RI/FS report (DOE 1995a),  proposed plan (DOE 1995b),  public comments,
and other documents contained in the administrative record file for this site.

This "Responsiveness Summary" serves three purposes.  First, it provides DOE, EPA, and TDEC
with information about community concerns with the site and preferences regarding the
preferred alternative presented in the proposed plan. Second, it demonstrates how public
comments were integrated into the decision-making process.  Third, it allows DOE to formally
respond to public comments.

COMMUNITY PREFERENCES

DOE received two comments on the proposed plan.  Both concurred with the no action selected
remedy.  However, the first commentor disputed DOE's claim that groundwater at the facility
cannot be used for drinking water due to the low yields.  He cited a groundwater spring west
of South Campus Facility and historic records on groundwater use at a school that once
existed on the site. The second commentor suggested format changes to the proposed plan.
Since the proposed plan had already been finalized and released for public comment at the
time the comment was made,  it cannot be changed.  DOE will consider the suggested format
changes on future proposed plans.

INTEGRATION OF COMMENTS

The ROD clarifies that DOE focused on several factors in determining that no action is
necessary to ensure protection of human health and the environment. These considerations are:

       1.     Groundwater wells  in the  area of TCE contamination have low yields and could not
              be relied upon to  meet minimum reguirements for residential use.   The first
              commentor disputed this point.   As stated previously,  he cited  a groundwater
              spring west of South Campus  Facility and historical  records on  groundwater use at
              the school that once existed on the  site.   DOE investigated these points for
              clarification.  Apparently a  bedrock  spring yielding 1-2 gpm is  located west of
              the site.   TCE is  mainly  in  the unconsolidated zone.   Migration through the
              unconsolidated zone is controlled by shallow groundwater flow,  which mimics the
              local topography.   Shallow groundwater near the TCE  area flows  south to the
              Scarboro Creek embayment.  Therefore,  it is unlikely TCE migration would impact
              the spring.   There are no known bedrock springs on South Campus Facility.   Verbal
              records indicate that the school used a groundwater  well after  it was rebuilt in
              1939 until DOE assumed control  of the  site.   No records exist  on productivity of
              this well,  and it  is not  known if the  well could have met the minimum
              reguirements  for residential use.   Regardless,  DOE recognizes  that these
              references are provided as examples  of possible groundwater use within the same
              geologic formation.  Therefore,  the ROD clarifies DOE's remedial action decision
              focused on yields  in  the immediate  area of TCE contamination  and not on yields

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       in the entire region.

2.      DOE concurs that data  from a few groundwater monitoring wells are not sufficient
       to completely characterize groundwater flow in carbonate systems.  As a result,
       DOE cannot absolutely  guarantee that the groundwater at South Campus Facility
       will never be used as  drinking water.   For this reason,  the selected remedy
       includes inserting a statement in the property title to alert any future site
       users to the TCE contamination and discouraging any future residential  use of
       the groundwater should the property be removed from DOE control before the TCE is
       degraded to acceptable levels.

3.      Municipal water currently serves,  and is expected to continue serving,  South
       Campus Facility.

4.      DOE has no plans to relinguish South Campus Facility.   Consequently,  residential
       development is unlikely within the next 20 years.

5.      Because hazardous constituents remain on the site,  a 5-year review will be
       conducted to evaluate  current site conditions.

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