FOURTH FIVE-YEAR REVIEW REPORT FOR
MAXEY FLATS DISPOSAL SITE
FLEMING COUNTY, KENTUCKY
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SEPTEMBER 2017
Prepared by
U.S. Environmental Protection Agency
Region 4
Atlanta, Georgia
Franklin E. Hill, Director
Superfund Division
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Table of Contents
LIST OF ABBREVIATIONS & ACRONYMS............ iv
I. INTRODUCTION..................................................................................................... 1
Site Background............................................................................................ 1
FIVE-YEAR REVIEW SUMMARY FORM., 2
II. RESPONSE ACTION SUMMARY 3
Basis for Taking Action............................................. 3
Response Actions................................ 3
Status of Implementation....,..,.,..,,..................,,,....., 7
Systems Operations/Operation & Maintenance (O&M).................................................................. 10
III. PROGRESS SINCE THE LAST REVIEW 10
Protectiveness Statement from Third FYR 10
Status of Recommendations from Third FYR. 10
IV. FIVE-YEAR REVIEW PROCESS 11
Community Notification, Involvement & Site Interviews.,...,.,.......,,,..... 11
Data Review..... 11
Institutional Controls 17
Engineering Controls 18
Site Inspection 19
V. TECHNICAL ASSESSMENT 20
QUESTION A: Is the remedy functioning as intended by the decision documents?,.......,...,,........ 20
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the
time of the remedy selection still valid? 21
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy?...,........,.,.....,..,..,...,,.........,.,,,...,.,............,..,...,......................,,.....,..,. 24
VI. ISSUES/RECOMMENDATIONS 24
Other Findings 25
VII. PROTECTIVENESS STATEMENT 26
VIII. NEXT REVIEW 26
APPENDIX A - REFERENCE LIST........................................
APPENDIX B - SITE CHRONOLOGY..................................................................................................
APPENDIX C - SITE BACKGROUND
APPENDIX D - SITE MAPS........,.....,,.,,,.....,..,..,,,..,..,....,..,.,....,.....,.......,.
APPENDIX E- PRESS NOTICE
APPENDIX F - SITE INSPECTION CHECKLIST.,...,....,...,,
APPENDIX G - SITE INSPECTION PHOTOS......................
APPENDIX H - INTERVIEW DOCUMENTATION.............................................................................
APPENDIX I - DETAILED ARARs REVIEW
APPENDIX J - DETAILED RISK REVIEW
APPENDIX K - VAPOR INTRUSION SCREENING
APPENDIX L - ANNUAL REPORTS
APPENDIX M - DEED RESTRICTIONS
APPENDIX N - CONTAMINANT TREND GRAPHS
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Tables
Table 1: Indicator Contaminants 3
Table 2: Groundwater COC ARARs 6
Table 3: Surface Water COC ARARs (Chemical Contaminants) 6
Table 4: Surface Water COC ARARs (Radiological Contaminants) 7
Table 5: Annual Average Tritium Activity (pCi/mL) at Perennial Surface Water Sample Locations 14
Table 6: Annual Average Tritium Activity (pCi/mL) at Drainage Channel Water Sample Locations.... 15
Table 7: Average of Quarterly Water Level Measurements by Year 17
Figures
Figure D-l: Site Vicinity Map D-l
Figure D-2: Site Overview Map D-2
Figure D-3: 2016 Areal View of the Maxey Flats Disposal Site D-3
Figure D-4: Perennial Streams and Drainage Channel Surface Water Sampling Locations D-4
Figure D-5: Groundwater Monitoring Locations D-5
Figure D-6: Additional Site Features of Note D-6
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LIST OF ABBREVIATIONS & ACRONYMS
ARAR
Applicable or Relevant and Appropriate Requirement
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act
CFR
Code of Federal Regulations
COC
Contaminant of Concern
EDB
East Detention Basin
EMDC
East Main Drainage Channel
EPA
United States Environmental Protection Agency
ESD
Explanation of Significant Differences
FS
Feasibility Study
FYR
Five-Year Review
HHRA
Human Health Risk Assessment
HQ
Hazard Quotient
IMP
Interim Maintenance Period
KY DEP
Kentucky Department of Environmental Protection
LR/D
Leachate Removal/Disposal
MCL
Maximum Contaminant Level
MCLG
Maximum Contaminant Level Goal
MFDS
Maxey Flats Disposal Site
Hg/L
Micrograms per Liter
mrem/year
Millirem per Year
N/A
Not Available
NCP
National Contingency Plan
NECO
Nuclear Engineering Company, Inc.
NPL
National Priorities List
NRWQC
National Recommended Water Quality Criteria
O&M
Operation and Maintenance
OU
Operable Unit
pCi/L
PicoCuries per Liter
PRP
Potentially Responsible Party
PVC
Polyvinyl Chloride
RAO
Remedial Action Objective
RI
Remedial Investigation
ROD
Record of Decision
RPM
Remedial Project Manager
RSL
Regional Screening Level
SPP
Settling Private Parties
SWMF
Surface Water Management Feature
TBC
To-Be-Considered
VISL
Vapor Intrusion Screening Level
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I. INTRODUCTION
The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy
to determine if the remedy is and will continue to be protective of human health and the environment.
The methods, findings, and conclusions of reviews are documented in FYR reports such as this one. In
addition, FYR reports identify issues found during the review, if any, and document recommendations to
address them.
The U.S. Environmental Protection Agency is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the
National Contingency Plan (NCP) [40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)],
and considering EPA policy.
This is the fourth FYR for the Maxey Flats Disposal Site (MFDS or Site). The triggering action for this
statutory review is the signature date of the previous FYR report, September 2012. The FYR has been
prepared due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above
levels that allow for unlimited use and unrestricted exposure.
The Site consists of a single operational unit (OU) that addresses soil, groundwater, and surface water
contamination. The entire OU will be addressed in this FYR.
The FYR was led by the EPA remedial project manager (RPM), Pam Scully, with support from
TechLaw, Inc. Participants included Jon Richards from EPA Region 4, Scott Wilburn from Kentucky
Department of Environmental Protection (KY DEP), and Curt Pendergrass from Kentucky Radiation
Health Branch. Relevant entities were notified of the initiation of the FYR. The review began on
February 27, 2017.
Site Background
The MFDS, located in Fleming County, Kentucky, is an inactive low-level radioactive waste site
encompassing approximately 770 acres, including an approximately 252-acre disposal tract and an
approximately 464-acre buffer zone. The Commonwealth of Kentucky (Commonwealth) owns the
disposal Site and surrounding buffer zone.
In 1963, the Commonwealth of Kentucky issued a license to a commercial organization, Nuclear
Engineering Company, Inc. (NECO), for the disposal of solid by-product, source, and special nuclear
waste at the MFDS. From May 1963 to December 1977, NECO managed and operated the disposal of
an estimated 4.75 million cubic feet of low-level radioactive waste at the MFDS.
Environmental monitoring conducted by the Commonwealth in 1972 revealed possible migration of
radionuclides from a 45-acre tract designated as the "Restricted Area." A study performed by the
Commonwealth in 1974 confirmed that tritium and other radioactive contaminants were migrating out of
disposal trenches, and that some radioactive material had migrated into unrestricted areas. In 1977, it
was determined that leachate was migrating through the subsurface geology and NECO was ordered to
cease the receipt and burial of radioactive waste. In 1986, MFDS was listed on the EPA's National
Priorities List (NPL). Notice letters were issued to 832 Potentially Responsible Parties (PRPs) informing
them of their potential liability with respect to contamination. In March 1987, 82 PRPs signed an
Administrative Order by Consent to perform a Remedial Investigation (RI) and Feasibility Study (FS).
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Subsequent to completion of the RI/FS, a Record of Decision (ROD) was signed for the Site on
September 30, 1991, documenting the selected remedy for the MFDS. Explanations of Significant
Difference (ESDs) were issued for the Site in February 2013 and September 2014.
The land surrounding the Site is primarily mixed woodlands and open farmland. The area is sparsely
populated and mostly undeveloped. The few residences in the area use a public water supply system.
Future land uses are expected to remain consistent with historical land uses.
Appendix A includes a list of references used for this FYR. Appendix B includes a site chronology.
Appendix C includes additional background information about the Site, including site history and
physical characteristics. Appendix D includes site figures.
FIVE-YEAR REVIEW SUMMARY FORM
site ii)i \ 11
"1 CAT'ION
Site Name:
Maxey Flats Disposal Site
EPA ID:
KYD980729107
Region: 4
State: KY City/County: Fleming County
SI 1 1 S 1 \ 1 US
NPL Status: Final
Multiple OUs?
No
Has the site achieved construction completion?
No (Construction Completion expected October 2017)
k i \ i r w s i \ 11 s
Lead agency: EPA
Author name: Pam Scully, with support from TechLaw, Inc.
Author affiliation: EPA, Region 4
Review period: February 27, 2017 - September 7, 2017
Date of site inspection: April 25, 2017
Type of review: Statutory
Review number: 4
Triggering action date: September 26, 2012
Due date (five years after triggering action date): September 2017
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II. RESPONSE ACTION SUMMARY
Basis for Taking Action
The MFDS has approximately 4.75 million cubic feet of low-level radioactive waste buried onsite.
Radionuclides and other chemical (non-radionuclide) contaminants have been detected in groundwater,
soil and surface water at the Site. The human health risk assessment (HHRA) indicated that, unless
remedial action is taken, exposure to soil, drinking water, surface water, and sediment at and in close
proximity to the Site in the future would pose an unacceptable risk to human health, defined as a greater
than 1E-04 risk (i.e., one additional case of fatal cancer for every 1,000 persons engaging in the off-site
exposure pathways). The HHRA also estimated that the risk from all combined off-site exposure
pathways would pose an unacceptable risk to human health. The selected remedy will reduce these risks
to 1E-04 or less. The EPA deems a risk of 1E-04 to be generally protective of human health and the
environment.
Indicator contaminants, as identified in the 1991 ROD, are listed below in Table 1. Tritium (Hydrogen-
3) is the most abundant and most mobile of the indicator contaminants and has, therefore, been
identified as the primary contaminant of concern.
Table 1: Indicator Contaminants
Radionuclides
Non-Radionuclides
Hydrogen-3 (Tritium)
Arsenic
Carbon-14
Benzene
Cobalt-60
Bis(2-ethylhexyl)phthalate
Strontium-90
Chlorobenzene
Iodine-129
1,2-Dichloroethane
Cesium-137
Lead
Radium-226
Nickle
Thorium-232
Toluene
Plutonium-238
Trichloroethylene
Plutonium-239
Vinyl Chloride
Americium-241
Response Actions
Between 1973 and April 1986, an evaporator was operated at the Site as a means of managing a large
volume of water infiltrating the disposal trenches as well as waste water generated by on-site activities.
The evaporator processed over 6,000,000 gallons of liquids during its operation, and the evaporator
concentrates were disposed of on-site. In addition, in 1981, a polyvinyl chloride (PVC) cover was placed
over the disposal trenches as a means of minimizing the infiltration of rainfall into the trenches. Liquid
storage tanks remained on-site for future storage of site-generated liquids and emergency trench
overflow pumping operations. Those steps, however, were temporary.
In November 1988, the EPA notified the PRPs of an imminent threat to public health, welfare and the
environment posed by the potential release of liquids stored in the on-site storage tanks. The threat arose
from the presence of eleven 20,000 gallon tanks located in a tank farm building that had been present
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on-site for 10 to 15 years, and whose structural integrity was of great concern. The unstable condition of
the tanks posed an immediate threat to public health and the environment. The PRPs declined the offer
to participate in the removal actions; therefore, on December 19, 1988, the EPA initiated phase one of
their removal.
Phase one consisted of the installation of heaters in the tank farm building to prevent the freezing, and
subsequent rupturing, of tank valves and fittings which were submerged under water that had infiltrated
the tank farm building. Phase one, which was completed in February 1989, also included the installation
of additional storage capacity on-site.
Phase two of the removal was initiated by the EPA in June 1989. Phase two began with the solidification
of approximately 286,000 gallons of radioactive liquids stored in the eleven tanks and of water that had
accumulated on the floor of the tank farm building. Solidification activities were completed in
November 1989, and resulted in the generation of 216 blocks of solidified tank and tank floor liquids.
Burial of these blocks on-site, which were stored on-site and above-ground, was initiated in August
1991.
In March 1987, 82 PRPs signed an Administrative Order by Consent to perform a RI/FS. The RI Report
for the MFDS was approved by the EPA in July 1989. The FS for the MFDS was finalized and
submitted to the public in May 1991. A ROD was signed for the Site on September 30, 1991,
documenting the selected remedy for the MFDS.
The remedial action objectives (RAOs) presented in the ROD are as follows:
• Minimize the infiltration of rainwater and groundwater into the trench areas and migration from
the trenches;
• Stabilize the Site such that an engineered cap that will require minimal care and maintenance
over the long-term can be placed over the trench disposal area;
• Minimize the mobility of trench contaminants by extracting trench leachate, to the extent
practicable;
• Promote Site drainage and minimize potential for erosion to protect against natural degradation;
• Implement institutional controls to permanently prevent unrestricted use of the Site; and,
• Implement a Site performance and environmental monitoring program.
The first and second ROD RAOs were subsequently expanded in the Administrative Order by Consent
Statement of Work to include the following components:
• Prevent or mitigate the continued release of hazardous substances, pollutants and contaminants
from the Site to underlying bedrock formations and groundwater aquifers;
• Prevent or mitigate the continued release of hazardous substances, pollutants and contaminants
from the Site to surface water bodies and sediments;
• Reduce the risks to human health associated with direct contact with hazardous substances,
pollutants or contaminants within the Site;
• Eliminate or reduce the risks to human health from inhalation of hazardous substances, pollutants
or contaminants from the Site;
• Eliminate or minimize the threat posed to human health and the environment from current and
potential migration of hazardous substances from the Site in the surface water, groundwater, and
subsurface and surface soil and rock;
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• Minimize the infiltration of rainwater and groundwater into the trench areas and migration from
the trenches; and,
• Allow natural stabilization of the Site to provide a foundation for a final cap over the trench
disposal area that will require minimal care and maintenance over the long term.
The remedy selected at the MFDS is natural stabilization, which will allow the materials in the trenches
to subside naturally to a stable condition prior to installation of a final engineered cap. The major
components of the selected remedy include the following:
• Excavation of additional on-site disposal trenches for disposal of Site debris and solidified
leachate;
• Demolition and on-site disposal of Site structures;
• Extraction, solidification, and on-site disposal of approximately three million gallons of trench
leachate;
• Installation of an initial cap consisting of clay and a synthetic liner;
• Re-contouring of capped disposal area to enhance management of surface water run-on and
runoff;
• Installation of a groundwater flow barrier, if necessary;
• Installation of an infiltration monitoring system to continuously verify remedy performance and
detect the accumulation of leachate in disposal trenches;
• Monitoring of groundwater, surface water, air, selected environmental indicators, and rates of
subsidence;
• Procurement of a buffer zone adjacent to the existing Site property boundary, estimated to range
from 200 to 400 acres, for the purposes of preventing deforestation of the hillslopes or other
activities which would accelerate hillslope erosion and affect the integrity of the selected
remedy, and providing frequent and unrestricted access to areas adjacent to the Site to allow
monitoring;
• Installation of a multi-layer engineered soil cap with synthetic liner after natural subsidence
process is complete;
• Five-year reviews to evaluate the protectiveness of the remedy and to ensure the selected remedy
is achieving the necessary remedial action objectives; and,
• Institutional controls to restrict the use of the MFDS and to ensure monitoring and maintenance
in perpetuity.
Applicable or Relevant and Appropriate Requirements (ARARs) for groundwater and surface water
contaminants of concern (COCs) (for both chemical and radiological contaminants) are listed below and
evaluated further in Section V (Technical Assessment).
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Table 2: Groundwater COC ARARs
COC
1991 ROD ARAR (in jig/L unless noted)
Arsenic
50
Benzene
5
Bis(2-ethylhexyl)phthalate
4
Chlorobenzene
100
Chloroform (trihalomethanes)
100
1,2-Dichloroethane
5
Lead
50
Nickel
100
Toluene
1000
Trichloroethene
5
Vinyl Chloride
2
Radionuclides
Beta particle and photon radioactivity
4 mrem/year
Gross alpha particles
15 pCi/L
Radium-226 and Radium-228 (total)
5 pCi/L
|ig/L = micrograms per Liter
mrem/year = millirems per year
pCi/L = picoCuries per Liter
N/A = Not available
Table 3: Surface Water COC ARARs (Chemical Contaminants)
COC
1991 ROD ARAR
1991 ROD ARAR
1991 ROD ARAR
(Human Health - Fish
Consumption)
(WJ/L)
(Aquatic Life -
Chronic)
(Hg/L)
(Aquatic Life -
Acute)
(Hg/L)
Arsenic
0.175
N/A
N/A
Benzene
400
N/A
5,300
Bis(2-
ethylhexyl)phthalate
N/A
3
940
Chlorobenzene
488
50
250
Chloroform
157
1,240
28,900
(trihalomethanes)
1,2-DichIoroethane
2,430
20,000
118,000
Lead
N/A
3.2
82
Nickel
100
160
1400
Toluene
424,000
160
17,500
Trichloroethene
807
21,900
45,000
Vinyl Chloride
5,246
N/A
N/A
|ig/L = micrograms per Liter
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Table 4; Surface Water COC ARARs (Radiological Contaminants)
COC
LGD ARAR (in pC
Total whole body exposure (all media)
25 mrem/year
Americium-241
0.02
Carbon-14
30
Cesium-137
1
Cobalt-60
3
Hydrogcn-3 (Tritium)
1,000
Iodine-129
0.2
Plutonium-238
0.02
Plutonium-239
;
Radium-226
0.06
Strontium-90
0.5
Technetiura-99
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*It is noted that these values are inconsistent with those listed in Table A-l, Applicable Action-Specific
and Contaminant-Specific Requirements for Remedial Alternatives at Maxey Flats. However, according
to Section 8.2, Contaminant-Specific ARARs, of the ROD, "The federal standards were lowered in May
1991 so as to limit the allowable dose in unrestricted areas to 100 mrem/year and to provide specific
radionuclide concentrations in Appendix B, Table II. In that these new federal standards are more
stringent than the Kentucky regulations, the federal standards shall be the governing ARARs for
allowable doses in. unrestricted areas." Therefore, the values listed above are based on the federal
btandardb (i e„ 10 CI R Part 20. Subpart O, Appendix B: Table 2, Column 2, "Water";
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mrem/year = miiiirems per \ear
pCi/L = picoCu.ries» per milliliter
Status of Implementation
The remedy for the Site is divided into four phases: the Initial Closure Period, the Interim
Maintenance Period, the Final Closure Period, and the Custodial Maintenance Period. The
remedy selection in the ROD led to the division of the remedy into the Initial Remedial Phase, which
incorporates the activities described as the Initial Closure Period, and the Balance of the Remedial
Phase, which incorporates the activities described as the Interim Maintenance Period and
the Final Closure Period. The final phase of the project, termed the Custodial Maintenance
Period in the ROD, is called the Institutional Control Period, and includes continued
monitoring for 100 years followed by the Post-Institutional Control Period, which will allow for
monitoring in perpetuity.
Two initial construction phases took place in 2003 as part of the Initial Remedial Phase: (1) leachate
removal/disposal and (2) "remaining work" (i.e., building demolition, southeast cap construction, and
east detention basin). The leachate removal/disposal phase included the following activities:
• Removing leachate from the trenches by pumping from specified sumps;
• Conveying removed leachate to field collection tanks;
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• Transferring the leachate from the field collection tanks to leachate storage tanks and sample
process control testing to confirm the proper leachate-to-cement ratio;
• Metering leachate from the storage tanks and cement from a storage silo into a transit mix truck
for mixing; and,
• Transferring leachate-cement mixture to bunkers where the mixture solidified.
The "remaining work" phase included the following activities:
• Demolition of buildings and on-site disposal of debris;
• Construction of a geomembrane cap to direct storm water away from disposal trenches to the
East Detention Basin (EDB) and minimize storm water infiltration into the trenches;
• Enlarging the EDB to accommodate a range of storm events including a 100-year, 24-hour storm
event. (The EDB contains storm water from the cap area and directs the water in a controlled
manner to the East Main Drainage Channel [EMDC]. Storm water is released from the EDB at
rates below the pre-development condition at the Site);
• Construction of a geomembrane and soil cover cap in the southeastern corner of the Site
immediately outside of the restricted area to prevent infiltration of rainwater into the subsurface
near several disposal trenches;
• Modifying/constructing the perimeter drainage channels to direct storm water to the EDB; and,
• Construction of erosion monuments along the East Main Drainage Channel.
During the Initial Remedial Phase, the Commonwealth performed the following activities:
• Acquisition of the additional buffer zone property;
• Buffer zone building demolition;
• Acquiring deed restrictions for the entire MFDS;
• Environmental monitoring; and,
• Continued Site maintenance.
The above-referenced deed restrictions, implemented on December 5, 2003, are as follows:
• Groundwater at the property shall not be used for drinking or other domestic, agricultural, or
industrial purposes. Groundwater will only be used for sampling and/or investigation purposes;
• No action shall be taken, allowed, suffered, or omitted on the property if such action or omission
is reasonably likely to (1) create a risk of migration of hazardous substances, pollutants, or
contaminants or a potential hazard to human health or the environment or (2) result in a
disturbance of the structural integrity of any engineering controls designed or utilized at the
property to contain hazardous substances, pollutants, or contaminants or limit human exposure to
hazardous substances, pollutants or contaminants. This includes cutting or otherwise damaging
tress on the side-slopes of the Site;
• Access shall be restricted to Commonwealth personnel and agents; and,
• The property shall not be sold, transferred, leased, or conveyed, nor allowed to be occupied by
any person other than Commonwealth personnel and agent until such time as the property owner
and the EPA enter into an agreement formally executed by a legal instrument, which is agreed to
by both parties.
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The balance of the remedial phase is divided into the Interim Maintenance Period (IMP) and the Final
Closure Period. The Commonwealth is responsible for implementation of the balance of the remedial
phase. The primary objective of the IMP, which began in 2003, was to allow the trenches to stabilize by
natural subsidence. During this period, the following activities were also required:
• Initial Remedial Phase cap maintenance and replacement as necessary;
• Trench leachate management and monitoring;
• Subsidence monitoring, periodic surveys, and repairs as necessary;
• Erosion evaluation in channels along the hillslopes;
• General site maintenance;
• Stream monitoring;
• Alluvial well monitoring;
• Data collection, analysis and reporting to the EPA;
• Maintenance of Site drainage and erosion control features; and,
• Waste burial.
It is noted that during the second FYR (September 2007), the need to process an ESD was identified to
address decisions made during the Initial Remedial Phase and the IMP that are different from the
specific requirements of the ROD. The ESD was to address three specific points from the ROD: (1)
installation of an infiltration monitoring system to continuously verify remedy performance and detect
the accumulation of leachate in disposal trenches; (2) use of a tiered approach to sampling and analysis
for compounds other than tritium; and (3) determination that no horizontal flow barrier other than the
North Channel, as constructed, is necessary.
The Final Closure Period began in November 2012, which includes the installation of a permanent
vegetative cap, installation of permanent surface water control features, and installation of surface
monuments to identify the location of buried waste.
An ESD was issued in February 2013 to document two changes that were implemented during the IMP:
(1) the decision to discontinue electronic water level monitoring in favor or manual monitoring and (2)
confirmation that no horizontal flow barrier other than the North Channel is necessary. An ESD was also
issued in September 2014. The changes documented in the 2014 ESD were based on revised cap layers
utilizing modern technologies evaluated in the Remedial Design of the Final Cap including (1) use of a
geosynthetic clay liner in-place of the two-foot layer of compacted clay described in the ROD; (2) use of
a 60-millimeter geomembrane liner rather than an 80-millimeter geomembrane liner described in the
ROD; and, (3) use of a geonet drainage layer in-place of the one-foot of crushed rock with a minimum
permeability of 1E-03 centimeter/second. Additionally, geogrid reinforcing layers were added to ensure
the stability of the cap over the trenches, and applicable location-specific Endangered Species Act
requirements were identified. It is noted that the first two issues identified in the second FYR listed
above were not subsequently addressed by an ESD.
Final cap construction began in 2015 and was completed in 2016; however, monitoring of the vegetative
cover is ongoing and the Final Closure Period has yet to be designated as complete. This designation is
expected in 2017. Once the Final Closure Period is completed, MFDS will enter into an
institutional control period of 100 years, which will include monitoring, maintenance and facility
control.
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Systems Operations/Operation & Maintenance (O&M)
Following completion of the balance of the remedial phase (when the remedial action has been fully
performed and the performance standards have been achieved), the Commonwealth will then be
responsible for the Custodial Maintenance Period, or Institutional Control Period. The Institutional
Control Period shall be conducted for 100 years following the EPA issuance of the Certification of
Completion of the Remedial Action. The Post-Institutional Control Period will follow the Institutional
Control Period with the necessary operations and maintenance activities to be performed in perpetuity.
III. PROGRESS SINCE THE LAST REVIEW
This is the fourth FYR for the Site.
Protectiveness Statement from Third FYR
The following is the Protectiveness Statement from the Third FYR:
The selected remedy at the MFDS is expected to be protective of human health and the environment
at the conclusion of the remedial action, and in the interim, exposure pathways that could result in
unacceptable risks are being controlled.
Status of Recommendations from Third FYR
No recommendations or required actions were needed to correct deficiencies affecting protectiveness
based on the Third FYR. The following "Other Comments" were included as recommendations in the
Third FYR:
1. The Commonwealth's IMP Work Plan, Appendix C, the Performance Standard and Verification
Plan, states that analysis for other contaminants will not occur unless any annual average
concentration of tritium exceeds 50% of the screening assessment (20pCi/ml or 100 pCi/ml as
applicable) during the previous five years. Based on the third Five Year review, one sampling
location exceeded the 50% of the screening assessment and therefore triggers the collection of
additional analytical data, including radionuclides other than tritium and some volatile organic
compounds.
To address the above-listed recommendation, an analysis of current groundwater and surface water COC
concentrations was conducted in 2012, subsequent to the Third FYR. Groundwater samples were
collected from the 14 alluvial wells located at the Site. In addition, surface water samples were collected
from four surface water sampling locations at the Site. Results of the sampling and analysis are
discussed under "Question B" in Section V (Technical Assessment).
2. Based upon the Horizontal Flow Barrier evaluation and statistical analysis, a Horizontal Flow
barrier is not needed at this time. This information will be included in an ESD subsequent to the
completion of this Five Year Review. EPA still plans to address the discontinuation of the continuous
level monitors in the ESD as well.
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An ESD was issued in February 2013 to document two changes that were implemented during the IMP:
(1) the decision to discontinue electronic water level monitoring in the trench sumps in favor or manual
monitoring and (2) confirmation that no horizontal flow barrier other than the North Channel is
necessary.
3. Pursuant to the statements in the previous Five-Year Review, the Commonwealth and EPA have had
numerous discussions and meetings relative to subsidence completion and initiation of the FCP
[Final Closure Period], The Commonwealth has appropriated additional funding to implement the
FCP... and, subsequent to the completion of this Five-Year Review, plans to provide documentation
to EPA demonstrating that the trench stabilization criteria have been achieved. EPA's written
approval of the Commonwealth's submission of meeting the trench stabilization criteria will initiate
the FCP.
The EPA approved the Commonwealth's submission of meeting the trench stabilization criteria on
November 12, 2016.
IV. FIVE-YEAR REVIEW PROCESS
Community Notification. Involvement & Site Interviews
Activities to involve the community in the FYR were initiated with a notification of the initiation of the
FYR in five local papers in August 2017. The results of the review and the FYR report will be made
available at the Site's information repository located at the Fleming County Public Library, Bypass
Boulevard, Flemingsburg, Kentucky, 41041. The public notice and table identifying where and when it
was published are provided in Appendix E.
During the FYR process, interviews were conducted to document any perceived problems or successes
with the remedy that has been implemented to date. The results of these interviews are summarized
below:
Interviews were conducted with several EPA and Commonwealth representatives regarding their
knowledge of and/or concerns with Site activities. All of the interviewed regulators expressed a positive
outlook on the remedy and its effectiveness at the Site. There was a general consensus that
implementation of the final cap was key to contaminant containment and that progress was due to
efficient collaboration at the State and federal regulatory levels. There were no outlier issues or
problems raised by the regulators. Additional interview information and detailed responses are provided
in Appendix H.
Data Review
This data review includes the data collected and reported by the Commonwealth pursuant to the IMP
Work Plan. Findings are presented in two subsections: (1) physical conditions and (2) contaminant
monitoring. The physical conditions include erosion monitoring of the drainage channels, interim cap
maintenance, Ieachate level monitoring, and EDB discharge flow monitoring. Contaminant monitoring
includes surface water sampling, alluvial and perimeter well sampling, and drainage channel sampling.
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Copies of the Annual Reports prepared by the Commonwealth that support this data review are provided
in Appendix L. Site maps are provided in Appendix D.
Physical Conditions - Erosion Monitoring
The erosion monitoring program monitors the EMDC, the South Drainage Channel and the West
Drainage Channel. The EMDC extends from the outlet of the EDB to its confluence with No-Name
Creek. As part of the Initial Remedial Phase design, all storm water from the cap area was routed to the
EDB. As a result, no storm water runoff from the cap flows down the South or West Drainage Channels.
During the Initial Remedial Phase, 22 fixed monuments (11 cross sections) were installed in the EMDC
and surveyed to establish baseline conditions.
Erosion control monitoring was conducted semi-annually unless otherwise noted via collection of cross-
sectional measurements and visual inspections per the IMP Work Plan. Results of the monitoring for
years 2012 through 2016 are discussed below.
Between 2012 and 2015, the inspections revealed no new erosion concerns. It is noted that in 2015, the
cap drainage system was altered to facilitate construction of the final cap. This allowed water to flow
from the cap via sheet flow to the South and West Drainage Channels and to other smaller drains on the
west and south hill slopes. Visual inspections of these drains indicted that the sheet flow increased the
rate of erosion in the drains on the west hillside. In addition, in 2015, MFDS staff noted that the
monuments at cross section 3.5 were damaged during Final Closure Period construction; this area was
not surveyed for 2015. All other cross-sectional area data were consistent with historical data. In 2016,
the spring survey was not completed. The fall survey was completed in December of 2016. The 2016
inspections revealed no erosion concerns in the east and south drains; however, the Final Closure Period
construction activities and the new storm water management functions of the cap resulted in notable
erosion in the West Drain. New erosion monuments and monitoring criteria for the three drains (East,
West, and South) receiving surface water flow from the final cap are being developed for the
Institutional Control Period Work Plan.
Physical Conditions — Interim Cap Maintenance
A total of 95 interim cap inspections were conducted each year between 2012 and 2016, including
monthly geomembrane liner, subsistence, and articulating concrete block mat system monitoring;
bimonthly diversion berm and anchor trench inspections; headwall maintenance; drainage channel
inspections; and, former leachate storage facility area inspections.
Between 2012 and 2016, no unsatisfactory notations were recorded that presented a persistent problem.
All unsatisfactory items either received actions to return them to satisfactory status or were designated
for monitoring.
Physical Conditions — Leachate Level Monitoring
Sump leachate levels are collected for two primary purposes: (1) detect recharge conditions
that may require leachate management or liner maintenance, and (2) provide data for
evaluation of possible horizontal flow barrier in addition to the North Channel installed
during the Initial Remedial Phase. Leachate levels may also be used in evaluating subsidence as
subsidence may affect localized water levels.
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Leachate levels were monitored up until 2014 when the sumps were abandoned to facilitate construction
of the final cap. In 2012, 2013, and 2014, the average loss of freeboard (available sump column from
baseline elevation to top of casing elevation) for all sumps was 1.3% (i.e., leachate collected in only
1.3% of the sump column).
Physical Conditions - EDB Discharge Flow Monitoring
Pursuant to the ROD and Initial Remedial Phase design, discharge from the EDB should be released to
the EMDC at a rate not to exceed predevelopment flow conditions. Following storm events exceeding
2.8 inches of rainfall in 24 hours (2-year storm event or greater), the Commonwealth is required to
collect recordings and report findings. These results are then evaluated by comparing the actual EDB
outflow rates and rainfall to the predicted flow rate/rainfall curve used in the outfall design (included in
the IMP Work Plan). If this screening comparison shows flow rates above predevelopment levels, then
the design model must be run to evaluate actual hydrographic conditions.
Based on data collected from the East Drain rain gauge, no rain event in 2012, 2013, or 2014 exceeded
the two-year storm event criteria; therefore, no comparison of current flow rate versus pre-developed
flow rate was required in those years.
In 2015, the East Drain rain gauge recorded a two-year storm event on April 3rd with a rainfall depth of
2.9 inches in 24 hours. A comparison of the discharge flow at the EDB flume to a predevelopment flow
rate of 11 cubic feet per second confirmed the predevelopment rate was not exceeded.
In 2016, the East Drain rain gauge recorded a two-year storm event on August 2nd. A total of 3.17
inches of rain fell in a 24-hour period. A comparison of the discharge flow at the EDB flume to the
predevelopment flow rate was not possible because the EDB flume was undergoing demolition and
renovation at the time the storm event occurred. The Final Closure Period-constructed EDB flume was
designed with a discharge rate below that of the IMP flume.
Contaminant Monitoring - Surface Water Sampling
Perennial surface water is monitored at five locations in three streams influenced by surface water runoff
from the MFDS. Sample location 122A serves as the source for background samples; it is located on
Rock Lick Creek, free from Site influence. Sample locations 106, 122C, and 103E are within the
perennial streams in the buffer zone area. Sample location 102D is the only sampling station outside the
established buffer zone at the MFDS. It is located downstream of all surface water runoff from the
MFDS and is the designated EPA compliance point. These locations are monitored using sequential
samplers that collect a four aliquot daily composite. Samples are analyzed for tritium and compared to
an action level of 20 pCi/mL and a screening level of 10 pCi/mL.
Based on the Commonwealth's collection of historical data and data obtained during the Initial Remedial
Phase, the configuration of the Site, the mobility of tritium, and the use of realistic exposure pathways,
compliance testing and monitoring related to source control focuses on water borne pathways for
tritium. Tritium is the most mobile and easily detectable contaminant at the Site. Other radiological and
chemical contaminants have not been historically detected in soils, groundwater, and surface water
unless tritium activities approach action levels.
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A summary of the data collected between 2012 and 2016 is as follows:
• During 2012, a total of 1,771 samples were collected and analyzed for tritium with no anomalous
data reported. The maximum activity reported was 13.35 pCi/mL at sample location 106.
• During 2013, a total of 1,819 samples were collected and analyzed for tritium with no anomalous
data reported. The maximum activity reported was 9.59 pCi/mL at sample location 106.
• During 2014, total of 1,771 samples were collected and analyzed for tritium with no anomalous
data reported. The maximum activity reported was 9.78 pCi/mL at sample location 106.
• During 2015, a total of 1,755 samples were collected and analyzed for tritium with no anomalous
data reported. The maximum activity reported was 9.89 pCi/mL at sample location 106.
• During 2016, a total of 1,718 samples were collected and analyzed for tritium with no anomalous
data reported. The maximum activity reported was 12.30 pCi/mL at sample location 106.
Between 2012 and 2016, all samples were below the average annual tritium screening level of 10
pCi/mL. A table summarizing the data is presented below. Tritium activity trend graphs are included in
Appendix N. In addition, in accordance with the IMP Work Plan, the Reasonably Maximally Exposed
Individual comparison indicated that none of the annual averages at location 102D (i.e., the compliance
point) exceeded the 4 mrem/year dose limit (equivalent to 20 pCi/mL).
Table 5: Annual Average Tritium Activity (pCi/mL) at Perennial Surface Water Sample
Locations
(2012-2016)
Year
Perennial Surface Water Sample Locations
122A
106
122C
103E
102D
2012
0.05
3.88
1.19
0.51
0.82
2013
0.05
3.61
1.00
0.44
0.67
2014
0.07
3.80
1.12
0.43
0.80
2015
0.07
2.79
0.77
0.39
0.52
2016
-0.02
4.05
0.61
0.50
0.39
Contaminant Monitoring - Drainage Channel Sampling
Drainage channel water is monitored at the west, south, and east drains that receive intermittent flow
from the cap. The three locations that are sampled represent the points of compliance at the former
licensed Site boundary. These locations were chosen to ensure early detection of releases from within
the Site boundary. Sample location CI 07 is located at the base of the West Drain, which discharges into
Drip Springs Creek. Sample location 143 is located near the base of the South Drain, which discharges
into Rock Lick Creek. Sample location 144 is located at the base of the East Drain, which discharges
into No Name Branch. These locations are monitored using automated samplers that collect a four
aliquot daily composite. The activity at these monitoring locations is compared to a 25 mrem/year Total
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Effective Dose Equivalent standard, an annual average action level of 100 pCi/mL, and an additional
screening level of 50 pCi/mL.
A summary of the data collected between 2012 and 2016 is as follows:
• In 2012, 919 samples were collected for tritium analysis. The average annual activity was less
than the average annual action level of 100 pCi/mL. The maximum activity reported in 2012
was 188.38 pCi/mL at sample location 144.
• In 2013, 947 samples were collected for tritium analysis. The average annual activity was less
than the average annual action level of 100 pCi/mL. The maximum activity reported in 2013 was
151.03 pCi/mL at sample location 144.
• In 2014, 826 samples were collected for tritium analysis. The average annual activity was less
than the average annual action level of 100 pCi/mL. The maximum activity reported in 2014 was
149.41 pCi/mL at sample location 144.
• In 2015, 869 samples were collected for tritium analysis. The average annual activity was 55.32
pCi/mL, which is less than the average annual action level of 100 pCi/mL. The maximum
activity reported in 2015 was 128.23 pCi/mL at sample location 144.
• In 2016, 825 samples were collected for tritium analysis. The average annual activity was 23.89
pCi/mL, which is less than the average annual action level of 100 pCi/mL. The maximum
activity reported in 2016 was 163.08 pCi/mL at sample location 144.
Between 2012 and 2016, all samples were below the average annual action level of 100 pCi/mL. A table
summarizing the data is presented below. Tritium activity trend graphs are included in Appendix N.
Table 6: Annual Average Tritium Activity (pCi/mL) at Drainage Channel Water Sample
Locations
(2012-2016)
Year
Drainage Channel
Water Sample Locations
C107
143
144
2012
12.96
0.06
67.85
2013
10.42
0.07
59.34
2014
11.01
0.06
46.01
2015
8.81
0.03
46.49
2016
15.86
0.10
55.73
It is noted that location 144 has higher tritium concentrations than the other two sample locations
because it is influenced by the east hillside seeps that receive intermittent flow from the cap. During this
FYR period, individual annual average tritium concentrations at location 144 exceeded 50% of the
screening assessment level (100 pCi/mL), which triggers the need for additional radionuclide, metals,
and volatile organic compound analysis pursuant to the Commonwealth's IMP Work Plan.
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Contaminant Monitoring - Alluvial and Perimeter Well Sampling
Groundwater monitoring at the MFDS is conducted via alluvial and perimeter monitoring wells.
Fourteen alluvial wells are located at the Site; currently, only four (AW-6, AW-7, AW-10, and AW-12)
are sampled regularly due to tritium concentrations in the remaining wells not exceeding the drinking
water standard or other applicable site-specific criterion. It is further noted that these four wells provide
coverage for assessing potential impacts to drinking water offsite. In addition, 12 of 16 perimeter
monitoring wells originally located at the Site were removed during construction of the final cap;
installation of one additional perimeter monitoring well is pending. The alluvial wells, located in the
buffer zone, were installed during the Initial Remedial Phase. Access to the alluvium within the buffer
zone is controlled by the Commonwealth; therefore, the alluvial wells are not considered a drinking
water source and do not represent a potential radiological dose to the public. The county road extending
through the buffer zone is restricted from public use, and a gate was installed to further limit access. The
perimeter monitoring wells, located along the west perimeter of the restricted area, were installed as
investigative monitoring points. The perimeter wells are maintained for water level monitoring which
satisfies an IMP Work Plan requirement and sampled to satisfy the tritium monitoring requirements in
the Site's Radioactive Material License.
During the preparation of the previous FYR in 2012, it was determined that surface water sampling
location 144 exceeded 50% of the established screening level for tritium. In accordance with
requirements of the IMP Work Plan, a sampling event was conducted specifically to quantify the
concentrations of COCs in groundwater as identified in the ROD. Therefore, in 2012, groundwater
samples were collected from all 14 alluvial wells located at the Site. Results indicated that
concentrations of arsenic in wells AW-1, AW-6, AW-13 and AW-14 exceeded the EPA Maximum
Contaminant Level (MCL) of 10 micrograms per Liter (ug/L). The Commonwealth proposed quarterly
sampling and analysis for arsenic for a minimum of four quarters. The sampling for this evaluation
ended in 2014 with concentrations in three out of the four wells falling below the MCL. Arsenic was not
detected in well AW-13 in the final three sampling events. Well AW-1 had an average concentration of
27p.g/L, which is within the historical range for isolated areas with Ohio Shale outcrops.
Five of the 14 alluvial wells were sampled between 2012 and 2015: samples were collected annually
from wells AW-6, AW-10, and AW-12, and samples were collected quarterly from wells AW-1 and
AW-7. Construction of Storm Water Management Feature (S WMF) #3 as part of the final cap
necessitated the removal of AW-1 in February 2015. Therefore, only four wells were sampled in 2016.
Between 2012 and 2016, all results were typical of historical ranges. Trend graphs are in included in
Appendix N. The maximum radioactivity was reported at AW-7 each year, and concentrations ranged
from 5.70 pCi/mL in 2012 to 6.66 pCi/mL in 2014. Comparison of the maximum concentrations at AW-
7 each year to 50 percent of the 20 pCi/mL ARAR requirement indicated that additional analysis was
not necessary.
Water levels were measured in the 16 perimeter monitoring wells on a quarterly basis each year. A table
summarizing the data is presented below. Measurements for all years indicated water levels typical of
historical data. With the exception of three wells (UF-5, UF-37, UF-45), water levels have generally
decreased between 2012 and 2016. In addition, the Site's Radioactive Material License-required tritium
analysis for select perimeter wells (i.e., wells N2B, UE-2, UF-2, UF-lOa, UK-1) were typical of
historical data and trends for each year. Trend graphs are included in Appendix N. Tritium
concentrations were observed to be generally decreasing in each perimeter well between 2012 and 2016.
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Table 7: Average of Quarterly Water Level Measurements by Year
(2012-2016)
Well ID
2012
2013
2014
2015
2016
ESI-1
14.13
14.31
14.62
12.32
Abandoned
ESI-2
11.79
11.82
11.87
10.76
11.05
ESI-4
12.36
12.40
12.58
12.02
12.05
ES1-5
13.33
13.40
13.38
13.20
Abandoned
ESI-12
19.12
19.17
19.62
18.57
Abandoned
ESI-19
14.10
14.16
14.34
13.74
Abandoned
N2B
9.04
9.12
9.38
8.71
8.60
UE-2
14.23
14.29
14.46
13.90
Abandoned
UE-11
14.32
13.47
14.32
13.86
Abandoned
UF-1
14.06
13.46
12.75
12.17
Abandoned
UF-2
10.22
10.30
10.46
9.89
Abandoned
UF-5
6.49
3.79
7.42
9.41
Abandoned
UF-lOa
28.42
28.26
Abandoned
Abandoned
Abandoned
UF-37
13.09
13.13
13.55
13.83
Abandoned
UF-45
14.41
14.49
14.51
14.55
Abandoned
UK-1
11.30
10.54
10.74
10.18
10.19
Institutional Controls
The following deed restrictions (see Appendix M) were implemented for the Site on December 5, 2003:
• Groundwater at the property shall not be used for drinking or other domestic, agricultural, or
industrial purposes. Groundwater will only be used for sampling and/or investigation purposes;
• No action shall be taken, allowed, suffered, or omitted on the property if such action or omission
is reasonably likely to (1) create a risk of migration of hazardous substances, pollutants, or
contaminants or a potential hazard to human health or the environment or (2) result in a
disturbance of the structural integrity of any engineering controls designed or utilized at the
property to contain hazardous substances, pollutants, or contaminants or limit human exposure to
hazardous substances, pollutants or contaminants. This includes cutting or otherwise damaging
tress on the side-slopes of the Site;
• Access shall be restricted to Commonwealth personnel and agents; and,
• The property shall not be sold, transferred, leased, or conveyed, nor allowed to be occupied by
any person other than Commonwealth personnel and agent until such time as the property owner
and the EPA enter into an agreement formally executed by a legal instrument, which is agreed to
by both parties.
In conjunction with the FYR, the deeds at the Fleming County Court House were reviewed to verify the
restrictions are still legally in place. No issues were identified in this review.
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Eneineering Controls
On January 15, 2016, the Kentucky Geologic Survey visited the MFDS to make preliminary
observations of a landslide complex that had damaged an embankment along the toe of the southwest
facing slope of the landfill due to the excavation of soil borrow pits for construction of the final cap. The
main landslide area lies within the Estill Shale. The purpose of the visit was to observe the ground
conditions, local geology, geomorphic setting, landslide features, property damage, and report the
findings. Several landslide features were observed along the southwest slope below the storage facility.
The toe of the slope had been excavated in September 2015 in order to mitigate a preexisting landslide,
and to harvest soil material for the disposal facility cap. After excavation, the soil material was re-
compacted to form an embankment with a similar slope angle to pre-excavation. Accelerated landslide
movement began in late September 2015. It was determined that the causes of the slide are a complex
interaction between slope modification and the physical properties of the rocks, soil, and slope
morphology. The weak bedrock geology, weak soils, steep slopes, and groundwater flow are cumulative
causes that when triggered (by a combination of slope modification and rainfall), produce stress
conditions leading to slope failure. Preexisting landslide activity, slope modification, varying lithology,
geomorphology, soil strength, and hydrologic conditions are all complex variables, and the forces that
act on a slope combined with these variables make landslide hazard assessment difficult. Landslide
monitoring and an in-depth geotechnical investigation were recommended in order to confirm the extent
of the hazard and address possible mitigation techniques.
Subsequently, an investigation was conducted to image subsurface features along geophysical electrical
resistivity survey lines to determine the extent and severity of the landslides. Five electrical resistivity
lines were laid out to conduct surveys, including a higher resolution line up the slope (Borrow Pit 4) and
across the smaller landslide complex. The investigation concluded that Borrow Pit 4 of the Estill Shale
below the Main Slide Complex will continue to have episodic landslide events. However, the processes
of weathering and erosion were concluded to be slow and should leave ample time to develop a
monitoring program and repair the slopes. It was also concluded that the landslides are likely episodic in
nature and will reactivate. Continued slope stability measures and monitoring were recommended.
A site inspection was conducted on April 25, 2017, as part of this FYR. The southwestern corner of the
landfill was observed to inspect the former borrow areas. The site inspection participants observed the
former borrow areas, included Borrow Area 4 where the most significant slips had occurred, which had
been seeded in 2016. Healthy vegetative growth was observed in the former borrow areas and on the
hillsides where slips had developed during the remediation work to install the landfill cap. The slips had
been repaired by installing surface and subsurface drains, grading, and re-seeding the areas. The slips
above the tree line were not addressed but are being monitored. KY DEP stated that no noticeable
movement had been observed in the slips since February 2017, but some bulging had been observed.
An O&M Plan is currently being prepared as part of an Institutional Control Period Work Plan for
Institutional Control Period, and it will provide the details for the activities needed to maintain the
integrity of the remedy upon the EPA issuance of the Final Closure Period. Anticipated O&M activities
may include, but are not limited, to the following:
• Final Closure Cap Monitoring, Inspection, and Maintenance
• Southeast Cap Inspection and Maintenance
• Roadways Inspection and Maintenance
• Stormwater System Inspection and Maintenance
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• Site Access and Security Inspection and Maintenance
• Buffer Zone Inspection and Maintenance
• Settlement/Subsidence Monitoring, Inspection, and Maintenance
• Erosion Monitoring, Inspection, and Maintenance
• Equipment Inspection and Maintenance
• Environmental Sampling and Monitoring
• Data Acquisition and Reporting
Site Inspection
The site inspection took place on April 25, 2017. In attendance were representatives of the EPA, KY
DEP, Kentucky Department for Public Health - Radiation Health Branch, and TechLaw, Inc. (EPA
contractor). The purpose of the inspection was to assess the protectiveness of the remedy. For a full list
of site inspection activities, including a list of those in attendance, see the Site Inspection Checklist in
Appendix F. Site photographs are available in Appendix G.
Participants met in a conference room in the KY DEP office building that is located at the Site. KY DEP
On-site Remediation Coordinator Scott Wilburn gave a PowerPoint presentation that covered the history
of the Site and remediation activities completed to-date. The final landfill cover installation was
completed in fall 2016. A number of items had yet to be completed, including installation of closed
circuit television cameras and re-seeding of areas with sparse vegetation on the landfill cover. Mr.
Wilburn informed the attendees that the contractors had three to six weeks of "touch-up work" to
complete, including cleanup of the perimeter drainage, removal of temporary erosion control features,
and checking the check dams. Mr. Wilburn reported that KY DEP had begun implementing the
Institutional Control Period Work Plan. At the time, they were awaiting completion of erosion surveys
to establish new baseline data and receipt of final as-built drawings and other documents.
After the meeting, participants conducted an inspection, walking around the capped area of the landfill
on the paved perimeter road. The area was accessed through the gate located southwest of the KY DEP
office building which provided access to the paved perimeter road. A new fence and gates had been
installed as part of the final closure period. Some work remained to be completed on the gates. Another
fence surrounded the landfill cap area and prevented direct access to the landfill from the perimeter road.
Gates at the southwest corner of the landfill and to the southeast of the KY DEP building provide access
to the landfill cap. Participants observed radiation warning monuments at the north end of the landfill,
south of the KY DEP building, and near the center of the landfill cap. Buried radiation waste caution
signs were posted on the fence at numerous locations around the fence line. Vegetative growth was well
established on most of the landfill cap area; however, several areas of sparse vegetation were observed.
The landfill cap was seeded in late summer and fall of 2016. KY DEP's Scott Wilburn stated that the
company that seeded the area would return to re-seed areas with sparse vegetation. Contractors were
observed on the landfill picking up rocks during the perimeter walk. Perimeter lights with solar panels
were installed at a number of locations around perimeter fence. Work was still being completed on the
drainage at the north end of the landfill, to the east of the KY DEP building.
After completing the walk around the landfill perimeter, the participants loaded into vehicles and were
taken over the hill down the haul road at the southwestern corner of the landfill to inspect the former
borrow areas. The participants observed the former borrow areas, which had been seeded in 2016.
Healthy vegetative growth was observed in the former borrow areas and on the hillsides where slips had
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developed during the remediation work to install the landfill cap. The most significant slips had occurred
in former Borrow Area 4. The slips had been repaired by installing surface and subsurface drains,
grading, and re-seeding the areas. The slips above the tree line were not addressed but are being
monitored. KY DEP's Scott Wilburn stated that no noticeable movement had been observed in the slips
since February 2017 but some bulging had been observed. A geologic study had been conducted in
2016, which concluded that the slips on the hillsides in the valleys were not a threat to compromise the
landfill integrity; however, long term monitoring of erosion was recommended.
The participants drove to the area to inspect drainage flow at the base of the hill that originated at the
EDB of the landfill. Survey markers were observed along and near the drainage flow path. The survey
markers were installed for monitoring erosion. SWMFs were inspected on the east side (SWMF #2) and
west side (SWMF #3). The SWMFs are retention ponds for managing storm water flow. No problems
were observed with the SWMFs. A small pond was observed on the west side, en route to SWMF #3.
Kentucky Radiation Health personnel stated that radioisotopes of uranium and strontium had been
detected in the pond water. A stake marked the location near the pond where a monitoring well was to
be installed.
After inspecting the former borrow areas and SWMFs, the participants returned to the KY DEP office
building for a wrap-up meeting. KY DEP's Scott Wilburn gave an overview of the status of final
documents related to the final closure. The final perimeter survey was in progress, but had not been
completed. Plans for potentially using light detection and ranging technology to survey and monitor for
erosion in the long-term had not been finalized. Wells planned for installation were expected to be
completed prior to finalization of this FYR. The O&M Plan for the Final Closure Period is currently
being prepared. KY DEP stated that the Site health and safety plan and contingency plan were being
updated, and would be submitted when completed.
After the meeting was adjourned, Michelle Dallessandro and Gene Nance of TechLaw conducted a
walkthrough inspection of the landfill cap area. Vegetation was well-established over most of the
landfill cap, but areas of sparse vegetation were observed. The areas with sparse vegetation were
primarily in areas that were seeded later in the fall of 2016, including the haul road across the landfill
that was used to transport loads of fill dirt onto the landfill. TechLaw observed the radiation warning
monument installed near the center of the landfill and a tower base where the closed circuit television
cameras were to be installed. Some minor erosion rills were observed in an area with sparse vegetation
near the radiation warning monument. The maximum depth of the rills was measure at approximately
two inches. Turf reinforcement mat was observed to have been installed in areas where higher storm
runoff would be expected. Vehicle tire ruts were observed near the southwestern access gate. No
evidence of trespassing was observed on the landfill cap and the former borrow areas. Minor issues
noted (e.g., sparse vegetation, minor erosion) during the inspection will be addressed as part of ongoing
O&M activities which will be incorporated into the O&M Plan which is currently being prepared. These
ongoing activities are further detailed in the Site Inspection Checklist in Appendix F.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
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Question A Summary:
The Site's remedy has not been fully implemented. The Final Closure Period began in November 2012,
which includes the installation of a permanent vegetative cap, installation of permanent surface water
control features, and installation of surface monuments to identify the location of buried waste. The
initial phases of the final capping plan also included the purchase of additional property surrounding the
Site. This measure increased the distance between the restricted areas of the Site and the public. Final
cap construction began in 2015 and was completed in 2016; however, monitoring of the vegetative cover
is ongoing and the Final Closure Period has yet to be designated as complete. This designation is
expected in 2017. Once the Final Closure Period is completed, MFDS will enter into an
institutional control period of 100 years which will include monitoring, maintenance and facility control.
The site inspection, interviews, and monitoring results (i.e., erosion monitoring of the drainage channels,
interim cap maintenance, leachate level monitoring, EDB discharge flow monitoring, surface water
sampling, alluvial and perimeter well groundwater sampling, and drainage channel sampling) discussed
herein indicate that the remedy is functioning as intended by the 1991 ROD. The final cap prevents
direct exposure to contaminated soil and waste materials, and minimizes the potential for migration of
COCs to groundwater and surface water. Institutional controls are in place to prevent use of groundwater
at the Site for drinking or other domestic, agricultural, or industrial purposes. Additional engineering
controls, including fences and surface monuments, are in place to restrict unauthorized access to the Site
and prevent trespassing.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time
of the remedy selection still valid?
Question B Summary:
The 1991 ROD ARARs for groundwater and surface water (for both chemical and radiological
contaminants) were compared with current ARARs to assess their validity. Table J-l in Appendix J
presents the review of groundwater ARARs and Tables J-2 and J-3 present the review of surface water
ARARs. The results of this assessment are discussed further below.
Groundwater
The 1991 ROD ARARs for groundwater COCs were based on the federal National Primary Drinking
Water Regulations [i.e., the MCLs]. These 1991 values were compared with the current MCLs. The
1991 ROD ARAR values also were compared to current EPA Regional Screening Levels (RSLs) (May
2016) for tap water (i.e., To-Be-Considered values). The analysis in Appendix J (Table J-l) indicates
that the 1991 ROD ARARs for arsenic, chloroform, and lead exceed the current MCLs. In addition,
based on comparison of the 1991 ROD ARARs to the May 2016 RSLs, the 1991 ROD ARARs for
arsenic, chlorobenzene, chloroform, lead, trichloroethene, and vinyl chloride result in a cancer risk level
that exceeds 1E-04 and/or a non-cancer hazard quotient (HQ) that exceeds one. Specifically, the 1991
ROD ARARs for the aforementioned COCs result in the following cancer risk and/or non-cancer hazard
estimates:
• An arsenic concentration of 50 jig/L results in a cancer risk of 9.62E-04 and an HQ of 8.3;
• A chlorobenzene concentration of 100 fig/L results in an HQ of 1.3;
• A chloroform concentration of 100 |ig/L results in a cancer risk of 4.55E-04;
21
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• A lead concentration of 50 jig/L results in an HQ of 3.3;
• A trichloroethene concentration of 5 (ig/L results in an HQ of 1.8; and,
• A vinyl chloride concentration of 2 |ig/L results in a cancer risk of 1.05E-04.
It is noted that while the 1991 ROD ARARs for chlorobenzene, trichloroethene, and vinyl chloride
result in a cancer risk greater that 1E-04 or a non-cancer HQ greater that one, none of the values exceed
the current MCLs (as the enforceable drinking water standards). Therefore, the 1991 ROD ARARs for
chlorobenzene, trichloroethene, and vinyl chloride remain valid. However, given that the 1991 ROD
ARARs for arsenic, chloroform, and lead exceed the current MCLs and result in a cancer risk that
exceeds 1E-04 and/or non-cancer HQ that exceeds one, revision to these values may warrant
consideration.
In addition to review of the validity of the 1991 ROD ARARs, an analysis of current groundwater COC
concentrations was conducted. In 2012, subsequent to the third FYR, groundwater samples were
collected from the 14 alluvial wells located at the Site. This sampling was required because, as reported
in the third FYR, the annual average concentration of tritium detected at one surface water sampling
location exceeded 50% of the screening level for tritium during the previous five years, and, therefore,
triggered the collection of additional analytical data for all COCs.
The maximum detected concentrations of the COCs in groundwater samples were compared to the
current MCLs (Table J-4). Only nickel, arsenic, and radium-226 were detected at concentrations of note:
• No MCL is currently available for nickel; however, the maximum detected concentration of
nickel (540 (ig/L) exceeded its 1991 ROD ARAR of 100 |ig/L. It is noted that the maximum
detected concentration results in an HQ of approximately 1.4 when compared with its RSL. No
other detected concentrations of nickel exceeded its 1991 ROD ARAR, and the arithmetic mean
of nickel concentrations does not exceed its 1991 ROD ARAR.
• Arsenic was detected in four samples (wells AW-1, AW-6, AW-13, AW-14) at concentrations
exceeding its current MCL of 10 ng/L; the maximum detected concentration of arsenic was 30.2
(j.g/L. It is noted that the maximum detected concentration results in an associated cancer risk of
5.81E-04 and an HQ of approximately 5 when compared with its RSLs. As a result of these
exceedances, the Commonwealth of Kentucky proposed quarterly sampling and analysis for
arsenic for a minimum of four quarters. The sampling for this evaluation ended in 2014 with
concentrations in three out of the four wells falling below the MCL. Arsenic was not detected in
well AW-13 during the final three sampling events. Well AW-1 had an average concentration of
27 ng/L, which is within the historical range for isolated areas with Ohio Shale outcrops (but still
above the EPA's upper brightline for acceptable cancer risk of 1E-04).
• Radium-226 was detected in four samples (wells AW-3 AW-4, AW-6, AW-13) at concentrations
exceeding its current MCL of 5 picoCuries per Liter (pCi/L); the maximum detected
concentration of radium-226 was 51 pCi/L. All other samples were non-detect for radium-226.
Institutional controls implemented via deed restrictions on December 5, 2003, are in place to prevent use
of groundwater at the Site for drinking or other domestic, agricultural, or industrial purposes. In
conjunction with the FYR, the deeds at the Fleming County Court House were reviewed to verify the
restrictions are still legally in place. No issues were identified in this review. In addition, no issues were
identified during the FYR site inspection.
22
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This FYR also evaluated the vapor intrusion exposure pathway using the EPA's Vapor Intrusion
Screening Level (VISL) calculator version 3.5.1 (based on the May 2016 RSLs) to identify if any of the
volatile groundwater COCs at the Site require further vapor intrusion evaluation (Appendix K). The
results of this evaluation demonstrate that the vapor intrusion pathway does not require further
evaluation. No volatile groundwater COCs were detected in groundwater at the time of the 2012
sampling event, with the exception of toluene, at a maximum estimated concentration of 1.3 ug/L. No
carcinogenic toxicity criterion is available for toluene; therefore, no carcinogenic risk attributable to the
vapor intrusion pathway could be projected. The projected residential-use based hazard associated with a
toluene concentration in groundwater of 1.3 ug/L is well below unity (1).
Surface Water
The 1991 ROD ARARs for non-radiological surface water COCs were based on the federal Ambient
Water Quality Criteria [Section 304(a)(1) of the Clean Water Act]. These values were compared with
the current federal water quality criteria (i.e., what are now called the National Recommended Water
Quality Criteria) and the State of Kentucky Water Quality Criteria (Kentucky Surface Water Standards,
401 KAR 10:031). The analysis in Appendix J (Table J-2) indicates that the human health-based 1991
ROD ARARs for arsenic; benzene; 1,2-dichloroethane; toluene; trichloroethene; and, vinyl chloride
exceed the lowest of the current human health-based ARAR values. In addition, the aquatic life-based
1991 ROD ARARs for lead and nickel exceed the lowest of the current aquatic life-based ARAR values.
The 1991 ROD human health-based ARARs for the aforementioned COCs exceed the current human
health-based ARARs as follows:
• A benzene concentration of 400 (ig/L is 25 times greater than lowest current ARAR;
• A 1,2-dichloroethane concentration of 2,430 |ig/L is 66 times greater than the lowest current
ARAR;
• A toluene concentration of 424,000 ug/L is 815 times greater than the lowest current ARAR;
• A trichlorethene concentration of 807 (ig/L is 115 times greater than the lowest current ARAR;
and,
• A vinyl chloride concentration of 5,246 |ig/L is 3,279 times greater than the lowest current
ARAR.
Based on the analysis described above and presented in Appendix J, revision to the values for arsenic,
benzene, 1,2-dichloroethane, lead, nickel, toluene, trichloroethene, and vinyl chloride may warrant
consideration.
In addition to the above-described analysis, the radiological surface water COC ARARs also were
reviewed for validity. The 1991 ROD ARARs for radiological surface water COCs were based on the
Federal Register notice on Nuclear Regulatory Commission revisions to Table II, 56 Federal Register
23409, May 21, 1991. These values were compared with the current values presented at 10 CFR Part 20,
Subpart O, Appendix B and 10 CFR Part 61.41. The analysis in Appendix J (Table J-3) indicates that the
1991 ROD ARARs remain valid.
In addition to review of the validity of the 1991 ROD ARARs, an analysis of current surface water COC
concentrations was conducted. In 2012, subsequent to the third FYR, surface water samples were
collected from four surface water sampling locations at the Site. This sampling was required because, as
reported in the third FYR, the annual average concentration of tritium detected at one surface water
23
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sampling location exceeded 50% of the screening level for tritium during the previous five years, and,
therefore, triggered the collection of additional analytical data for all contaminants.
The maximum detected concentrations of the COCs detected in surface water samples were compared to
the current ARARs (Table J-5 and Table J-6), Arsenic was detected in one sample (1.2 (jg/L) at a
concentration exceeding the current human-health based ARAR of 0.14 jig/L. In addition, bis(2-
ethylhexyDphthalate was detected in one sample (1.1 |ig/L) at a concentration exceeding its current
human health-based ARAR of 0.37 ng/L. These exceedances were detected in samples collected from
perennial streams within the Site buffer zone area (locations 122C and 103E); no exceedances were
detected at the surface water sample location located outside the buffer zone that serves as a point of
compliance (location 102D), None of the maximum detected concentrations ofradioiiiiclid.es exceeded
their current ARARs.
The RAOs used at the time of remedy selection are still valid.
QUESTION C: Has any other information come to light that could call into question the protectiveness
of the remedy?
No other information has come to light that could call into question the protectiveness of the remedy.
VI. ISSUES/RECOMMENDATIONS
OU(s) without Issaes/RecommendatioBs Ideatified in the FYR:
None
Issues and Recommends tioss Identified in tie FYR:
OU(s): N/A
(Sitewide)
Issue Category; Other
Changes in ARARs
- Groundwater
Issue: The 1991 ROD ARARs for arsenic, chloroform, and lead exceed the
current MCLs. In addition, based on comparison oi the * W1 ROD ARARs
to the May 2016 RSLs, the 1991 ROD ARARs for arsenic, chlorobeiizene,
chloroform, lead, trichloroethene, and vinyl chloride result in a cancer risk
level that exceeds 1E-04 and/or a non-cancer HQ that exceeds one.
Recommendation: Evaluate whether the 1991 ROD ARAR values for
groundwater require revision.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone Date
No
Yes
EPA
EPA
September 7. 2022
24
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OU(s): N/A
(Sitewide)
Issue Category: Other
Changes in ARARs - Surface Water
Issue: The human health-based 1991 ROD ARARs for arsenic; benzene;
1,2-dichloroethane; toluene; trichloroethene; and, vinyl chloride exceed the
lowest of the current human health-based ARAR values. In addition, the
aquatic life-based 1991 ROD ARARs for lead and nickel exceed the lowest
of the current aquatic life-based ARAR values.
Recommendation: Evaluate whether the 1991 ROD ARAR values for
arsenic, benzene, 1,2-dichloroethane, lead, nickel, toluene, trichloroethene,
and vinyl chloride require revision.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party
Milestone Date
No
Yes
EPA
EPA
September 7, 2022
Other Findings
In addition, the following are recommendations identified during this FYR. They do not affect current or
future protectiveness:
• Drainage channel water is monitored at the west, south, and east drains that receive intermittent
flow from the cap. The three locations (CI07, 143, and 144) that are sampled represent the points
of compliance at the former licensed Site boundary. The activity at these monitoring locations is
compared to a 25 mrem/year Total Effective Dose Equivalent standard, an annual average action
level of 100 pCi/mL, and an additional screening level of 50 pCi/mL. During this FYR period,
the individual annual average tritium concentrations at location 144 exceeded 50% of the
screening assessment level (100 pCi/mL), which triggers the need for collection of one round of
surface water and groundwater samples for radionuclide, metals, and volatile organic compound
analysis pursuant to the Commonwealth's IMP Work Plan. Surface water locations requiring
sampling include 102D, 122A, 122C, and 103; groundwater monitoring well locations requiring
sampling include all 14 alluvial wells. This additional sampling should be conducted pursuant to
the Commonwealth's IMP Work Plan.
25
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VII. PROTECTIVENESS STATEMENT
Sitewide IVoteetiveness Statement
Protectiveness Determination:
Short-term Protective
Protectiveness Statement:
The remedy at MFDS is protective of human health and the environment in the short-term,
because remedial activities completed to date have adequately addressed all exposure
pathways that could result in unacceptable risks at MFDS.
VIII. NEXT REVIEW
The next FYR for the Site is required five years from the completion date of this review.
26
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APPENDIX A - REFERENCE LIST
Record of Decision, Summary of Remedial Alternative Selection, Maxey Flats Disposal Site, Fleming
County, Kentucky. EPA Region 4. September 1991.
First Five-Year Review Report for MFDS. September 2002.
Second Five-Year Review Report for MFDS. September 2007.
Third Five-Year Review Report for MFDS. September 2012.
Explanation of Significant Differences. EPA Region 4. February 2013.
Maxey Flats Project Annual Report, 2012. March 27, 2013.
Maxey Flats Project Annual Report, 2013. March 24, 2014.
Maxey Flats Project Annual Report, 2014. Undated.
Explanation of Significant Differences. EPA Region 4. September 2014.
Maxey Flats Project Annual Report, 2015. Undated.
Landslide Observations at Maxey Flats, Fleming County, Kentucky: Report for the Kentucky
Department for Environmental Protection. Kentucky Geologic Survey. Undated.
Preliminary Electrical Resistivity Survey of the Slide Complex at the Maxey Flats Project. March 13,
2016.
Maxey Flats Project Annual Report, 2016. March 28, 2017.
A-l
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APPENDIX B - SITE CHRONOLOGY
Table B-l: Site Chronology
Event
Date
NECO managed and operated the disposal of approximately
4,750,000 cubic feet of low-level radioactive waste.
May 1963 - December 1977
Evaporator operations processed more than 6,000,000
gallons of liquid.
1973-April 1986
PVC cover was placed over the disposal trenches.
1981
The EPA lists Maxey Flats Disposal Site on National
Priorities List.
1986
PRPs sign Administrative Order by Consent (EPA Docket
No. 87-08-C) for the RI/FS. PRPs formed the Maxey Flats
Steering Committee.
1987
The EPA performed Emergency Action.
December 1988 - November
1991
The EPA approves the RI Report.
July 1989
The EPA submits the FS and the Administrative Record to
the public.
May 1991
The EPA issues the Record of Decision for the MFDS,
Fleming County, Kentucky.
September 1991
The EPA issues Special Notice to the Potentially
Responsible Parties.
1992
Settling Defendants Consent Decree and Statement of Work,
de minimis Consent Decree, Settlement Agreement between
the Federal Agencies and the Settling Private Parties (SPPs),
Steering Committee Participation and Cost Sharing
Agreement, and the Operating Agreement of the Maxey Flats
Site IRP, L.L.C. negotiated among SPPs, Commonwealth of
Kentucky, Settling Federal Agencies and EPA.
1992-1995
Consent Decree, U.S. District Court for the Eastern District
of Kentucky No. 95-58, for the Maxey Flats Disposal Site is
lodged. SPPs initiate installation of Construction cover.
July 1995
SPPs complete installation of Construction cover.
October 1995
Consent Decree is entered by the Court. Initial Remedial
Phase Remedial Design activities begun by SPPs; Initial
Remedial Phase Monitoring and Maintenance activities
begun by the Commonwealth.
April 1996
SPPs mobilize to Site, initiate Leachate Removal/Disposal
(LR/D) Design Construction.
June 1997
The EPA approves SPP's Final LR/D Design Report.
January 1998
The EPA holds Public Open House at MFDS.
August 1998
SPPs complete LR/D Construction and initiate LR/D
operations.
September 1998
The EPA holds Public Meeting, Fleming County Courthouse
to discuss LR/D Operations and winter shutdown.
February 1999
B-l
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Event
Date
SPPs initiate Remaining Work with Southeast Cap
construction.
June 1999
The EPA holds Public Open House at MFDS to review
ongoing Initial Remedial Phase LR/D activities.
October 1999
The EPA finds Leachate Removal Performance Standards
met, Leachate removal operations cease and shutdown/
decommissioning is initiated.
August 2000
The EPA holds Public Open House at MFDS to discuss
LR/D decommissioning and RW construction.
September 2000
SPPs initiate balance of RW construction.
October 2000
The EPA conducts Five-Year Review. SPPs continue RW
Construction.
June 2002
Commonwealth begins Interim Maintenance Period
Monitoring.
January 2003
SPPs complete the Initial Remedial Phase work.
May 2003
SPPs submit Initial Remedial Phase Remedial Action
Construction Report to EPA. EPA approves Commonwealth
IMP Work Plan.
June 2003
The EPA issues the Initial Remedial Phase Certification of
Completion.
October 2003
Commonwealth holds Public Open House at MFDS.
April 2006
The EPA completes second Five-Year review.
September 2007
Commonwealth holds Public Open House at MFDS.
April 2008
Greater than 25-year project storm occurs at Site.
May 2, 2010
Commonwealth holds Public Open House at MFDS.
October 2010
The EPA Initiates third Five-Year Review.
October 2011
The EPA completes third Five-Year Review
September 2012
Final Closure Period begins
November 2012
The EPA issues an ESD for the Site.
February 2013
The EPA issues an ESD for the Site.
September 2014
Final cap construction begins
2015
Final cap construction is completed
To Be Determined
B-2
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APPENDIX C - SITE BACKGROUND
C-l: Site Description
The MFDS, located in Fleming County, Kentucky, is an inactive low-level radioactive waste site owned
by the Commonwealth of Kentucky. The property encompasses approximately 770 acres and includes a
disposal tract and buffer zone.
The Site is located in the Knobs physiographic region, which is characterized by hills and relatively flat-
topped ridges. The disposal cell is located on a spur of Maxey Flats, one of the larger flat-topped ridges
in the region. The Site is bounded by steep slopes on the west, east, and south and is approximately 350
feet above the adjacent valleys.
The land surrounding the Site is primarily mixed woodlands and open farmland. The area is sparsely
populated and mostly undeveloped. The few residences in the area have a public water supply system.
C-2: Site History and Operations
In January 1963, the Commonwealth of Kentucky issued a license to NECO for the disposal of solid by-
product, source and special nuclear material on a 252-acre disposal tract. From May 1963 through
December 1977, NECO managed and operated the disposal of an estimated 4,750,000 cubic feet of low-
level radioactive waste at the Site. Environmental monitoring in 1972 by the Commonwealth revealed
possible migration of radionuclides from the disposal area known as the "Restricted Area." A special
study was performed by the Commonwealth in 1974 that confirmed that tritium and other radioactive
contaminants were migrating out of the disposal trenches and that some radioactive material had
migrated into unrestricted areas. In 1977, it was determined that leachate was migrating through the
subsurface geology and NECO was ordered to cease the receipt and burial of radioactive waste. NECO's
license was transferred back to the Commonwealth Department of Natural Resources and Environmental
Protection in 1979.
From 1973 through April 1986, an evaporator was operated at the Site as a means of managing the large
volume of water infiltrating the disposal trenches as well as waste water generated by on-site activities.
The evaporator processed over 6,000,000 gallons of liquids during its operation and the evaporator
concentrates were disposed of on-site.
From 1983 to 1986, MFDS was in the process of being listed on the EPA's NPL at the request of the
Commonwealth. In 1986, the listing was finalized and the EPA issued general notice letters to 832 PRPs
informing them of their potential liability with respect to Site contamination. In March 1987, 82 PRPs
signed an Administrative Order by Consent to perform a RI/FS.
In December 1989, the EPA initiated an Emergency Response Action at MFDS due to an imminent
threat to public health, welfare, and the environment posed by the potential release of liquids stored in
on-site storage tanks. The EPA installed heaters in the tank farm building to prevent freezing and
possible rupturing and installed additional storage capacity on-site. The EPA also solidified 286,000
gallons of radioactive liquids stored in the tanks and on the floor of the tank building. These 216
solidified blocks were buried in newly constructed trenches within the Restricted Area.
C-l
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The RI Report for the MFDS was approved by the EPA in July 1989. The FS for the MFDS was
finalized and submitted to the public in May 1991. A ROD was signed for the Site on September 30,
1991.
C-3: Physical Site Characteristics
The MFDS includes an inactive low-level radioactive waste landfill and a 464-acre buffer zone. The
whole Site encompasses 770 acres. The Site is owned by the Commonwealth of Kentucky. The landfill
is capped to reduce groundwater infiltration.
The MFDS is located in the Appalachian Plateau, in the Knobs physiographic region of northeast
Kentucky, an area characterized by relatively flat-topped ridges (flats) and hills (knobs). The MFDS is
located on a spur of Maxey Flats, one of the larger flat-topped ridges in the region. The MFDS is
bounded by steep slopes to the west, east, and south and is approximately 350 feet above the adjacent
valley bottoms.
Numerous studies have reported on the geology of the MFDS. The following text is a summary of the
geology, hydrology, and hydrogeology from the RI report and the ROD:
The MFDS lies in a tectonically stable region of North America with few exposed faults and relatively
infrequent earthquakes. The rock units exposed in the area surrounding the MFDS consist of shale,
siltstone, and sandstone ranging in age from the Silurian to Mississippian (320 to 430 million years old).
In the MFDS area, the rock units dip 25 feet per mile (0.3 degrees); regionally they dip to the east at 30
to 50 feet per mile.
The Nancy Member of the Borden Formation is exposed on the hilltop at Maxey Flats and is 27 to 60
feet thick. The unit is mostly shale with two laterally extensive siltstone beds, the Lower Marker Bed
and Upper Marker Bed. These beds were up to 2.8 feet thick at locations encountered during drilling
operations at Maxey Flats.
Underlying the Nancy Member, the Farmers member of the Borden Formation is characterized as an
interbedded siltstone and shale, approximately 29 to 42 feet thick. Underlying the Farmers Member is
the 4 to 7 feet thick shale of the Henley Bed, 17 to 18 feet thick Sunbury Shale, and 21 feet thick
Bedford Shale. The Ohio Shale lies beneath the Bedford Shale and above the upper part of the Crab
Orchard formation.
Fractures are present in all rock units at the MFDS with fracture sets oriented in descending 6 order,
northeast-southwest, northwest-southeast, and north-south. The fracture sets are generally within 20
degrees of vertical. The weathered shale of the Nancy Member is the most highly fractured.
The distinguishing feature of the Nancy Member, and perhaps that of the MFDS geology, is the Lower
Marker Bed of the Nancy Member. The Lower Marker Bed is a thin siltstone layer that is generally flat-
lying (some local undulations of the bed are present), fractured and weathered, and lies approximately
15 to 25 feet below ground surface. The Lower Marker Bed has been identified as the principal leachate
flow pathway at the MFDS and underlies or intersects the majority of disposal trenches. Consequently,
the Lower Marker Bed is a highly contaminated geologic unit at the MFDS. Another distinguishing
characteristic of the Lower Marker Bed that underlying units are hydraulically connected to the Lower
Marker Bed.
C-2
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Groundwater resources in a three county area, including the Maxey Flats area, are very limited, with
adequate residential supplies (up to 500 gallons per day) generally available only in broad valley
bottoms like the Licking River valley. The small valleys adjacent to MFDS would not produce enough
water for a dependable domestic water supply. On hills the Borden Formation yields little water (less
than 100 gallons per minute), and almost no water from wells drilled in shale. Groundwater is
sometimes present in the fractures of rock units. Wells drilled in the Ohio Shale can provide up to 500
gallons per day, but locally can be of poor quality.
The residents of Maxey Flats have been on a public water supply since about 1985. Before then, water
was typically obtained from shallow wells dug in the soil or weathered shale of the Nancy Member,
which supplied approximately 25 to 50 gallons per day. Most investigators have considered the water to
be from a perched water table. The source of this water was apparently from secondary porosity in the
soil or weathered rock, and also from roof downspouts routed into the wells. These shallow wells were
unreliable sources of water and may have acted more as storage cisterns than as wells.
Below is a geologic cross-section of MFDS:
*
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FIGURE AQAPTED FRCU FiCURE
<•2 OF EBASC0 (1939)
SCHEMATIC GEOLOGIC
CROSS-SECTION
MAXEY FLATS DISPOSAL SITE
MOREHEAD. KENTUCKY
INTERNATIONAL
TECHNOLOGY
CORPORATION
C-3
-------
Vertical migration of groundwater between geological strata is limited by low permeability shale layers,
which act as aquitards. Because the MFDS is bounded on the three sides by steep slopes, the
contaminated leachate migrating horizontally through the fractured siltstone layers generally moves into
the bottom of the soil layer on these hillslopes. However, as evidenced by the occurrence of seeps on the
east hillside, not all leachate migrates to the bottom of the soil layer.
Hydrogeologic evaluations of the MFDS indicate that groundwater movement through the rock strata
into the disposal trenches may be negligible. Regardless, the potential pathway for groundwater flow
into the trenches through the narrow neck at the north side of Maxey Flats where the trench area is
connected to the main portion of the Maxey Plateau was partially eliminated during Initial Remedial
Phase by construction of the North Channel.
Drip Springs Creek, located on the west side of the MFDS, and No Name Creek, located on the east side
of the MFDS, both flow into Rock Lick Creek to the southwest of the MFDS. Rock Lick Creek flows
into Fox Creek approximately two miles southwest of Maxey Flats. Fox Creek flows into the Licking
River, approximately 6.5 miles west of MFDS, which empties into the Ohio River near Cincinnati, Ohio,
approximately 100 miles from Maxey Flats.
C-4
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APPENDIX D - SITE MAPS
Figure D-l: Site Vicinity Map
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is
for informational purposes only regarding the EPA's response actions at the Site.
D-l
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Figure D-2: Site Overview Map
Attachment 1
Sit® Overview Map
Matey Hats
Fleming County. Kertucky
BaMfnap Sot«ct
Bmg *nage*y 20>0
df nmxinuy inc.
Vddms
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the
EPA's response actions at the Site.
D-2
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Figure D-3: 2016 Areal View of the Maxey Flats Disposal Site
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the
EPA's response actions at the Site.
D-3
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Figure D-4: Perennial Streams and Drainage Channel Surface Water Sampling Locations
LEGEND:
ORIGINAL PROPERTY
BOUNDARY
CURRENT SITE
PROPERTY BOUNDARY
Perennial Streams
• Surface Water Sampling
Locations
Drainage Channel Surface
Water Sampling Locations
1.0DD 2,GOD
Feet
Basemap Source
USDA FSA (NAIP 2016)
08 June 2016
Perennial Streams and
Surface Water
Sampling Locations
Maxey Flats Disposal Site
Fleming County, Kentucky
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the
EPA's response actions at the Site.
D-4
-------
Figure D-5: Groundwater Monitoring Locations
LEGEND.
ORIGINAL PROPERTY
OOUHDARY
CURRENT SITE
PROPERTY BOUNDARY
„ Alluvial Wells
m (Active)
Alluvial Wells
(Abandoned 2017)
Groundwaiei Monitoring
Locations - Alluvial Wells
Maxey Flats Disposal Site
Fleming County, Kentucky
Basemap Source:
USOAFSA(NAIP2D16)
03 June 2016
2.0M
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the
EPA's response actions at the Site.
D-5
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Figure D-6: Additional Site Features of Note
ik*.Vi ¦$'© i<"'i . 'i i r*7T
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. V V_,"V- {\ i- /'{(;(({/,< ¦ Abandoned Monitoring We#
&\\fc
Monitoring Wefl
30 Trend* Locations
Groundwater Monitoring
Locations - USGS Wells
Maxey Flats Disposal Site
Fleming County, KY
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the
EPA's response actions at the Site.
D-6
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APPENDIX E - PRESS NOTICE
E-l
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U.S. Environmental Protection Agency, Region 4
Announces the Fourth Five-Y ear Review
Tor Maxey Flats Nuclear Disposal Site
Fleming County, Kentucky
A Five-Year Review is being conducted by the U.S. Environmental Protection Agency (EPA) of
the clean-up activities taken at the Maxey Flats Nuclear Disposal Site (the Site) located in
Fleming County, Kentucky The Superfund law, known as the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), requires that Superfund cleanup actions
be reviewed ever/ five years, to ensure that the selected remedy remains protective of human
health and the environment Thus the purpose of this Five-Year Review, the fourth for this Site,
is to evaluate the performance and effectiveness of the remedy selected, which includes, but is
not limited to, an interim cap, natural stabilization of waste, a final cap, stormwater drainage
components, and other supporting infrastructure When completed, a copy of the review report
will be placed in the Information Repository located at the Fleming County Public Library,
Bypass Blvd., Flemingsburg, K Y 4104 1; (60(5) 845-7351
The EPA will also conduct a number of interviews with nearby businesses, residents, local and
state officals to sohcite feedback on the clean-up process. The EPA will complete the current
Five-Year Review process this year
If you would like more information or have any questions, comments, andfor concerns about the
Five-Year Review, you may contact:
Pam Scully
Remedial Project Manager
U.S EPA. Region 4
61 Forsyth Street, S\V.
Atlanta, GA 30303
Phone -104-562-8935
Email ¦¦ru.'iv fa'.i K-
StephanieYvette Brown
Community Inwlvement Coordinator
U.S EPA, R.egion 4
61 Forsyth Street, S'\V.
Atlanta, GA 30303
Phone 404-562-8450
E-mail. 'Kyvv;. stfrti|iamcv@CM-.»
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Media Name
Contact
Publication Schedule/Circulation
Comments
Ashland Daily Independent
224 I7,h Street
Ashland, KY 41101
(606)326-2622
Kim Harper
The Daily Independent
khurpcrt/ldai lYindcDcndcnt.com
Daily
15,295 Sunday Largest
Circulation
$
Publication on Sunday
August 6th
Lexington Herald Leader
100 Midland Avenue
Lexington. KY 40508
(859)231-1361
hllcuiikids a hci'iikl-lcndcr.cnm
Ryan Dixon
R Dixon a horaUI-k-iidcr.cuni
Daily
500,060 circulation
Sunday largest circulation day
Must be in by Wed AM
Publication on
Sunday August 6th
Maysvillc
Ledger/Independent
41 -43 West Second Street
P.O. Box 518
Maysville, KY 41506
(606) 564-9091
.lohnna Dorn
Advertising Assistant
The Ledger Independent
120 Limestone Street
Maysvillc, Kentucky 41056
Phone: 606-564-9091 ext. 388 or
390
Email: .lohnna.Doiivi/ Icc.ik-i
Monday-Saturday
8500 Circulation
Saturday largest circulation
Publication on
Saturday August 5,h
Morchcad News
722 West First Street
Morehead, KY
Alyssa Dulen
Advertising Coordinator
Phone: (606) 784-4116
adulcii a I lum hit head new s.com
Tuesday and Friday
Deadline Friday for Tuesday
Wednesday for Friday
5800 Circulation
Friday is the largest circulation
Publication on Friday
August 41'1
Flcmingsburg Gazette
P.O. Box 32
Flemingsburg, KY 41041
(606) 845-9211
Tonya or Charles
Charles
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APPENDIX F - SITE INSPECTION CHECKLIST
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
I. SITE INFORMATION
Site Name: Maxev Flats DisDosal Site
Date of Inspection: April 25, 2017
Location and Region: Fleming Countv.
EPA ID: KYD980729107
Kentuckv/Reaion 4
Agency, Office or Company Leading the Five-Year
Review: EPA Region 4
Weather/T emperature:
Remedy Includes: (Check all that apply)
[R1 Landfill cover/containment
1 1 Monitored natural attenuation
[x] Access controls
~ Ground water containment
^ Institutional controls
~ Vertical barrier walls
I | Ground water pump and treatment
~ Surface water collection and treatment
1 I Other:
Attachments: ^ Inspection team roster attached
l~l Site map attached
II. INTERVIEWS (See Appendix H, Interview Documentation)
1. O&M Site Manager
Name
Title Date
Interviewed Q at site Q at office Q by phone :
Problems, suggestions ~ Report attached:
2. O&M Staff
Name
Title Date
Interviewed ~ at site Q at office ~ by phone :
Problems/suggestions Report attached:
3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices). Fill in all that apply.
Agencv
Contact
Name Title Date Phone No.
Problems/sueaestions PI Renort attached:
Agencv
Contact Name
Title Date Phone No.
Problems/suaeestions I-] Report attached:
Agencv
Contact
Name Title Date Phone No.
Problems/suesestions 1 1 Renort attached:
Agencv
Contact
Name Title Date Phone No.
Problems/sueeestions PI Reoort attached:
F-l
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Aeencv
Contact
Name Title Date Phone No.
Problems/suggestions ~ Report attached:
4.
Other Interviews (optional) HI Report attached:
III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)
1.
O&M Documents
~ O&M manual Q Readily available ~ Up to date N/A
~ As-built drawings Q Readily available ~ Up to date K! N/A
~ Maintenance logs O Readily available ~ Up to date S N/A
Remarks: O&M Manual and as-built drawings are currentlv beine prepared and are not final. Final
Cap installation completed in Late 2016.
2.
Site-Specific Health and Safety Plan ~ Readily available 1 1 Up to date [3 N/A
~ Contingency plan/emergency response ~ Readily available Q Up to date ^ N/A
plan
Remarks: HASP & contineencv/ER Dlan currentlv beine updated. Site Mer will provide for review
when updated.
J.
O&M and OSHA Training Records ~ Readily available Q Up to date ^ N/A
Remarks: O&M records N/A because the O&M Dlan has not been comDleted. Inspection team did not
review OSHA training records while on Site.
4.
Permits and Service Agreements
~ Air discharge permit ~ Readily available 1 I Up to date [X] N/A
~ Effluent discharge ~ Readily available Q Up to date El N/A
~ Waste disposal, POTW ~ Readily available ~ Up to date El N/A
I-! Other permits: (~~| Readilv available I-! Up to date Kl N/A
Remark: The Site has no permits. The Site is currentlv renewine its nuclear license.
5.
Gas Generation Records Q Readily available ~ Up to date K N/A
Remarks: Not Applicable
6.
Settlement Monument Records ~ Readily available ~ Up to date EH N/A
Remarks: Baseline monument survev had not been completed at the time of the Site Inspection.
7.
Ground Water Monitoring Records ~ Readily available Q Up to date [H N/A
Remarks: Records not reviewed while on Site. The EPA has applicable groundwater monitorine
records.
8.
Leachate Extraction Records ~ Readily available ~ Up to date K N/A
Remarks: Not Applicable
9.
Discharge Compliance Records
~ Air Q Readily available ~ Up to date K N/A
F-2
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~ Water (effluent) ~ Readily available ~ Up to date K N/A
Remarks: Not ADDlicable
10. Daily Access/Security Logs
~ Readily available Q Up to date IZH N/A
Remarks: Site sign-in sheet available. Historical access/securitv loes were not reviewed while on Site.
IV. O&M COSTS
1. O&M Organization
State in-house
I~1 Contractor for state
1 1 PRP in-house
1 1 Contractor for PRP
H] Federal facility in-house
1 1 Contractor for Federal facility
n
2. O&M Cost Records
l~~l Readily available
1 1 Up to date
l~~l Funding mechanism/agreement in place Unavailable O&M plan has not been finalized
Original O&M cost estimate:
1 1 Breakdown attached
Total annual cost by year for review period if available
From: To:
H Breakdown attached
Date Date
Total cost
From: To:
H Breakdown attached
Date Date
Total cost
From: To:
H Breakdown attached
Date Date
Total cost
From: To:
n Breakdown attached
Date Date
Total cost
From: To:
I"! Breakdown attached
Date Date
Total cost
3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons:
V. ACCESS AND INSTITUTIONAL CONTROLS ^Applicable QN/A
A. Fencing
1. Fencing Damaged Q Location shown on site map ^ Gates secured ~ N/A
Remarks: New fencina has been installed around the Site and around the landfill can. Gate controllers
had not vet been installed at the time of the Site Inspection: however, sates were secure at the time of the
site insDection. The Site contractor subseauentlv renorted that thev have been installed.
B. Other Access Restrictions
1. Signs and Other Security Measures
Location shown on site map Q N/A
Remarks: Radiation siens were posted on the fence around the perimeter of the landfill caD. Marker
monuments were installed at the north end of the landfill and at the aDDroximate center of the landfill.
F-3
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C. Institutional Controls (ICs)
~ Yes No ~ N/A
~ Yes No ~ N/A
6063562965
1. Implementation and Enforcement*
Site conditions imply ICs not properly implemented
Site conditions imply ICs not being fully enforced
Type of monitoring (e.g., self-reporting, drive by): Personnel on Site
Frequency: Daily (during week davs)
Responsible party/agency: Kentucky PEP
Contact Scott Wilburn Site Manager
Name Title
Reporting is up.to date
Reports are verified by the lead agency
Specific requirements in deed or decision documents have been met
Violations have been reported
Other problems or suggestions: ~ Report attached
No site records were reviewed during site inspection: however, available documents were provided
and reviewed following the site inspection.
Date
Phone no.
~ Yes
~ No
~n/a
~ Yes
~ No
~ n/a
~ Yes
~ No
~ n/a
~ Yes
~ No
~ n/a
2.
Adequacy
Remarks:
53 ICs are adequate
~ ICs are inadequate
~ N/A
D. General
1. Vandalism/Trespassing l~~l Location shown on site map Rl No vandalism evident
Remarks: No indications of trespassing or vandalism were observed during the Site Inspection.
2. Land Use Changes On Site
Remarks:
^ N/A
3. Land Use Changes Off Site
Remarks:
I N/A
VI. GENERAL SITE CONDITIONS
A. Roads
| Applicable ~ N/A
1. Roads Damaged ~ Location shown on site map ^ Roads adequate ~ N/A
Remarks: Road around landfill cap was installed last year and was in good condition.
B. Other Site Conditions
Remarks: Slips on hillside over the hill near former borrow areas. Some have been repaired, remaining
slip areas to be monitored and repaired as necessary. Monitoring will be included in the O&M Plan.
VII. LANDFILL COVERS ^Applicable ~ N/A
A. Landfill Surface
Settlement (low spots)
Arial extent:
Remarks:
~ Location shown on site map
Kl Settlement not evident
Depth:
2.
Cracks
~ Location shown on site map
F_4
^ Cracking not evident
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Lengths: Widths: Depths:
Remarks:
3. Erosion I~1 Location shown on site map I I Erosion not evident
Arial extent: estimated 5' x 25' Depth: 2" maximum
Remarks: Only one small area with some minor erosion channeling was observed in an area with
sparse/no vegetation located near monument-marker near center of landfill (see Appendix G1.
Maximum depth of channels 2" depth. Monitoring will be included in the O&M Plan.
4. Holes Q Location shown on site map ^ Holes not evident
Arial extent: Depth:
Remarks:
5. Vegetative Cover ^ Grass I~1 Cover properly established
PI No signs of stress EH Trees/shrubs (indicate size and locations on a diagram)
Remarks: Most of landfill cap had adequate vegetative cover: however, some areas sparsely vegetated-
Some areas were not seeded until late in the Fall 2016. KY PEP had landscaping company scheduled
to return to re-seed areas with sparse vegetation.
6.
Alternative Cover (e.g., armored rock, concrete)
IEHn/a
Remarks:
7.
Bulges Q Location shown on site map
13 Bulges not evident
Arial extent:
Height:
Remarks:
8. Wet Areas/Water £3 Wet areas/water damage not evident
Damage
O Wet areas
1 1 Location shown on site map
Arial extent:
n Ponding
1 1 Location shown on site map
Arial extent:
~ Seeps
~ Location shown on site map
Arial extent:
1~1 Soft subgrade
l~~l Location shown on site map
Arial extent:
Remarks: One area had vehicle tracks where vehicle had driven across the area before it dried after a
rain event. KY PEP was aware of this issue and planned for repairs.
9. Slope Instability Q Slides Q Location shown on site map
^ No evidence of slope instability
Arial extent:
Remarks:
B. Benches Q Applicable ^ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
1. Flows Bypass Bench O Location shown on site map Q N/A or okay
Remarks:
2. Bench Breached ~ Location shown on site map ~ N/A or okay
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Remarks:
3.
Bench Overtopped O Location shown on site map
Remarks:
~ N/A or okay
C.
Letdown Channels ~ Applicable ^ N/A
Turf reinforcement mats (TRM) installed in hi eh flow areas of landfill, thoueh not considered Letdown Channels
(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement (Low spots) Q Location shown on site map
~ No evidence of settlement
Arial extent:
Depth:
Remarks:
2.
Material Degradation ~ Location shown on site map
~ No evidence of degradation
Material tvt>e:
Arial extent:
Remarks:
3.
Erosion Q Location shown on site map
~ No evidence of erosion
Arial extent:
DeDth:
Remarks:
4.
Undercutting ~ Location shown on site map
~ No evidence of undercutting
Arial extent:
DeDth:
Remarks:
5.
Obstructions TvDe:
~ Location shown on site map Arial extent:
Size:
Remarks:
~ No obstructions
6.
Excessive Vegetative Growth Tvoe:
[3 No evidence of excessive growth
O Vegetation in channels does not obstruct flow
Q Location shown on site map Arial extent:
Remarks:
D.
Cover Penetrations ~ Applicable ^ N/A
1.
Gas Vents Q Active
[~1 Passive
[~l Properly secured/locked Q Functioning Q Routinely sampled EH Good condition
I~1 Evidence of leakage at penetration 1 1 Needs maintenance Q N/A
Remarks:
2.
Gas Monitoring Probes
1 1 Properly, secured/locked Q Functioning Q Routinely sampled d Good condition
O Evidence of leakage at penetration Q Needs maintenance O N/A
F-6
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Remarks:
3. Monitoring Wells (within surface area of landfill)
[~~1 Properly secured/locked EH Functioning Q Routinely sampled
EH Good condition
f~l Evidence of leakage at penetration EH Needs maintenance
EH N/A
Remarks:
4. Extraction Wells Leachate
l~~l Properly secured/locked EH Functioning EH Routinely sampled
EH Good condition
1 1 Evidence of leakage at penetration EH Needs maintenance
EH N/A
Remarks:
5. Settlement Monuments EH Located EH Routinely surveyed
EHn/a
Remarks:
E. Gas Collection and Treatment EH Applicable ^ N/A
1. Gas T reatment Facilities
l~~l Flaring EH Thermal destruction
EH Collection for reuse
n Good condition EH Needs maintenance
Remarks:
2. Gas Collection Wells, Manifolds and Piping
~ Good condition EH Needs maintenance
Remarks:
3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
EH Good condition EH Needs maintenance EH N/A
Remarks:
F. Cover Drainage Layer ^ Applicable EH N/A
1. Outlet Pipes Inspected EH Functioning ^ N/A
Remarks:
2. Outlet Rock Inspected ^ Functioning EH N/A
Remarks: Rock CriD ran) installed around perimeter of landfill caD
G. Detention/Sedimentation Ponds ^ Applicable EH N/A
1. Siltation Area extent: Depth:
EHn/a
EH Siltation not evident
Remarks: Minimal/unmeasurable sediment in East Basin.
2. Erosion Area extent: Depth:
153 Erosion not evident
Remarks:
3. Outlet Works £3 Functioning EH N/A
Remarks:
F-7
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4. Dam Functioning
~ n/a
Remarks:
H. Retaining Walls ~ Applicable ^ N/A
1. Deformations EH Location shown on site map
~ Deformation not evident
Horizontal displacement: Vertical displacement:
Rotational displacement:
Remarks:
2. Degradation ~ Location shown on site map
1 1 Degradation not evident
Remarks:
1. Perimeter Ditches/Off-Site Discharge ^ Applicable
~ n/a
1. Siltation ~ Location shown on site map
Kl Siltation not evident
Area extent-
Depth:
Remarks: No siltation in ditches or storm drains in and alone the landfill Derimeter road.
2. Vegetative Growth HH Location shown on site map
~ n/a
E3 Vegetation does not impede flow
Area extent:
Type:
Remarks: Vecetative growth in drainaae swale/ditches alone eastern Derimeter that drain into east basin.
Turf reinforcement mat installed.
3. Erosion 0 Location shown on site map
Ex] Erosion not evident
Area extent:
Depth:
Remarks:
4. Discharge Structure 0 Functioning
El N/A
Remarks:
VIII. VERTICAL BARRIER WALLS ~ Applicable
£x]N/a
1. Settlement ~ Location shown on site map
[~1 Settlement not evident
Area extent:
Depth:
Remarks:
2. Performance Monitoring Type of monitoring:
I~1 Performance not monitored
Freauencv:
I~1 Evidence of breaching
Head differential:
Remarks:
IX. GROUND WATER/SURFACE WATER REMEDIES ~ Applicable g] N/A Containment
A. Ground Water Extraction Wells, Pumps and Pipelines
~ Applicable ^ N/A
1. Pumps, Wellhead Plumbing and Electrical
~ Good condition ~ All required wells properly operating HH Needs maintenance Q N/A
F-8
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Remarks:
2.
Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
~ Good condition [H Needs maintenance
Remarks:
3.
Spare Parts and Equipment
l~1 Readily available Q Good ~ Requires upgrade O Needs to be provided
condition
Remarks:
B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable ^ N/A
1.
Collection Structures, Pumps and Electrical
I~1 Good condition Q Needs maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
1 1 Good condition H] Needs maintenance
Remarks:
3.
Spare Parts and Equipment
l~1 Readily available Q Good Q Requires upgrade Q Needs to be provided
condition
Remarks:
C.
Treatment System Q Applicable [3 N/A
1.
Treatment Train (check components that apply)
n Metals removal EH Oil/water separation Q Bioremediation*
~ Air stripping HI Carbon adsorbers EH In-situ chemical oxidation*
I-! Filters: HI Monitored natural attenuation*
HI Additive fe.e.. chelation aaent. flocculent):
HI Others:
HI Good condition O Needs maintenance
CU Sampling ports properly marked and functional
HI Sampling/maintenance log displayed and up to date
HI Equipment properly identified
HI Ouantitv of ground water treated annuallv:
HI Ouantitv of surface water treated annuallv:
Remarks:
2.
Electrical Enclosures and Panels (properly rated and functional)
~ N/A ~ Good ~ Needs maintenance
condition
Remarks:
F-9
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Tanks, Vaults, Storage Vessels
~ n/a
~ Good
condition
~ Proper secondary containment ~ Needs maintenance
Remarks:
Discharge Structure and Appurtenances
~ n/a
~ Good
condition
I~1 Needs maintenance
Remarks:
Treatment Building(s)
~ N/A Q Good condition (esp. roof and
doorways)
I~1 Chemicals and equipment properly stored
Remarks:
I~1 Needs repair
Monitoring Wells (pump and treatment remedy)
CH Properly secured/locked dl EH Routinely sampled
Functioning
~ All required wells located ~ Needs maintenance
Remarks:
l~~l Good condition
~ N/A
D. Monitoring Data* Not evaluated durine Site InsDection visit: however, available documents were Drovided
and reviewed following the site inspection. The EPA oreviouslv received aoDlicable eroundwater data/reDorts.
1. Monitoring Data
1 1 Is routinely
submitted on time
~ Is of acceptable
quality
2. Monitoring Data Suggests:
r~l Ground water plume is effectively
contained
~ Contaminant concentrations are declining
E. Monitored Natural Attenuation*
1. Monitoring Wells (natural attenuation remedy)
I~1 Properly secured/locked
~ All required wells located
Remarks:
Q Functioning O Routinely sampled
Q Needs maintenance
~ Good condition
~ N/A
F-10
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X. OTHER REMEDIES
If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
XI. OVERALL OBSERVATIONS
A.
Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).
Landfill caD has been installed Ceo mole ted Fall 2016). Landfill caD is intact and aDDears to be functioning
as intended. Monitoring well data was not reviewed during site insDection visit to evaluate containment
effectiveness as this information had undergone subsequent review.
B.
Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
Landfill caD installation corrroleted in late Fall 2016. O&M Plan has not been completed/finalized.
C.
Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.
None observed. However. State Division of Public Health Protection & Safetv - Radiation Health Branch
personnel indicated that radioisotoDes had been detected in a small Dond over the hill on the west side of
the landfill, near Storm Water Management Feature #3. KY DEP reDorted that a new monitorine well will
be installed near the oond.
D.
Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Nothing noted.
Site Inspection Participants:
EPA: Pam Scully, Jon Richards, Stephanie Brown
K.Y DEP: Scott Wilburn, Jeff Webb, Tim Hubbard, Mary Kornman, Tom Stewart
Kentucky Department of Public Health - Radiation Health Branch: Stephanie Brock, AJ Bhuttacharyya,
Curt Pendergrass
TechLaw, Inc. (EPA consultant): Michelle Dallessandro, Gene Nance
F-ll
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APPENDIX G - SITE INSPECTION PHOTOS
G-l
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APPENDIX G - SITE INSPECTION PHOTOS
1. Man-made lake in a former borrow area near the KyDEP office.
04/25/2017 09:01
2. Former borrow area at the entrance to site.
G-l
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3. A "Do not dig" monument.
4. Close up of the "Do not dig" monument.
G-2
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6.
5. Landfill (LF) liner materials taken from inside meeting room
Storm drain and culvert to the left and fence and gate to perimeter road in the distance.
G-3
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7. Fence around LF cap.
8. Survey monument near the northwest corner of the LF.
G-4
-------
9. Close up of survey monument near the northwest corner of the LF.
10. Radiological caution sign on fence
G-5
-------
11. Looking toward KyDEP facility buildings.
12. Storm drain in the perimeter road in the distance.
G-6
-------
13. Storm drain in the perimeter road.
14. West side of the perimeter road.
G-7
-------
15. West side of perimeter road.
16. West side of the LF perimeter.
G-8
-------
17. Contractors picking up rocks on the LF cap.
18. Facing down into a storm sump, which provides a break in the drainage direction.
G-9
-------
19. West side of the perimeter road.
20. A survey monument.
G-10
-------
22. West perimeter road and fence.
G-ll
A
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23. Southwest corner of LF cap and the haul road leading to borrow areas over the hill to the
right.
24. Southwest corner fence with access gate and storm drain.
G-12
-------
26. Access gate at southwest corner of the LF.
G-13
-------
27. South perimeter road and fence at the south side of the LF.
28. Storm drain along the south perimeter road.
G-14
-------
29. Turf reinforcement mat in drainage path near the south perimeter road.
30. Drainage along the south perimeter road.
G-15
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31. South drain.
32. South drain.
G-16
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33. Southern survey monument.
34. Southern survey marker and drain in the distance.
G-17
-------
35. Coordinates on the southern marker.
04/25/2017 10:39
36. Solar panels to power perimeter lighting.
G-18
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38. A road and fence at the southern perimeter of the LF.
37. Close up of solar panels to power perimeter lighting.
G-19
-------
40. Solar panels near southeast corner of the LF.
G-20
-------
41. Drainage at southeast corner of the LF.
42. Southeast corner of the LF.
G-21
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43. Panorama of the LF taken from the southeastern corner, from west to north (Photo 1 of 3).
44. Panorama of the LF taken from the southeastern corner, from west to north (Photo 2 of 3).
G-22
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45. Panorama of the LF taken from the southeastern corner, from west to north (Photo 3 of 3).
46. LF warning monument near center of the LF.
G-23
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47. Old and new survey markers near the southeastern corner of the LF.
48. East survey marker.
G-24
-------
49. Drainage path between the LF cap and the east perimeter road near the southeastern corner of
the LF.
50. The east perimeter road and east drainage basin in the distance.
G-25
-------
51. Rock check dam in drainage path to the east basin.
52. East drainage basin.
G-26
-------
54. Panorama of the east drainage basin from west to north (Photo 1 of 3).
G-27
-------
55. Panorama of the east drainage basin from west to north (Photo 2 of 3).
56. Panorama of the east drainage basin from west to north (Photo 3 of 3).
G-28
-------
57. East drainage basin.
58. East drainage.
G-29
-------
59. East drainage.
60. East drainage basin.
G-30
-------
61. East drainage.
62. Fence between LF cap and the East drainage basin at the LF east perimeter.
G-31
-------
63. Rock check dam in the drainage path to the East basin.
64. Drainage path to the East basin.
G-32
-------
65. East perimeter drainage.
66. Storm drain outlet near the northeastern corner of LF.
G-33
-------
67. Close up of a storm outlet near the northeastern corner of the LF.
68. Survey monument near the northeastern corner of the LF.
G-34
-------
69. Perimeter road and storm drainage near the northeastern corner of the LF.
70. The fence between the LF area and the perimeter road near the northeastern corner of the LF.
G-35
-------
71. Perimeter Road and storm drain near the LF northeastern corner of the LF
72. LF fence and storm drain in the northern perimeter road.
G-36
-------
73. Northeastern perimeter road and drainage.
74. Water drainage along the edge of riprap at the edge of the LF.
G-37
-------
75. Storm drain at the northern perimeter under the access road to the LF cap
76. Drainage construction along the northern perimeter of the LF.
G-38
-------
78. Drainage and access gate at the north end of the LF.
77. Drainage and access gate at the north end of the LF.
G-39
-------
79. Panorama of the northern portion of the LF taken from the access road from east to west
(Photo 1 of 4).
80. Panorama of the northern portion of the LF taken from the access road from east to west
(Photo 2 of 4).
G-40
-------
81. Panorama of the northern portion of the LF taken from the access road from east to west
(Photo 3 of 4).
82. Panorama of the northern portion of the LF taken from the access road from east to west
(Photo 4 of 4).
G-41
-------
84. A slip on the hillside and constructed drainage in the former Borrow Area #4.
G-42
-------
85. A slip on the hillside and constructed drainage in the former Borrow Area #4.
86. View down the haul road to the borrow areas over the hill.
G-43
-------
87. Hillside where slip occurred in Borrow Area #4.
88. Hillside where slip occurred in Borrow Area #4.
G-44
-------
90. Constructed surface drainage in slip area, Borrow Area #4.
G-45
-------
91. A surface drain constructed on the hillside in Borrow Area #4.
92. East drainage at the base of hill.
G-46
-------
93. East drainage at the base of the hill.
94. East drainage at the base of the hill.
G-47
-------
95. East drainage at the base of the hill.
96. A survey marker adjacent to the east drainage at the base of the hill.
G-48
-------
97. A former borrow area with vegetative growth.
98. Surface Water Management Feature (SWMF) #2 located at the base of the hill on the east
side of the LF.
G-49
-------
- .--.i ¦*** 'C,-* ¦: *j> • -flr-. i»r - *•.-» -v_-
99. SWMF #2 located at the base of the hill on the east side of the LF.
100. SWMF #3 located at the base of the hill on the west side of the LF.
G-50
-------
102. Drainage path into SWMF #3.
G-51
-------
103. West drainage
104. West drainage into SWMF #3
G-52
I
-------
105. SWMF #3.
106. Close up of SWMF #3
G-53
»
-------
107. The northern portion of SWMF #3.
108. Outlet drainage structure from SWMF #3.
G-54
-------
109. Outlet drainage structure from SWMF #3.
110. Stakes marking the location where a new monitoring well will be installed near a pond at
the base of the hill. Radionuclides were detected in a water sample collected from the pond.
G-55
-------
111. Borrow Area #3 where a slip occurred. The slip was repaired and surface drains were
installed.
112. The haul road taken from bottom of hill.
G-56
-------
113. The haul road taken from bottom of hill.
114. The haul road taken from near the bottom of hill.
G-57
-------
115. The north side of LF near the KyDEP office.
116. The north side of LF with the KyDEP office visible on the right.
G-58
-------
117. The former haul road across the LF cap with light/sparse vegetation.
118. An area with sparse vegetation near the north end of the LF
G-59
-------
G-60
-------
121. Panorama of the eastern half of the LF taken from near the top of the LF cap, from north to
south (Photo 1 of 4).
122. Panorama of the eastern half of the LF taken from near the top of the LF cap, from north to
south (Photo 2 of 4).
G-61
-------
123. Panorama of the eastern half of the LF taken from near the top of the LF cap, from north to
south (Photo 3 of 4).
124. Panorama of the eastern half of the LF taken from near top of the LF cap, from north to
south (Photo 4 of 4).
G-62
-------
125. Panorama of the western half of the LF taken from near the highest point of the LF cap.
from north to south (Photo 1 of 5).
126. Panorama of the western half of the LF taken from near the highest point of the LF cap,
from north to south (Photo 2 of 5).
G-63
-------
127. Panorama of the western half of the LF taken from near the highest point of the LF cap,
from north to south (Photo 3 of 5).
128. Panorama of the western half of the LF taken from near the highest point of the LF cap,
from north to south (Photo 4 of 5).
G-64
-------
129. Panorama of the western half of the LF taken from near the highest point of the LF cap,
from north to south (Photo 5 of 5).
130. Mount for a closed-circuit television (CCTV) surveillance system on top of the LF cap.
G-65
-------
131. An area with sparse vegetation near the highest point in the LF.
132. An area with sparse vegetation near the center of the LF.
G-66
-------
133. A well-established vegetative cover near the center of the LF.
134. Sparse vegetation in the east central area of the LF.
G-67
-------
135. A small area with some soil erosion/channeling near the LF monument marker located near
the center of the LF.
136. A small area with some soil erosion/channeling near the LF monument marker located near
the center of the LF.
G-68
-------
137. Close up of soil erosion/channeling area near the LF monument (the channel is 2 inches
deep maximum).
138. More erosion channels that extend towards monument and are downgradient of previous
photo location.
G-69
-------
CAUTION
, million copies or RWABTive
WASTE tS bUPttrn IN THIS ARE.A
YOU
AFC
HERE
DO NOT DIG OR
DRILL
MAXEY FLATS LOW LEVEL RADIOACTIVE
WASTE DISPOSAL FACILITY 1962-2016
139. A "Do not dig" monument near the center of the LF cap.
G-70
-------
141. An area with turf reinforcement mat (TRM) that drains towards East Basin.
MM
(HE
142. Close up of an area with TRM that drains towards East Basin.
G-71
-------
143. An area with sparse vegetation cover located west-southwest of the East Basin.
144. Panorama of the northern portion of the LF, from east to west (Photo 1 of 4).
G-72
-------
145. Panorama the northern portion of the LF, from east to west (Photo 2 of 4).
146. Panorama of the northern portion of the LF, from east to west (Photo 3 of 4).
G-73
-------
147. Panorama of the northern portion of the LF, from east to west (Photo 4 of 4).
148. Wood chips from erosion control sock remaining on the LF after removal of the outer
fabric, located near the East Basin.
G-74
-------
149. The East Basin is pictured in the distance.
150. Rocks at the edge of the LF cover on the east side of the LF adjacent to the East Basin.
G-75
-------
151. Rocks at the edge of the LF cover on the east side of the LF adjacent to the East Basin.
152. Panorama of the east drainage basin from south to north (Photo 1 of 4).
G-76
-------
153. Panorama of east drainage basin from south to north (Photo 2 of 4).
154. Panorama of the east drainage basin from south to north (Photo 3 of 4).
G-77
-------
155. Panorama of the east drainage basin from south to north (Photo 4 of 4).
156. An area with sparse vegetation located to the southwest of the East Basin.
G-78
-------
157. Panorama of the LF taken from near the southeastern corner from north to west
(Photo 1 of 3).
158. Panorama of the LF taken from near the southeastern corner from north to west
(Photo 2 of 3).
G-79
-------
w*..
159. Panorama of the LF taken from near the southeastern corner from north to west
(Photo 3 of 3).
160. An area of sparse vegetation near the southeastern corner of the LF.
G-80
-------
161. Sparse vegetation near the southern end of the LF near the fence.
162. Sparse vegetation on the haul road on the LF cap. The southwestern access gate is visible in
the distance.
G-81
-------
163. Tire ruts in the LF cap near the southwestern access gate.
164. Close up of tire ruts in the LF cap near the southwestern access gate.
G-82
-------
165. Sparse vegetation on the haul road near the southwestern corner of the LF.
166. Stone at the edge of the LF cap on the south end of the west perimeter.
G-83
-------
167. Stone and drainage on the west side of the LF.
168. A monitoring well to the west of the LF.
G-84
-------
CAUTION
2* mil: 'ON CURIES OF RADIOACTIVE
i/VASTf IS BURIED IN THIS AREA
YOU
ARtz
HERE
DO NOT DIG OR
DRILL
MAXEy FLATS LOW LEVEL RADIOACTIVE
WASTE DISPOSAL FACILITY. 1962-2016
04/25/20
169. A "Do not dig" monument at the north end of the LF, facing south.
G-85
-------
APPENDIX H - INTERVIEW DOCUMENTATION
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review. See the attached contact
record(s) for a detailed summary of the interviews.
Remedial Project Manager
Pam Scully (RPM) EPA 5/1/2017
Name
Title/Position
Organization
Date
Jon Richards
RPM and Radiation Expert
EPA
4/27/2017
Name
Title/Position
Organization
Date
Scott Wilburn
On-Site Project Manger
Kentucky Department of
Environmental Protection
5/3/2017
Name
Title/Position
Organization
Date
Curt
Pendergrass
Supervisor, Radioactive
Materials Section
Kentucky Radiation
Health Branch
5/1/2017
Name
Title/Position
Organization
Date
Name
Title/Position
Organization
Date
Name
Title/Position
Organization
Date
H-l
-------
INTERVIEW RECORD
Site Name: Maxey Flats
EPA ID No:
Subject: Maxey Flats Fourth Five Year Review Report
Time: 0835- _
.... Date: 5/1/2017
0844
Type: ISI Telephone ~ Visit ~ Other
Location of Visit: n/a
~ Incoming M Outgoing
Contact Made By:
Name: Vivian Lopez
Title: Environmental Scientist
Organization: TechLaw, Inc.
Individual Contacted:
Name: Pam Scully
Title: Remedial Project
Manager
Organization: EPA
Telephone No.: 404-562-8935
Fax No.:
E-Mail Address: scully.pam@epa.gov
Street Address, City, State, Zip:
61 Forsyth Street SW, Atlanta, GA 30303
Summary of Conversation
The remedy is functioning as expected and the data shows that contaminants are decreasing at a
steady rate. Significant project optimization is underway at the Site and will encourage efficiency
of activities from here on out. The Site is under CERCLA compliance and the state of Kentucky
has done a very good job ensuring that the issues at Maxey Flats are addressed.
1. What is your overall impression of the project? (general sentiment)
It is complex, but we have done everything we can do to make it safe in the long term for the
public around thie facility.
2. Is the remedy functioning as expected? How well is the remedy performing?
Yes, it is functioning as expected.
3. What does the monitoring data show? Are there any trends that show contaminant levels
are decreasing?
The problem is that we are dealing with tritium, which will take approximately 100 years to
decay. It is decreasing because it has a half-life and so we have to wait for time to assist the
process. We have not seen it increase and it is encouraging.
4. Is there a continuous on-site O&M presence? If so, please describe staff and activities. If
there is not a continuous on-site presence, describe staff and frequency of site inspections
and activities.
Yes there is. For the last 10 years the same staff have been on the Site. With the low turnover,
Site activities have been consistent and efficient. Additionally, the state is heavily involved and
keeps it fully funded, which helps with progress on the Site and the consistency of Site activities
H-2
-------
5. Have there been any significant changes in the O&M requirements, maintenance
schedules, or sampling routines since start-up or in the last five years? If so, do they affect
the protectiveness or effectiveness of the remedy? Please describe changes and impacts.
Yes, previously we had an interim cap in place that required more O&M. The new cap reduces
activities and is in the process of being finalized.
6. Have there been unexpected O&M difficulties or costs at the site since start-up or in the
last five years? If so, please give details.
Not to my knowledge.
7. Have there been opportunities to optimize O&M, or sampling efforts? Please describe
changes and resultant or desired cost savings or improved efficiency.
We have been doing a lot of optimization. The 10 years of data available allow us to modify the
frequency of activities and encourage efficiency, now that we have a clear understanding of the
baseline.
8. Do you have any comments, suggestions, or recommendations regarding the project?
Not at this time.
9. What is your position in the Commonwealth of Kentucky?
The Commonwealth of Kentucky have a lot staff that have been involved since the beginning
and do a good job. I am the EPA remedial project manager for the Site.
10. Are you aware of any noncompliances with the project?
Not on my end. They have had issues with nuclear regulations on the NRC side, but not on the
CERCLA side of compliances.
11. Are you aware of any exceedances of regulatory standards?
Not to my knowledge.
12. Is there unacceptable risk to human health and the environment posed by the site?
Not the way we have the cap in place.
13. Is the Commonwealth of Kentucky complying with the elements of the Consent Decree?
Yes they are.
H-3
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INTERVIEW RECORD
Site Name: Maxey Flats
EPA ID No:
Subject: Maxey Flats Fourth Five Year Review Report
Ttae:12°4- Date. 4/27/2017
Type: IE Telephone ~ Visit ~ Other
Location of Visit: n/a
~ Incoming IE Outgoing
Contact Made By:
Name: Vivian Lopez
Title: Environmental Scientist
Organization: TechLaw, Inc.
Individual Contacted:
Name: Jon Richards
Title: RPM and Radiation
Expert
Organization: EPA
Telephone No.: 404-431-1340
Fax No.:
E-Mail Address: Richards.jon@epa.gov
Street Address, City, State, Zip:
61 Forsyth Street SW, Atlanta, GA 30303
Summary of Conversation
Placing the final cap on the Site has been pivotal to bringing the Site closer to being safe for the
public. While monitoring data was not present at the time of the interview, tritium concentrations
are expected to be reducing because of its half-life of 12 years. There have not been any non-
compliances and all activities appear to be going well at the Site.
1. What is your overall impression of the project? (general sentiment)
I am glad that the project is near completion. It has been in progress since 1988.
2. Is the remedy functioning as expected? How well is the remedy performing?
Yes it is. Putting the final cap on was the key to preventing infiltration. Every five-year review
will verify that.
3. What does the monitoring data show? Are there any trends that show contaminant levels
are decreasing?
The data is not currently in reach to answer the question. Tritium has a half-life of
approximately 12 years, so it should be decreasing, especially since the Site has been there since
1962.
4. Have there been unexpected O&M difficulties or costs at the site since start-up or in the
last five years? If so, please give details.
No.
H-4
-------
5. Do you have any comments, suggestions, or recommendations regarding the project?
I would suggest additional gross beta testing for tritium.
6. What is your position in the commonwealth of Kentucky?
We [the EPA] have worked well with Kentucky over the years, they are taking over now. Further
detail could be provided by Pam, as Pam serves as the EPA regional project manager for the Site.
Personally, I have worked well with Kentucky Radiation staff.
7. Are you aware of any noncompliances with the project?
No.
8. Are you aware of any exceedances of regulatory standards?
No.
9. Is there unacceptable risk to human health and the environment posed by the site?
No.
10. Is the Commonwealth of Kentucky complying with the elements of the Consent Decree?
To my knowledge, yes.
H-5
-------
INTERVIEW RECORD
Site Name: Maxey Flats
EPA ID No:
Subject: Maxey Flats Fourth Five Year Review Report
Time:1325 - Date: 5/4/2017
Type: IE Telephone ~ Visit ~ Other
Location of Visit: n/a
~ Incoming M Outgoing
Contact Made By:
Name: Vivian Lopez
Title: Environmental Scientist
Organization: TechLaw, Inc.
Individual Contacted:
Name: Scott Wilburn
Title: Site Manager-
Organization: Kentucky
Department of Environmental
Protection
Telephone No.: 606-783-8680
Fax No.:
E-Mail Address: scott.wiIburn@ky.gov
Street Address, City, State, Zip:
300 Sower Blvd, Frankfort, KY 40601
Summary of Conversation
The overall project has been a success and the remedy is functioning as expected. Monitoring
data shows that tritium levels are decreasing and both sampling and O&M activities are in the
process of being optimized to reflect the status of this Site. There have been no noncompliances
or exceedances of regulatory standards. The Site is moving towards being established for
beneficial re-use.
1. What is your overall impression of the project? (general sentiment)
The project has been a success and expect that it will continue to be a success.
2. Is the remedy functioning as expected? How well is the remedy performing?
Yes it is. Evidence shows that the remedy is functioning very well and that data shows it.
3. What does the monitoring data show? Are there any trends that show contaminant levels
are decreasing?
The monitoring data shows that the Site has declining levels of tritium in areas of concern.
4. Is there a continuous on-site O&M presence? If so, please describe staff and activities. If
there is not a continuous on-site presence, describe staff and frequency of site inspections
and activities.
Yes there is a continuous on-site O&M presence. There are four full-time staff and an additional
part-time employee. Different types of inspections are conducted in intervals of daily, weekly,
monthly, semi-annual, and annual time periods.
H-6
-------
5. Have there been any significant changes in the O&M requirements, maintenance
schedules, or sampling routines since start-up or in the last five years? If so, do they affect
the protectiveness or effectiveness of the remedy? Please describe changes and impacts.
Yes, there have been major changes in O&M as a result of the final stage of remediation that is
being completed as we speak. 1 anticipate that the final remediation stage will be completed
sometime in June. The protectiveness and effectiveness of the remedy has improved since the
remedy has been in place.
6. Have there been unexpected O&M difficulties or costs at the site since start-up or in the
last five years? If so, please give details.
There have not been any O&M difficulties that were unexpected. Many changes have been
made to the inspection program based on constantly changing conditions of the Site.
7. Have there been opportunities to optimize O&M, or sampling efforts? Please describe
changes and resultant or desired cost savings or improved efficiency.
Yes, we are currently in the process of optimizing both O&M and sampling efforts. We have an
institutional controls work plan in the works that has a new O&M schedule and an updated
sampling plan.
8. Do you have any comments, suggestions, or recommendations regarding the project?
The only comment that I have is that the project continues on its current trajectory. We are
currently looking for a way to convert the Site for beneficial re-use, including stream mitigation,
establishing honey bee colonies, planting native grasses, and registering the Site with the
Department of Fish and Wildlife to open it for select hunts.
9. What is your position in the Commonwealth of Kentucky?
Environmental Scientist, specifically the Facilities RSO and on-site remediation coordinator.
10. Are you aware of any noncompliances with the project?
No.
11. Are you aware of any exceedances of regulatory standards?
No.
12. Is there unacceptable risk to human health and the environment posed by the site?
No.
13. Is the Commonwealth of Kentucky complying with the elements of the Consent Decree?
Yes.
H-7
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INTERVIEW RECORD
Site Name: Maxey Flats
EPA ID No:
Subject: Maxey Flats Fourth Five Year Review Report
Time: 1045- _ e/mnii
Date: 5/1/2017
Type: E3 Telephone ~ Visit ~ Other
Location of Visit: n/a
~ Incoming IE Outgoing
Contact Made By:
Name: Vivian Lopez
Title: Environmental Scientist
Organization: TechLaw, Inc.
Individual Contacted:
Name: Curt Pendergrass
Title: Supervisor, Radioactive
Materials Section
Organization: Kentucky
Radiation Health Branch
Telephone No.: 502-564-370C
Fax No.:
E-Mail Address:
curt.pendergrass@ky.gov
ext. 4183
Street Address, City, State, Zip:
275 East Main Street, Frankfort, KY 40621
Summary of Conversation
Significant progress has been made at the Site due to excellent coordination at the state and
federal level. Despite the cap remedy being in place for a short amount of time, it appears to be
working very well and radionuclide levels have decreased. To reflect the Site's ongoing status.
Operation & Maintenance sampling will be reduced from weekly sampling and analysis to
weekly sampling that will be composited monthly. There has only been one major contractor
issue, but the rest of the Site and contaminant containment have been moving in protective
direction.
1. What is your overall impression of the project? (general sentiment)
A lot of progress has been made on this project and it is very well run due to excellent
coordination at the state and federal level. 1 am biased because my office gives the license for
the Site.
2. Is the remedy functioning as expected? How well is the remedy performing?
So far, looking at radionuclide levels in runoff and seeps, it appears that they are decreasing and
water flow is decreasing. It has not been long since the cap was installed, but it already appears
to be working very well.
3. What does the monitoring data show? Are there any trends that show contaminant levels
are decreasing?
I do not have the data in front of me, so I cannot speak to it in detail but from the two sets of data
1 have seen from the EPA and our own labs, there appears to be a general decreasing trend of
radionuclides.
H-8
-------
4. Is there a continuous on-site O&M presence? If so, please describe staff and activities. If
there is not a continuous on-site presence, describe staff and frequency of site inspections
and activities.
Yes there is a continuous on-site O&M presence and that will be for many years. There is
permanent staffing at the Site through another cabinet. This includes five full time employees
who are involved in collecting and analyzing samples, contributing to the upkeep and
maintenance of the Site and overseeing contractors.
5. Have there been any significant changes in the O&M requirements, maintenance
schedules, or sampling routines since start-up or in the last five years? If so, do they affect
the protectiveness or effectiveness of the remedy? Please describe changes and impacts.
Yes there have been major changes through the years. All sumps and monitoring wells have
been removed as part of the final closure. We are currently in progress of changing the
monitoring plan, which includes replacing monitoring wells that were lost. We also want to
scale back activities significantly by altering sampling from weekly sampling and weekly
analysis to weekly sampling, monthly compositing, and monthly sampling. This change in
sampling and analysis has not happened yet but is in progress.
6. Have there been unexpected O&M difficulties or costs at the site since start-up or in the
last five years? If so, please give details.
There have been a few final closure difficulties. A contractor did not plan very well for the Site,
requiring a final closure plan revision based on the reality of the Site. However, another
contractor was doing a very good job on-site and was able to help work through most issues.
7. Have there been opportunities to optimize O&M, or sampling efforts? Please describe
changes and resultant or desired cost savings or improved efficiency.
We are currently in the process right now to find a schedule that reflects the Site's ongoing
status. Very significant changes will be made in the near future (e.g., the same radionuclides will
still be monitored monthly, but with less frequent analysis).
8. Do you have any comments, suggestions, or recommendations regarding the project?
None that have not been evaluated and taken into account already. A very cooperative process
exists for this Site, I have been very pleased.
9. What is your position in the commonwealth of Kentucky?
I am the supervisor of the Radiation Materials Section and the Radiation Health Branch.
10. Are you aware of any noncompliances with the project?
Not to my knowledge.
11. Are you aware of any exceedances of regulatory standards?
Not to my knowledge.
12. Is there unacceptable risk to human health and the environment posed by the site?
Not at the moment.
H-9
-------
13. Is the Commonwealth of Kentucky complying with the elements of the Consent Decree?
Yes we are.
H-10
-------
APPENDIX I - DETAILED ARARs REVIEW
CERCLA Section 121(d)(1) requires that Superfund remedial actions attain "a degree of cleanup of
hazardous substance, pollutants, and contaminants released into the environment and of control of
further release at a minimum which assures protection of human health and the environment." The
remedial action must achieve a level of cleanup that at least attains those requirements that are legally
ARAR. In performing the FYR for compliance with ARARs, only those ARARs that address the
protectiveness of the remedy are reviewed. All ARARs are listed in Table 1-1, including the requirement
description and whether there has been a change in the ARAR since the 1991 ROD.
Groundwater ARARs
Appendix B of the 1991 ROD identified multiple potential chemical-specific ARARs and to-be-
considered (TBC) values for groundwater. However, only the following ARARs were used as a basis for
selection of groundwater cleanup goals:
• Federal National Primary Drinking Water Standards -MCLs and Maximum Contaminant Level
Goals (MCLGs) (40 CFR Parts 141,142, and 143)
• Kentucky Drinking Water Standards (MCLs) (401 KAR 6:015)
The recently added MCLs and MCLGs will supplement the Kentucky MCLs as relevant and appropriate
requirements at the MFDS, because groundwater at the Site is a current and/or future potential source of
drinking water.
This FYR compared groundwater ARARs in the 1991 ROD against the current National Drinking Water
MCLs (See Table 1-2, Groundwater ARAR Review). The ARARs for arsenic, bis(2-
ethylhexyl)phthalate, chloroform, lead, and nickel have changed since the 1991 ROD.
Surface Water ARARs
Appendix B of the 1991 ROD selected several potential chemical-specific ARARs for surface water.
Potential surface water ARARs include:
• National Recommended Water Quality Criteria (NRWQC), Human Health Criteria
• NRWQC, Aquatic Life Criteria for freshwater (acute) and freshwater (chronic)
• Kentucky Surface Water Quality Standards (401 KAR 5:026 - :035)
This FYR compared the ARARs for human health criteria (fish consumption only) and aquatic life as
listed in Appendix B of the 1991 ROD to the current human health criteria (consumption of organisms
only) and aquatic life values as listed in the NRWQC and the Kentucky Surface Water Quality
Standards [see Table 1-3, Surface Water ARAR Review (Chemical Contaminants)]. One or more of the
ARAR values for each COC have changed since the 1991 ROD.
The surface water ARARs for radionuclides require that combined doses from air, water, drinking water,
and soil pathways shall not exceed 25 mrem/year effective dose equivalent to the whole body, 75 mrem
to the thyroid, and 25 mrem to any other organ of any member of the public. Compliance with the 25
mrem/year standard is measured at the current licensed Site boundary. None of the ARARs for
1-1
-------
radionuclides have changes since the 1991 ROD [see Table 1-4, Surface Water ARAR Review
(Radiological Contaminants)].
Soil ARARs
Appendix B of the 1991 ROD did not identify chemical-specific ARARs for soil.
1-2
-------
Table 1-2
Groundwater ARAR Review
1991 ROD ARARs8
Current ARARb
Contaminant of Concern
(in ug/L unless noted)
(in ug/L unless noted)
Change in ARAR?
Arsenic
50
10
Yes
Benzene
5
5
No
Bis(2-ethylhexyl)phthalate
4
6
Yes
Chlorobenzene
100
100
No
Chloroform (trihalomethanes)
100
80
Yes
1,2-Dichloroethane
5
5
No
Lead
50
15
Yes
Nickel
100
N/A
Yes
Toluene
1000
1000
No
Trichloroethene
5
5
No
Vinyl chloride
2
2
No
Radionuclides
Beta particle and photon radioactivity
4 mrem/year
4 mrem/year
No
Gross alpha particles
15 pCi/L
15 pCi/L
No
Radium-226 and Radium -228 (total)
5 pCi/L
5 pCi/L
No
Notes:
a. Groundwater ARARs presented in the 1991 Record of Decision.
b. National Primary Drinking Water Regulations, 40 CFR 141, MCLs; https://www.epa.gov/ground-
water-and-drinking-water/national-primary-drinking-water-regulations.
Acronyms:
ARAR = Applicable, Relevant and Appropriate Requirements
MCL = Maximum Contaminant Level
mrem/year = millirem per year
N/A = Not available
NA = Not applicable
pCi/L = picoCuries per Liter
ROD = Record of Decision
ug/L = micrograms per Liter
-------
Table 1-3
Surface Water ARAR Review (Chemical Contaminants)
Contaminant of Concern
1991 ROD ARARs*
Current ARARs
Change in one or more
ARAR?
Ken
tucky Water Quality Criteria6
National Recommended Water Quality Criteria
Human Health Criteria
Warm Water Aqua
tic Habitat Criteria
Human Health Criteria1
Aquatic Lie Criteria"
Human Health (Fish
Consumption)
(ug/L)
Aquatic Life (Acute)
(ug/L)
Aquatic Life (Chronic)
(ug/L)
Fish
(ug/L)
Acute
(ug/L)
Chronic
(ug/L)
Consumption of
Organism Only
(ug/L)
Freshwater (Acute)
(ug/L)
Freshwater (Chronic)
(ug/L)
Arsenic
0.175
N/A
N/A
N/A
340
150
0.14
340
150
Yes
Benzene
400
5,300
N/A
51
N/A
N/A
16-58
N/A
N/A
Yes
Bis(2-ethylhexyl)phthalate
N/A
940
3
2.2
N/A
N/A
0 37
N/A
N/A
Yes
Chloroberuerie
488
250
50
1600
N/A
N/A
800
N/A
N/A
Yes
Chloroform (trihakimethanes)
157
28,900
1,240
470
N/A
N/A
2,000
N/A
N/A
Yes
1,2-Dichloroethane
2,430
118,000
20,000
37
N/A
N/A
650
N/A
N/A
Yes
Lead
N/A
82e
3.2®
N/A
65'
2.5'
N/A
65
2.5
Yes
Nickel
100
1400e
160®
4600
470®
52®
4,600
470
52
Yes
Toluene
424,000
17,500
N/A
15000
N/A
N/A
520
N/A
N/A
Yes
Trichloroethene
807
45,000
21,900
30
N/A
N/A
7
N/A
N/A
Yes
Vinyl chloride
5,246
N/A
N/A
2.4
N/A
N/A
1.6
N/A
N/A
Yes
Notes:
a. Surface water ARARs presented in the 1991 Record of Decision.
b. Kentucky Surface Water Standards, 401 KAR 10:031, Table 1, http://www.Irc.ky.gov/kar/401/010/031.htm.
c. NRWQC, Human Health Criteria Table; https://www.epa.gov/wqc/national-recommended-water-quality-criteria-human-health-criteria-table; Accessed May 2017.
d. NRWQC, Aquatic Life Criteria Table; https://www.epa.gov/wqc/national-recommended-water-quality-criteria-aquatic-life-criteria-table; Accessed May 2017.
e. The toxicity of lead and nickel are dependent on the hardness of the water column. A hardness of 100 mg/L was assumed. The acute criteria were calculated using the following formula: e f0M6°l|nl * °osmi
Acronyms:
ARAR = Applicable, Relevant and Appropriate Requirements
N/A = Not available
NA = Not applicable
NRWQC = National Recommended Water Quality Criteria
ROD = Record of Decision
USEPA = United States Environmental Protection Agency
ug/L = micrograms per Liter
-------
Table 1-4
Surface Water ARAR Review (Radiological Contaminants)
Contaminant of Concern
1991 ROD ARARs"
(in pCi/mL unless noted)
Current ARARb
(in pCi/mL unless noted)
Change in ARAR?
Americium-241
0.02
0.02
No
Carbon-14
30
30
No
Cesium-137
1
1
No
Cobalt-60
3
3
No
Hydrogen-3 (Tritium)
1,000
1,000
No
lodine-129
0.2
0.2
No
Plutonium-238
0.02
0.02
No
Plutonium-239
0
0
No
Radium-226
0
0
No
Strontium-90
0.5
0.5
No
Technetium-99
60
60
No
Thorium-232
0.03
0.03
No
Total whole body exposure (all media)
25 mrem/year
25 mrem/yearc
No
Notes:
It is noted that 1991 ROD ARAR values listed herein are inconsistent with those listed in Table A-l, Applicable Action-Specific and
Contaminant-Specific Requirements for Remedial Alternatives at Maxey Flats. However, according to Section 8.2, Contaminant-
Specific ARARs, of the ROD, "The federal standards were lowered in May 1991 so as to limit the allowable dose in unrestricted areas
to 100 mrem/year and to provide specific radionuclide concentrations in Appendix B, Table II. In that these new federal standards
are more stringent than the Kentucky regulations, the federal standards shall be the governing ARARs for allowable doses in
unrestricted areas."
a. Surface water ARARs presented in the 1991 Record of Decision.
b. 10 CFR Part 20, Subpart 0, Appendix B: Table 2, Column 2, "Water"; https://www.ecfr.gov/cgi-bin/text-
idx?SID=9398224a6c8f44c47e2b05f5fc913a0e&mc=true&node=apl0.1.20_12402.b&rgn=div9.
c. 10 CFR Part 61.41; https://www.nrc.gov/reading-rm/doc-collections/cfr/part061/part061-
0041.html.
Acronyms:
ARAR = Applicable, Relevant and Appropriate Requirements
mrem/year = millirem per year
pCi/mL= picoCuries per milliliter
ROD = Record of Decision
-------
APPENDIX J - DETAILED RISK REVIEW
J-l
-------
Table J-l
Review of Groundwater ARARs
Contaminant of Concern
1991 ROD ARARs"
Current ARAR
Current TBC Values
ARAR Risk and Hazard Levels based on Current
(in ug/L unless noted)
Tapwater RSLC
TBC Values'1
MCLb
(in ug/L unless noted)
Target Risk = 1E-06
(in ug/L)
HQ = 1
(in ug/L)
Risk
Hazard
Arsenic
50
10
0.052
6
9.62E-04
8.3
Benzene
5
5
0.46
33
109E-05
0.2
Bis(2-ethylhexyl)phthalate
4
6
5.6
400
7.14E-07
0.0
Chlorobenzene
100
100
N/A
78
NA
1.3
Chloroform (trihalomethanes)
100
80
0.22
97
4.55E-04
1.0
1,2-Dichloroethane
5
5
0.17
13
2.94E-05
0.4
Lead
50
15
N/A
15
NA
3.3
Nickel
100
N/A
N/A
390
NA
0.3
Toluene
1000
1000
N/A
1100
NA
0.9
Trichloroethene
5
5
0.49
2.8
1.02E-05
1.8
Vinyl chloride
2
2
0.019
44
1.05E-04
0.05
Radionuclides
Beta particle and photon radioactivity
4 mrem/year
4 mrem/year
N/A
N/A
NA
NA
Gross alpha particles
15 pCi/L
15 pCi/L
N/A
N/A
NA
NA
Radium-226 and Radium -228 (total)
5 pCi/L
5 pCi/L
N/A
N/A
NA
NA
Uranium
N/A
30
N/A
60
NA
NA
Notes:
The 1991 groundwater ARARs were compared to the current MCLs and USEPA RSLs for Resident Tapwater to assess their validity. The 1991 ROD ARARs for groundwater contaminants of concern were
based on the federal National Primary Drinking Water Regulations (i.e., the MCLs). These values were compared with the current MCLs. In addition, these values also were compared to current EPA
RSLs (May 2016) for tap water (i.e., To-Be-Considered values).
Those ARARs exceeding the current MCLs and resulting in a risk greater than 1E-04 or a HQ greater than 1 are highlighted in yellow.
Those ARARs not exceeding the current MCLs but resulting in a risk greater than 1E-04 or a HQ greater than 1 are highlighted in green.
a. Groundwater ARARs presented in the 1991 Record of Decision.
b. National Primary Drinking Water Regulations, 40CFR 141, MCLs; https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations.
c. USEPA RSLs for Resident Tapwater, May 2016; https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables-may-2016; Accessed May 2017.
d. Carcinogenic risk was calculated as follows: (ARARv Carcinogenic RSL) x 1E-06. Non-carcinogenic hazard was calculated as follows: (ARAR Non-carcinogenic RSL).
Acronyms:
ARAR = Applicable, Relevant and Appropriate Requirements
HQ = Hazard Quotient
MCL = Maximum Contaminant Level
mrem/year - millirem per year
N/A = Not available
NA = Not applicable
pCi/L = picoCuries per Liter
ROD = Record of Decision
RSL = Regional Screening Level
TBC = To-Be-Considered
ug/L = micrograms per Liter
USEPA = United States Environmental Protection Agency
-------
Table J-2
Review of Surface Water ARARs for Chemical Contaminants
Contaminant Of Concern
1991 ROD ARARs1
Current ARARs
Ratio Of ROD ARAR to
Lowest of Current
Human Health-Based
ARARsh
Kentucky Water Quality Criteria6
National Recommended Water Quality Criteria
Human Health Criteria
Warm Water Aquatic Habitat Criteria
Human Health Criteria'
Aquatic Life Criteria"
Human Health (Fish
Consumption)
(ug/L)
Aquatic Life (Acute)
(ug/L)
Aquatic Life (Chronic)
(ug/L)
Fish
(ug/L)
Acute
(ug/L)
Chronic
(ug/L)
Consumption of
Organism Only
(ug/L)
Freshwater (Acute)
(ug/L)
Freshwater (Chronic)
(Ug/L)
Arsenic
0.175
N/A
N/A
N/A
340
150
0.14
340
150
1
Benzene
400
5,300
N/A
51
N/A
N/A
16-58
N/A
N/A
25
Bis(2-ethylhexyl)phthalate
N/A
940
3
2.2
N/A
N/A
0.37
N/A
N/A
NA
Chlorobenzene
488
250
50
1600
N/A
N/A
800
N/A
N/A
0.61
Chloroform (trihalomethanes)
157
28,900
1,240
470
N/A
N/A
2,000
N/A
N/A
0.33
1,2-Dichloroethane
2,430
118,000
20,000
37
N/A
N/A
650
N/A
N/A
66
Lead
N/A
82e
3.2*
N/A
65'
2.5'
N/A
65
2.5
NA
Nickel
100
1400e
160e
4600
470s
52g
4,600
470
52
0.02
Toluene
424,000
17,500
N/A
15000
N/A
N/A
520
N/A
N/A
815
Trichloroethene
807
45,000
21,900
30
N/A
N/A
7
N/A
N/A
115
Vinyl chloride
5,246
N/A
N/A
2.4
N/A
N/A
1.6
N/A
N/A
3,279
Notes:
The 1991 ROD surface water ARARs were compared to the current Kentucky and federal ARARs to assess their validity. The 1991 ROD ARARs for non-radiological surface water COCs were based on the federal Ambient Water Quality Criteria (Section 304(a)(1) of the Clean Water Act). These values
were compared with the current federal water quality criteria (i.e., what are now called the National Recommended Water Quality Criteria) and the State of Kentucky Water Quality Criteria (Kentucky Surface Water Standards, 401 KAR 10:031).
Those 1991 ROD ARARs exceeding a current ARAR are highlighted in yellow.
a. Surface water ARARs presented in the 1991 Record of Decision.
b. Kentucky Surface Water Standards, 401 KAR 10:031, Table 1; http://www.lrc.ky.gov/kar/401/010/031.htm.
c. NRWQC, Human Health Criteria Table; https://www.epa.gov/wqc/national-recommended-water-quality-criteria-human-health-criteria-table; Accessed May 2017.
d. NRWQC, Aquatic Life Criteria Table; https://www.epa.gov/wqc/national-recommended-water-quality-criteria-aquatic-life-criteria-table; Accessed May 2017.
e. The toxicity of lead and nickel are dependent on the hardness of the water column. A hardness of 100 mg/L was assumed. The acute criteria were calculated using the following formula: e l08460 l|n P""*1"5)! * *3S12,_ The chronic criteria were calculated using the following formula: *
1.1645)
f: The acute criterion is based on the following formula: el12'3f|nfhirdness" 1460' chronic criterion is based on following formula: e'1-273i|n'ha,dneiSH 4-7Dsl
g: The acute criterion is based on the following formula: e<08460lh,(ha,<,ness>l*iZ55> jhe chronic criterion is based on following formula: el° 84605|nthar
-------
Table J-3
Review of Surface Water ARARs for Radiological Contaminants
Contaminant of Concern
1991 ROD ARARs"
(in pCi/mL unless noted)
Current ARARb
(in pCi/mL unless noted)
Americium-241
0.02
0.02
Carbon-14
30
30
Cesium-137
1
1
Cobalt-60
3
3
Hydrogen-3 (Tritium)
1,000
1,000
lodine-129
0.2
0.2
Plutonium-238
0.02
0.02
Plutonium-239
0
0
Radium-226
0
0
Strontium-90
0.5
0.5
Technetium-99
60
60
Thorium-232
0.03
0.03
Total whole body exposure (all media)
25 mrem/year
25 mrem/yearc
Notes:
The surface water ARARs were compared to the current Kentucky and federal ARARs to assess their
validity. The 1991 ROD ARARs for radiological surface water COCs were based on the Federal
Register notice on Nuclear Regulatory Commission revisions to Table II, 56 Federal Register 23409,
May 21,1991. These values were compared with the current values presented at 10 CFR Part 20,
Subpart 0, Appendix B and 10 CFR Part 61.41.
a. Surface water ARARs presented in the 1991 Record of Decision.
b. 10 CFR Part 20, Subpart O, Appendix B: Table 2, Column 2, "Water"; https://www.ecfr.gov/cgi-
bin/text-
idx?SID=9398224a6c8f44c47e2b05f5fc913a0e&mc=true&node=apl0.1.20_12402.b&rgn=div9.
c. 10 CFR Part 61.41; https://www.nrc.gov/reading-rm/doc-collections/cfr/part061/part061-
0041.html.
Acronyms:
ARAR = Applicable, Relevant and Appropriate Requirements
mrem/year = millirem per year
pCi/L = picoCuries per milliliter
ROD = Record of Decision
-------
Table J-4
Comparison of Groundwater Data to Current ARARs
Contaminant of Concern
Minimum Detected
Concentration
(in ug/L unless noted]
Maximum Detected
Concentration
(in ug/L unless noted)
Location of Maximum
Detected Concentration
Mean of Detected
Concentrations
(in ug/l unless noted]
1991 ROD ARARs*
(in ug/L unless noted]
Current ARAR
Current TBC Values
Risk and Hazard Levels based on Current TBC
Values'
Tapwa
er RSL'
MCLb
(in ug/L unless noted)
Target Risk = 1E-06
(ug/L)
HQ = 1
(ug/L)
Risk
Hazard
Arsenic
1.2 J
30.2
AW-1
8.46
50
10
0.052
6
S.81E-04
5.0
Benzene
ND
ND
NA
NA
5
5
0.46
33
NA
NA
8ls{2-ethylhexyl)phthalate
2.8 J
2.8 i
AW-13
2.8
4
6
5.6
400
5.00E-07
0.007
Chlorobenzene
ND
ND
NA
NA
100
100
N/A
78
NA
NA
Chloroform (trihalomethanes)
ND
ND
NA
NA
100
80
0.22
97
NA
NA
1,2-Dichloroethane
ND
ND
NA
NA
S
5
0.17
13
NA
NA
Lead
0 23 J
6.9
AW-13
1.64
50
15
N/A
15
NA
0.5
Nickel
3.0 J
540
AW-13
63.33
100
N/A
N/A
390
NA
1.4
Toluene
1.2 J
1.3 J
AW-6/AW-8/AW-12/AW-14
1.28
1000
1000
N/A
1100
NA
0.001
Trichloroethene
ND
ND
NA
NA
5
5
0.49
2.8
NA
NA
Vinyl chloride
ND
ND
NA
NA
2
2
0.019
44
NA
NA
Radionuclide '
Radium-226 | 22 pCi/l | 51 pCi/L | AW-4 | 36.5 pCi/L | 5 pCi/L | 5 pCi/L | N/A | N/A I NA 1 NA
Notes:
Data were collected In October 2012.
Data were collected from 18 sample locations.
Concentrations that exceed the current MCLs and result in a risk greater than 1E-04 and/or a HQ greater than 1 are highlighted in yellow
Green highlight Indicates no current MCL is available but the maximum detected concentration results in a risk greater than 1E-04 and/or a HQ greater than 1.
a. Groundwater ARARs presented in the 1991 Record of Decision
b. National Primary Drinking Water Regulations, 40 CFR 141, MCls; https://www.epa gov/ground-water-and-drinking-water/national-primary-drinking-water-regutations
c. USEFA RSLs for Resident Tapwater, May 2016; https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables-may-2016; Accessed May 2017.
d. Carcinogenic risk was calculated as follows: (MDC 4- Carcinogenic RSI) x 1E-06. Non-carcinogenic hazard was calculated as follows: (MDC t Non-carcinogenic RSI).
e. Only radium-226 was sampled for in 2012.
Acronyms:
ARAR = Applicable, Relevant and Appropriate Requirements
HQ = Hazard Quotient
J = Estimated value
MCL = Maximum Contaminant Level
MDC = Maximum detected concentration
N/A = Not available
NA = Not applicable
ND = Not detected
pCi/L = picoCuries per Liter
ROD = Record of Decision
RSL = Regional Screening Level
TBC = To-Be-Considered
USEPA = United States Environmental Protection Agency
-------
Table J-5
Comparison of Surface Water Data to Current ARARs (Chemical Contaminants)
Contaminant of Concern
Minimum
Detected
Concentration
("t/U
Maximum
Detected
Concentration
l«*A»
location of
Maximum
Detected
Concentration
Mean of Detected
Concentrations
1991 ROD ARARs'
Current ARARs
Ratio of Maximum
Detected Concentration
to lowest of Current
Human Health-Be sed
ARARs*
Ken
tucky Water Quality Criteria
ecommended Water Quality Criterie
Warm Water Aqua
tie Habitat Criteria
Human Health Criteria'
Aquatic U
e Criteria"
Human Health (Fish
Consumption)
Aquatic life (Acute)
lug/l)
Aquatic Life (Chronic)
(ue/U
Fish
l«*A»
Acute
lufA)
Chronic
(ug/l)
Consumption of
Organism Onfy
(Ug/L)
freshwater (Acute)
(Mt/U
Freshwater (Chronic)
ci»a The chronic criterion is based on following formula, e"''' " O05,_
g: The acute criterion is based on the following formula: *S3S51 Tbe chronic criterion is based on following formula: •C05W
h: Those current ARARs considered In the ratio of the maximum detected concentration to the lowest of the current human health-based ARARs are in red text. It is further noted that there Is no consistent health basis for the ROD or current ARARs; therefore, this ratio does not represent a level or risk or linear relationship to toxic health implications. It only represents the
degree to which the maximum detected concentration exceeds the current ARARs
Acronyms:
ARAR = Applicable, Relevant and Appropriate Requirements
B = Estimated result, less than reporting limit
J = Estimated value
mg/L = milligrams per Liter
N/A = Not available
NA = Not applicable
NO = Not detected
NRWQC = National Recommended Water Quality Criteria
ROD = Record of Decision
USEPA = United States Environmental Protection Agency
-------
Table J-6
Comparison of Surface Water Data to Current ARARs (Radiological Contaminants)
Maximum Detected
Ratio of Maximum Detected
Concentration
Location of Maximum
1991 ROD ARARs*
Current ARARb
Concentration to Current
Contaminant of Concern
(in pCi/mL unless noted)
Detected Concentration
(in pCi/mL unless noted)
(in pCi/mL unless noted)
ARAR
Americium-241
ND
NA
0.02
0.02
NA
Carbon-14
ND
NA
30
30
NA
Cesium-137
ND
NA
1
1
NA
Cobalt-60
ND
NA
3
3
NA
Hydrogen-3 (Tritium)
1.16
ISCO 102D
1,000
1,000
0.001
lodine-129
ND
NA
0.2
0.2
NA
Plutonium-238
ND
NA
0.02
0.02
NA
Plutonium-239
ND
NA
0.02
0.02
NA
Radium-226
0.049
ISCO 122A
0.06
0.06
0.82
Strontium-90
ND
NA
0.5
0.5
NA
Technetium-99
ND
NA
60
60
NA
Thorium-232
0.000068
ISCO 122A
0.03
0.03
0.002
Total whole body exposure (all media)
N/A
NA
25 mrem/year
25 mrem/yearc
NA
Notes:
Data were collected In October 2012.
Concentrations that exceed the current ARARs are highlighted in yellow.
a. Surface water ARARs presented in the 1991 Record of Decision.
b. 10 CFR Part 20, Subpart 0( Appendix B: Table 2, Column 2, "Water"; https://www.ecfr.gov/cgi-bin/text-
idx?SID=9398224a6c8f44c47e2b05f5fc913a0e&mc=true&node=apl0.1.20_12402.b&rgn=div9.
c. 10 CFR Part 61.41; https://www.nrc.gov/reading-rm/doc-collections/cfr/part061/part061-0041.html.
Acronyms:
ARAR = Applicable, Relevant and Appropriate Requirements
mrem/year = millirem per year
N/A = Not available
NA = Not applicable
ND = Not detected
pCi/L = picoCuries per milliliter
ROD = Record of Decision
-------
APPENDIX K - VAPOR INTRUSION SCREENING
EPA-OLEM VAPOR WTRUSION ASSESSMENT
Groundwater Concentration io indoor Air Concentration (GWC-IAC) Calculator Version 5.5.1 (May 2016 RSL3)
Parameter
Symbol
value inetnicttone
Exposiae So&nahb
scenario
Res-:ert)a I S&eci residentlai or commefdai scenario item puif do*n Est
TKost Rtti tor Carcnooer.6
TCR
i SOE-oe Enter target r»* tot carcinogens {tor comparison is ire cateilated Vi cafcnogenc risk m column Fi
Target Hazard Quoeent tor Nan-carsftooens
Av«age.Grpw^» TemjerKure (^Cj.
THQ
1 | Enter target (vazara cpjotleit tor non-carcinogens i^or con^artson »the cafewated Vl hazariJ ;n coumn G)
Tflff
25 [Enter a*erage of the stabilized ground«a»r temperature to coned Herd's Law Constant tor groundwater target concentrapons
Groundwater
Concentration
calculated
indoor Air
Concentration
VI
carcinogenic
Risk
VI Hazard
Inhalation UnR
Risk
IUR
Reference
Concentration
RFC
Mutagenic
Indicator
Co*
cu
CR
HQ
IJR
RfC
CAS
Chemical Name
mhL.
t»9>my
. m*&h
.Ml .
[ 155-62-5
Toluene
1 3E-.00
3 S3E-05
NORJR
6 3E-25
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APPENDIX L - ANNUAL REPORTS
L-l
-------
ENERGY AND ENVIRONMENT CABINET
Steven L. Beshear
Governor
Department for Environmental Protection
Division of Waste Management
Leonard K. Peters
Secretary
Maxey Flats Project
2597 Maxey Flat Road
Hillsboro, KY 41049
Phone (606) 783-8680
http://waste.ky.gov
March 27, 2013
Ms. Pam Scully, SRPM, Kentucky/Tennessee Section
USEPA-Region IV
Sam Nunn Federal Center
61 Forsyth Street SW
11th Floor
Atlanta, GA 30303-8960
Subject: Maxey Flats Project - 2012 Annual Report
Dear Ms. Scully;
The Commonwealth of Kentucky is submitting the 2012 Annual Report for the Maxey Flats Project to
fulfill the requirements of Section 4.0 of the Performance Verification Standard Plan (PSVP). The report
was prepared by the Maxey Flats Section and summarizes information from the period of January 2012
through December 2012.
If you have any questions, please contact me at (606)-783-8680.
e-attachment
cc: Nicole Barkasi, de maximis, inc.
Michelle Miller, USDOE
Jane Powell, USDOE
Gwen Hooten, USDOE
Matt McKinley, CHFS, Radiation Health Branch
Tim Hubbard, DEP, Division of Waste Management
Sincerely,
Scott Wilbum, Project Coordinator
KentudcyUnbridIcdSpirit.com
Kentucky^
^ UNBRIDLED SPIRIT-JF-
An Equal Opportunity Employer M/F/D
-------
MAXEY FLATS PROJECT
ANNUAL REPORT
2012
March 27, 2013
Energy and Environment Cabinet
Department for Environmental Protection
Division of Waste Management
Superfund Branch
Maxey Flats Project
2597 Maxey Flat Road
Hillsboro, KY 41049
606-783-8680
-------
Table of Contents
Page
List of Figures ii
List of Acronyms . ii
List of Appendices iii
1.0 Introduction 1
2.0 Scope of Work 1
3.0 Surface Water Monitoring 1
3.1 East Detention Basin 1
3.2 Perennial Streams Surface Water 2
3.3 Drainage Channels Surface Water 3
3.4 Sampling Equipment Status 3
4.0 Groundwater Monitoring 4
4.1 Alluvial Wells 4
4.2 Perimeter Monitoring Wells 4
5.0 Data Management 5
6.0 Rainfall Data 5
7.0 Initial Remedial Phase Cap Maintenance 5
7.1 Geomembrane Liner and Boots 5
7.2 Headwall Maintenance 6
7.3 Subsidence Monitoring and Repair 6
7.4 Diversion Berms 6
7.5 Anchor Trenches 6
7.6 Drainage Channels 7
7.7 Articulating Concrete Block Mat (AB Mat) System 7
7.8 Former Leachate Storage Facility Area 7
7.9 Inspections 7
7.10 Equipment Status 7
8.0 Trench Leachate Management and Monitoring 7
9.0 Contaminated Liquid and Solid Waste 8
10.0 Erosion Monitoring 8
Maxey Flats Project 2012 Annual Report
i
-------
Table of Contents
(continued)
Page
11.0 IMP Workplan Revisions, Changes, and Correspondence 9
12.0 Custodial Care Activities 9
12.1 Vegetation 9
12.2 Building and Grounds Maintenance 9
12.3 Security Fence 9
12.4 Roadway Maintenance 9
13.0 Cathodic Protection 9
14.0 Non IMP Work Plan Activities and Developments 10
15.0 2012 Five Year Review 11
16.0 Conclusions 11
List of Figures
Figure 3-1 IMP Annual Average Tritium Concentrations (pCi/mL) 2004-2012 3
List of Acronyms
ARARs Applicable or Relevant and Appropriate Requirements
BoRP Balance of Remedial Phase
Commonwealth Commonwealth of Kentucky
DCSW Drainage Channels Surface Water
IRP Initial Remedial Phase
IMP Interim Maintenance Period
MFP Maxey Flats Project
O&M Operation and Maintenance Requirement Summary
PS VP Performance Standards Verification Plan
PSSW Perennial Streams Surface Water
REI Reasonably Exposed Individual
RML Radioactive Material License
US EPA U.S. Environmental Protection Agency
USGS U.S. Geological Survey
Maxey Flats Project 2012 Annual Report
ii
-------
Table of Contents
(continued)
List of Appendices
(Files separate from Main Report included on disc)
Appendix A Maxey Flats Project Analytical Data 2012
2012 MFP 5YR Review Non Rad Analyses.pdf
2012 MFP Tritium Data.xlsx
2012 MFP VOC Summary to US EPA.pdf
Appendix B Maxey Flats Project Well Levels 2012
2012 MFP Alluvial Well Levels.xlsx
2012 MFP Perimeter Well Levels.xlsx
Appendix C Maxey Flats Project Precipitation 2012
2012 MFP Daily Rainfall.xlsx
Appendix D Maxey Flats Project IRP Cap 2012
2012 MFP Liner Repair Map.pdf
2012 MFP Subsidence Measurements Estes Surveying.xlsx
MFP Subsidence Tracking Form 2003-2012.xlsx
US EPA Change Req 2012 No 11
Appendix £ Maxey Flats Project Trench Sump Information 2012
2012 MFP Sump Bottom Measurements.xlsx
2012 MFP Sump Leachate Levels.xlsx
2012 MFP Trench Freeboard Table.xlsx
Leachate Levies for Trench Sump 7-4 2002_2012.pdf
Appendix F Maxey Flats Project Compliance Information 2012
2012-13 MFP RML.pdf
2012 MFP LLRWReport.pdf
Appendix G Maxey Flats Project Drainage Channel Erosion Monitoring 2012
MFP 2012 East Drain Shaw Monumen1s.pdf
MFP East Drain Erosion USGS Monuments 2003-2012.xlsx
Appendix H Maxey Flats Project Cathodic Protection Inspection 2012
2012 MFP Cathodic Protection Evaluation.pdf
Appendix I Maxey Flats Project Non-IMP Information 2012
2012 MFP Monthly Reports.pdf
Trench Stabilization Criteria Eval 092112.pdf
Trench Stabilization Criteria US EPA Approval 111612.pdf
Maxey Flats Project 2012 Annual Report iii
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1.0 Introduction
The Commonwealth is submitting this report in accordance with Section 4.0 of the
PSVP. The report summarizes sampling and maintenance activities listed in the
Interim Maintenance Period Work Plans, PSVP, and the O&M.
2.0 Scope of Work
The IMP is ongoing pursuant to the Consent Decree (Civil Action Number 95-58)
signed by the USEPA, the Maxey Flats Steering Committee (Settling Private Parties),
and the Commonwealth. The Commonwealth is responsible for completion of the
BoRP that includes the Interim Maintenance Period, Final Closure Period, and
Associated Remedial Activities and Performance Monitoring.
The Interim Maintenance Period Work Plan describes the tasks to be completed
including:
Surface/ground water monitoring
IRP cap maintenance and replacement
Trench leachate management and monitoring
Subsidence monitoring and surveys
Erosion evaluation
General site maintenance
Contaminated liquid and waste disposal
Data collection, analysis, and reporting
Site drainage and erosion control features
3.0 Surface Water Monitoring
All IMP Surface water monitoring locations are evaluated based on tritium sampling
results. The 2012 annual tritium averages for all surface water locations yielded
results below their specified screening assessment levels. Tritium results for all
surface water monitoring appear in Appendix A: Maxey Flats Project Analytical Data
2012; 2012 MFP Tritium Data.xlsx.
3.1 East Detention Basin
The first point of monitoring surface water runoff from the MFP is at the East
Detention Basin (EDB). Sampling is performed at the EDB as a requirement of the
RML, not the IMP Work Plan. Sampling occurs based on storm events of 2.8 inches
of rainfall in a 24-hour period. In order for the sequential sampler to collect a storm
event sample, the sampler is programmed to collect a sample based on 0.11 inches of
rainfall per hour. A total of 34 samples were collected in 2012 and analyzed for
tritiurrj. Results range from -0.14 to 2.33 pCi/mL. Figure 3-1 on page 3 provides the
IMP Annual Average for Tritium Concentrations for 2004-2012.
Maxey Flats Project 2012 Annual Report
Page 1 of 11
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Pursuant to the ROD and IRP Design, discharge from the East Detention Basin
should be released to the East Main Drainage Channel at a rate not to exceed
predevelopment flow conditions. Following storm events exceeding 2.8 inches
rainfall in 24 hours (2 year storm event or greater), the Commonwealth is required to
collect recordings and report findings. Based on data collected from the East Drain
Rain Gauge, no rain events in 2012 exceeded the storm event criteria; therefore no
screening comparison of current flow rate versus pre-developed flow rate was
required.
3.2 Perennial Streams Surface Water
Perennial Streams Surface Water (PSSW) monitoring is conducted at five locations in
three streams inside and outside the MFP's boundary. These locations are monitored
using sequential samplers that collect a four aliquot daily composite.. The PSSW
samples are compared to a specific action level of 20 pCi/mL and a screening level of
50% of the Action Level. A total of 1,819 PSSW samples were collected and
analyzed for tritium during 2012 with no anomalous data reported. For 2012, all
PSSW locations were below the average annual tritium screening level of 10 pCi/mL;
ensuring that the 4 mrem/yr IMP specified dose limit has been met. Figure 3-1 on
Page 3 provides the IMP Annual Average Tritium Concentrations for 2004-2012.
Sample location 122A serves as the background sample. It is located on Rock Lick
Creek up-gradient from site influence. For 2012, this location yielded 360 samples
for tritium analysis. Tritium results range from -0.27 to 0.92 pCi/mL.
Sample location 106 is located on No Name Branch, a tributary to Rock Lick Creek.
Location 106 receives direct influence from drain 144 and exhibits seasonal tritium
level fluctuation concurrent with drain 144. For 2012, this location yielded 366
samples for tritium analysis. Tritium results range from -0.03 to 13.35 pCi/mL.
Sample location 122C is located on Rock Lick Creek, downstream of 106 and 143
influences. For 2012, this location yielded 363 samples for tritium analysis. Tritium
results range from 0.35 to 3.00 pCi/mL.
Sample location 103E is located on Drip Springs Creek and receives influence from
Drain 107. For 2012, this location yielded 365 samples for tritium analysis. Tritium
results range from -0.07 to 2.71 pCi/mL.
Sample location 102D is the only PSSW sampler located outside the Buffer Zone.
Due to its location below the confluence of three streams; and its location outside the
Buffer Zone, 102D is designated as the compliance point for site runoff. This
location is the point for monitoring the Reasonably Exposed Individual (REI) and is
compared to a 4 mrem/year dose limit. For 2012, this location yielded 365 samples
for tritium analysis. Tritium results range from 0.09 to 2.10. The annual average was
well below the action level, ensuring compliance to the 4 mrem/yr dose limit.
Maxey Flats Project 2012 Annual Report
Page 2 of 11
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3.3 Drainage Channels Surface Water
Drainage Channels Surface Water (DCSW) monitoring is conducted at three locations
inside the MFP's boundary. The three primary drains that produce intermittent flow
are monitored and compared to a 25 mrem/year Total Effective Dose Equivalent
standard and a more restrictive annual 100 pCi/mL action level. These drains are
sampled as a composite by automated samplers that collect a four aliquot daily
sample. For 2012, all DCSW locations had annual averages below the 100 pCi/mL
action level, ensuring compliance to the 25 mrem/yr standard. A total of 919 samples
were collected from the drains for tritium analysis. Figure 3-1, below provides the
IMP Annual Average Tritium Concentrations for 2004-2012.
Sample location CI 07 is located at the base of the West Drain, which discharges into
Drip Springs Creek. For 2012, this location yielded 199 samples for tritium analysis.
Results range from 1.64 pCi/mL to 30.55 pCi/mL
Sample location 143 is located near the base of the South Drain, which discharges
into Rock Lick Creek. For 2012, this location yielded 359 samples for tritium
analysis. Results range from -0.19 pCi/mL to 0.30 pCi/mL
Sample location 144 is located at the base of the East Drain, which discharges into No
Name Branch. For 2012, this location yielded 361 samples for tritium analysis.
Results range from 1.64 pCi/mL to 188.38 pCi/mL
3.4 Sampling Equipment Status
Samples were collected in accordance with the PSVP, unless problems occurred
beyond control such as: freezing lines, washouts, equipment failure, no flow, or
power outages.
Figure 3-1
Maxey Flats Project
Annual Average Tritium Concentration (pCi/mL)
2004-2012
Perennial Streams Surface Water
Drainage Channels
Surface Water
EDB
122A
106B
122C
103E
102D
C107
143
144
2004
0.14
0.06
4.55
1.10
0.90
0.78
14.58
0.21
60.66
2005
0.16
0.05
4.23
1.01
0.67
0.79
16.97
0.10
40.03
2006
0.16
0.05
3.41
0.86
0.47
0.62
8.62
0.10
43.35
2007
0.55
0.02
5.24
1.27
0.62
0.93
13.28
0.07
70.03
2008
0:05
-0.10
3.33
0.87
0.47
0.62
10.42
-0.11
33.76
2009
0.90
0.07
3.39
0.88
0.36
0.58
5.87
0.10
44.34
2010
0.59
0.06
4.41
1.34
0.49
0.79
10.99
0.06
61.60
2011
0.38
0.06
3.21
0.91
0.37
0.61
8.63
0.03
56.43
2012
0.72
0.05
3.88
1.19
0.51
0.82
12.96
0.06
67.85
Maxey Flats Project 2012 Annual Report
Page 3 of 11
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4.0 Groundwater Monitoring Wells
Groundwater monitoring at MFP is accomplished using Alluvial and Perimeter
Monitoring Wells. The alluvial wells, located in the buffer zone, were installed
during the IRP to satisfy the requirements of the SOW. Seventeen monitoring wells
referred to as Perimeter Monitoring Wells are located along the west perimeter fence
of the restricted area, with the exception of one interior well, which is located within
the restricted area between the EMC bunker and North Channel. Sixteen of the
seventeen perimeter wells were installed as investigative monitoring points prior to
the Consent Decree. Originally, over 300 investigative monitoring wells were
installed; IRP operations removed all but the remaining sixteen. The one interior well
was installed during the IRP. These seventeen wells are maintained for water level
monitoring to satisfy the requirements of the IMP Work Plan and sampled to satisfy
the contaminant monitoring requirements of the RML. Tritium analyses for all the
wells are contained in Appendix A: Maxey Flats Project Analytical Data 2012; 2012
MFP Tritium Data.xlsx. Water level monitoring tables for both alluvial and perimeter
wells are contained in Appendix B: Maxey Flats Project Well Levels 2012; 2012
MFP Alluvial Well Levels.xlsx and 2012 MFP Perimeter Well Levels.xlsx.
4.1 Alluvial Wells
Alluvial well samples for 2012 were collected as outlined in the PS VP and the 2007
US EPA Five Year Review. Five wells were sampled in 2012: AW-6, 10, and 12
were sampled once (annual), and AW-1 and 7 were sampled on a quarterly basis.
During this reporting period, a total of 20 alluvial well samples were collected and
analyzed for tritium, yielding results typical of historic range.
Additional sampling of all alluvial wells was completed as part of the USEPA 2007-
2012 Five Year Review. Section 15 of this annual report contains further details on
this sampling.
For 2012, AW-7 yielded the highest tritium concentration, with a value of 5.70
pCi/mL. Comparison of this value to 50% of the 20 pCi/mL ARAR screening
assessment level indicated that action levels for additional radiological analysis were
not exceeded.
Access to the alluvium within the buffer zone is controlled by the Commonwealth,
therefore the alluvial wells are not considered a drinking water source and do not
represent a potential radiological dose to the public.
4.2 Perimeter Monitoring Wells
Well water levels were collected from the seventeen Perimeter Monitoring Wells
quarterly. The 2012 measurements indicated the water levels are typical of historic
data. In past years these measurements were used to develop a potentiometeric
surface map but this requirement was rescinded in accordance with Technical Change
10.
Maxey Flats Project 2012 Annual Report
Page 4 of 11
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The 2012 tritium results for the Perimeter Wells were typical of historical data and
trends. Contamination monitoring of the Perimeter Monitoring Wells is a
requirement of the RML, not the IMP Work Plan.
5.0 Data Management
A data package is prepared for each group of samples analyzed on site. The data
package contains the tritium instruments' QC charts (efficiency and background),
chain of custody forms, raw data sheets, and data reduction sheets. Data is reviewed
and validated by DeNuke, Inc., a third party contractor that specializes in radiation
services. Following data validation, the results are entered into the site's database
and transmitted to USEPA, USDOE, de maximis, inc. and the Commonwealth. These
packets are available on site for review. Analytical results are contained in the
electronic file, Appendix A: Maxey Flats Project Analytical Data 2012; 2012 MFP
Tritium Data.xlsx
6.0 Rainfall Data
Presently, there are three rain gauge locations associated with the MFP: the East
Detention Basin (EDB), sampling location 102D, and the main office. The official
annual rainfall data is obtained from the EDB rain gauge, when available. This rain
gauge was chosen because of its conjunction with the sampler at the EDB. Rainfall
data from an alternate rain gauge, maintained at the main office, may be used to
determine official rainfall totals if the EDB rain gauge is non-functional. A total of
39.40 inches of rainfall was measured at the EDB gauge during 2012. This is
compared to an annual average precipitation of 47.33 inches (NOAA, National
Climatic Data Center; Farmers, Kentucky). Annual precipitation data appears in
Appendix C: Maxey Flats Project Precipitation 2012; 2012 MFP Daily Rainfall.xlsx.
7.0 Initial Remedial Phase Cap Maintenance
7.1 Geomembrane Liner and Boots
The liner covering the trench cap and the sump boots were inspected monthly as part
of the monthly inspection. The comprehensive visual and air lancing inspections
were completed in April and May as part of the annual inspection. During 2012, a
total of 57 repairs were made to the liner and boots. A total of 465 repairs have been
made from 2004-2012. The repair map appears in Appendix D: Maxey Flats Project
IRP Cap 2012; 2012 MFP Liner Repair Map.pdf.
Permanent geomembrane repairs continue to become more difficult with each passing
year. This is likely due to the more rapid aging of the geomembrane as a result of the
exposed installation of the IRP cap. The effects of full UV exposure and the expected
process of oxidation have made it difficult to bond new patching material to the
existing geomembrane. Due to the ineffectiveness of the IMP prescribed repair
method, anticipated installation of the final cap, and the observed effectiveness of
Maxey Flats Project 2012 Annual Report
Page 5 of 11
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Tapecoat G-25 temporary patch material, the Commonwealth submitted Technical
Change 11 (Appendix D: Maxey Flats Project IRP Cap 2012; USEPA Change Req
2012 No ll.pdf. Technical Change 11 instituted the use of temporary patches for
small defects. These temporary patches will be inspected annually and replaced if
their integrity appears to be compromised.
7.2 Headwall Maintenance
Headwall maintenance includes four headwalls and associated items along the North
Channel, the northeast corner piping, geomembrane liner battens, and the liquid
collection system.
During this reporting period, debris/leaves were removed numerous times from the
trash grate and restricting plate of the upstream headwall of the northeast corner
piping. Removal of the leaves/debris will be a continuous maintenance issue for the
site.
7.3 Subsidence Monitoring and Repair
Subsidence inspections were conducted monthly in accordance with the O&M,
Section 3.3.3; Subsidence Monitoring. No areas warranted subsidence repair during
2012. Areas near trenches 15, 21, 36, 37, and 46 are being visually monitored
monthly for subsidence qualification. A total of four subsidence repairs have been
made since the 2003 Certification of Completion. Appendix D: Maxey Flats Project
IRP Cap 2012; 2012 MFP Subsidence Tracking Form 2003-2012.xlsx contains the
subsidence repair tracking information.
Estes Land Surveying performed the annual engineering subsidence survey of the
trench cap in June 2012. Elevations were obtained for the 28 subsidence control
points established during the remedial work and six additional points established in
2008. The measured variations between the 2011 and 2012 subsidence control points
range from +0.17 feet to -0.01 feet. The variations between the 2004 (baseline) and
the 2012 subsidence control points range from +0.08 feet to -0.48 feet. No particular
area of significant subsidence was indicated. The report provided by Estes Land
Surveying is available in Appendix D: Maxey Flats Project IRP Cap 2012; 2012 MFP
Subsidence Measurements Estes Surveying.pdf.
7.4 Diversion Berms
The diversion berms were inspected twice a month as required by the O&M.
Excluding possible liner repairs, all were found to be in satisfactory condition.
7.5 Anchor Trenches
The anchor trenches were inspected twice a month as required by the O&M. A
significant hole was located during the 2008 annual inspection on the perimeter
Anchor Trench (at LP 363) along the restricted area fence near the north perimeter
channel. This hole has not been permanently patched. There is an excessive amount
Maxey Flats Project 2012 Annual Report
Page 6 of 11
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of moisture in the soil which renders the welding process ineffective. Due to the
location, this hole does not impact the protectiveness of the liner to prevent
infiltration that would affect trench liquid levels. All other anchor trenches appear to
be functioning to design.
7.6 Drainage Channels
All drainage channels were inspected during 2012 as required by the O&M.
Maintenance within the drains included control of vegetation in the Articulating
Block mats and gabions. This was accomplished by spraying the areas with weed
killer and/or manually removing the vegetation.
7.7 Articulating Concrete Block Mat (AB Mat) System
The AB mat system was inspected monthly as required by the O&M. Buildup of
sediment within the AB mats has been observed, but appears to have minimal impact
on reducing the velocity of water flowing to the EDB, nor does it appear to have
impacted the EDB's ability to control flow. This buildup of sediment should be
expected, as it is an inherent design feature of AB mats. In various locations, the
cable linking the blocks is showing signs of stress; this has been observed for several
years and will continue to be monitored. One section of blocks in the east drainage
channel on LP-191 EX continues to be monitored closely due to accelerated erosion of
the concrete blocks, but no decrease in performance has been observed.
7.8 Former Leachate Storage Facility Area
The covered area of the former leachate storage facility was found to be in
satisfactory condition. The area shows no signs of subsidence or any damage to the
geomembrane liner or boots around the tank extensions.
7.9 Inspections
A total of 95 inspections were performed in 2012. Excluding the items discussed in
Section 7.5 and 7.7, no unsatisfactory notations were recorded that presented a
persistent problem. All unsatisfactory items either received actions to return them to
satisfactory status or were designated for monitoring.
7.10 Equipment Status
All liner repair equipment remains in good working condition.
8.0 Trench Leachate Management and Monitoring
Trench sump liquid level measurements were obtained in accordance with the PSVP,
Section 2.3, Sump Measurement, and the 2007 US EPA Five Year Review. The
purpose of collection and evaluation of the trench sump leachate levels is to detect
recharge conditions that may require leachate management.
Maxey Flats Project 2012 Annual Report
Page 7 of 11
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The average loss of freeboard for all sumps is 1.30%. Three sumps have a greater
than 10% loss of freeboard. Sumps 7-4, 46-1, and 46-2 have a freeboard percentage
loss of 71%, 18%, and 13%, respectively. Due to freeboard loss of greater than 50%,
Sump 7-4 continues to be evaluated under the 2011 revised Leachate Management
Engineering Evaluation.
In addition to the previously mentioned documents, Appendix E: Maxey Flats Project
Trench Sump Information 2012 contains tables for trench freeboard, leachate levels,
sump bottom measurements and a graph of leachate levels of Trench Sump 7-4.
9.0 Contaminated Liquid and Solid Waste
Contaminated liquid and waste generated on site will be disposed of in accordance
with the IMP Work Plan, Section 3.2: Treatment of Other Contaminated Liquids, and
Section 3.3: Waste Burial.
For 2012, no liquid beneath the trench cap liner was managed. No solid waste was
disposed of on site during this reporting period. Solid and liquid waste generated
from laboratory, radiological activities and site maintenance is temporarily stored in a
secured area.
Appendix F: Maxey Flats Project Compliance Information 2012, contains the Annual
Low Level Radioactive Waste Report submitted to the Cabinet for Health and Family
Services, Radiation Health Branch (RHB); 2012 MFP LLRWReport.pdf.
10.0 Erosion Monitoring
Estes Land Surveying was contracted for the fifth consecutive measurement to
complete erosion monitoring and to produce a drain profile of the east drain using
IMP Methodology. Estes Land Surveying conducted erosion measurements in May
and November of 2012. The IMP Methodology cross-sections and tables for the
2011-2012 East drain erosion measurements and the calculated areas are presented in
Appendix G: Maxey Flats Project Drainage Channel Erosion Monitoring 2012; MFP
2012 East Drain Shaw Monuments.pdf.
The Maxey Flats Project staff completed the 2012 erosion screening measurements in
March using the USGS methodology. Results of this screening appear in Appendix
G: Maxey Flats Project Drainage Channel Erosion Monitoring 2012; MFP East Drain
Erosion USGS Monuments 2003-2012.xlsx,
Seasonal visual erosion monitoring of the east, south, and west drainage channels was
completed in compliance with IMP Work Plan requirements. These inspections
revealed no new erosion concerns since those noted in 2011.
Maxey Flats Project 2012 Annual Report
Page 8 of 11
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11.0 IMP Work Plan Revisions, Changes, and Correspondence
Revisions and changes to the IMP Work Plan are required to be submitted in writing
to USEPA for approval. Technical Change 11 was submitted to US EPA on May 3,
2102 and appears in Appendix D: Maxey Flats Project IRP Cap 2012; US EPA
Change Req 2012 Noll.pdf. Technical Change 11 expands the use of temporary
patches from temporary to permanent with the requirement of annual inspections to
ensure patch integrity. Technical Change 11 will be utilized until completion of the
final cap installation.
12.0 Custodial Care Activities
12.1 Vegetation
All vegetation was maintained below required height limits to permit leachate
monitoring.
12.2 Building and Grounds Maintenance
In addition to the established buildings receiving routine maintenance, a storage
bunker was constructed to hold gravel and sand. In addition to routine grounds
maintenance, an excavator was used to make needed improvements around sampling
location 106B.
12.3 Security Fence
The security fence surrounding the site remains in satisfactory condition with minor
maintenance required.
12.4 Roadway Maintenance
In addition to routine maintenance on all facility owned roadways, 128 tons of gravel
was placed on the perimeter road and around maintenance buildings.
13.0 Cathodic Protection
Operation of the cathodic protection system installed on the 20,000 gallon UST
within the restricted area has been checked monthly with all readings documented
within the accepted range. Jeffery D. Harris of Corrosion Concerns, LLC completed
the 2012 annual evaluation of the cathodic system on June 15. The system evaluation
report appears in Appendix H: Maxey Flats Project Cathodic Protection Inspection
2012; 2012 MFP Cathodic Protection Evaluation.pdf.
Maxey Flats Project 2012 Annual Report
Page 9 of 11
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14.0 Non IMP Work Plan Activities and Developments
The main purpose of this document is to summarize completion of the tasks required
by the IMP Work Plan for the calendar year. Many other activities and developments
relevant to MFP operations took place during 2012. Some of the major Non-IMP
Work Plan activities and developments undertaken are included in this section.
In September of 2012, the DWM formally requested entry into the Final Closure
Period (FCP) with the submission of the Trench Stabilization Criteria Evaluation
report to US EPA (Appendix I: Maxey Flats Project Non-IMP Information 2012;
Trench Stabilization Criteria Eval 092112). On November 16th, the DWM received
confirmation from US EPA that Trench Stabilization Criteria had been met, officially
placing the MFP in the Final Closure Period (Appendix I: Maxey Flats Project Non-
IMP Information 2012; Trench Stabilization Criteria US EPA Approval 111612.pdf).
Concurrent with the request to enter FCP, the DWM and KY Finance Cabinet
initiated a request for proposal (RFP) for Cap Design and development of the FCP
Remedial Design Work Plan. The following events led to the selection of the FCP
design contractor:
• October 16th and 18th: the MFP hosted open house events for prospective
bidders.
• November 28th: a selection committee evaluated the submitted proposals to
select a short list of three companies to formally present their design
proposals.
• December 12th: a detailed facility tour was provided to the three companies
selected.
• January 16th: the short list contractors presented their proposals to the
selection committee. URS, Inc. was selected as the design contractor.
Pending contract approval, URS will begin FCP Remedial Design activities the spring
of2013.
During September 2011, the MFP office was approached by Jerry Gibbs, the
administrator of 38 acres of land that borders the MFP site boundary. Mr. Gibbs
presented an offer to sell the property to the Commonwealth below market value.
The Commonwealth Finance Cabinet finalized purchase of the property in October
2012. The Commonwealth Finance Cabinet is evaluating the purchase of two more
tracts of land (Jent and Conn Properties) that would provide multiple benefits for
FCP.
Appendix 1 contains the Maxey Flats Project monthly reports file, 2012 MFP Monthly
Reports.pdf. These reports are generated for the purpose of keeping the
Commonwealth's Superfund Branch informed of ongoing IMP, RML, and other
administrative activities. The reports also contain further details about the topics
discussed in this report.
Maxey Flats Project 2012 Annual Report
Page 10 of 11
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15.0 2012 Five Year Review
The third five year review process was completed in September 2012. As required by
the review, all surface water locations were further evaluated based on annual
averages and compared to 50% of the screening assessment level. Drainage channel
sampling location (location 144) exceeded this screening assessment level. In
accordance with Figure 13 of the IMP PSVP, additional radiological and non-
radiological analyses was performed for all 14 alluvial wells, and sampling stations
102D, 122A, 122C, and 103E. Both radiological and non-radiological results for
specified surface and ground water monitoring locations appear in Appendix A:
Maxey Flats Project Analytical Data 2012; 2012 MFP 5YR Rev Non Rad
Analyses.pdf. Also included in Appendix A is the summary submitted to US EPA
with recommendations for further actions as related to the analyses (2012 MFP VOC
Summary to US EPA.pdJ).
The 2012 Five Year Review stated that no recommendations or required actions were
needed to correct deficiencies in protectiveness of the selected remedy. The 2012
review stated: "The selected remedy at the MFDS is expected to be protective of
human health and the environment at the conclusion of the RA, and in the interim,
exposure pathways that could result in unacceptable risks are being controlled."
16.0 Conclusions
This concludes the textual outlining of the IMP activities at the Maxey Flats Project
for 2012. If copies of inspections or deliverables not included in this report are
required, please contact the MFP office.
Maxey Flats Project 2012 Annual Report
Page 11 of 11
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r»C V3V ANO KWmOMEHT CABINET
ftevt?r> Sesj»H>ar
Leonard K. Peter*
Governor
y
Maxey Rats Project
2597 max Road
41049
IS) 783-8680
hlprffwaste. ky.gov
. c'.
014
Ms, Pam Scully, SRPM, Kentucky/Tennessee Section
USEPA-Region IV
Sam Nunn Federal Center
61 Forsyth Street SW
11l' Floor
Atlaria, (> \ 3U303-8960
Subject: Maxey Flats Project - 2013 Annual Report
Dear Ms. Scully;
The Commonwealth of Kentucky is submitting the 2013 Annual Report for the Maxey Flats Project to
fulfill the requirements of Section 4.0 of the Performance Verification Standard Plan (PSVP). The report
was prepared by the Maxey Flats Section and summarizes infonnation from, the period of January 201.3
through December 21)13,
If you have any questions, please contact me at (606)-783-8680.
e-attachment
cc: Nicole Barkasi, de maximis, inc.
Michelle Miller, USDOE
Gwen Hooten, USDOE
Mall McKinley, CHFS, Radiation Health. Branch.
Larry Hughes, DIM, Superfund Branch
Sincerely,
Environmental Scientist III
KeimickfUiifcriiteiSptiti
«er M/F/D
-------
MAXEY FLATS DISPOSAL SITE
ANNUAL REPORT
2013
March 24,2014
Energy and Environment Cabinet
Department for Environmental Protection
Division of Waste Management
Superfund Branch
Maxey Flats Disposal Site
2597 Maxey Flat Road
Hillsboro, KY 41049
606-783-8680
-------
Table of Contents
Page
List of Figures ii
List of Acronyms ii
List of Appendices iii
1.0 Introduction 1
2.0 Scope of Work 1
3.0 Surface Water Monitoring 1
3.1 East Detention Basin 1
3.2 Perennial Streams Surface Water 2
3.3 Drainage Channels Surface Water .3
3.4 Sampling Equipment Status 3
4.0 Groundwater Monitoring Wells 4
4.1 Alluvial Wells 4
4.1.1 Tritium Evaluation 2013 4
4.1.2 Arsenic Evaluation 2012-2013 4
4.2 Perimeter Monitoring Wells 5
5.0 Data Management 5
6.0 Rainfall Data 6
7.0 Initial Remedial Phase Cap Maintenance 6
7.1 Geomembrane Liner and Boots 6
7.2 Headwall Maintenance 6
7.3 Subsidence Monitoring and Repair 6
7.4 Diversion Berms 7
7.5 Anchor Trenches 7
7.6 Drainage Channels 7
7.7 Articulating Concrete Block Mat (AB Mat) System 7
7.8 Former Leachate Storage Facility Area 7
7.9 Inspections 8
7.10 Equipment Status 8
8.0 Trench Leachate Management and Monitoring 8
9.0 Contaminated Liquid and Solid Waste ..... 8
Maxey Flats Disposal Site 2013 Annual Report i
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Table of Contents
(continued)
Page
10.0 Erosion Monitoring 9
11.0 IMP Workplan Revisions, Changes, and Correspondence 9
12.0 Custodial Care Activities ; 9
12.1 Vegetation .....9
12.2 Building and Grounds Maintenance 9
12.3 Security Fence 9
12.4 Roadway Maintenance 9
13.0 Cathodic Protection 10
14.0 Non IMP Work Plan Activities and Developments 10
15.0 Conclusions 11
List of Figures
Figure 3-1 MFDS Annual Average Tritium Concentrations (pCi/mL) 2004-2013 3
List of Acronyms
ARARs
Applicable or Relevant and Appropriate Requirements
BoRP
Balance of Remedial Phase
Commonwealth
Commonwealth of Kentucky
DCSW
Drainage Channels Surface Water
IRP
Initial Remedial Phase
IMP
Interim Maintenance Period
MFDS
Maxey Flats Disposal Site
O&M
Operation and Maintenance Requirement Summary
PSVP
Performance Standards Verification Plan
PSSW
Perennial Steams Surface Water
REI
Reasonably Exposed Individual
RML
Radioactive Material License
US EPA
U.S. Environmental Protection Agency
USGS
U.S. Geological Survey
Maxey Flats Disposal Site 2013 Annual Report
ii
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Table of Contents
(continued)
List of Appendices
(Files separate from Main Report included on disc)
Appendix A Maxey Flats Disposal Site Analytical Data 2013
2013 MFDS Tritium Dataxlsx
2013 MFDS Alluvial Well Arsenic Study.xlsx
Appendix B Maxey Flats Disposal Site Well Levels 2013
2013 MFDS Alluvial Well Levels.xlsx
2013 MFDS Perimeter Well Levels.xlsx
Appendix C Maxey Flats Disposal Site Precipitation 2013
2013 MFDS Daily Rainfall.xlsx
Appendix D Maxey Flats Disposal Site IRP Cap 2013
2013 MFDS Liner Repair Map.pdf
2013 MFDS Subsidence Measurements Estes Surveying.xlsx
MFDS Subsidence Tracking Form 2003-2013.xlsx
Appendix E Maxey Flats Disposal Site Trench Sump Information 2013
Leachate Levies for Trench Sump 7-4 2002_2013.pdf
2013 MFDS Sump Bottom Measurements.xlsx
2013 MFDS Sump Leachate Levels.xlsx
2013 MFDS Trench Freeboard Table, xlsx
Appendix F Maxey Flats Disposal Site Compliance Information 2013
2013-14 MFDS RML.pdf
2013MFDSLLRWReport.pdf
Appendix G Maxey Flats Disposal Site Drainage Channel Erosion Monitoring 2013
MFDS 2013 East Drain Shaw Monuments.pdf
MFDS East Drain Erosion USGS Monuments 2011-2013.xlsx
Appendix H Maxey Flats Disposal Site Cathodic Protection Inspection 2013
2013 MFDS Cathodic Protection Evaluation.pdf
Appendix I Maxey Flats Disposal Site Non-IMP Information 2013
2013 Maxey Flats Monthly Reports.pdf
Maxey Flats Disposal Site 2013 Annual Report
in
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1.0 Introduction
The Commonwealth is submitting this report in accordance with Section 4.0 of the
PSVP. The report summarizes sampling and maintenance activities listed in the 2003
Interim Maintenance Period Work Plans, PSVP, and the O&M.
2.0 Scope of Work
The IMP is ongoing pursuant to the Consent Decree (Civil Action Number 95-58)
signed by the USEPA, the Maxey Flats Steering Committee (Settling Private Parties),
and the Commonwealth. The Commonwealth is responsible for completion of the
BoRP that includes the Interim Maintenance Period, Final Closure Period (FCP), and
Associated Remedial Activities and Performance Monitoring. Although the MFDS is
officially in the FCP relevant IMP activities will be completed throughout the FCP as
long as they are applicable and don't interfere with remedial progress. IMP activities
will cease upon US EPA's approval of a Institutional Control Period Work Plan.
The Interim Maintenance Period Work Plan describes the tasks to be completed
including:
• Surface/ground water monitoring
• IRP cap maintenance and replacement
• Trench leachate management and monitoring
• Subsidence monitoring and surveys
• Erosion evaluation
• General site maintenance
• Contaminated liquid and waste disposal
• Data collection, analysis, and reporting
• Site drainage and erosion control features
3.0 Surface Water Monitoring
All IMP Surface water monitoring locations are evaluated based on tritium sampling
results. The 2013 annual tritium averages for all surface water locations yielded
results below their specified screening assessment levels. Tritium results for all
surface water monitoring appear in Appendix A: Maxey Flats Disposal Site
Analytical Data 2013; 2013 MFDS Tritium Data.xlsx.
3.1 East Detention Basin
The first point of monitoring surface water runoff from the MFDS is at the East
Detention Basin (EDB). Sampling is performed at the EDB as a requirement of the
RML, not the IMP Work Plan. Sampling occurs based on storm events of 2.8 inches
of rainfall in a 24-hour period. In order for the sequential sampler to collect a storm
event sample, the sampler is programmed to collect a sample based on 0.11 inches of
Maxey Flats Disposal Site 2013 Annual Report
Page 1 of 11
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rainfall per hour. A total of 34 samples were collected in 2013 and analyzed for
tritium. Results range from 0.06 to 2.77 pCi/mL. Figure 3-1 provides the IMP
Annual Average for Tritium Concentrations for 2004-2013.
Pursuant to the ROD and IRP Design, discharge from the East Detention Basin
should be released to the East Main Drainage Channel at a rate not to exceed
predevelopment flow conditions. Following storm events exceeding 2.8 inches
rainfall in 24 hours (2 year storm event or greater), the Commonwealth is required to
collect recordings and report findings. Based on data collected from the East Drain
Rain Gauge, no rain event in 2013 exceeded the storm event criteria; therefore no
screening comparison of current flow rate versus pre-developed flow rate was
required. The highest 24 hour recorded rain event for 2013 was 1.92".
3.2 Perennial Streams Surface Water
Perennial Streams Surface Water (PSSW) monitoring is conducted at five locations in
three streams inside and outside the site boundary. These locations are monitored
using sequential samplers that collect a four aliquot daily composite. The PSSW
samples are compared to a specific action level of 20 pCi/mL and a screening level of
50% of the Action Level. A total of 1,819 PSSW samples were collected and
analyzed for tritium during 2013 with no anomalous data reported. For 2013, all
PSSW locations were below the average annual tritium screening level of 10 pCi/mL;
ensuring that the 4 mrem/yr IMP specified dose limit has been met. Figure 3-1 on
Page 3 provides the IMP Annual Average Tritium Concentrations for 2004-2013.
Sample location 122A serves as the background sample. It is located on Rock Lick
Creek up-gradient from site influence. For 2013, this location yielded 365 samples
for tritium analysis. Tritium results range from -0.24 to 1.55 pCi/mL.
Sample location 106 is located on No Name Branch, a tributary to Rock Lick Creek.
Location 106 receives direct influence from drain 144 and exhibits seasonal tritium
level fluctuation concurrent with drain 144. For 2013, this location yielded 365
samples for tritium analysis. Tritium results range from 0.41 to 9.59 pCi/mL.
Sample location 122C is located on Rock Lick Creek, downstream of 106 and 143
influences. For 2013, this location yielded 365 samples for tritium analysis. Tritium
results range from 0.37 to 2.74 pCi/mL.
Sample location 103E is located on Drip Springs Creek and receives influence from
Drain 107. For 2013, this location yielded 365 samples for tritium analysis. Tritium
results range from -0.07 to 1.29 pCi/mL.
Sample location 102D is the only PSSW sampler located outside the Buffer Zone.
Due to its location below the confluence of three streams; and its location outside the
Buffer Zone, 102D is designated as the compliance point for site runoff. This
location is the point for monitoring the Reasonably Exposed Individual (REI) and is
compared to a 4 mrem/year dose limit. For 2013, this location yielded 359 samples
for tritium analysis. Tritium results range from -0.20 to 2.23. The annual average
was well below the action level, ensuring compliance to the 4 mrem/yr dose limit.
Maxey Flats Disposal Site 2013 Annual Report
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3.3 Drainage Channels Srnface Water
Drainage Channels Surface Water (DCSW) monitoring is conducted at three locations
inside the MFDS's boundary. The three primary drains that produce intermittent flow
are monitored and compared to a 25 mrem/year Total Effective Dose Equivalent
standard and a more restrictive annual 100 pCi/mL action level. These drains are
sampled as a composite by automated samplers that collect a four aliquot daily
sample. For 2013, all DCSW locations had annual averages below the 100 pCi/mL
action level, ensuring compliance to the 25 mrem/yr standard. A total of 947 samples
were collected from the drains for tritium analysis. Figure 3-1, below provides the
IMP Annual Average Tritium Concentrations for 2004-2013.
Sample location CI 07 is located at the base of the West Drain, which discharges into
Drip Springs Creek. For 2013, this location yielded 218 samples for tritium analysis.
Results range from 0.35 pCi/mL to 24.14 pCi/mL.
Sample location 143 is located near the base of the South Drain, which discharges
into Rock Lick Creek. For 2013, this location yielded 365 samples for tritium
analysis. Results range from -0.24 pCi/mL to 0.81 pCi/mL.
Sample location 144 is located at the base of the East Drain, which discharges into No
Name Branch. For 2013, this location yielded 364 samples for tritium analysis.
Results range from 0.29 pCi/mL to 151.03 pCi/mL.
3.4 Sampling Equipment Status
Samples were collected in accordance with the PSVP, unless problems occurred
beyond control such as: freezing lines, washouts, equipment failure, no flow, or
power outages.
Figure 3-1
Maxey Flats Disposal Site
Annual Average Tritium Concentration (pCi/mL)
2004-2013
Perennial Streams Surface Water
Drainage Channels
Surface Water
EDB
122A
106B
122C
103E
102D
C107
143
144
2004
0.14
0.06
4.55
1.10
0.90
0.78
14.58
0.21
60.66
2005
0.16
0.05
4.23
1.01
0.67
0.79
16.97
0.10
40.03
2006
0.16
0.05
3.41
0.86
0.47
0.62
8.62
0.10
43.35
2007
0.55
0.02
5.24
1.27
0.62
0.93
13.28
0.07
70.03
2008
0.05
-0.10
3.33
0.87
0.47
0.62
10.42
-0.11
33.76
2009
0.90
0.07
3.39
0.88
0.36
0.58
5.87
0.10
44.34
2010
0.59
0.06
4.41
1.34
0.49
0.79
10.99
0.06
61.60
2011
0.38
0.06
3.21
0.91
0.37
0.61
8.63
0.03
56.43
2012
0.72
0.05
3.88
1.19
0.51
0.82
12.96
0.06
67.85
2013
0.94
0.05
3.61
1.00
0.44
0.67
10.42
0.07
59.34
Maxey Flats Disposal Site 2013 Annual Report
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4.0 Groundwater Monitoring Wells
Groundwater monitoring at MFDS is accomplished using Alluvial and Perimeter
Monitoring Wells. The alluvial wells, located in the buffer zone, were installed
during the IRP to satisfy the requirements of the SOW. Seventeen monitoring wells
referred to as Perimeter Monitoring Wells are located along the west perimeter fence
of the restricted area, with the exception of one interior well, which is located within
the restricted area between the EMC bunker and North Channel. Sixteen of the
seventeen perimeter wells were installed as investigative monitoring points prior to
the Consent Decree. Originally, over 300 investigative monitoring wells were
installed; IRP operations removed all but the remaining sixteen. The one interior well
was installed during the IRP. These seventeen wells are maintained for water level
monitoring to satisfy the requirements of the IMP Work Plan and sampled to satisfy
the contaminant monitoring requirements of the RML. Tritium analyses for all the
wells are contained in Appendix A: Maxey Flats Disposal Site Analytical Data 2013;
2013 MFDS Tritium Data.xlsx. Water level monitoring tables for both alluvial and
perimeter wells are contained in Appendix B: Maxey Flats Disposal Site Well Levels
2013; 2013 MFDS Alluvial Well Levels.xlsx and 2013 MFDS Perimeter Well
Levels.xlsx.
4.1 Alluvial Wells
4.1.1 Tritium Evaluation 2013
Alluvial well samples for 2013 were collected for tritium analysis as outlined
in the PS VP and the 2007 US EPA Five Year Review. Five wells were
sampled in 2013; an annual sample is collected from AW-6, 10, and 12, and
quarterly samples were collected from AW-1 and 7. During this reporting
period, a total of 18 alluvial well samples were collected and analyzed for
tritium, yielding results typical of historic range.
For 2013, AW-7 yielded the highest tritium concentration, with a value of
6.05 pCi/mL. Comparison of this value to 50% of the 20 pCi/mL ARAR
screening assessment level indicated that action levels for additional
radiological analysis were not exceeded.
Access to the alluvium within the buffer zone is controlled by the
Commonwealth, therefore the alluvial wells are not considered a drinking
water source and do not represent a potential radiological dose to the public.
4.1.2 Arsenic Evaluation 2012-2013
During the course of preparing the Five Year Review in 2012, it was
determined surface water sampling location 144 exceeded 50% of the
established screening level for tritium. In accordance with requirements of the
Interim Maintenance Plan (IMP), a sampling event was conducted specifically
to quantify the concentrations of contaminants of concern in groundwater as
identified in the Record of Decision. Fourteen alluvial wells and four stream
sampling locations were sampled and extensively analyzed in September
2012. The Third Party (Test America) laboratory results identified four
Maxey Flats Disposal Site 2013 Annual Report
Page 4 of 11
1
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locations that exceeded the current 10 (ig/L Maximum Contaminant Level
(MCL) for arsenic: alluvial well locations AW-1, AW-6, AW-13 and AW-14.
The Commonwealth proposed quarterly sampling and analysis specifically for
arsenic at the four wells for a minimum of four quarters to evaluate the
environmental criterion. The results of this study will be used to determine the
appropriate course of action.
Laboratory results and subsequent inquires to experts in drinking water well
conditions or local geology have proven inconclusive. Jerry Martin with the
Kentucky Division of Water (DOW) informed MFP that no Arsenic Level
Profile has ever been done for the area and Robert Blair (DOW) stated the
levels of arsenic in wells at MFP were very similar to the levels he is finding
in his study of Ohio River Basin drink water wells. A study of the
Ohio/Sunbury Shale Formation by Geologist Charles Mason at Morehead
State University identified high levels of arsenic in the Ohio Shale Formation,
a prominent geologic feature at MFP. A meeting with Dr. Mason is scheduled
to discuss the possible influences Ohio Shale in the alluvium could have on
alluvial well water.
The results of this sampling are presented in Appendix A: Maxey Flats
Disposal Site Analytical Data 2013; 2013 MFDS Alluvial Well Arsenic
Study, xlsx.
4.2 Perimeter Monitoring Wells
Well water levels were collected from the seventeen Perimeter Monitoring Wells on a
quarterly basis. The 2013 measurements indicate the water levels are typical of
historic data.
The 2013 tritium results for the Perimeter Wells were typical of historical data and
trends. Contamination monitoring of the Perimeter Monitoring Wells is a
requirement of the RML, not the IMP Work Plan.
5.0 Data Management
A data package is prepared for each group of samples analyzed on site. The data
package contains the tritium instruments' QC charts (efficiency and background),
chain of custody forms, raw data sheets, and data reduction sheets. Data is reviewed
and validated by DeNuke, Inc., a third party contractor that specializes in radiation
services. Following data validation, the results are entered into the site's database
and transmitted to USEPA, USDOE, de maximis, inc. and the Commonwealth. These
packets are available on site for review. Analytical results are contained in the
electronic file, Appendix A: Maxey Flats Disposal Site Analytical Data 2013; 2013
MFDS Tritium Data, xlsx
Maxey Flats Disposal Site 2013 Annual Report
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6.0 Rainfall Data
Presently, there are three rain gauge locations associated with the MFDS: the East
Detention Basin (EDB), sampling location 102D, and the main office. The official
annual rainfall data is obtained from the EDB rain gauge. This rain gauge was chosen
because of its conjunction with the sampler at the EDB. Rainfall data from an
alternate rain gauge, maintained at the main office, may be used to determine official
rainfall totals if the EDB rain gauge is non-functional. A total of 42.51 inches of
rainfall was measured at the EDB gauge during 2013. This is compared to an annual
average precipitation of 47.33 inches (NOAA, National Climatic Data Center;
Farmers, Kentucky). Annual precipitation data appears in Appendix C: Maxey Flats
Disposal Site Precipitation 2013; 2013 MFDS Daily Rainfall.xlsx.
7.0 Initial Remedial Phase Cap Maintenance
7.1 Geomembrane Liner and Boots
The liner covering the trench cap and the sump boots were inspected monthly as part
of the monthly inspection. The comprehensive visual and air lancing inspections
were completed in April and May as part of the annual inspection. During 2013, a
total of 46 repairs were made to the liner and boots. A total of 511 repairs have been
made from 2004-2013. The repair map appears in Appendix D: Maxey Flats
Disposal Site IRP Cap 2013; 2013 MFDS Liner Repair Map.pdf.
7.2 Headwall Maintenance
Headwall maintenance includes four headwalls and associated items along the North
Channel, the northeast corner piping, geomembrane liner battens, and the liquid
collection system.
During this reporting period, debris/leaves were removed numerous times from the
trash grate and restricting plate of the upstream headwall of the northeast corner
piping. Removal of the leaves/debris will be a continuous maintenance issue for the
site.
7.3 Subsidence Monitoring and Repair
Subsidence inspections were conducted monthly in accordance with the O&M,
Section 3.3.3; Subsidence Monitoring. No areas warranted subsidence repair during
2013. Areas near trenches 15, 21, 36, 37, and 46 are being visually monitored
monthly for subsidence qualification. A total of four subsidence repairs have been
made since the 2003 Certification of Completion. Appendix D: Maxey Flats Disposal
Site IRP Cap 2013; 2013 MFDS Subsidence Tracking Form 2003-2013.xlsx contains
the subsidence repair tracking information. Monitoring of these areas will continue in
the FCP but any required subsidence repairs not deemed critical will be addressed
during cap construction.
Maxey Flats Disposal Site 2013 Annual Report
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Estes Land Surveying performed the annual engineering subsidence survey of the
trench cap in June 2013. Elevations were obtained for the 28 subsidence control
points established during the remedial work and six additional points established in
2008. The measured variations between the 2012 and 2013 subsidence control points
range from +0.20 feet to -0.32 feet. The variations between the 2004/2008 (baseline)
and the 2013 subsidence control points range from +0.17 feet to -0.59 feet.
Monitoring points 20 and 29 have been identified as having significant subsidence.
These areas will be closely monitored in 2014 and addressed during cap design and
construction. No particular area of significant subsidence was indicated. The report
provided by Estes Land Surveying is available in Appendix D: Maxey Flats Disposal
Site IRP Cap 2013; 2013 MFDS Subsidence Measurements Estes Surveying.pdf.
7.4 Diversion Berms
The diversion berms were inspected twice a month as required by the O&M.
Excluding possible liner repairs, all were found to be in satisfactory condition.
7.5 Anchor Trenches
The anchor trenches were inspected twice a month as required by the O&M. All
anchor trenches appear to be functioning to design.
7.6 Drainage Channels
All drainage channels were inspected during 2013 as required by the O&M.
Maintenance within the drains included control of vegetation in the Articulating
Block mats and gabions. This was accomplished by spraying the areas with weed
killer and/or manually removing the vegetation.
7.7 Articulating Concrete Block Mat (AB Mat) System
The AB mat system was inspected monthly as required by the O&M. Buildup of
sediment within the AB mats has been observed, but appears to have minimal impact
on reducing the velocity of water flowing to the EDB, nor does it appear to have
impacted the EDB's ability to control flow. This buildup of sediment should be
expected, as it is an inherent design feature of AB mats. In various locations, the
cable linking the blocks is showing signs of stress; this has been observed for several
years and will continue to be monitored. One section of blocks in the east drainage
channel on LP-191EX continues to be monitored closely due to accelerated erosion of
the concrete blocks, but no decrease in performance has been observed.
7.8 Former Leachate Storage Facility Area
The covered area of the former leachate storage facility was found to be in
satisfactory condition. The area shows no signs of subsidence or any damage to the
geomembrane liner or boots around the tank extensions.
Maxey Flats Disposal Site 2013 Annual Report
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7.9 Inspections
A total of 95 inspections were performed in 2013. Excluding the item discussed in
7.7, no unsatisfactory notations were recorded that presented a persistent problem.
All unsatisfactory items either received actions to return them to satisfactory status or
were designated for monitoring.
7.10 Equipment Status
All liner repair equipment remains in good working condition.
8.0 Trench Leachate Management and Monitoring
Trench sump liquid level measurements were obtained in accordance with the PSVP,
Section 2.3, Sump Measurement, and the 2007 US EPA Five Year Review. Hie
purpose of collection and evaluation of the trench sump leachate levels is to detect
recharge conditions that may require leachate management.
The average loss of freeboard for all sumps is 1.30%. Three sumps have a greater
than 10% loss of freeboard. Sumps 7-4, 46-1, and 46-2 have a freeboard percentage
loss of 71%, 17%, and 12%, respectively. Due to freeboard loss of greater than 50%,
Sump 7-4 continues to be evaluated under the 2011 revised Leachate Management
Engineering Evaluation.
Appendix E: Maxey Flats Disposal Site Trench Sump Information 2013 contains
tables for trench freeboard, leachate levels, sump bottom measurements and a graph
of leachate levels of Trench Sump 7-4.
9.0 Contaminated Liquid and Solid Waste
Contaminated liquid and waste generated on site will be disposed of in accordance
with the IMP Work Plan, Section 3.2: Treatment of Other Contaminated Liquids, and
Section 3.3: Waste Burial.
For 2013, no liquid beneath the trench cap liner was managed. No solid waste was
disposed of on site during this reporting period. Solid and liquid waste generated
from laboratory, radiological activities and site maintenance is temporarily stored in a
secured area.
Appendix F: Maxey Flats Disposal Site Compliance Information 2013, contains the
Annual Low Level Radioactive Waste Report submitted to the Cabinet for Health and
Family Services, Radiation Health Branch (RHB); 2013 MFDSLLRWReport.pdf.
Maxey Flats Disposal Site 2013 Annual Report
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10.0 Erosion Monitoring
Estes Land Surveying was contracted for the seventh (based on the area report
spreadsheet) consecutive measurement to complete erosion monitoring and to
produce a drain profile of the east drain using IMP Methodology. Estes Land
Surveying conducted erosion measurements in May and November of 2013. The
IMP Methodology cross-sections and tables for the 2011-2013 East drain erosion
measurements and the calculated areas are presented in Appendix G: Maxey Flats
Disposal Site Drainage Channel Erosion Monitoring 2013; MFDS 20J3 East Drain
Shaw Monuments.pdf.
The Maxey Flats Disposal Site staff completed the 2013 erosion screening
measurements in April using the USGS methodology. Results of this screening
appear in Appendix G: Maxey Flats Disposal Site Drainage Channel Erosion
Monitoring 2013; MFDS East Drain Erosion USGS Monuments 2011-2013.xlsx.
Seasonal visual erosion monitoring of the east, south, and west drainage channels was
completed in compliance with IMP Work Plan requirements. These inspections
revealed no new erosion concerns since those noted in 2011.
11.0 IMP Work Plan Revisions, Changes, and Correspondence
Revisions and changes to the IMP Work Plan are required to be submitted in writing
to USEPA for approval.
12.0 Custodial Care Activities
12.1 Vegetation
All vegetation was maintained below required height limits to permit leachate
monitoring.
12.2 Building and Grounds Maintenance
In addition to the established buildings receiving routine maintenance, a storage
bunker was constructed to hold gravel and sand. In addition to routine grounds
maintenance, an excavator was used to make needed improvements around sampling
location 106B.
12.3 Security Fence
The security fence surrounding the site remains in satisfactory condition with minor
maintenance required.
12.4 Roadway Maintenance
Routine maintenance was performed on all facility owned roadways.
Maxey Flats Disposal Site 2013 Annual Report
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13.0 . Cathodic Protection
Operation of the cathodic protection system installed on the 20,000 gallon UST
within the restricted area has been checked monthly with all readings documented
within the accepted range. Jeffery D. Harris of Corrosion Concerns, LLC completed
the 2013 annual evaluation of the cathodic system on July 31st. The system
evaluation report appears in Appendix H: Maxey Flats Disposal Site Cathodic
Protection Inspection 2013; 2013 MFDS Cathodic Protection Evaluation.pdf
14.0 Non IMP Work Plan Activities and Developments
The main purpose of this document is to summarize completion of the tasks required
by the IMP Work Plan for the calendar year. Many other activities and developments
relevant to MFDS operations took place during 2013. Some of the major Non-IMP
Work Plan activities and developments undertaken are included in this section.
January 2013: The initial RCP Remedial Design Work Plan prepared by DWM was
submitted to US EPA. URS, Inc. was selected as the design contractor. URS
submitted the draft final Remedial Design Work Plan to KDEP and EPA on June 21,
2013. This plan was revised and finalized by URS and submitted to US EPA during
November 2013.
April 2013: URS contacted Photo Science for completion of LiDAR map of MFDS.
May 2013: URS completed geological hydro evaluation study that evaluated the need
for additional capping north of the IRP cap. This study was presented to CHFS and
discussed during meetings in July. It was later concluded that additional capping was
not wan-anted.
June 2013: Explanation of Significant Difference identifying elements in the ROD
that should be modernized submitted to US EPA for approval. US EPA approves
URS as the Supervising Contractor.
July 2013: KY Governor Steve Beshear, KY Senator Walter Blevins, KY
Representative Mike Denham and other dignitaries visited the site to announce
funding and the beginning of the FCP process. The event had forty attendees.
April 2013: The design contract with URS was finalized. The contract includes:
information gathering, cost estimates, completion of Remedial Design Work Plans;
development of sump abandonment method, preparation of sump abandonment bid
package, sump abandonment oversight and Final Closure Period Cap Design. Cap
Construction Oversight will also be performed by URS.
August 2013: Sump Abandonment Bid Package Submitted to US EPA for approval.
Maxey Flats Disposal Site 2013 Annual Report
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October 2013: URS completed Geotechnical Work that included: 17 cone
penetrometers, 14 hollow stem auger boreholes, 9 hand auger boreholes and 20 soil
test pits. Over 80 samples were submitted for geotechnical laboratory testing. In
addition, all drains flowing from the cap area were evaluated and a route for the haul
road was chosen.
November 2013: Sump abandonment Bid Package received approval from US EPA.
The bid package was posted on the Commonwealth's procurement webpage.
December 2013: URS submitted Maxey Flats Final Cap 30% Design Package to US
EPA. Sump Abandonment Site tour bid meeting completed. Sump Abandonment
Bids to be submitted and contractor selected in January 2014.
The Commonwealth Finance Cabinet initiated purchase of the Conn Property located
at the end of Upper Rock Lick road during 2013. An appraisal and sales contract
have been completed for the purchase. The survey work was started in 2013 but
won't be completed until 2014. Additional work remaining is the environmental
impact study and renewal of the sales contract.
Appendix I contains the Maxey Flats Disposal Site monthly reports file, 2013 MFDS
Monthly Reports.pdf. These reports are generated for the puipose of informing the
Commonwealth's Superfund Branch of ongoing IMP, RML, and other administrative
activities. The reports also contain further details about the topics discussed in this
report.
15.0 Conclusions
This concludes the textual outlining of the IMP activities at the Maxey Flats Disposal
Site for 2013. If copies of inspections or deliverables not included in this report are
required, please contact the MFDS office.
Maxey Flats Disposal Site 2013 Annual Report
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MAXEY FLATS DISPOSAL SITE
ANNUAL REPORT
2014
Energy and Environment Cabinet
Department for Environmental Protection
Division of Waste Management
Superfund Branch
Maxey Flats Disposal Site
2597 Maxey Flat Road
Hillsboro, KY 41049
606-783-8680
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Table of Contents
Page
List of Figures ii
List of Acronyms ..ii
List of Appendices iii
1.0 Introduction 1
2.0 Scope of Work 1
B.O Surface Water Monitoring 1
3.1 East Detention Basin 2
3.2 Perennial Surface Water 2
3.3 Drainage Channels Water 3
3.4 Sampling Equipment Status 3
4.0 Groundwater Monitoring Wells 4
4.1 Alluvial Wells 4
4.1.1 Tritium Evaluation 2014 4
4.1.2 Arsenic Evaluation 2012-2014 5
4.2 Perimeter Monitoring Wells 5
5.0 Data Management 6
6.0 Rainfall Data 6
7.0 Initial Remedial Phase Cap Maintenance 6
7.1 Geomembrane Liner and Boots 6
7.2 Headwall Maintenance 6
7.3 Subsidence Monitoring and Repair 7
7.4 Diversion Berms 7
7.5 Anchor Trenches 7
7.6 Drainage Channels 7
7.7 Articulating Concrete Block Mat (AB Mat) System 7
7.8 Former Leachate Storage Facility Area 8
7.9 Inspections 8
7.10 Equipment Status 8
8.0 Trench Leachate Management and Monitoring 8
Maxey Flats Disposal Site 2014 Annual Report i
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Table of Contents
(Continued)
Page
9.0 Contaminated Liquid and Solid Waste 8
10.0 Erosion Monitoring 9
11.0 IMP Work Plan Revisions, Changes, and Correspondence 9
12.0 Custodial Care Activities 9
12.1 Vegetation 9
12.2 Building and Grounds Maintenance 10
12.3 Security Fence 10
12.4 Roadway Maintenance 10
13.0 Cathodic Protection 10
14.0 Other Activities and Developments 10
15.0 Conclusions 11
List of Figures
Figure 3-1 MFDS Annual Average Tritium Concentrations (pCi/mL) 2004-2014 4
List of Acronyms
ARARs
Applicable or Relevant and Appropriate Requirements
BoRP
Balance of Remedial Phase
Commonwealth
Commonwealth of Kentucky
DOE
U.S. Department of Energy
DCW
Drainage Channels Water
FCP
Final Closure Period
IRP
Initial Remedial Phase
IMP
Interim Maintenance Period
MFDS
Maxey Flats Disposal Site
O&M
Operation and Maintenance Requirement Summary
PSVP
Performance Standards Verification Plan
PSW
Perennial Surface Water
REI
Reasonably Exposed Individual
RML
Radioactive Material License
EPA
U.S. Environmental Protection Agency
USGS
U.S. Geological Survey
Maxey Flats Disposal Site 2014 Annual Report ii
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Table of Contents
(Continued)
List of Appendices
Included on Disc
Appendix A Maxey Flats Disposal Site Analytical Data 2014
2014 MFDS Tritium Data
2014 MFDS Alluvial Well Arsenic Study
Appendix B Maxey Flats Disposal Site Well Levels 2014
2014 MFDS Alluvial Well Levels
2014 MFDS Perimeter Well Levels
Appendix C Maxey Flats Disposal Site Precipitation 2014
2014 MFDS Daily Rainfall
Appendix D Maxey Flats Disposal Site IRP Cap 2014
2014 MFDS Liner Repair Map
2014 MFDS Subsidence Measurements Estes Surveying
MFDS Subsidence Tracking Form 2003-2014
Appendix E Maxey Flats Disposal Site Trench Sump Information 2014
Leachate Levels for Trench Sump 7-4 2002-2014
2014 MFDS Sump Bottom Measurements
2014 MFDS Sump Leachate Levels
2014 MFDS Trench Freeboard Table
Appendix F Maxey Flats Disposal Site Compliance Information 2014
2013-14 MFDS RML
2014 MFDS LLRW Report
Appendix G Maxey Flats Disposal Site Drainage Channel Erosion Monitoring 2014
MFDS 2014 East Drain Shaw Monuments
MFDS East Drain Erosion USGS Monuments 2011-2014
Maxey Flats Disposal Site 2014 Annual Report
iii
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1.0 Introduction
The Commonwealth is submitting this report in accordance with Section 4.0 of the
Performance Standard Verification Plan PSVP (Appendix C of the Interim
Maintenance Period (IMP) Work Plan). This report summarizes sampling and
maintenance activities listed in the 2003 IMP Work Plan, PSVP, and the Operations
and Maintenance (O&M) Requirement Summary (Appendix D of the IMP Work Plan).
2.0 Scope of Work
The Final Closure Period (FCP) is ongoing pursuant to the Consent Decree (Civil
Action Number 95-58) signed by the United States Environmental Protection Agency
(EPA), the Maxey Flats Steering Committee (Settling Private Parties), and the
Commonwealth. As of September 2014, the Maxey Flats Steering Committee
disbanded, placing the Commonwealth under EPA regulation. The Commonwealth is
responsible for the Balance of Remedial Phase (BoRP), which includes tasks that
comprise the IMP and FCP as described in the Record of Decision (ROD). Relevant
IMP monitoring activities will continue until they are no longer applicable or
interfere with remediation currently ongoing within FCP, and will conclude upon
EPA's approval of an Institutional Control Period Work Plan, which is being
developed.
The following IMP Work Plan obligations will continue through FCP until no longer
applicable:
• Surface/ground water monitoring
• Initial Remedial Phase (IRP) cap maintenance and replacement
• Subsidence monitoring
• Erosion evaluation
• General site maintenance
• Contaminated liquid and waste disposal
• Data collection, analysis, and reporting
• Site drainage and erosion control features
The following IMP Work Plan obligations have been suspended:
• Trench leachate management and monitoring
• Subsidence survey
3.0 Surface Water Monitoring
All IMP surface water monitoring locations are evaluated based on tritium sampling
results. The 2014 annual tritium averages for all surface water locations were below
their specified screening levels. Tritium results for all surface water monitoring
appear in Appendix A: 2014 MFDS Tritium Data
Maxey Flats Disposal Site 2014 Annual Report
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3.1
East Detention Basin
Surface water runoff from the Maxey Flats Disposal Site (MFDS) is monitored at the
East Detention Basin (EDB). Sampling is triggered by storm events of 2.8 inches of
rainfall in a 24-hour period. A sequential sampler linked to a meteorological station
is programmed to collect a storm event sample at 0.11 inches of rainfall per hour. A
total of 28 storm event samples were collected in 2014 and analyzed for tritium; the
results range from 0.05 to 3.17 pCi/mL. Figure 3-1 on page 4 provides the annual
average for tritium concentrations for 2004-2014. Sample collection from the EDB is
a requirement in the Radiological Materials License (RML) issued by the Radiation
Health Branch of the Cabinet for Health and Family Services.
Pursuant to the ROD and Initial Remedial Phase (IRP) design, discharge from the East
Detention Basin should be released to the East Main Drainage Channel at a rate not
to exceed predevelopment flow conditions. Following storm events exceeding 2.8
inches of rainfall in 24 hours (two-year storm event or greater), the Commonwealth
is required to conduct an inspection of the interim cap and all three drainage
channels, and report findings. Based on data collected from the East Drain rain
gauge, no rain event in 2014 exceeded the two-year storm event criteria; therefore,
no comparison of current flow rate versus pre-developed flow rate was required.
The highest 24-hour recorded rain event for 2014 was 1.87 inches.
3.2 Perennial Surface Water Monitoring
Perennial surface water (PSW) monitoring is conducted at five locations in three
streams inside and outside the site boundary. These locations are monitored using
sequential samplers that collect a four-aliquot daily composite sample. The PSW
samples are compared to a specific action level of 20 pCi/mL and a screening level of
50 percent of the action level. A total of 1,771 PSW samples were collected and
analyzed for tritium during 2014 with no anomalous data reported. During 2014, all
PSW locations were below the average annual tritium screening level of 10 pCi/mL.
Figure 3-1 on page 4 provides the IMP Annual Average Tritium Concentrations for
2004-2014.
Sample location 122A serves as the source for background samples. It is located on
Rock Lick Creek up gradient from site influence. During 2014, 355 samples were
collected from this location for tritium analysis. Tritium results range from -0.23 to
1.04 pCi/mL.
Sample location 106 is located on No Name Branch, a tributary to Rock Lick Creek.
Location 106 receives direct influence from Drain 144 and exhibits seasonal tritium
level fluctuation concurrent with location 144. During 2014, 356 samples were
collected from this location for tritium analysis. Tritium results range from 1.08 to
9.78 pCi/mL.
Maxey Flats Disposal Site 2014 Annual Report
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Sample location 122C is located on Rock Lick Creek, downstream of 106 and 143
influences. During 2014, 355 samples were collected from this location for tritium
analysis. Tritium results range from 0.04 to 2.71 pCi/mL.
Sample location 103E is located on Drip Springs Creek and receives influence from
Drain 107. During 2014, 345 samples were collected from this location for tritium
analysis. Tritium results range from -0.09 to 1.86 pCi/mL.
Sample location 102D is the only PSW sampler located outside the buffer zone.
Because of its location below the confluence of three streams influenced by surface
water from MFDS, 102D is designated as the compliance point for site runoff. This
location is the monitoring point for the reasonably exposed individual (REI) and is
compared to a 4 mrem/year dose limit. During 2014, 360 samples were collected
from this location for tritium analysis. Tritium results range from 0.18 to 1.99
pCi/mL. The annual average at 102D is 0.08 pCi/ml.
3.3 Drainage Channels Water
Drainage channels water (DCW) monitoring is conducted at three locations inside
the MFDS's boundary. The three primary drains that produce intermittent flow are
monitored and compared to a 25 mrem/year total effective dose equivalent (TEDE)
standard and a more restrictive annual 100 pCi/mL action level. These drains are
sampled by automated samplers that collect a four-aliquot daily composite sample.
In 2014, the annual average for all DCW locations was below the 100 pCi/mL action
level. A total of 826 samples were collected from the drains for tritium analysis.
Figure 3-1 provides the IMP Annual Average Tritium Concentrations for 2004-2014.
Sample location C107 is located at the base of the West Drain, which discharges into
Drip Springs Creek. During 2014, 156 samples were collected from this location for
tritium analysis. Results range from 0.49 pCi/mL to 21.93 pCi/mL.
Sample location 143 is located near the base of the South Drain, which discharges
into Rock Lick Creek. During 2014, 333 samples were collected from this location for
tritium analysis. Results range from 0.19 pCi/mL to 0.64 pCi/mL.
Sample location 144 is located at the base of the East Drain, which discharges into
No Name Branch. During 2014, 364 samples were collected from this location for
tritium analysis. Results range from 0.90 pCi/mL to 149.41 pCi/mL.
3.4 Sampling Equipment Status
Samples were collected in accordance with the PSVP, unless problems occurred
beyond control such as: freezing lines, washouts, equipment failure, no flow, or
power outages.
Maxey Flats Disposal Site 2014 Annual Report
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Figure 3-1
Maxey Flats Disposal Site
Annual Average Tritium Concentration (pCi/mL)
2004-2014
Perennial Surface Water
Drainage Channels
Water
EDB
122A
106B
122C
103E
102D
C107
143
144
2004
0.14
0.06
4.55
1.10
0.90
0.78
14.58
0.21
60.66
2005
0.16
0.05
4.23
1.01
0.67
0.79
16.97
0.10
40.03
2006
0.16
0.05
3.41
0.86
0.47
0.62
8.62
0.10
43.35
2007
0.55
0.02
5.24
1.27
0.62
0.93
13.28
0.07
70.03
2008
0.05
-0.10
3.33
0.87
0.47
0.62
10.42
-0.11
33.76
2009
0.90
0.07
3.39
0.88
0.36
0.58
5.87
0.10
44.34
2010
0.59
0.06
4.41
1.34
0.49
0.79
10.99
0.06
61.60
2011
0.38
0.06
3.21
0.91
0.37
0.61
8.63
0.03
56.43
2012
0.72
0.05
3.88
1.19
0.51
0.82
12.96
0.06
67.85
2013
0.94
0.05
3.61
1.00
0.44
0.67
10.42
0.07
59.34
2014
0.59
0.07
3.80
1.12
0.43
0.80
11.01
0.06
46.01
4.0 Groundwater Monitoring Wells
Groundwater monitoring at MFDS is performed using the existing alluvial and
perimeter monitoring wells. The alluvial wells, located in the buffer zone, were
installed during the IRP to satisfy the requirements of the Statement of Work (SOW).
The perimeter monitoring wells are located along the west perimeter fence of the
restricted area, and were installed as investigative monitoring points prior to the
Consent Decree. Originally, over 300 investigative monitoring wells were installed;
IRP operations removed all but 17. Perimeter well UF-lOa, located within the
restricted area was removed during the sump abandonment phase of FCP. The
remaining 16 wells are maintained for water level monitoring, satisfying the
requirements of the IMP Work Plan, and sampled to satisfy the tritium monitoring
requirements in the RML. Tritium analyses for all the wells are contained in
Appendix A: 2014 MFDS Tritium Data. Water level monitoring tables for both
alluvial and perimeter wells are contained in Appendix B: 2014 MFDS Alluvial Well
Levels and 2014 MFDS Perimeter Well Levels.
4.1 Alluvial Wells
4.1.1 Tritium Evaluation 2014
Alluvial well (AW) samples were collected for tritium analysis as outlined in
the PSVP and the 2007 EPA Five Year Review. Five wells were sampled in
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2014; annual samples were collected from AW-6, 10, and 12, and quarterly
samples from AW-1 and 7. During 2014, a total of 14 alluvial well samples
were collected and analyzed for tritium. Results were typical of historical
ranges.
The maximum tritium concentration at AW-7 was 6.66 pCi/mL. Comparison
of this value to 50 percent of the 20 pCi/mL applicable or relevant and
appropriate (ARAR) requirements indicated that additional radiological
analyses were not necessary.
Access to the alluvium within the buffer zone is controlled by the
Commonwealth, therefore the alluvial wells are not considered a drinking
water source and do not represent a potential radiological dose to the public.
The county road extending through the buffer zone has been closed and a
gate has been installed to further limit access.
4.1.2 Arsenic Evaluation 2012-2014
During the course of preparing the Five Year Review in 2012, it was
determined surface water sampling location 144 exceeded 50 percent of the
established screening level for tritium. In accordance with requirements of
the IMP, a sampling event was conducted specifically to quantify the
concentrations of contaminants of concern in groundwater as identified in
the ROD. In September 2012, 14 alluvial wells and four stream sampling
locations were sampled and analyzed by a third-party laboratory (Test
America). Results indicated AW-1, AW-6, AW-13 and AW-14 exceeded the
currently established EPA 10 ng/L maximum contaminant level (MCL) for
arsenic. The Commonwealth proposed quarterly sampling and analysis for
arsenic for a minimum of four quarters. The sampling for this evaluation
ended in 2014 with three out of the four wells falling below the 10 ng/L MCL.
AW-13 registered "Not Detected" for arsenic in the final three sampling
analysis. AW-1 has an average concentration of 27jig/L, which is within the
historical range for isolated areas with Ohio Shale outcrops.
The results of this sampling are presented in Appendix A: 2014 MFDS Alluvial
Well Arsenic Study.
4.2 Perimeter Monitoring Wells
Water levels were measured in the 16 perimeter monitoring wells on a quarterly
basis. The 2014 measurements indicate water levels typical of historic data.
The 2014 tritium results for the perimeter wells were typical of historical data and
trends. Tritium analysis of the perimeter monitoring wells is a requirement of the
RML.
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5.0 Data Management
A data package is prepared for each group of samples analyzed on-site. The data
package contains the tritium instruments' QC charts (efficiency and background),
chain of custody forms, raw data sheets, and data reduction sheets. The radiation
service contractor, DeNuke, Inc., hired by the Commonwealth to complete third
party data validation for MFDS, was purchased by ATL during 2014. ATL fulfilled the
contractual obligations of DeNuke, Inc., and renewed the contract for 2015.
Following data validation, the results are entered into the site's database and
transmitted to EPA, United States Department of Energy (DOE), and multiple groups
within the Commonwealth. These packets are available on-site for review.
Analytical results are contained in the electronic file, Appendix A: 2014 MFDS Tritium
Data.
6.0 Rainfall Data
Presently, there are three rain gauge locations associated with MFDS: the East
Detention Basin (EDB), sampling location 102D, and the main office. The official
annual rainfall data for MFDS is collected at the EDB rain gauge. This rain gauge is
linked to the sampler at the EDB. Rainfall data from an alternate rain gauge
maintained at the main office may be used for official rainfall totals if the EDB rain
gauge is nonfunctional. A total of 37.29 inches of rainfall was measured at the EDB
gauge during 2014. This is compared to an annual average precipitation of 47.33
inches (NOAA, National Climatic Data Center; Farmers, KY.). Annual precipitation
data appears in Appendix C: 2014 MFDS Daily Rainfall.
7.0 Initial Remedial Phase Cap Maintenance
7.1 Geomembrane Liner and Boots
The liner covering the trench cap and the sump boots was inspected as part of the
monthly inspection. The comprehensive visual and air lancing inspections were
suspended for 2014 to accommodate FCP activities. All liner repairs were made
within the scope of work for sump abandonment by RECON or RECON
subcontractors. A complete accounting of the repairs made during sump
abandonment will be available in the sump abandonment final report.
7.2 Headwall Maintenance
Headwall maintenance includes four headwalls and associated items along the
North Channel, the northeast corner piping, geomembrane liner battens, and the
liquid collection system.
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During this reporting period, debris and leaves were removed numerous times from
the trash grate and restricting plate at the upstream headwall of the northeast
corner inlet pipe. Removal of the leaves and debris will be a continuous
maintenance issue at this headwall.
7.3 Subsidence Monitoring and Repair
Subsidence inspections were conducted monthly in accordance with the O&M,
Section 3.3.3; Subsidence Monitoring. No areas warranted subsidence repair during
2014. Areas near trenches 15, 21, 36, 37, and 46 are being visually monitored
monthly for subsidence qualification. A total of four subsidence repairs have been
made since the 2003 Certification of Completion. Appendix D: 2014 MFDS
Subsidence Tracking Form 2003-2014 contains subsidence repair tracking
information. Monitoring of these areas will continue throughout FCP. Any required
subsidence repairs not deemed critical will be addressed during cap construction.
The annual engineering subsidence survey of the trench cap has been suspended as
a result of FCP.
7.4 Diversion Berms
The diversion berms were inspected twice a month as required by the O&M. All
were found to be in satisfactory condition.
7.5 Anchor Trenches
The anchor trenches were inspected twice a month as required by the O&M. All
anchor trenches appear to be functioning as designed.
7.6 Drainage Channels
All drainage channels were inspected during 2014 as required by the O&M.
Unrestricted flow through the articulating block mats and gabions was maintained
using herbicides and/or manual removal of vegetation.
7.7 Articulating Concrete Block Mat (AB Mat) System
The AB mat system was inspected monthly as required by the O&M. A buildup of
sediment within the AB mats has been observed. This appears to have minimal
impact in reducing the velocity of water flowing to the EDB and it does not appear to
impact the EDB's ability to control flow. This buildup of sediment should be
expected, as it is an inherent design feature of AB mats. In various locations, the
cable linking the blocks is showing signs of stress; this has been observed for several
years and will be monitored. One section of AB blocks in the East Drainage Channel
at LP-191EX continues to erode, but no decrease in performance has been observed.
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7.8 Former Leachate Storage Facility Area
The former leachate storage facility (LFS) area was found to be in satisfactory
condition. The area shows no signs of subsidence or any damage to the
geomembrane liner or boots around the tank extensions at the time sump
abandonment was initiated. As defined in the scope of work for sump
abandonment, LSF-1 was grouted and closed permanently. All riser pipes and
cathodic protection equipment associated with the LSF tanks were removed and
disposed in LSF-1.
7.9 Inspections
A total of 95 inspections were performed in 2014. No unsatisfactory notations were
recorded that present a persistent problem. All unsatisfactory items either received
actions to return them to satisfactory status or were designated for monitoring.
7.10 Equipment Status
All liner repair equipment remains in good working condition.
8.0 Trench Leachate Management and Monitoring
Trench sump liquid level measurements were obtained in accordance with the PSVP,
Section 2.3, Sump Measurement, and the 2011 revised Leachate Management
Engineering Evaluation.
The average loss of freeboard for all sumps is 1.30 percent. Three sumps have a
greater than 10 percent loss of freeboard. Sumps 7-4, 46-1, and 46-2 have a
freeboard percentage loss of 72 percent, 16 percent, and 12 percent, respectively.
The freeboard loss of greater than 50 percent in Sump 7-4 initiated the 2011 revised
Leachate Management Engineering Evaluation, and was ongoing for 2014. Appendix
E contains tables for trench freeboard, leachate levels, sump bottom measurements
and a graph of leachate levels of Sump 7-4.
The sump abandonment process was completed by RECON in 2014. Trench leachate
management and monitoring will no longer be performed. The sump abandonment
final report will be available upon certificate of completion of FCP.
9.0 Contaminated Liquid and Solid Waste
Contaminated liquid and waste generated on site will be disposed of in accordance
with the IMP Work Plan, Section 3.2: Treatment of Other Contaminated Liquids, and
Section 3.3: Waste Burial.
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No liquid beneath the trench cap liner was managed in 2014. Solid waste left from
previous IRP activities was disposed of in LSF-1 during sump abandonment. A
complete accounting will be available in the FCP sump abandonment final report
upon certificate of completion of FCP. Solid and liquid waste generated from
laboratory, radiological activities, and site maintenance, since the certificate of
completion of IRP in 2003, was temporarily stored in a secured area. This stored
radiological waste was released to Bionomics for proper disposal in November 2014.
A list of the disposed materials is detailed in Appendix F: 2014 MFDS Waste Disposal.
The Annual Low Level Radioactive Waste Report submitted to the Cabinet for Health
and Family Services, Radiation Health Branch (RHB) is included in Appendix F: 2014
MFDS LLRW Report.
10.0 Erosion Monitoring
Estes Land Surveying was contracted to complete erosion monitoring and to
produce a cross-sectional profile of the East Drain using IMP methodology. Estes
Land Surveying conducted erosion measurements in May and November of 2014.
The IMP methodology cross-sections and tables for the 2011-2014 East Drain
erosion measurements and the calculated areas are presented in Appendix G: MFDS
2014 East Drain Shaw Monuments.
The MFDS staff completed the 2014 erosion measurements in November using the
USGS methodology. Results of this screening appear in Appendix G: MFDS East
Drain Erosion USGS Monuments 2011-2014.
Seasonal visual erosion monitoring of the east, south, and west drainage channels
was completed in compliance with IMP Work Plan requirements. These inspections
revealed no new erosion concerns.
11.0 IMP Work Plan Revisions, Changes, and Correspondence
Revisions and changes to the IMP Work Plan are required to be submitted in writing
to EPA for approval. No revisions were submitted in 2014.
12.0 Custodial Care Activities
12.1 Vegetation
All vegetation was maintained below required height limits to permit leachate
monitoring.
Maxey Flats Disposal Site 2014 Annual Report
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12.2 Building and Grounds Maintenance
All routine building and grounds maintenance was performed according to IMP
Work Plan requirements. The tank storage building used for access to the restricted
area was surveyed for unrestricted release by ATL in 2014.
12.3 Security Fence
The security fence surrounding the site remains in satisfactory condition with minor
maintenance required.
12.4 Roadway Maintenance
Routine maintenance was performed on all facility-owned roadways.
13.0 Cathodic Protection
Operation of the cathodic protection system installed on the 20,000 gallon
Underground Storage Tank (UST) within the restricted area has been terminated
during sump abandonment activities. The UST was filled with waste generated
during the sump abandonment process and any waste left from previous IRP
activities. An inventory of waste disposal will be available in the FCP sump
abandonment final report upon certificate of completion of FCP. No annual
evaluation of the cathodic system was completed this year.
14.0 Other Activities and Developments
The main purpose of this document is to summarize completion of the tasks
required by the IMP Work Plan. Many other activities and developments relevant to
MFDS operations occurred during 2014. Select activities and developments not
required by the IMP Work Plan are included in this section.
February 2014: RECON was awarded the contract for sump abandonment.
April 2014: RECON mobilized and began sump abandonment.
June 2014:
• The final sump within the restricted area was abandoned on June 5.
• High point contouring was added to RECON's sump abandonment contract.
• An issue developed with an adjacent property owner regarding access to his
property for logging.
• URS submitted the Maxey Flats Final Design Package to EPA.
September 2014: Division of Engineering and Contract Administration (DECA)
awarded the final cap construction contract to The Walker Company.
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October 2014: Massive sump abandonment patch failure was discovered. The
failure was the result of dramatic temperature changes and high winds. Several 50-
degree temperature fluctuations were recorded early in the month. A change order
was negotiated to finance the repairs. All patches were leistered by RECON
subcontractor JH Waters.
November 2014:
• Sump abandonment final completion was declared. The contract included
sump abandonment, patch repair, high point contouring, and diversion berm
installation.
• The Upper Rock Lick Road extension through the buffer zone was removed
from the County Road Maintenance Map and a gate was installed in
preparation for FCP.
• MFDS released all temporarily stored liquid and dry radiological waste to
Bionomics for proper disposal.
15.0 Conclusions
This concludes the textual outlining of the IMP activities at the Maxey Flats Disposal
Site for 2014. If copies of inspections or deliverables not included in this report are
required, please contact the MFDS office.
Maxey Flats Disposal Site 2014 Annual Report
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MAXEY FLATS DISPOSAL SITE
ANNUAL REPORT
2015
Energy and Environment Cabinet
Department for Environmental Protection
Division of Waste Management
Superfund Branch
Maxey Flats Disposal Site
2597 Maxey Flat Road
Hillsboro, KY 41049
606-783-8680
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Table of Contents
Page
List of Figures ii
List of Acronyms iii
List of Appendices iii
1.0 Introduction 1
2.0 Scope of Work 1
3.0 Surface Water Monitoring 1
3.1 East Detention Basin 2
3.2 Perennial Surface Water 3
3.3 Drainage Channels Water 3
3.4 Sampling Equipment Status 4
4.0 Groundwater Monitoring Wells 5
4.1 Alluvial Wells 5
4.1.1 Tritium Evaluation 2015 5
4.2 Perimeter Monitoring Wells 6
5.0 Data Management 6
6,0 Rainfall Data 6
7.0 Initial Remedial Phase Cap Maintenance 6
7.1 Geomembrane Liner and Boots 6
7.2 Headwall Maintenance 7
7.3 Subsidence Monitoring and Repair 7
7.4 Diversion Berms 7
7.5 Anchor Trenches 7
7.6 Drainage Channels 7
7.7 Articulating Concrete Block Mat (AB Mat) System 7
7.8 Former Leachate Storage Facility Area 7
7.9 Inspections 8
7.10 Equipment Status 8
8.0 Trench Leachate Management and Monitoring 8
Maxey Flats Disposal Site 2015 Annual Report i
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Table of Contents
(Continued)
Page
9.0 Contaminated Liquid and Solid Waste 8
10.0 Erosion Monitoring 8
11.0 IMP Work Plan Revisions, Changes, and Correspondence 9
12.0 Custodial Care Activities 9
12.1 Vegetation 9
12.2 Building and Grounds Maintenance 9
12.3 Security Fence 9
12.4 Roadway Maintenance 10
13.0 Cathodic Protection 10
14.0 Other Activities and Developments 10
15.0 Conclusion 10
List of Figures
Figure 3-1 ISCO EDB Two Year Storm Event, 4/3/15 2
Figure 3-2 MFDS Annual Average Tritium Concentrations (pCi/mL) 2011-2015 4
Maxey Flats Disposal Site 2015 Annual Report ii
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Table of Contents
(Continued)
List of Acronyms
ARARs
Applicable or Relevant and Appropriate Requirements
BoRP
Balance of Remedial Phase
Commonwealth
Commonwealth of Kentucky
DOE
U.S. Department of Energy
DCW
Drainage Channels Water
EPA
U.S. Environmental Protection Agency
FCP
Final Closure Period
IRP
Initial Remedial Phase
IMP
Interim Maintenance Period
MFDS
Maxey Flats Disposal Site
O&M
Operation and Maintenance Requirement Summary
PSVP
Performance Standards Verification Plan
PSW
Perennial Surface Water
REI
Reasonably maximally Exposed Individual
RML
Radioactive Material License
SWMF
Stormwater Management Feature
USGS
U.S. Geological Survey
List of eAppendices
Included on Disc
Appendix A Maxey Flats Disposal Site Analytical Data 2015
2015 MFDS Tritium Data.xlsx
Appendix B Maxey Flats Disposal Site Well Levels 2015
2015 MFDS Alluvial Well Levels.xlsx
2015 MFDS Perimeter Well Levels.xlsx
Appendix C Maxey Flats Disposal Site Precipitation 2015
2015 MFDS Daily Rainfall.xlsx
Appendix D Maxey Flats Disposal Site Compliance Information 2015
2015 MFDS LLRW Report.pdf
2015-16 MFDS RMLpdf
Appendix E Maxey Flats Disposal Site Drainage Channel Erosion Monitoring 2015
2011-2015 MFDS East Drain Erosion USGS Monuments.xlsx
2015 MFDS East Drain Erosion Shaw Monuments.pdf
Maxey Flats Disposal Site 2015 Annual Report
in
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1.0 Introduction
The Commonwealth is submitting this annual report for the Maxey Flats Disposal
Site (MFDS) in accordance with Section 4.0 of the Performance Standards
Verification Plan (PSVP) (Appendix C of the Interim Maintenance Period (IMP) Work
Plan). This report summarizes the sampling and maintenance activities listed in the
2003 IMP Work Plan, PSVP, and the Operations and Maintenance (O&M)
Requirement Summary (Appendix D of the IMP Work Plan).
2.0 Scope of Work
The Final Closure Period (FCP) is ongoing pursuant to the Consent Decree (Civil
Action Number 95-58) signed by the United States Environmental Protection Agency
(EPA), the Settling Private Parties (represented by the Maxey Flats Steering
Committee), and the Commonwealth. The Maxey Flats Steering Committee
disbanded in September 2014 as the Settling Private Parties had fulfilled the
responsibilities defined in the Consent Decree. With the dissolution of the Maxey
Flats Steering Committee, the Balance of Remedial Phase (BoRP) became the full
responsibility of the Commonwealth. This includes tasks outlined in the IMP Work
Plan and FCP development as described in the Record of Decision (ROD). Relevant
IMP monitoring activities will continue until they are no longer applicable or
interfere with FCP remediation and will ultimately conclude upon EPA's approval of
an Institutional Control Period (ICP) Work Plan, which is currently under
development.
The following IMP Work Plan obligations will continue through FCP until no longer
applicable:
• Surface/ground water monitoring
• Erosion evaluation
• General site maintenance
• Contaminated liquid and waste disposal
• Data collection, analysis, and reporting
• Site drainage and erosion control features
The following IMP Work Plan obligations have been suspended:
• Trench leachate management and monitoring
• Subsidence survey
• Initial Remedial Phase (IRP) cap maintenance
• Subsidence monitoring
3.0 Surface Water Monitoring
Radioactivity as a result of tritium concentration is used to evaluate the spread of
contamination at MFDS. No annual average activity for any surface water location
exceeded specified screening levels for 2015. The tritium activity for all surface
water monitoring samples appear in Appendix A: 2015 MFDS Tritium Data.xlsx
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3.1 East Detention Basin
Surface water runoff from the Initial Remedial Phase (IRP) cap is monitored at the
East Detention Basin (EDB). A sequential sampler connected to a rain gauge is
programmed to collect samples at 0.11 inches per hour rainfall rate, which is the
divided hourly equivalent of a two-year storm event (2.8 inches of rainfall in 24
hours). In 2015, 39 rain event samples were collected for analysis; the activity
ranged from -0.14 to 1.56 pCi/mL. Figure 3-2 on page 4 provides the annual average
for tritium concentrations for 2004-2015.
Pursuant to the ROD and Initial Remedial Phase (IRP) design, discharge from the East
Detention Basin is released into the East Main Drainage Channel at a rate not to
exceed predevelopment flow conditions. Following a 2.8 inch, two year storm event
or greater, the Commonwealth is required to conduct an inspection of the interim
cap and all three drainage channels, and report findings. The East Drain rain gauge
recorded a two year storm event on April 3rd with a rainfall depth of 2.9 inches. A
comparison of the discharge flow at the EDB flume to a predevelopment flow rate of
11 cfs confirms the predevelopment rate was not exceeded. Figure 3-1 details the
4/3/15 storm event.
Figure 3-1
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3.2 Perennial Surface Water
Perennial Surface Water (PSW) monitoring is conducted at five locations in three
streams influenced by surface water runoff from the MFDS. These locations are
monitored using sequential samplers that collect a four aliquot daily composite. The
PSW samples are compared to an action level of 20 pCi/mL and a screening level of
10 pCi/mL. During 2015, 1,755 PSW samples were collected for analysis with no
anomalous data reported. All PSW location averages were below the screening level
of 10 pCi/mL. Figure 3-2 on page 4 provides the IMP Annual Average Tritium Activity
for 2004-2015.
Sample location 122A serves as the source for background samples. It is located on
Rock Lick Creek up gradient from site influence. During 2015, 344 samples were
collected at this location for analysis. The activity ranged from -0.47 to 6.33 pCi/mL.
Sample location 106 is located on No Name Branch, a tributary to Rock Lick Creek.
Location 106 receives direct influence from Drain 144 and exhibits seasonal activity
fluctuation consistent with location 144. During 2015, 348 samples were collected
from this location for analysis. The activity ranged from -1.12 to 9.89 pCi/mL.
Sample location 122C is located on Rock Lick Creek, downstream of 106 and 143
influences. During 2015, 356 samples were collected from this location for analysis.
The activity ranged from -1.15 to 2.57 pCi/mL.
Sample location 103E is located on Drip Springs Creek and receives influence from
Drain 107. During 2015, 353 samples were collected from this location for analysis.
The activity ranged from -0.56 to 1.79 pCi/mL.
Sample location 102D is the only sampling station outside the established buffer
zone at the MFDS. It is deliberately located below the confluence of the three
streams influenced by surface water from the MFDS and is the designated EPA
compliance point for site runoff. During 2015, 360 samples were collected from this
location for analysis. The activity ranged from -1.11 to 2.15 pCi/mL. The 2015 annual
average at 102D was 0.52 pCi/ml. In accordance with the IMP Work Plan, the
Reasonably maximally Exposed Individual (REI) comparison indicated that the annual
average did not exceed the 4 mrem/year dose limit (equivalent to 20 pCi/mL).
3.3 Drainage Channels Water
Drainage Channels Water (DCW) monitoring is conducted at the three primary
drains that receive intermittent flow from the IRP cap using automated samplers
that collect a four aliquot daily composite. The activity at these monitoring
locations is compared to a 25 mrem/year Total Effective Dose Equivalent (TEDE)
standard, an annual average action level of 100 pCi/mL, and an additional screening
level of 50 pCi/mL. In 2015, 869 samples were collected at the DCW locations for
analysis. No location exceeded the 50 pCi/mL screening level. No additional
Maxey Flats Disposal Site 2015 Annual Report
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investigation was required. Figure 3-2 provides the IMP Annual Average Tritium
Concentrations for 2004-2015.
Sample location C107 is located at the base of the West Drain, which discharges into
Drip Springs Creek. During 2015, 224 samples were collected from this location for
analysis. Activity ranged from 1.56 pCi/mL to 18.00 pCi/mL.
Sample location 143 is located near the base of the South Drain, which discharges
into Rock Lick Creek. During 2015, 308 samples were collected from this location for
analysis. Activity ranged from -1.18 pCi/mL to 0.65 pCi/mL.
Sample location 144 is located at the base of the East Drain, which discharges into
No Name Branch. During 2015, 337 samples were collected from this location for
analysis. Activity ranged from 1.52 pCi/mL to 128.23 pCi/mL.
Maxey Flats Disposal Site
Annual Average Tritium Activity (pCi/mL)
2011-2015
\
Perennial Surface Water
Drainage Channels
Water
EDB
122A
106
122C
103E
102D
C107
143
144
2011
0.38
0.06
3.21
0.91
0.37
0.61
8.63
0.03
56.43
2012
0.72
0.05
3.88
1.19
0.51
0.82
12.96
0.06
67.85
2013
0.94
0.05
3.61
1.00
0.44
0.67
10.42
0.07
59.34
2014
0.59
0.07
3.80
1.12
0.43
0.80
11.01
0.06
46.01
2015
0.37
0.07
2.79
0.77
0.39
0.52
8.81
0.03
46.49
Figure 3-2
3.4 Sampling Equipment Status
A reliable ISCO sampler is in operation at each sampling location. Samplers perform
in accordance with the PSVP, except during events beyond control such as: freezing
lines, washouts, equipment failure, lack of flow, or power outages. In the spring of
2015, the sampler at 107C was damaged by a falling tree and replaced with the back
up unit. Multiple replacement units will be purchased at the completion of FCP.
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4.0 Groundwater Monitoring Wells
Groundwater monitoring at the MFDS is conducted at alluvial and perimeter
monitoring wells. The alluvial wells, located in the buffer zone, were installed during
the IRP to satisfy the requirements of the Statement of Work (SOW). The perimeter
monitoring wells located along the west perimeter fence of the restricted area were
installed as investigative monitoring points prior to the Consent Decree. The 16
perimeter wells are maintained for water level monitoring which satisfies an IMP
Work Plan requirement and sampled to satisfy the tritium monitoring requirements
in the RML. Multiple perimeter wells are scheduled for removal to accommodate
FCP construction requirements. Analytical results for all groundwater samples are
contained in Appendix A: 2015 MFDS Tritium Data.xlsx. Water level monitoring
tables for both alluvial and perimeter wells are contained in Appendix B: 2015 MFDS
Alluvial Well Levels and 2015 MFDS Perimeter Well Levels.xlsx.
4.1 Alluvial Wells
4.1.1 Tritium Evaluation 2015
Alluvial well (AW) samples were collected for analysis as outlined in the PSVP
and the 2007 EPA Five Year Review. Five wells were sampled in 2015:
annual samples were collected from AW-6,10, and 12, and quarterly samples
were collected from AW-1 and 7. Construction of Storm Water Management
Feature (SWMF) 3 necessitated the removal of AW-1 in February. During
2015, 7 alluvial well samples were collected for analysis. Results were typical
of historical ranges. The Commonwealth reports a lapse in AW-7 sample
collection for the third quarter, a result of overwhelming FCP demands,
specifically the slope failure in borrow area 4A.
The maximum activity at AW-7 was 6.36 pCi/mL. Comparison of this value to
50 percent of the 20 pCi/mL applicable or relevant and appropriate (ARAR)
requirement indicated that additional analysis was not necessary.
Access to the alluvium within the buffer zone is controlled by the
Commonwealth, therefore the alluvial wells are not considered a drinking
water source and do not represent a potential radiological dose to the public.
The county road extending through the buffer zone has been closed and a
gate was installed to further limit access.
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4.2 Perimeter Monitoring Wells
Water levels were measured in the 16 perimeter monitoring wells on a quarterly
basis. The 2015 measurements indicate water levels typical of historic data.
The RML required tritium analysis for the perimeter wells in 2015 were typical of
historical data and trends.
5.0 Data Management
A data package is prepared for each group of samples analyzed on site. The data
package contains the tritium instruments' QC charts (efficiency and background),
chain of custody forms, raw data sheets, and data reduction sheets. ATL, a radiation
service contractor, completes third party data validation for the MFDS. Following
data validation, the results are entered into the MFDS electronic database and
transmitted to EPA, United States Department of Energy (DOE), and multiple groups
within the Commonwealth. These packets are available on site for review.
6.0 Rainfall Data
Presently, there are three rain gauge locations associated with the MFDS: the East
Detention Basin (EDB), sampling location 102D, and the main office. The official
annual rainfall data for the MFDS is collected at the EDB rain gauge. Rainfall data
from the main office rain gauge can be used for official rainfall totals in the event of
an EDB rain gauge malfunction. The measured rainfall at the EDB gauge during 2015
was 50.34 inches. This is compared to an annual average precipitation of 47.33
inches (NOAA, National Climatic Data Center; Farmers, KY.). Annual precipitation
data appears in Appendix C: 2015 MFDS Daily Rainfall.xlsx.
7.0 Initial Remedial Phase Cap Maintenance
7.1 Geomembrane Liner and Boots
The liner covering the trench cap was inspected monthly. The comprehensive visual
and air lancing (annual) inspection was suspended for 2015 to accommodate FCP
activities. The integrity of the IRP was evaluated during the placement of leveling fill
and every effort was made to maintain that integrity.
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7.2 Headwall Maintenance
Headwall maintenance includes four headwails and associated items along the
North Channel, the northeast corner piping, geomembrane liner battens, and the
liquid collection system.
During this reporting period, debris and leaves were removed numerous times from
the trash grate and restricting plate at. the upstream headwall of the northeast
corner inlet pipe. FCP construction activities focused on the North Channel through
September 2015, including completion of leveling fill placement in this area.
7.3 Subsidence Monitoring and Repair
Subsidence inspections were conducted monthly in accordance with the O&M,
Section 3.3.3; Subsidence Monitoring. Areas near trenches 15, 21, 36, 37, and 46
were visually monitored monthly for subsidence qualification until these areas were
covered with leveling fill. The annual engineering subsidence survey of the IRP cap
has been suspended as a result of FCP.
7.4 Diversion Berms
The diversion berms were inspected twice a month as required by the O&M until
leveling fill was placed over them. All were found to be in satisfactory condition.
7.5 Anchor Trenches
The anchor trenches were inspected twice a month as required by the O&M until
leveling fill was placed over them. All anchor trenches functioned as designed.
7.6 Drainage Channels
All drainage channels were inspected during 2015 as required by the O&M until
leveling fill was placed over them. Unrestricted flow through the articulating block
mats and gabions was maintained using herbicides and/or manual removal of
vegetation.
7.7 Articulating Concrete Block Mat (AB Mat) System
The AB mat system was inspected monthly as required by the O&M until leveling fill
was placed over them.
7.8 Former Leachate Storage Facility Area
The former leachate storage facility (LFS) area was grouted in place during the Sump
Abandonment construction in 2014. The storage tank was used for the disposal of
the generated waste during construction. A complete list of disposed waste will be
available in the FCP Final Report.
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7.9 Inspections
A total of 95 inspections were performed in 2015. No unsatisfactory notations were
recorded that present a persistent problem. All unsatisfactory items either received
actions to return them to satisfactory status or were designated for monitoring.
7.10 Equipment Status
All liner repair equipment remains in good working condition.
8.0 Trench Leachate Management and Monitoring
Sump abandonment was completed by RECON in 2014. Trench leachate
management and monitoring is no longer performed. The sump abandonment final
report will be available upon certificate of completion of FCP.
9.0 Contaminated Liquid and Solid Waste
Contaminated liquid and waste generated on site will be disposed of in accordance
with the IMP Work Plan, Section 3.2: Treatment of Other Contaminated Liquids, and
Section 3.3: Waste Burial.
Solid and liquid waste generated from laboratory, radiological, and maintenance
activities is stored in a secured area in the on site Radiological Laboratory. All
radiological waste is transferred to 55 gallon drums and will accumulate until space
restrains require contracted, off site disposal. One 55 gallon drum was accumulated
during 2015.
The Annual Low Level Radioactive Waste Report is included in Appendix F: 2015
MFDS LLRW Report.pdf.
10.0 Erosion Monitoring
MFDS staff completed the annual evaluation of the East Main Drainage channel in
December of 2015. The monuments at cross section 3.5 were damaged during FCP
construction; this area was not surveyed for 2015. All other cross-sectional area data
was consistent with historical data. New monuments will be placed for all survey
points as part of FCP construction. A new erosion monitoring plan will be developed
at the conclusion of FCP.
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Curd Surveying & Land Consulting was contracted to complete erosion monitoring
and to produce a cross-sectional profile of the East Drain using IMP methodology.
This survey was conducted in May and November of 2015. The cross-sections and
tables for the 2011-2015 East Drain erosion measurements and the calculated areas
are presented in Appendix G: 2015 MFDS East Drain Erosion Shaw Monuments.pdf.
Seasonal visual erosion monitoring of the east, south, and west drainage channels
was completed in compliance with IMP Work Plan requirements. These inspections
revealed no erosion concerns.
11.0 IMP Work Plan Revisions, Changes, and Correspondence
Revisions and changes to the IMP Work Plan are required to be submitted in writing
to EPA for approval. No revisions were submitted in 2015.
12.0 Custodial Care Activities
12.1 Vegetation
All vegetation was maintained below required height limits to permit leachate
monitoring.
12.2 Building and Grounds Maintenance
All routine building and grounds maintenance was performed according to IMP
Work Plan requirements. The former tank storage/restricted area access building
surveyed for unrestricted use by ATL in 2014 has since undergone major renovation
for beneficial reuse. This building can now be used as a conference/meeting room,
interpretive center, or open house location.
12.3 Security Fence
The security fence surrounding the site has been dramatically changed. All of the
previous galvanized fencing was removed for cap construction. The office complex
fencing has been replaced with a more aesthetic aluminum fence. The restricted
area fence was removed and replaced with temporary rope and signage to facilitate
cap construction. Discussion regarding the restricted area fencing will ensue after
cap construction completion.
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12.4 Roadway Maintenance
Routine maintenance was performed on all facility-owned roadways. Upper Rock
Lick Road that traversed the buffer zone was removed from County maintenance.
The Commonwealth has assumed maintenance responsibilities and installed a gate
at the site boundary to restrict public access.
13.0 Cathodic Protection
The cathodic protection system installed on the 20,000 gallon Underground Storage
Tank (UST) within the restricted area was removed during sump abandonment
activities in 2014. No further annual evaluation of the cathodic system will be
performed.
14.0 Other Activities and Developments
The main purpose of this document is to summarize the requirements of the IMP
Work Plan. Other activities and developments in 2015 include:
• The Walker Company completely covered the existing cap with leveling fill
before demobilizing for the winter.
• The development of several landslides above Borrow Area 4 occurred in
September. Repairs were completed in 2015; but resurgence will require
continued monitoring.
15.0 Conclusion
This concludes the textual outlining of the IMP activities at the MFDS for 2015. If
copies of inspections or deliverables not included in this report are required, please
contact the MFDS office.
Maxey Flats Disposal Site 2015 Annual Report
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MAXEY FLATS DISPOSAL SITE
ANNUAL REPORT
2016
March 28, 2017
Energy and Environment Cabinet
Department for Environmental Protection
Division of Waste Management
Superfund Branch
Maxey Flats Disposal Site
2597 Maxey Flat Road
Hillsboro, KY 41049
606-783-8680
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Table of Contents
Page
List of Figures ii
List of Acronyms ii
List of Appendices iii
I.0 Introduction 1
2.0 Scope of Work 1
3.0 Surface Water Monitoring 1
3.1 East Detention Basin 2
3.2 Perennial Surface Water 2
3.3 Drainage Channels Water 3
3.4 Sampling Equipment Status 4
4.0 Groundwater Monitoring Wells 4
4.1 Alluvial Wells 4
4.2 Perimeter Monitoring Wells 5
5.0 Data Management 5
6.0 Rainfall Data 5
7.0 IMP Inspections 6
8.0 Contaminated Liquid and Solid Waste 6
9.0 Erosion Monitoring 6
10.0 IMP Work Plan Revisions, Changes, and Correspondence 7
II.0 Custodial Care Activities 7
11.1 Vegetation 7
11.2 Building and Grounds Maintenance 7
11.3 Security Fence 7
11.4 Roadway Maintenance 7
12.0 Other Activities and Developments 8
13.0 Conclusion 8
Maxey Flats Disposal Site 2016 Annual Report i
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Table of Contents
(Continued)
Page
List of Figures
Figure 3-1 MFDS Annual Average Tritium Concentrations (pCi/mL) 2011-2016 4
List of Acronyms
ARARs
Applicable or Relevant and Appropriate Requirements
ATL
Advanced Technologies and Laboratories
AW
Alluvial Wells
BoRP
Balance of Remedial Phase
Commonwealth
Commonwealth of Kentucky
DOE
U.S. Department of Energy
DCW
Drainage Channels Water
EDB
East Detention Basin
EPA
U.S. Environmental Protection Agency
FCP
Final Closure Period
ICP
Institutional Control Period
IRP
Initial Remedial Phase
IMP
Interim Maintenance Period
MFDS
Maxey Flats Disposal Site
O&M
Operation and Maintenance Requirement Summary
NOAA
National Oceanographic Atmospheric Administration
PSVP
Performance Standards Verification Plan
PSW
Perennial Surface Water
RECON
Remedial Construction Services, LP
REI
Reasonably maximally Exposed Individual
RML
Radioactive Material License
SOW
Statement of Work
SWMF
Stormwater Management Feature
TEDE
Total Effective Dose Equivalent
TWC
The Walker Company
USGS
U.S. Geological Survey
Maxey Flats Disposal Site 2016 Annual Report ii
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Table of Contents
(Continued)
List of eAppendices
Included electronically
Appendix A Maxey Flats Disposal Site Analytical Data 2016
2016 MFDS Tritium Data.xlsx
Appendix B Maxey Flats Disposal Site Well Levels 2016
2016 MFDS Alluvial Well Levels.xlsx
2016 MFDS Perimeter Well Levels.xlsx
Appendix C Maxey Flats Disposal Site Precipitation 2016
2016 MFDS Daily Rainfall.xlsx
Appendix D Maxey Flats Disposal Site Compliance Information 2016
2016 MFDS LLRW Report.pdf
2016-17 MFDS RML.pdf
Appendix E Maxey Flats Disposal Site Drainage Channel Erosion Monitoring 2016
2016 MFDS East Drain Erosion Shaw Monuments.pdf
Maxey Flats Disposal Site 2016 Annual Report
iii
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1.0 Introduction
The Commonwealth is submitting this annual report for the Maxey Flats Disposal
Site (MFDS) in accordance with Section 4.0 of the Performance Standards
Verification Plan (PSVP) (Appendix C of the Interim Maintenance Period (IMP) Work
Plan). This report summarizes the sampling and maintenance activities listed in the
2003 IMP Work Plan, PSVP, and the Operations and Maintenance (O&M)
Requirement Summary (Appendix D of the IMP Work Plan).
2.0 Scope of Work
The Final Closure Period (FCP) is ongoing pursuant to the Consent Decree (Civil
Action Number 95-58) signed by the United States Environmental Protection Agency
(EPA), the Settling Private Parties (represented by the Maxey Flats Steering
Committee), and the Commonwealth. The Maxey Flats Steering Committee
disbanded in September 2014 as the Settling Private Parties had fulfilled the
responsibilities defined in the Consent Decree. With the dissolution of the Maxey
Flats Steering Committee, the Balance of Remedial Phase (BoRP) became the full
responsibility of the Commonwealth. This includes tasks outlined in the IMP Work
Plan and FCP development as described in the Record of Decision (ROD). Relevant
IMP monitoring activities will continue until they are no longer applicable or
interfere with FCP remediation and will ultimately conclude upon the EPA's approval
of an Institutional Control Period (ICP) Work Plan, which is currently under
development.
The following IMP Work Plan obligations will continue through FCP until no longer
applicable:
• Surface water monitoring
• Groundwater monitoring
• Data management
• IMP inspections
• Contaminated liquid and solid waste handling
• Erosion monitoring
• Custodial care activities
The following IMP Work Plan obligations have been suspended:
• Initial Remedial Phase (IRP) cap maintenance
• Subsidence monitoring and surveying
3.0 Surface Water Monitoring
Tritium is the indicator isotope used to evaluate the spread of contamination at the
MFDS. No surface water annual average activity exceeded specified screening levels
for 2016. Tritium activity levels for all surface water samples appear in Appendix A:
2016 MFDS Tritium Data.xlsx
Maxey Flats Disposal Site 2016 Annual Report
Page 1 of 8
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3.1 East Detention Basin
A sequential sampler connected to a rain gauge is programmed to collect samples at
0.11 inches per hour rainfall rate, which is the divided hourly equivalent of a two-
year storm event (2.8 inches of rainfall in 24 hours). In 2016, 29 rain event samples
were collected for analysis; the activity ranged from -0.31 to 0.76 pCi/mL. Figure 3-1
provides the annual average for tritium concentrations for 2011-2016.
As a result of Final Cap construction, rainfall runoff is no longer channeled primarily
to the EDB. The resultant post-precipitation detention and discharge volume at the
EDB has been dramatically reduced. No pre-FCP storm event resulted in discharge
rates that exceeded predevelopment flow, therefore, IMP mandated two-year
storm event flow rate comparison calculations will no longer be performed for EDB
discharge.
The East Drain rain gauge recorded a two year storm event on August 2nd. A total of
3.17 inches of rain fell in a 24 hour period starting at 1 pm on August 1st. A
comparison of the discharge flow at the East Detention Basin (EDB) flume to the
predevelopment flow rate was not possible because the EDB flume was undergoing
demolition and renovation at the time the storm event occurred. The FCP
constructed EDB flume was designed with a discharge rate below that of the IMP
flume.
3.2 Perennial Surface Water
Perennial Surface Water (PSW) is monitored at five locations in three streams
influenced by surface water runoff from the MFDS. These locations are monitored
using sequential samplers that collect a four aliquot daily composite. The PSW
samples are compared to an action level of 20 pCi/mL and a screening level of 10
pCi/mL. During 2016, 1,718 PSW samples were collected for analysis with no
anomalous data reported. All PSW location averages were below the screening level
of 10 pCi/mL. Figure 3-1 provides the IMP Annual Average Tritium Activity for 2011-
2016.
Sample location 122A serves as the source for background samples. It is located on
Rock Lick Creek, free from site influence. During 2016, 349 samples were collected
at this location for analysis. The activity ranged from -0.47 to 0.72 pCi/mL.
Sample location 106 is located on No Name Branch, a tributary of Rock Lick Creek.
Location 106 receives runoff from Drain 144 and exhibits seasonal activity
fluctuation consistent with location 144. During 2016, 300 samples were collected
from this location for analysis. The activity ranged from 0.29 to 12.30 pCi/mL.
Sample location 122C is located on Rock Lick Creek, downstream of locations 106
and 143. During 2016, 350 samples were collected from this location for analysis.
The activity ranged from -0.20 to 2.00 pCi/mL.
Maxey Flats Disposal Site 2016 Annual Report
Page 2 of 8
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Sample location 103E is located on Drip Springs Creek downstream of Drain 107.
During 2016, 359 samples were collected from this location for analysis. The activity
ranged from -0.18 to 2.81 pCi/mL.
Sample location 102D is the only sampling station outside the established buffer
zone at the MFDS. It is located downstream of all surface water runoff from the
MFDS and is the designated EPA compliance point. During 2016, 360 samples were
collected from this location for analysis. The activity ranged from -0.35 to 1.50
pCi/mL. The 2016 annual average at 102D was 0.39 pCi/ml. In accordance with the
IMP Work Plan, the Reasonably maximally Exposed Individual (REI) comparison
indicated that the annual average did not exceed the 4 mrem/year dose limit
(equivalent to 20 pCi/mL).
3.3 Drainage Channel Water
Drainage Channel Water (DCW) is monitored at the west, south, and east drains that
receive intermittent flow from the FCP cap. These locations are monitored using
automated samplers that collect a four aliquot daily composite. The activity at these
monitoring locations is compared to a 25 mrem/year Total Effective Dose Equivalent
(TEDE) standard, an annual average action level of 100 pCi/mL, and an additional
screening level of 50 pCi/mL. In 2016, 825 samples were collected at the DCW
locations for analysis. No location exceeded the 50 pCi/mL screening level. No
additional investigation was required. Figure 3-1 provides the IMP Annual Average
Tritium Concentrations for 2011-2016.
Sample location C107 is located at the base of the West Drain, which discharges into
Drip Springs Creek. During 2016, 219 samples were collected from this location for
analysis. Activity ranged from 0.37 pCi/mL to 44.28 pCi/mL.
Sample location 143 is located near the base of the South Drain, which discharges
into Rock Lick Creek. During 2016, 277 samples were collected from this location for
analysis. Activity ranged from -0.38 pCi/mL to 4.29 pCi/mL.
Sample location 144 is located at the base of the East Drain, which discharges into
No Name Branch. During 2016, 329 samples were collected from this location for
analysis. Activity ranged from 0.29 pCi/mL to 163.08 pCi/mL.
Maxey Flats Disposal Site 2016 Annual Report
Page 3 of 8
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Maxey Flats Disposal Site
Annual Average Tritium Activity (pCi/mL)
2011-2016
Perennial Surface Water
Drainage Channel
Water
EDB
122A
106
122C
103 E
102D
C107
143
144
2011
0.38
0.06
3.21
0.91
0.37
0.61
8.63
0.03
56.43
2012
0.72
0.05
3.88
1.19
0.51
0.82
12.96
0.06
67.85
2013
0.94
0.05
3.61
1.00
0.44
0.67
10.42
0.07
59.34
2014
0.59
0.07
3.80
1.12
0.43
0.80
11.01
0.06
46.01
2015
0.37
0.07
2.79
0.77
0.39
0.52
8.81
0.03
46.49
2016
0.18
-0.02
4.05
0.61
0.50
0.39
15.86
0.10
55.73
Figure 3-1
3.4 Sampling Equipment Status
A reliable ISCO sampler is in operation at each sampling location. Sampler
performance is in accordance with the PSVP, except during events beyond control
such as freezing lines, washouts, equipment failure, lack of flow, or power outages.
Replacement units and spares were purchased and received at the end of 2016.
These samplers will be installed in early 2017 according to a USEPA approved
Institutional Control Period (ICP) Field Sampling and Analysis Plan.
4.0 Groundwater Monitoring Wells
Groundwater monitoring at the MFDS is conducted via alluvial and perimeter
monitoring wells. The alluvial wells, located in the buffer zone, were installed during
the IRP to satisfy the requirements of the Statement of Work (SOW). The perimeter
monitoring wells located along the west perimeter of the restricted area were
installed as investigative monitoring points prior to the Consent Decree. The
perimeter wells are maintained for water level monitoring which satisfies an IMP
Work Plan requirement and sampled to satisfy the tritium monitoring requirements
in the RML. Analytical results for all groundwater samples are contained in
Appendix A: 2016 MFDS Tritium Data.xlsx. Water level monitoring tables for both
alluvial and perimeter wells are contained in Appendix B: 2016 MFDS Alluvial Well
Levels and 2016 MFDS Perimeter Well Levels.xlsx.
4.1 Alluvial Wells
Alluvial well (AW) samples were collected for analysis as outlined in the PSVP and
the 2007 EPA Five Year Review. Four wells were sampled in 2016. Annual samples
Maxey Flats Disposal Site 2016 Annual Report
Page 4 of 8
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were collected from AW-6, 10 and 12, and quarterly samples were collected from
AW-7, resulting in 7 alluvial well samples collected for analysis. Results were typical
of historical ranges. The maximum activity at AW-7 was 5.71 pCi/mL. Comparison
of this value to 50 percent of the 20 pCi/mL applicable or relevant and appropriate
(ARAR) requirement indicated additional analysis was not necessary.
Access to the alluvium within the buffer zone is controlled by the Commonwealth,
therefore the alluvial wells are not considered a drinking water source and do not
represent a potential radiological dose to the public. The county road extending
through the buffer zone is restricted from public use and a gate was installed to
further limit access.
4.2 Perimeter Monitoring Wells
Perimeter monitoring well water levels were measured and recorded in February
before FCP cap construction activities along the west side necessitated the closure of
12 of the 16 wells. Water levels were measured in the four remaining wells on a
quarterly basis and samples were collected for tritium analysis from N2B and UK-1
on a semi-annual basis, as required by the RML. Only three samples were collected
during 2016; N2B was dry during the 4th quarter sampling event. The tritium
analyses for the perimeter well locations in 2016 were typical of historical data and
seasonal trends.
5.0 Data Management
Data packages are prepared for all samples collected and analyzed at the MFDS.
Data packages contain the instrument quality control (QC) charts, chain of custody
forms, raw data sheets, and data reduction sheets. Advanced Technologies and
Laboratories (ATL), is contracted for third party data validation. Following
validation, data is entered into the MFDS electronic database and transmitted to
EPA, United States Department of Energy (DOE), and multiple groups within the
Commonwealth. These packets are available on site for review.
6.0 Rainfall Data
Presently, there are three rain gauge locations associated with the MFDS: the East
Detention Basin (EDB), sampling location 102D, and the main office. The official
annual rainfall data for the MFDS is collected at the EDB rain gauge. The main office
rain gauge can be used for official rainfall totals in the event of an EDB rain gauge
malfunction. The measured rainfall at the EDB gauge during 2016 was 41.14 inches.
This can be compared to the annual average precipitation of 47.33 inches (NOAA,
National Climatic Data Center; Farmers, KY). Annual precipitation data appears in
Appendix C: 2016 MFDS Daily Rainfall.xlsx.
Maxey Flats Disposal Site 2016 Annual Report
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7.0 IMP Inspections
There were 95 modified inspections performed in 2016 to the areas unaffected by
FCP construction.
8.0 Contaminated Liquid and Solid Waste
Contaminated liquid and waste generated on site will be disposed of in accordance
with the IMP Work Plan, Section 3.2: Treatment of Other Contaminated Liquids, and
Section 3.3: Waste Burial.
Solid and liquid waste generated from laboratory, radiological, and maintenance
activities is stored in a secured area in the on-site Radiological Laboratory. All
radiological waste is transferred to 55 gallon drums and will accumulate until space
restraints require contracted, off-site disposal. Approximately one 55 gallon drum of
accumulated waste was collected during 2016.
The Annual Low Level Radioactive Waste Report is included in Appendix D: 2016
MFDS LLRW Report.pdf.
9.0 Erosion Monitoring
Curd Surveying & Land Consulting was contracted to complete erosion monitoring
and produce a cross-sectional profile of the East Drain using IMP (Shaw)
methodology. The spring survey was not completed. The fall survey was completed
in December of 2016. The 2016 East Drain erosion measurements are presented in
Appendix E: 2016 MFDS East Drain Erosion Shaw Monuments.pdf.
The fall erosion screening conducted by the MFDS staff using the USGS methodology
was not performed in 2016. New erosion monuments and monitoring criteria for
the three drains receiving surface water flow from the Final Cap are being developed
for the ICP Work Plan.
Seasonal visual erosion monitoring of the east, south, and west drainage channels
was completed in compliance with IMP Work Plan requirements. These inspections
revealed no erosion concerns in the East and South Drains. The FCP construction
activities and the new storm water management functions of the cap have resulted
in notable erosion in the West Drain. This erosion data will be evaluated in the 2017
Five Year Review.
Following a 4.2 inch, 24 hour storm event or greater, the Commonwealth must
conduct visual inspections of east drainage channel and report findings. No 4.2 inch,
24 hour storm event inspections were performed in 2016.
Maxey Flats Disposal Site 2016 Annual Report
Page 6 of 8
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10.0 IMP Work Plan Revisions, Changes, and Correspondence
Revisions and changes to the IMP Work Plan are required to be submitted in writing
to EPA for approval. No revisions were submitted in 2016. The ICP Work Plan is
currently under joint development by AECOM and the Commonwealth.
11.0 Custodial Care Activities
11.1 Vegetation
All vegetation was maintained at required height limits in accordance with IMP Work
Plan requirements.
11.2 Building and Grounds Maintenance
All routine building and grounds maintenance was performed according to IMP
Work Plan requirements.
11.3 Security Fence
The temporary rope and signage for cap construction was replaced with six foot
aluminized chain link fencing in December. The office complex and disposal area are
now enclosed in the same fenced area with gates at the main entrance, West and
East sides and a cap access gate at the South. New signage was posted every 200
feet.
11.4 Roadway Maintenance
Tasks pertaining to routine road maintenance were minimized because of the cap
construction. The road around the disposal area was improved to asphalt and
concrete as part of the FCP cap perimeter drainage system. The entry road and
parking lot were also resurfaced after construction of the FCP cap was complete.
The Walker Company (TWC) built, improved, and maintained all roads in the buffer
zone for borrow hauling. All access roads in the buffer zone were graded and
graveled before TWC demobilized for the winter.
Maxey Flats Disposal Site 2016 Annual Report
Page 7 of 8
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12.0 Other Activities and Developments
The main purpose of this document is to summarize the requirements of the IMP
Work Plan being performed until the ICP Workplan is approved. Other activities and
developments in 2016 include:
• The Walker Company filed and achieved Substantial Completion in December
2016. A vegetative cover across the cap was established before the growing
season ended resulting in minimal erosion on the cap surface.
• The landslides above Borrow Area 4 are being monitored visually until a
comprehensive monitoring plan can be developed. Movement in the slide
area has slowed dramatically since the last repair.
13.0 Conclusion
This concludes the textual outlining of the IMP activities at the MFDS for 2016. If
copies of inspections or deliverables not included in this report are required, please
contact the MFDS office.
Maxey Flats Disposal Site 2016 Annual Report
Page 8 of 8
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APPENDIX M - DEED RESTRICTIONS
M-l
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182
DECLARATION OF RESTRICTIONS
THIS DECLARATION is made as 2003 by the Commonwealth of
Kentucky, for the use and benefit of the Department for Natural Resources and Environmental
Protection as provided in Executive Order 79-170 (Declarant).
WHEREAS, Declarant is the owner of real property located at 2597 Maxey Rats Road,
Hillsboro, (in Fleming County), Kentucky 41049 (the Property), more particularly described in
Deed Book 120, Page 274, of the Fleming County Clerk's Office as indicated in Exhibit A.
WHEREAS, this property Isa low-level nudear disposal site with a history of releases to
the environment, specifically the Maxey Flats site (site). The site is on the National Priority List
pursuant to the Comprehensive Environmental Response, Compensation and Liabflity Act of
1980.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (Civil Action Number 95-58). The site has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and Interim Maintenance Period Workplan at the site (a document which governs
Operations arid Maintenance activities, among other items), and the Commonwealth of
Kentucky is performing the actions required by the approved Workplan. However, tritium and
other radioactive isotopes remain onsite in amounts that could pose risks above the de
minimum levels for all exposure scenarios if the . Remedy were to fail. Any releases could
migrate to this property.
WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 Reflly Road, Frankfort
Kentucky 40801.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified in the Record of Decision, Declarant imposes the following restrictions:
1.) Definitions. (A) "Residential use" means arty use of the property related to a (I)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (ii)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner' means
the Declarant or any successor owner or owners.
2.) Restrictions Applicable to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Property are restricted as follows:
A. Groundwater. Groundwater at the Property shall not be used for drinking or
other domestic, agricultural or industrial purposes. Groundwater will only be used for sampling
and/or investigation purposes.
B. Except as necessary to protect human health, safety or the environment no
action shall be taken, allowed, suffered, or omitted on the Property if such action or omission is
reasonably likely to:
I. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human health or the environment; or
ii. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
This includes cutting or otherwise damaging trees on the sideslopes of the site.
C. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents.may access the property
with permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the site pursuant to a Community Relations Ran. However, such activity
shall be carried out under a Health and Safety Plan meeting Occupational Safety and Health Act
requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions Run With Land.
(A) Declarant shall not sell, transfer, lease, or convey this property, nor allow it to be
occupied by any person other than Commonwealth of Kentucky personnel (with exceptions as
stated in (2).C, above), until such time as Declarant and EPA enter into an agreement formally
executed by a legal instrument, which is agreed to by both parties.
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(B). Unless canceled, altered or amended under the provisions of paragraph 4 of this
Declaration, these restrictions are to run with the land and shall be binding on Declarant, his
successors, heirs and assigns unless an instrument signed by the Declarant and EPA has been
recorded, agreeing to change these restrictions in whole or in part
(C). Except as provide in paragraph 4 of this Declaration, the Declarant hereby
declares that the Property shall hereafter be held, transferred, sold, leased, conveyed and
occupied subject to the restrictions set forth herein, each and all of which Is and are for, and
shafl inure to the benefit of and pass with each and every part of the Property and shall apply to
and bind the heirs, assignees and successors in interest of the Declarant
4.) Release of Restriction. These restrictions may not be canceled, altered or
amended without the affirmative action of the Declarant and EPA, in an instrument executed by
both parties agreeing to change these restrictions in whole or in pat
5.) Effect of InvaBdation. Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shall in no way affect any of the other provisions, which
shall remain in full force and effect
Recommended:
Environmental Protection Cabinet
Examined:
Counsel to the Governor
Paul E. Patton, Governor
183
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MAXEY FLAT
DEED DESCRIPTION
Beginning at a set stone in. the southwest right of way line of KY 1895;
thence S 26°59'45"W, 744.25 feetto an iron pin in a fence post; thence
5 55c,48,12nE, 180.19 feet to an iron pin in a 14" black oak stump; thence
S 21°46'03"E, 128.61 feet to an iron pin in a 24" black oak stump; thence
S 09°12'09"E, 200.17 fieet to an iron pin; thence S 06°34'53"W, 115.91 feet
to an iron pin; thence S 13°27'16"E, 167.65 feet to an iron pin in a fence
comer; thence S 06°18'00"M, 132.39 feet to an iron pin in a 30" white oak
tree; thence S 20°38'34"W, 264.36 feet to an iron pin in a 6" white oak
tree; thence S 02°06'07DE, 352.95 feet to an iron pin in a 30" white oak
tree, said point also being a fence corner; thence S 85°00'49DE, 484.75 feet
to an Iron pin in a 15" maple tree; thence 5 33°23'31"W, 1167.05 feet to an
iron pin; thence S 28°57,56"E, 299.37 feet to an iron pin in an 18" black
oak tree; thence S 37022'57"W, 982.00 feet to an iron pin in a poplar and
dogwood tree; thence S 32°50'53"W, 1376.27 feet to an iron pin in a black
oak stump; thence N 88°49'24"E, 1395.07 feet to an iron pin; thence
5 79°41'0T,E, 221.80 feet to an iron pin; thence S 01 03'00"W, 1299.17 feet
to a point 1n the north right of viy line of KY 158; thence N 62°35'05"E,
1125.23 feet to a tack in a 40" white oak tree; thence-N 17°4V13"E, 497.63
feet to an Iron pin; thence S 76°4D'00"E, 594.01 feet to an iron pin;
thence N 28°23'50"E1 258.24 feet to an iron pin in a 12" white oak stump;
thence N 88°35'28"E, 567.87 feet to an iron pin in a white oak stimip; thence
N 06°30'40"E, 1102.81 feet to an iron pin in a 36" white oalt stump; thence
N 21°30'38"W, 548.72 feet to an iron pin in an 18" black oak stump; thence
N 39o04,07nW, 438.44 fieet to an iron pin in an 18" white oak tree; thence
N 39°01 '34nM, 511.22 feet to an iron pin; thence N 23°4V43"WJ 672.60 feet
to an iron pin in a 26" white oak stump; thence N 4{fl35'07uH, 31.31 feet
.to an iron .pin in existing fence; thence with the existing .fence N 07o27'50"H,
649.39 feet to an iron pin in a fence post; thence N 32°07,04"E, 135.03 feet
to an iron pin in a fence post, said point also being in the southwest
right of way line of KY 1895; thence with said right of way line N 47°18,24"W,
174.61 feet, N 47°09'36,,H, 207.76 feet, N 45°20'29,,W. 182.89 feet,
N 41o10'lQ"W, 194.06 feet, N 37°I4,20"W. 210.19 feet, N 34°08,09"W. 185.87 -
feet, N 31°26,48"W, 139.44 feet, N 29°46'23nW, 185.78 feet, N 33°09'33"U,
228.48 feet; N 37°40'06"W, 198.12 feet, N 43°23'04',W, 310.64 feet,
N 53°33'47"W, 120.97 feet to the point of beginning, containing 278.94 acres.
DOCUMENT# J rffi L^:
STO* OF KENTUCKY)
OWYOFRailNG)
/•••: HV
I 1
L
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ECEIVE
JUL 0 2 2012
DECLARATION OF RESTRICTIONS
THIS DECLARATION is made as 2005 by the Commonwealth of
Kentucky, for the use and benefit of the Department for Natural Resources and Environmental
Protection as provided in Executive Order 79-170 (Declarant).
WHEREAS, Declarant is the owner of real property located at 2597 Maxey Flats Road,
Hillsboro, (in Fleming County), Kentucky 41049 (the Property), more particularly described in
Deed Book 148, Page 65, of the Fleming County Clerk's Office as indicated in Exhibit A.
WHEREAS, this property js_a low-level nuclear disposal site with a history of releases to
the environment, specifically the Maxey Flats site (site). The site is on the National Priority List
pursuant to the Comprehensive Environmental Response, Compensation and Liability Act of
1980.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (Civil Action Number 95-58). The site has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and Interim Maintenance Period Workpian at the site (a document which governs
Operations and Maintenance activities, among other items), and the Commonwealth of
Kentucky is performing the actions required by the approved Workplan. However, tritium and
other radioactive isotopes remain onsite in amounts that could pose risks above the de
minimum levels for all exposure scenarios if the Remedy were to faiL Any releases could
migrate to this property.
WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 ReQIy Road, Frankfort,
Kentucky 40601.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified in the Record of Decision, Declarant imposes the following restrictions:
1.) Definitions. (A) "Residential use" means any use of the property related to a (i)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (n)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner" means
the Declarant or any successor owner or owners.
2.) Restrictions Applicable to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Property are restricted as follows:
A. Groundwater. Groundwater at the Property shall not be used for drinking or
other domestic, agricultural or industrial purposes. Groundwater will only be used for sampling
and/or investigation purposes.
B. Except as necessary to protect human health, safety or the environment, no
action shall be taken, allowed, suffered, or omitted on the Property if such action or omission is
reasonably likely to:
i. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human health or the environment; or
li. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
This includes cutting or otherwise damaging tress on the sideslopes of the site.
C. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents.may access the property
with permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the site pursuant to a Community Relations Plan. However, such activity
shall be carried out under a Health and Safety Plan meeting Occupational Safety and Health Act
requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions Run With Land.
(A) Declarant shall not sell, transfer, lease, or convey this property, nor allow it to be
occupied by any person other than Commonwealth of Kentucky personnel (with exceptions as
stated in (2).C, above), until such time as Declarant and EPA enter into an agreement formally
executed by a legal instrument, which is agreed to by both parties.
-------
(B). Unless canceled, altered or amended under the provisions of paragraph 4 of this
Declaration, these restrictions are to run with the land and shall be binding on Declarant, his
successors, heirs and assigns unless an instrument signed by the Declarant and EPA has been
recorded, agreeing to change these restrictions in whole or in part
(C). Except as provide in paragraph 4 of this Declaration, the Declarant hereby
declares that the Property shall hereafter be held, transferred, sold, leased, conveyed and
occupied subject to this restrictions set forth herein, each and all of which is and are for, and
shall Inure to the benefit of and pass with each and every part of the Property and shall apply to
and bind the heirs, assignees and successors in interest of the Declarant.
4.) Release of Restriction. These restrictions may not be canceled, altered or
amended without the affirmative action of the Declarant and EPA, in an instrument executed by
both parties agreeing to change these restrictions bi whole or in part
5.) Effect of Invalidation. Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shall in no way affect any of the other provisions, which
shall remain in full force and effect
Recommended:
Natural Rasoijfces and
Environmental Protection Cabinet
Gary Bale, General Counsel Gordon C. Dulie, Secretary
Rnanca and Administration Cabinet Finance and Administration Cabinet
Examined:
*p A
Counsel to the Governor raw t. ration, governor
189
-------
190
BttaiitnirrB at the fence post by the County road
on the boundary between W. G. Cox and Sterl
Cox; thence S 34 deg. 14 minutes W 129.9 feet
to a fence post; thence S 9 degrees 47 minutes
E 680.6 feet to an 18 inch.white oak; thence
W 45 degrees 33 min-utes W 2288.0 feet; thence
N 27 degrees 18 minutes E 800.0 feet to county
road; thence 5 36 degrees 31 minutes E 400.0
feet; thence S 31 degrees 30 minutes E
feet; thence S 37 degrees 35 minutes E 506.0
feet; thence 5 46 degrees 18 minutes E 601.9
foot tn the beginning, containing 27.586 acres.
document#J3SS1
nATF.-X - «=>-OM TTVfE: H'-M ^
DEED TAX
MARI LYN SPENCER, FLEMING CO CLERK
rTP&mStkc PC
BOOICJDai3—PAGEJ25
STATHCFiaiTUa
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170
DECLARATION QF RESTRICTIONS
THIS DECLARATION is made as of/jsaeeeMaSu 2005 by the Commonwealth of
Kentucky, for the use and benefit of the Natural Resources and Environmental Protection
Cabinet (Declarant).
WHEREAS, Declarant is the owner of real property located at Rock Lick Road, in
Fleming County. Kentucky (the Property), more particularly described in Deed Book 181, Page
548. of the Fleming County Cterit's Office as indicated in Exhibit A.
WHEREAS, this property is adjacent to (and serves as a "buffer zone" for) a low-level
nuclear disposal site with a history of releases to the environment specifically the Maxey Flats
sits (site). The site is on the National Priority List pursuant to the Comprehensive
Environmental Response, Compensation and Liability Act of 1980.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (Civil Action Number 95-58). The site has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and Interim Maintenance Period Workplan at the site (a document which governs
Operations and Maintenance activities, among other items), and the Commonwealth of
Kentucky is performing the actions required by the approved Workplan. However, tritium and
other radioactive isotopes remain onsite in amounts that could pose risks above the de
minimum levels for all exposure scenarios if the Remedy were to fail. Any releases could
migrate to this property.
WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 ReDty Road, Frankfort,
Kentucky 40601.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified in the Record of Dedsion, Declarant impose the following restrictions:
1.) Definitions. (A) "Residential use" means any use of the property related to a (i)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (ii)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner* means
the Declarant or any successor owner or owners.
. 2.) Restrictions Applicable to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Properly are restricted as follows:
A. Groundwater. Groundwater at the Property shall not be used for drinking or
other domestic, agricultural or Industrial purposes. Groundwater will only be used for sampling
and/or investigation purposes.
B. Except as necessary to protect human health, safety or the environment no
action shall be taken, allowed, suffered, or omitted on the Property if such action or omission is
reasonably likely to:
i. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human health or the environment; or
ii. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
This includes cutting or otherwise damaging trees on the sideslopes of the site.
C.. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents may access the property
with permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the property pursuant to a Community Relations Plan. However, such
activity shall be carried out under a Health and Safety Plan meeting Occupational Safety and
Health Act requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions With I anrl
(A) Declarant shall not sell, transfer, lease, or convey this property, nor allow it to be
occupied by any person other than Commonwealth of Kentucky personnel and agents (with
exceptions as stated in (2).C, above), until such time as Declarant and EPA enter into an
agreement formally executed by a legal instrument which Is agreed to by both parties.
-------
(B). Unless canceled, altered or amended under the provisions of paragraph 4 of this
Declaration, these restrictions are to run with the land and shall be binding on Declarant, his
successors, heirs and assigns unless an instrument signed by the Declarant and EPA has been
recorded, agreeing to change these restrictions in whole or in pait.
(C). Except as provide in paragraph 4 of this Declaration, the Declarant hereby
declares that the Property shall hereafter be held, transferred, sold, leased, conveyed and
occupied subject to the restrictions set forth herein, each and ail of which is and are for, and
shall inure to the benefit of and pass with each and every part of the Property and shall apply to
end bind the heirs, assignees and successors in interest of the Declarant
4.) RcImm nf Pggftfction. These restrictions may not be canceled, altered or
amended without the affirmative action of the Declarant and EPA, in an instrument executed by
both parties agreeing to change these restrictions in whole or In part.
5.) Effect of Invalidation. Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shall In no way affect any of the other provisions, which
shall remain in full force and effect
IN WITNESS WHEREOF, Declarant has executed this Declaration of Restrictions as of the date
set forth above.
Recommended:
Environmental Protection Cabinet
Counsel to the Governor
Paul E. Patton, Governor
171
-------
172
TRACT NO. I. A certain tract or parcel of land lying in Fleming County,
Kentucky, on the waters of Rocklick, bounded as follows: BEGINNING at a
stone; thence N 78 E 122 poles, F.obinsor. comer; thence N 69 E 125 poles to a
black oak S 30 W 125 poles to a white oak; thence with an agreed straight line
to the beginning, containing 100 acres, more or less. This land is sold by the
boundary and not by the acre.
TRACT NO. II.: A certain tract or parcel of land lying in Fleming County,
Kentucky, on the waters of Rock Lick Creek and described by boundary in the
absence of a general survey. Bounded on the North by the lands of R.Y. Hutton,
on the East by tht lands of W.G. Cox, on the South by the lands of Russell
McLain, and on the West by the lands of Bert Johnson, and containing 75 acres,
: more or less, be whBt it may.
TRACT NO. III.: A certain tract or parcel of land lying and being in Fleming
County, Kentucky, and bounded and described as follows: On the waters of Rock
Lick Creek, bounded on the North by the lands of R.M. Bowalin and Thomas L.
McClain; on the East by the lands of A.T. Denton Heirs; on the South by the
lands of A.T. Denton Heirs and on the West by the lands of R.M. Bowalin,
containing 25 acres, more or less.
This being the same property conveyed to the Grantors by C.L. Armstrong and Freda
Armstrong, his wife; Paul J. Reynolds and Mable C. Reynolds, his wife; and Homer
Gregory and Ada Gregory, his wife by Deed dated June 30, 1972 and recorded in
Deed Book 134, Page 255, in the Office of the Fleming County Clerk.
DEED TAX
XERK
: _ . DC
book page no
state Of KBITUCXY)
COUNTY OF aaarej
DEPUTY CLERK
-------
DECLARATION OF RESTRICTIONS
THIS DECLARATION is made as of 2003 by the Commonwealth of
Kentucky, for the use and benefit of the Natural Resources and Environmental Protection
Cabinet (Declarant).
WHEREAS, Declarant is the owner of real property located at Rock Lit* Road, in
Fleming County, Kentucky (the Property), more particularly described In Deed Book 182, Page
-nsa. of the Fleming County Clerk's Office as indicated m Exhibit A.
WHEREAS, this property is adjacent to (and serves as a "buffer zone" for) a low-tevel
nuclear rffrpngai site with a history of releases in 9ie environment, specifically the Maxey Flats
site (site). The site is on the National Priority List pursuant to the Comprehensive
Environmental Response, Compensation and Liability Act of 1980.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (Civil Action Number 95-58). The site has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and Interim Maintenance Period Workplan at the site (a document which governs
Operations and Maintenance activities, among other items), and (he Commonwealth of
Kentucky is performing the actions required by the approved Workplan. However, tritium and
other radioactive isotopes remain onsite in amounts that could pose risks above the de
minimum levels for all exposure scenarios if the Remedy were to fail. Any releases could
migrate to this property.
WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 Rflilly Road, Frankfort,
Kentucky 40601.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified hi the Record of Decision, Declarant imposes the following restrictions:
1.) Definitions. (A) "Residential use" means any use of the property related to a (i)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (ii)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner" means
the Declarant or any successor owner or owners.
2.) PattrirKnns Applicable to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Property are restricted as follows:
A. Groundwater. Groundwater at the Property shall not be used for drinking or
other domestic, agricultural or industrial purposes. Groundwater will only be used for sampling
and/or investigation purposes.
B. Except as necessary to protect human health, safety or the environment, no
action shad be taken, allowed, suffered, or omitted on the Property if such action or omission is
reasonably likely to:
i. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human health or the environment; or
ii. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
Thls.indudes cutting or otherwise damaging trees on the sldeslopes of the site.
C. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents may access the property
wtth permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the property pursuant to a Community Relations Plan. However, such
activity shall be carried out under a Health and Safety Plan meeting Occupational Safety and
Health Act requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions Run With Land.
(A) Declarant shall not sell, transfer, lease, or convey this property, nor allow it to be
occupied by any person other than Commonwealth of Kentucky personnel and agents (with
exceptions as stated in (2).C, above), until such time as Declarant and EPA enter into an
agreement formally executed by a legal instrument which is agreed to by both parties.
173
-------
174
(B). Unless canceled, altered or amended under the provisions of paragraph 4 of this
Declaration, these restrictions are to run with the land and shall be binding on Dedarant, his
successors, heirs and assigns unless an Instrument signed by the Declarant and EPA has been
recorded, agreeing to change these restrictions in whole or in part
(C). Except as provide In paragraph 4 of this Declaration, the Declarant hereby
declares that the Property shall hereafter be held, transferred, sold, leased, conveyed and
occupied subject to the restrictions set forth herein, each end ail of which is and are for, and
shall inwe to the benefit of and pass with each and every part of the Property and shall apply to
and bind the heirs, assignees and successors in interest of the Declarant
4.) Release of Restriction. These restrictions may not be canceled, altered or
amended without the affirmative action of the Dedarant and EPA, in an instrument executed by
both parties agreeing to change these restrictions in whole or in part
5.) Effect of Invalidation. Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shall in no way affect any of Hie other previsions, which
shall remain in full force and effect
IN WITNESS WHEREOF, Dedarant has executed this Declaration of Restrictions as of the date
set forth above.
Recommended:
Environmental Protection Cabinet
Examined: Approved:
Counsel to the Governor
Examined:
Paul E. Patton, Governor
/
-------
BEGINNING at a point career to Rock Lick Road and the land of
Johnson at an iron stake 150 fcet E. to an iron stake; thence 292 fecit S 1to a state
tbeiice at a right angle 150 feet W. to a stake; thence a right angle 292 Feet N. to
the stake at the beginning, containing 1 acre, more or less.
Being the same property conveyed Marcus Ball, married, by Deed from GienM
Ball (now Rawlings) and Roland Rawlings, her husband, dated August 28. 1983,
and recorded in Deed Book 16Q, Page 506 in the Fleming County Clerk's Office.
document#
DATE: \ -.^q. 7TMF- ^
DEED TAX
STATE OF KfiWCXr |
rawvoFHaiaiBj
tJ/WIDDRj
THEfDI©ami^i^^J>^SQWJNiy00HBay(SrnFy
00^crc^fc-2^'w
no* CbM.-><^3t*v"
¦— -— ' * —3*3-Ofcrt/rvciBK
v*0.
175
-------
176
DECLARATION OF RESTRICTIONS
THIS DECLARATION is made as of by the Commonwealth of
Kentucky, for the use and benefit of the Natural Resources and Environmental Protection
Cabinet (Dedarant).
WHEREAS, Dedarant is the owner of real property located at Rock Lick Road, in
Fleming County, Kentucky (the Property), more particularly described in Deed Book 182, Page
178, of the Reming County Clerk's Office as indicated in Exhibit A.
WHEREAS, this property is adjacent to (and serves as a "buffer zone" for) a low-level
nuclear disposal site with a history of releases to the environment, specifically the Maxey Rats
site (site). The site is on the National Priority List pursuant to the Comprehensive
Environmental Response, Compensation and Liability Act of 1980.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (Civil Action Number 95-58). The site has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and Interim Maintenance Period Workplan at the site (a document which governs
Operations and Maintenance activities, among other items), and the Commonwealth of
Kentucky is performing the actions required by the approved Workplan. However, tritium and
other radioactive isotopes remain, onsite in amounts that could pose risks above the de
minimum levels for all exposure scenarios if the Remedy were to foil. Any releases could
migrate to this property.
WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 Reiily Road, Frankfort,
Kentucky 40601.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified in the Record of Decision, Declarant imposes the following restrictions:
1.) Definitions. (A) "Residential use" means any use of the property related to a (i)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (ii)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner" means
the Dedarant or any successor owner or owners.
2.) Restrictions Applicable to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Property are restricted as follows:
A. Groundwater. Groundwater at the Property shall not be used for drinking or
other domestic, agricultural or industrial purposes. Groundwater will only be used for sampling
and/or investigation purposes.
B. Except as necessary to protect human health, safety or the environment, no
action shall be taken, allowed, suffered, or omitted on the Property if Such action or omission is
reasonably likely to:
i. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human health or the environment; or
ii. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
This includes cutting or otherwise damaging trees on the sideslopes of the site.
C. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents may access the property
with permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the property pursuant to a Community Relations Plan. However, such
activity shall be carried out under a Health and Safety Plan meeting Occupational Safety and
Health Act requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions Run WHh Land.
(A) Dedarant shall not sett, transfer, lease, or convey this property, nor allow It to be
occupied by any person other than Commonwealth of Kentucky personnel and agents (with
exceptions as stated in (2).C, above), until such time as Declarant and EPA enter into an
agreement formally executed by a legal instrument, which is agreed to by both parties.
(
-------
(B). Unless canceled, altered or amended under the provisions of paragraph 4 of this
Declaration, these restrictions are to run with the land and shall be binding on Declarant, his
successors, heirs and assigns unless an Instrument signed by the Dedarant and EPA has been
recorded, agreeing to change these restrictions in whole or in part
(C). Except as provide in paragraph 4 of this Declaration, the Dedarant hereby
declares that the Property shall hereafter be held, transferred, sold, leased, conveyed and
occupied subject to the restrictions set forth herein, each and all of which is and are for, and
shall inure to the benefit of and pass with each and every part of the Property and shall apply to
and bind the heirs, assignees and successors in interest of the Declarant
4.) Release of p^strinton. These restrictions may not be canceled, altered or
amended without the affirmative action of the Declarant and EPA, in an instrument executed by
both parties agreeing to change these restrictions in whole or in part.
5.) Effect of Invalidation Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shall in no way affect any of the other provisions, which
shall remain in full force and effect
IN WITNESS WHEREOF, Declarant has executed this Declaration of Restrictions as of the date
set forth above.
Recommended:
Natural Resources and
Environmental Protection Cabinet
177
-------
178
"Exhibit
deed description
PARCEL 37B
A certain tract or parcel of land located in Flemming County,
Kentucky, on the waters of Rock Lick Creek, situated along
Rock Lick Road, 1 mile east of KY 158 and being more
particularly described as follows:
Beginning at a PK Hail in the center of Rock Lick Road,
corner to Willie Skaggs, thence with Rock Lick Road and
Willie Skaggs; :
South BO*59'06" West 16.05 feet to a Mail & Cap, thence;
South 83*35'13n West 61.12 feet to a Nail & Cap, thence;
South 85"16'31™ West 63.59 feet to a Nail t Cap, thence;
South 86*16'09" West 75.92 feet to a Nail 6 Cap, thence;
South 89*55'51" West 62.13 feet to a PK Nail,, corner to John.
Viae, thence leaving Rock Lick Road with John Vise;
. North 06" 16'54™ West 16.33 feet tb an Iron Pin, thence;
North 34*30'09n East 397.96 feet to an Iron Pin at' a 48"
Beech, corner to Willie Skaggs, thence with Willie Skaggs;
South 09 *28/32" East 308.00 feet to an 8" Oak, thence;
South 09 *34 '41° East 21.10 feet to a the beginning.
Parcel 37B contains 1.12± Acres and is the same property as
conveyed to Wendell . McCarty from Willie Skaggs, by deed,
dated February 1990, as recorded in Deed Book 171, Page 765,
in the Flemming County Clerk's Office.
-This description prepared by Palmer Engineering from a survey
.performed Warch 1995.
D0CUMENT#_l3Sy3__
nATF. \ -cS-g><4 TIME: ^TD
DEED TAX.
Vf
STATE Or KENTUCKY)
coufmrof aataiG)
UKE15SME
lQEpurvn CP*
-------
DECLARATION OF RESTRICTIONS
THIS DECLARATION is made as 2003 by the Commonwealth of
Kentucky, for the use and benefit of the Natural Resources and Environmental Protection
Cabinet (Declarant).
WHEREAS, Declarant is the owner of real property located at Rock Uck Road, in
Fleming County. Kentucky (the Property), more particularly described in Deed Book 189, Page
501. of the Fleming County Clerk's Office as indicated in Exhibit A
WHEREAS, this property is adjacent to (and serves as a "buffer zone" for) a low-level
nuclear disposal site with a history of releases to the environment, specifically the Maxey Fists
site (site), "me site is on the National Priority List pursuant to the Comprehensive
Environmental Response, Compensation and Liability Act of 1980.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (C/vfl Action Number 95-58). The sfle has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and Interim Maintenance Period Workplan at the site (a document which governs
Operations and Maintenance activities, among other items), and the Commonwealth of
Kentucky is performing the actions required by the approved Worfcplan. However, tritium and
other radioactive isotopes remain onsHs in amounts that could pose risks above the de
minimum levels for all exposure scenarios if the Remedy were to fail. Any releases could
migrate to this property.
' WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 Reiliy Road, Frankfort
Kentucky 40601.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified in the Record of Decision, Declarant imposes the following restrictions:
1.) • Definitions. (A) "Residential use" means any use of the property related to a (i)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (D)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner" means
the Declarant or any successor owner or owners.
2.) Restrictions Applicable to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Property are restricted as foliows:
A. Groundwater. Groundwater at the Property shall not be used for drinking or
other domestic, agricultural or industrial purposes. Groundwater will only be used tar sampling
and/or investigation purposes.
B. Except as necessary to protect human health, safety or the environment, no
action shall be taken, allowed, suffered, or omitted on the Property if such action or omission is
reasonably likely to:
i. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human heafth or the environment; or
ii. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
This includes cutting or otherwise damaging trees on the sldestopes of the site.
C. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents may access the property
with permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the property pursuant to a Community Relations Plan. However, such
activity shall be carried out under a Health and Safety Plan meeting Occupational Safety and
Health Act requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions Run wan i nnH
(A) Declarant shall not sell, transfer, lease, or convey this property, nor allow it to be
occupied by any person other than Commonwealth of Kentucky personnel and. agents (with
exceptions as stated in (2).C, above), until such time as Declarant and EPA enter into an
agreement formally executed by a legal instrument which is agreed to by both parties.
179
-------
•180
v —1
(B). Unless canceled, altered or amended under the provisions of paragraph 4 of this
Declaration, these restrictions are to nin with the land and shall be binding on Dedarant, his
successors, heirs and assigns unless an instrument signed by the Dedarant and EPA has been
recorded, agreeing to change these restrictions In whole or in part
(C). Except as provide in paragraph 4 of this Declaration, the Dedarant hereby
declares that the Property shall hereafter be held, transferred, sold, leased, conveyed and
occupied subject to the restrictions set forth herein, each and all of which is and are for, and
shall inure to the benefit of and pass with each and every part of the Properly and shad apply to
and bind the heirs, assignees and successors'm interest of the Declarant
4.) Release of Restriction. These restrictions may not be canceled, altered or
amended without the affirmative action of the Declarant and EPA, in an Instrument executed by
both parties agreeing to change these restrictions in whole or in part
5.) Effect of Invalidation. Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shall in no way affect any of the other provisions, which
shall remain in full force and effect
IN WITNESS WHEREOF, Declarant has executed this Declaration of Restrictions as of the date
set forth above.
Recommended:
Natural Ffesoun£s and
Environmental Protection Cabinet
Examined:
G«y Bale, Genera KCounsel
Finance and Administration Cabinet
Examined:
Ai jtUU -r. A
Counsel to the Governor
Approved:
Gordon C. Dtike, Secretary
Finance ana Administration Cabinet
Paul E. Patton, Governor
-------
A certain parcel fronting on the Old County Road, (fbnnwly known as the King
Road), leading off the Upper Rock Lick Road, in Fleming County. Kentucky and
BEGINNING at a point in the center of the old County Road; theacc in a general
-Westerly direction J57 feet: thcncc is a general Northerly direction 186 feet thence
in a general Easterly direction 121 feet, thence in a general Southerly direction 139
feet to the jjoint of beginning.
This being the same property conveyed to the Grantors by Rufus McRoberts and
Helen McRoberts, his wife, by Deed dated January 6. 1973 and recorded in Deed
Book 138. Page 586,10 the Office of the Fleming County Clerk.
document#. -
DATE;\^o3_3^^
rvcCT* T A Y
BOOK_SiaJ3—page__L3£l
STATE OF KENTUCKY)
COUNTY OF FUMNei
-MAHODA FRITZ CLS1K
ntrnivriim
181
-------
DECLARATION OF RESTRICTIONS
THIS DECLARATION is made as of20t>£ by the Commonwealth of
Kentucky, for the use and benefit of the Natural Resources and Environmental Protection
Cabinet (Declarant).
WHEREAS. Declarant Is the owner of real property located at Rock Uck Road, in
Fleming County. Kentucky (the Property), more particularly described in Deed Book 182, Page
173, of the Fleming County Clerk's Office as Indicated in Exhibit A.
WHEREAS, this property, is adjacent to (and serves as a "buffer zone" for) a low-level
nuclear disposal site with a history of releases to the environment, specifically the Maxey Flats
site (site). The site is on the National Priority Ust pursuant to the Comprehensive
Environmental Response, Compensation and Liability Act of 1980.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (Civil Action Number 95-58). The site has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and Interim Maintenance Period Workpian at the site (a document which governs
Operations and Maintenance activities, among other items), and the Commonwealth of
Kentucky is performing the actions required by the approved Workpian. However, tritium and
other radioactive isotopes remain onsite in amounts that could pose risks above the de
minimum levels for all exposure scenarios if the Remedy were to fail. Any releases could
migrate to this property.
WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 Reilly Road, Frankfort
Kentucky 40601.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified in the Record of Decision, Declarant imposes the following restrictions:
1.) Definitions. (A) "Residential use' means any use of the property related to a (i)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (ii)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner" means
the Declarant or any successor owner or owners.
2.) Restrictions Applicable to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Property are restricted as follows:
A Groundwater. Groundwater at the Property shall not be used for drinking ot
other domestic, agricultural or industrial purposes. Groundwater will only be used for sampling
and/or Investigation purposes.
B. Except as necessary to protect human health, safety or the environment, no
action shall be taken, allowed, suffered, or omitted on the Properly if such action or omission is
reasonably likely to:
i. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human health or the environment; or
ii. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
This includes cutting or otherwise damaging trees on the sideslopes of the 6ite.
C. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents may access the property
with permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the property pursuant to a Community Relations Plan. However, such
activity shall be canted out under a Health and Safety Plan meeting Occupational Safety and
Health Act requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions Run With Land.
(A) Declarant shall not sell, transfer, tease, or convey this property, nor allow it to be
occupied by any person other than Commonwealth of Kentucky personnel and agents (with
exceptions as stated in (2).C, above), until such time as Declarant and EPA enter into an
agreement formally executed by a legal instrument, which is agreed to by both parties.
185
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136
(B). Unless canceled, altered or amended under the provisions of paragraph 4 of this
Declaration, these restrictions are to run with the land and shall be binding on Declarant, his
successors, heirs and assigns unless an instrument signed by the Declarant and EPA has been
recorded, agreeing to change these restrictions in whole or in part
(C). Except as provide in paragraph 4 of this Declaration, the Declarant hereby
declares that the Property shall hereafter be held, transferred, sold, teased, conveyed and
occupied subject to the restrictions set forth herein, each and all of which is and are for, and
shall inure to the benefit of and pass with each and every part of the Property and shall apply to
and bind the heirs, assignees and successors in interest of the Declarant
4.) Release of Restriction. These restrictions nay not be canceled, altered or
amended without the affirmative action of the Declarant and EPA, in an instrument executed by
both parties agreeing to change these restrictions in whole or in part
5.) Effect of Invalidation. Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shall in no way affect any of the other provisions, which
shalt remain in full force and effect
IN WITNESS WHEREOF. Declarant has executed this Declaration of Restrictions as of the date
set forth above.
Recommended:
Natural Resources and
Environmental Protection Cabinet
Counsel to the Governor
Examined:
Paul E. Ration, Governor
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DEED
DESCRIPTION
PARCEL 37A
A certain tract or parcel of land located in Flemming County,
Kentucky, on the waters of Rock Lick Creek, situated along
Rock Lick Road, 1.1 miles east of KY 158 and being more
particularly described as follows:
Beginning at a FX Nail' the center o£ Rock liick Creek Road,
corner to Willie skaggs, thence. with Rock Lick Road and
Willie Skaggs;
North B1*25'4B" West 78.03 feet to a Hail 6 Cap, thence;
North 78*35'42n West 91.32 feet to a PK Nail, corner to
Willie Skaggs, thence leaving Rock Lick Road with Willie
Skaggs;
North 13*57'52" East 22.47 feet to a 20" White Oak, thence;
North 13*57'47" East 111.67 feet to a 15" Tulip Poplar,
thence;
South :71*49'24" East 169.53 feet to an 8" Maple, thence;
South 14*02'45" West 84.73 feet to a 26" White Oak, thence;
South 14"02/44n West 25.55 feet to the beginning.
Parcel 37A contains 0.48± Acres and is the sane property as
conveyed to Willie Skaggs, Jr. by deed fron Willie Skaggs,
dated October 27, 1990, as recorded in Deed Book 170, Page
527, in the Flenuning County Clerk's Office.
This description prepared by Palmer Engineering from a survey
performed March 1995.
DEED TAX
STATE Or KENTUCKY
COUNTY OF RBUNG]
JAHHDDR. FRITZ, CLERK
DEPUTY OBK
10?
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J
DECLARATION OF RESTRICTIONS
THIS DECLARATION is made as o((jhfiS8SBLjL 20q£ by the Commonwealth of
Kentucky, for the use and benefit of the Natural Resources and Environmental Protection
Cabinet (Declarant).
WHEREAS. Declarant is the owner of real property located at Rode Lick Road, in
Fleming County, Kentucky (the Property), mote particularly described in Deed Book 182, Page
168, of the Fleming County Cleric's Office as indicated*m Exhibit A.
WHEREAS, this property is adjacent to (and serves as a "buffer zone" for) a tow-level
nuclear disposal site with a history of releases to the environment, specifically the Maxey Flats
site (site).. The site is on the National Priority List pursuant to the Comprehensive
Environmental Response, Compensation and Liability Act of 1960.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (Civil Action Number 95-58). The site has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and interim Maintenance Period Workplan at the site (a document which governs
Operations and Maintenance activities, among other items), and the Commonwealth of
Kentucky is performing the actions required by the approved Workplan. However, tritium and
other radioactive isotopes remain onsite in amounts that could pose risks above the de
minimum lewis for aO exposure scenarios if the Remedy were to foil. Any releases could
migrate to this property.
WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 Reiily Road, Frankfort,
Kentucky 40601.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified in the Record of Decision, Declarant imposes the following restrictions:
1.) Definitions: (A) "Residential use" means any use of the property related to a (I)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (ii)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner" means
the Declarant or any successor owner or owners.
2.) Restrictions Anoficabte to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Property are restricted as follows:
A. Groundwater. Groundwater at the Property shall not be used for drinking or
other domestic, agricultural or industrial purposes. Groundwater will only be used for sampling
and/or investigation purposes.
B. Except as necessary to protect human health, safety or the environment, no
action shall be taken, allowed, suffered, or omitted on the Property if such action or omission is
reasonably likely to:
i. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human health or the environment; or
ii. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
This includes cutting or otherwise damaging trees on the sideslopes of the site.
C. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents may access the property
with permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the property pursuant to a Community Relations Plan. However, such
activity shall be carried out under a Health and Safety Plan meeting Occupational Safety and
Health Act requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions Run With I anrf
(A) Declarant shall not sell, transfer, lease, or convey this property, nor allow it to be
occupied by any person other than Commonwealth of Kentucky personnel and agents (with
exceptions as stated in (2).C, above), until such time as Declarant and EPA enter Into an
agreement formally executed by a legal instrument which is agreed to by both parties.
191
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-.192
(B). Unless canceled, altered or amended under the provisions of paragraph 4 of this
Declaration, these restrictions are to run with the land and shall be binding on Declarant his
suooessore, heirs and assigns unless an instrument signed by the Declarant and EPA has been
recorded, agreeing to change these restrictions in whole or in part.
(C). Except as provide in paragraph 4 of this Declaration, the Declarant hereby
declares that the Property shall hereafter be held, transferred, sold, leased, conveyed and
occupied subject to the restrictions set forth herein, each and all of which is and are for, and
shall inure to the benefit of and pass with each and every part of the Property and shad apply to
and bind the heire, assignees and successors in interest of the Declarant
4.) Release of Restriction. These restrictions may not be canceled, altered or
amended without the affirmative action of the Declarant and EPA, in an instrument executed by
both parties agreeing to change these restrictions in whole or in part
5.) Effect of Invalidation. Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shall in no way affect any of the other provisions, which
shall remain in full force and effect
IN WITNESS WHEREOF, Declarant has executed this Declaration of Restrictions as of the date
set forth above.
Recommended:
Natural Resources and
Environmental Protection Cabinet
Examined:
Approved:
Gordon C. puke, Secretary
Finance and Administration Cabinet
Examined:
jfisioUJ. t. AWL
Counsel to the Governor
Paul E. Patton, Governor
i ™ 1
; ~~ i
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"Exhibit A"
deed description
PARCEL 37
A certain tract or parcel of land located in Flemming County,
Kentucky, on the waters of Rock Lick Creek, situated along
Rock Lick Road, l mile east of KJf 15B and being more
particularly described as follows:
Beginning at a spike in the center of Rock Lxck Road, corner
to John Vise and Wendell McCarty, thence with Rock Lick Road
and Wendell McCarty;
North 89*55'51" East 62.13 feet to a Nail S Cap, thence;
North 86*16'09n East 75.92 feet to a Nail & Cap, thence;
North 85*16'31" East 63.59 feet to a Nail & Cap, thence;
North 83*35'13d East 61.12 feet to a Nail S Cap, thence;
North 80'59'06" East 16.05 feet to a PK Nail, thence leaving
Rock Lick Road with Wendell McCarty;
North 09*34'4l" West 21.10 feet to an 8" oak, thence;
North 09*28*32™ West 308.00 feet to an Iron Fin at 48" Beech,
corner to John Vise, thence leaving Wendell McCarty with John
vise;
North 38"34'07n East 677.42 feat to an Iron Fin at a 30"
White Oak, thence;
North 45"39'15" East 601.03 feet to an Iron Pin, corner to
the Commonwealth of Kentucky, thence leaving John Vise' with
the Commonwealth of Kentucky;
South 82*10'17n East 221.31 feet to an Iron Pin, thence;
South oo*57'17" Sast 1299.17 feet to an Iron ?ia, thence;
North 60*41'52" East 1124.08 feet to a 40" White oak, .corner
to Roscoe Johnson, thence leaving the Commonwealth of
Kentucky with Roscoe Johnson;
South 11 *29 '07" West 672.30 feet to a spike in the center- o£
Rock Lick Road, corner to John Vise, thence leaving Roscoe
Johnson with John Vise;
Sou£h 05*23'35" East 216.96 feet to a 24" Sweet Gum, thence;
South 04*15'30" East 1488.01 feet to an iron pin, corner to
Charles Blevins, thence leaving John Vise with Charles
Bleyins;
North 76*30'28" West 989.78 feet to an iron pin, corner to
Edson Whitt, thence leaving Charles Blevins with Edson Whitt;
North 5B*li' 17" west 378.79 feet to an iron pin at a 14"
Maple, thence;
193
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1S4
North 56*33'16" West 524.98 feet to an iron pin at a 24"
Maple, thence;
South 83*08'12" West 445.16 feet to an iron pin, corner to
Edson Whitt and John Vise, thence leaving Edson Whitt with
John Vise;
North 06*16'57" West 1184.13 feet to the beginning.
Parcel 37 contains (by this description) 100.621 Acres,
however, there is included within this boundary a parcel of
land owned by Willie Skaggs, Jr. (Parcel 37A) which contains
0.481 Acre, and is deducted from the net area, leaving a
remainder of 100.141 Acres, and is a part of the sane
property as conveyed to Willie Skaggs from Arvel Ratliff, by
deed, dated July 19, 1974, as recorded in Deed Book 137, Page
765, in the Fleming County Clerk's Office.
This description prepared by Palmer Engineering froa a survey
performed March 1995.
DATE: t -S-Q4 mreMitj ^
DEED TAX
DOCUMENT# Q%5a<
page 2 of 2
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DECLARATION OF RESTRICTIONS
THIS DECLARATION is made as ofAnSauet S". 2003 by the Commonwealth of
Kentucky, for the use and benefit of the Natural Resources and Environmental Protection
Cabinet (Declarant).
WHEREAS, Declarant is the owner of real property located at Rock Lick Road, in
Fleming County, Kentucky (the Property), more particularly described'm Deed Book 182, Page
368, of the Fleming County Clerk's Office as indicated In Exhibit A.
WHEREAS, this property is adjacent to (and serves as a 'buffer zone" for) a low-level
nuclear disposal site with a history of releases to the environment, specifically the Maxey Flats
site (site). The site is on the National Priority List pursuant to the Comprehensive
Environmental Response, Compensation and Liability Act of 1980.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (Civil Action Number 95-58). The site has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and Interim Maintenance Period Workplan at (he site (a document which governs
Operations and Maintenance activities, among other items), and the Commonwealth of
Kentucky is performing the actions required by the approved Workplan. However, tritium and
other radioactive isotopes remain onsite In amounts that could pose risks above the de
minimum levels for all exposure scenarios if the Remedy were to faiL Any releases could
migrate to this property.
WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 Reilly Road, Frankfort,
Kentucky 40601.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified In the Record of Decision, Declarant imposes the following restrictions:
1.) Definitions. (A) "Residential use" means any use of the property related to a (i)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (h)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner* means
the Declarant or any successor owner or owners.
2.) Restrictions Applicable to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Property are restricted as follows:
A. Groundwater. Groundwater at the Property shad not be used for drinking or
other domestic, agricultural or industrial purposes. Groundwater will only be used for sampling
and/or Investigation purposes.
B. Except as necessary to protect human health, safety or the environment no
action shall be taken, allowed, suffered, or omitted on the Property if such action or omission is
reasonably likely to:
i. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human health or the environment or
II. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
This includes cutting or otherwise damaging trees on the sideslopes of the site.
C. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents may access the property
with permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the property pursuant to a Community Relations Plan. However, such
activity shall be earned out under a Health and Safety Plan meeting Occupational Safety and
Health Act requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions Run With Land
(A) Declarant shall not sell, transfer, lease, or convey this property, nor allow it to be
occupied by any person other than Commonwealth of Kentucky personnel and agents (with
exceptions as stated in (2).C, above), until such time as Declarant and EPA enter into an
agreement formally executed by a legal instrument which is agreed to by both parties.
195
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£96
(B). Unless canceled, altered or amended under (he provisions of paragraph 4 of (his
Declaration, these restrictions are to run with the land and shall be binding on Declarant, his
successors, heirs and assigns unless an instrument signed by the Declarant and EPA has been
recorded, agreeing to change these restrictions in whole or in part
(C). Except as provide in paragraph 4 of this Declaration, the Declarant hereby
declares that the Property shall hereafter be held, transferred, sold, leased, conveyed and
occupied subject to the restrictions set forth herein, each and all of which is and are for, and
shall inure to the benefit of and pass with each and every part of the Property and shall apply to
and bind the heirs, assignees and successors in interest of the Declarant
4.) Release of Restriction. These restrictions may not be canceled, altered or
amended wfthout the affirmative action of the Declarant and EPA, in an instrument executed by
both parties agreeing to change these restrictions in whole or in part
5.) Effect of Invalidation. Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shall in no way affect any of the other provisions, which
shall remain in full force and effect
IN WITNESS WHEREOF, Declarant has executed this Declaration of Restrictions as of the date
set forth above.
Recommended:
Nature'Resources and
Environmental Protection Cabinet
Examined:
Approved:
al Counsel
Finance and Administration Cabinet
Examined:
/hiefaU.-r: Atunsfi/
Counsel to the Governor
Gordon C. DuKe, Secretary
Finance and Administration Cabinet
Paul E. Pattern, Governor
(' I
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(_j
ftE*h\b">+ A''
DEED DESCRIPTION
PARCEL 41
A certain tract or parcel of land located in Flemming County,
Kentucky, on the waters of Rock Lick Creek, situated along
Rock lick Road, 1.3 miles east of KY 158 and being more
particularly described as follows:
Beginning at a Spike in the center of Rock Lick Road, corner
to John Vise, thence vith Rock Lick Road and John Vise;
North 89"13'32" West 87.97 feet to a Nail & Cap, thence;
South 89 *22'26" West 58.85 feet to a Nail & Cap, thence;
North 89*43'24" West 55.49 feet to a Nail & Cap, thence;
North 87"39'21" West 59.73 feet to a Nail & Cap, thence;
North. 84"50'08" West 61.02 feet to a Nail & Cap, thence;
North 83" 36 '50" West .57.62 feet to a Nail & Cap, thence;
North 85*13'30" West 200.13 feet to a Nail & Cap, thence;
North 85'47'00" West 59.28 feet to a Nail fi Cap, thence;
North 86"21'13" West 60.75 feet to Spike, comer to Willie
Skaggs, thence leaving.Rock Lick Road and John Vise, vith
Willie Skaggs;
North ll*29'07" East 672.30 feet to a 40" White Oak, corner
to Commonwealth of Kentucky, thence leaving Willie Skaggs
vith the Commonvealth of Kentucky;
North 15'35'15" East 500.08 feet to an Iron pin, thence;
South 78*40'17" East 594.01 feet to an Iron Pin, .thence;
North 26*23'33" East 258.24 feet to an Iron Pin in a Stump,
thence;
North 86*35'il" East 567.87 feet to ah Iron Pin, corner to
Alia Huffman, thence leaving the Commonvealth of Kentucky
with Alia Huffman;
South 21*09'38" East 616.63 feet to an iron pin, thence; ¦
»
South 21*09'38" East 616.63 feet to an iron pin, corner to
Roscoe Johnson, thence leaving Alia Huffman vith Roscoe
Johnson;
South 63*08'19" West 663.34 feet to a Spike in the center of
Rock Lick Road, thence continuing vith Roscoe Johnson and
Rock Lick Road;
197
-------
198
North 73*17'51" West 73^84 feet to a Nail & cap, thence;
North 67*19'09" West 58.81 feet to a Nail S Cap, thence;
North 63*27'43*' West 62.97 feet to a Spike, thence;
Korth 70*16,43" West 56.42 feet to a Nail & Cap; thence;
North 80'03'38" West 55.82 feet to a Spike, thence leaving
Rock Lick Road and continuing vith Roscoe Johnson;
South 09-" 15'43" West 123.10 feet to an Iron Fin, thence;
South 80*00'44" East 72.69 feet to an Iron Fin at a 8" Wild
Cherry tree, thence;
South 29"31'03" West 373.31 feet to an Iron Pin,- thence;
South 22*23'26" West 69.87 feet to an Iron Pin, corner to
John Vise, thence leaving Roscoe Johnson vith John vises
North 08"18'39" West 37.59 feet to a point in Rock Idck
Creek, thence continuing vith John Vise and Rock Lick CreeOt;
North 58'24'25.221" West 57.4366 feet to a point in the
creek, thence;
North 3B*36'39.214" West 25.0614 feet to a point in the
creek, thence;
North 14"03'53.401" West 36.4538 feet to a point in the
creek, thence;
North 05"12'51.819" East 72.4890 feet to a point in the
creek, thence;
North 52*36'44.337" West 23.4814 feet to a point in the
creek, thence;
North 63*03'32.2B9" West 54.0442 feet to a point in the
creek,, thence;
North 82"32'56.976" West 44.3646 feet to a point in the
creek, thence;
South 77-30'18.395" West 49.1050 feet to a point in the
creek, thence;
South 82*00'02•823" West 65.1267 feet to a point in the •
creek, thence;
South 86'36'16.725" West 67.5386 feet to a point in the
creek, thence;
North 87'18 '23.589" West 78.8641 feet to a point in Che
creek, at a ditch, thence leaving Sock Lick Creek vith i-he
ditch?
North 59"03'53.852" East 63.3051 feet to a point in the
ditch, thence;
2 of 3
-------
L I
North 44 * 16' 04.840" East 111.5849 feet to a point in the
ditch, thence;
North 42"45'57. 592" East 30.4931 feet to a point in the
ditch, thence;
North 26 *29'36.273" East 14.3064 feet to a point in the
ditch, thence;
North 10*59'50.283" East 29.2929 feet to a point iii the
ditch, thence;
North 01 *29'34.342" West 46.3677 feet to a point in the
ditch, thence;
North ll*54'02.983" East 19.3969 feet to a point in the
ditch, thence;
North 16-42'29.301n East 35.7848 feet to a point in the
ditch, thence;
North 27*33'26.479" East 54.9265 feet to the beginning..
Parcel 41 contains (by this description) 50.72± Acres,
however, there is included within this boundary a parcel of
land owned by Marcus Ball (Parcel 39) which contains 1.00±
Acre, and is deducted from the net area, leaving a remainder
of 49.72+ Acres, and is a part of the same property as
conveyed to Roscoe Johnson from Lois NcKee, by by deed, dated
April 12, 1971, as recorded in Deed Book 132, Page 201, in
the Flemming County Clerk's Office.
This description prepared by Palmer Engineering from a survey
performed March 1995.
~ " 3 of 3
DOCUMENT#
DATE: \ -*>- 4 TTMF- U
DEED TAX
MAI^YNSPENCH^ FLE^G COjCLERK
BOOK rial "A PAfTF
coumyoFnBmej
UWRODR
7"EFWfflSOJ*D«oJTr^lL" ' 13)1 rmv Qg ,,
'wa
LERK
iroF
asw
199
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20ff
DECLARATION OF RESTRICTIONS
THIS DECLARATION is made as 2003 by the Commonwealth of
Kentucky, for the use and benefit of the Natural Resources and Environmental Protection
Cabinet (Declarant).
WHEREAS, Declarant is the owner of real property located at Rock Lick Road, in
Fleming County, Kentucky (the Property), more particularly described in Deed Book 182. Page
64, of the Fleming County Clerk's Office as indicated in Exhibit A.
•• - WHEREAS, this property is adjacent to (and serves as a "buffer zone" for) a low-level
nuclear disposal site with a history of releases to the environment, specifically the Maxay Flats
dffe- (site). The site is on the National Priority List pursuant to the Comprehensive
Environmental Response, Compensation and Liability Act of 1960.
WHEREAS, this site has been the subject of a Remedial Action and is undergoing
Operations and Maintenance pursuant to a Consent Decree with the U.S. Environmental
Protection Agency (Civil Action Number 95-58). The site has been capped to control exposure
to the hazardous substances, pollutants or contaminants by restricting direct contact and
diverting rainfall.
WHEREAS, U.S. Environmental Protection Agency (EPA) has approved the Remedial
Action and Interim Maintenance Period Workplan at the site (a document which governs
Operations and Maintenance activities, among other items), and the Commonwealth of
Kentucky is performing the actions required by the approved Workplan. However, tritium and
other radioactive isotopes remain onsite in amounts that could pose risks above the de
minimum levels for all exposure scenarios if the Remedy were to foil. Any releases could
migrate to this property.
WHEREAS, further information concerning the site may be obtained by contacting the
Custodian of Records of the Division of Waste Management at 14 Reilly Road. Frankfort
Kentucky 40601.
NOW THEREFORE, pursuant to the Consent Decree, and the Remedial Action as
specified in the Record of Decision, Declarant imposes the following restrictions:
1.) Definitions. (A) "Residential use" means any use of the property related to a (i)
residence or dwelling, including but not limited to a house, apartment, or condominium, or (ii)
school, hospital, day care center, playground, or outdoor recreational area. (B) "Owner* means
the Declarant or any successor owner or owners.
2.) Restrictions Applicable to the Property. Declarant shall assure that the use,
occupancy, and activity of and at the Property are restricted as follows:
A. Groundwater. Groundwater at the Property shall not be used for drinking or
other domestic, agricultural or industrial purposes. Groundwater will only be used for sampling
and/or investigation purposes.
B. Except as necessary to protect human health, safety or the environment, no
action shall be taken, allowed, suffered, or omitted on the Property if such action or omission is
reasonably likely to:
i. Create a risk of migration of hazardous substances, pollutants or
contaminants or a potential hazard to human health or the environment; or
ii. Result in a disturbance of the structural integrity of any engineering
controls designed or utilized at the Property to contain hazardous substances, pollutants or
contaminants or limit human exposure to hazardous substances, pollutants or contaminants.
This includes cutting or otherwise damaging trees on the sidestopes of the sits.
C. Access shall be restricted to Commonwealth of Kentucky personnel and agents.
Persons other than Commonwealth of Kentucky personnel and agents may access the property
with permission of the Commonwealth of Kentucky for purposes of investigation, remediation, or
support activities related to investigation and remediation. Also, members of the public may
access portions of the property pursuant to a Community Relations Plan. However, such
activity shall be carried out under a Health and Safety Plan meeting Occupational Safety and
Health Act requirements. Note this restriction precludes residential and industrial uses.
3.) Restrictions Run With Land.
(A) Declarant shall not sell, transfer, lease, or convey this property, nor aQow it to be
occupied by any person other than Commonwealth of Kentucky personnel and agents (with
exceptions as stated In (2).C, above), until such time as Declarant and EPA enter into an
agreement formally executed by a legal instrument, which is agreed to by both parties.
-------
(B). Unless canceled, altered or amended under the provisions of paragraph 4 of this
Declaration, these restrictions are to run with the land and shall be binding on Declarant, his
successors, heirs and assigns unless an instrument signed by the Declarant and EPA has been
recorded, agreeing to change these restrictions in whole or in part.
(C). Except as provide in paragraph 4 of the Declaration, the Declarant hereby
declares that the Property shall hereafter be held, transferred, sold, leased, conveyed and
occupied subject to the restrictions set forth herein, each and all of which is and are for, and
shall inure to the benefit of and pass with each and every part of the Property and shall apply to
and bind the heirs, assignees and successors in interest of the Declarant
- 4.) Rptaaw cf Restriction. These restrictions may not be canceled, altered or
amended without the affirmative action of the Declarant and EPA, in an instrument executed by
both parties agreeing to change these restrictions in whole or in part
5.) Effect of Invalidation. Invalidation of any one of these restrictions, conditions or
covenants by judgment or court order shad in no way affect any of the other provisions, which
shall remain in full force and effect
IN WITNESS WHEREOF, Declarant has executed this Dedaration of Restrictions as of the date
set forth above.
Recommended:
Examined:
Counsel to the Governor
Paul E. Patton, Governor
201
-------
202
. PARCEL 34
A certain tract or parcel of land located in Fleming County) Kentucky, on the
waters^of RockLick Creek, situated along Rock Lick Creek Road, 0.6 mile east
of KY.158 ahd being inore particularly described as follows:
. .^Beginning at a spike in the center of Rock Lick Creek Road, comer to Bill Hall
and *Richud Bhimagen, tbence leaving Rock Lick Creek Road with Richard
'S *^oith 01 degree 12'43* East 577.50 feet to an iron pin, thence;
mSh^'/K ¦¦
' v^ath 6$ degrees 14'57" West 435.94 feet to a 6" Hickory, comer to Parcel 34A,
... 'thence with Parcel 34A;
04 degrees 4835" East 109.50 feet to a 24" Poplar, thence;
A' p v North 19 degrees 13*20" East 224.95 feet to a 16" Chestnut Oak, thence;
J " rti v'North 33 degrees I2'46" East 100.57' feet to a 22" Tulip Poplar, thence;
v '
South 85 degrees 25'56" East 167.48 feet to a 36" White Oak, comer to Ray
Lambert, thence with Ray Lambert;'
South 64 degrees 14'07" East 623.86 feet to an iron pin, Comer to Hurl Johnson,
thence with Hurl Johnson;
South 67 degrees 05'58" East 159.56 feet to a point in the center of'the gravel
road, thence with the gravel road and Hurl Johnson;
North 01 degree 46'42" West 46.74 feet to a point in the center of the gravel road,
thence;
-------
North 04 degrees 48'07" East 62.83 feet to a point in the gravel road, thence;
North 07 degrees 28*08" East 46.43 feet to a point in the center of the gravel road,
comer to Ray Lambert, thence with Ray Lambert;
North 10 degrees 52*22" East 74.07 feet to a point in the center of the gravel road,
thence;
North 13 degrees 16*33" East 61.29 feet to a point in the center of the gravel road,
tljerice;
''North 18 degrees. 33*37" East 75.33 feet to a point in the center of the gravel road,
thence;
North 80 degrees 26*33" East 467.56 feet to an iron pin, comer to Commonwealth
of Kentucky, Maxey Flats, thence with Commonwealth of Kentucky;
North 86 degrees 49*17" East 1395.07 feet to an iron pin, comer to Willie Skaggs,
thence with Willie Skaggs;
South 45 degrees 39*15" West 601.03 feet to an iron pin at a 30" White Oak,
thence;
South 38 degrees 34*07" West 677.42 feet to an iron pin at a 48" Beech, comer
to Wendell McCarty, thence with Wendell McCarty;
South 34 degrees 30*09" West 397.96 fefct to an iron pin, thence;
South 06 degrees 16*54" East 16.33 feet to a spike in the center of Rock Lick
Creek Road, comer to Willie Skaggs, thence with Willie Skaggs;
South 06 degrees 16'57" East 1184.13 feet to an iron pin, corner to Edson Whitt,
thence with Edson Whitt;
South 82 degrees 00*56" West 1641.96 feet to an iron pin, comer to Bill Hall,
thence with Bill Hall;
North 01 degree 12'43" East 1373.00 feet to the beginning.
Parcel 34 contains 99.530 Acres and is the same or a part of the same property
as conveyed to John Vise from Linda Denton, by deed dated April 11, 1953, as
recorded in Deed Book 111, Page 219, in the Fleming County Clerk's Office.
This description prepared by Palmer Engineering from a survey performed January
.1995.
PARCEL A
A certain tract or parcel of land located in Fleming County, Kentucky, on the
waters of Rock Lick Creek, and being more particularly described as follows:
Beginning at a 6" Hickory, comer to John Vise and Richard Brumagen, thence
with Richard Brumagen;
North 63 degrees 49,14" West 924.55 feet to an iron pin,-thence;
North 40 degrees 36*11" East 496.64 feet to an iron pin, comer to Ray Lambert,
thence with Ray Lambert;
Page 2
203
-------
204
South 64 degrees 14*07" East 898.94 feet to a 36" White Oak, comer to John
Vise, thence with John Vise;
North 85 degrees 25'56" West 167.48 feet to a 22" TuJip Poplar, thence;
South 33 degrees 12'46" West 100.57 feet to a 16" Chestnut Oak, thence;
South 19 degrees 13"20" West 224.95 feet to a 24" Poplar, thence;
South 04 degrees 48'35" West 109.50 feet to the beginning.
Parcel A contains 9.120 Acres and may be a part of property owned by Ray
Lambert or John Vise. Deed descriptions of Ray Lambert and John Vise do not
precisely describe the area (Parcel A) in question. Both Ray Lambert and John
Vise believe Parcel 34A .to be part of their respective lands.
This description prepared by Palmer Engineering from a survey performed January
1995.
PARCEL 38
A certain tract or parcel of land located in Fleming County, Kentucky, on the
waters of Rock Lick Creek, situated along Rock Lick Creek Road, 1.3 miles east
of KY 158, and being more particularly described as follows:
Beginning at a spike in the center of Rock Lick Creek Road, comer to Willie
Skaggs and Roscoe Johnson, thence with the center of Rock Lick Creek Road and
Roscoe Johnson;
South 86 degrees 21'13" East 60.75 feet to a nail and cap in the center of the road,
thence;
South 85 degrees 47'00" East 59.28 feet to a nail and cap in the center of the road,
thence;
South 85 degrees 13*00" East 200.13 feet to a nail and cap in the center of the
road, thence;
South 83 degrees 36'50" East 57.62 feet to a nail and cap in the center of the road,
thence;
South 84 degrees 50*08" East 61.02 feet to a nail and cap in the center of the road,
thence;
South 87 degrees 39*21" East 59.73 feet to a nail and cap in the center of the road,
thence;
South 89 degrees 43'24" East 55.49 feet to a nail and cap in the center of the road,
thence;
North 89 degrees 22*26" East 58.85 feet to a nail and cap in the center of the road,
thence;
South 89 degrees 13'32" East 87.97 feet to a spike in the center of the road, at the
ditch, thence leaving the road continuing with Roscoe Johnson down and
meandering with the ditch;
South 27 degrees 3376.479" West 54.9265 feet to an iron pin, thence;
Page 3
-------
South 16 degrees 42*29.301" West 35.7848 feet to a point, thence;
South 11 degrees 54'02.983" West 19.3969 feet to a point, thence;
South 01 degree 29*34.342" East 46.3677 Teet to a point, thence;
South 10 degrees 59'50.283" West 29.2929 feet to a point, thence;
South 26 degrees 2936.273" West 14.3064 feet to a point, thence;
- .South 42 degrees 45*57.592" West 30.4931 feet to a point, thence;
South 44 degrees 16'04.840" West 111.5849 feet to an iron pin, thence;
South 59 degrees 03*53.852" West 63.3051 feet to a point in Rock Lick Creek,
thence down and meandering with Rock Lick Creek;
South 87 degrees 1873.589" East 78.8641 feet to a point, thence;
North 86 degrees 36'16.725" East 67.5386 feet to a point, thence;
¦ North 82 degrees 00'02.823" East 65.1267 feet to & point, thence;
North 77 degrees 30'18.395" East 49.1050 feet to a point, thence;
South 82 degFees 32'56.976" East 44.3646 feet to a point, thence;
South 63 degrees 03*32.289" East 54.0442 feet to a point, thence;
South 52 degrees 36*44.337" East 23.4814 feet to a point, thence;
South 05 degrees 12*51.819" West 72.4890 feet to a point, thence;
South 14 degrees 03*53.401" East 36.4538 feet to a point, thence;
South 38 degrees 36*39.214" East 25.0614 feet to a point, thence;
South 58 degrees 2475.221" East 57.4366 feet to a point at the mouth of a drain,
thence up and meandering with the drain;
South 08 degrees 1839.377" East 37.5938 feet to a point, thence;
South 25 degrees 19*12.958" West 158.6171 feet to a point, thence;
South 19 degrees 17*25.797" West 101.5081 feet to a point, thence; '
South'28 degrees 22*16.338" West 45.7740 feet to b point, thence;
South 10 degrees 31*35.301" West 40.6043 feel to a point, thence;
South 34 degrees 37*56.069" West 40.9532 feet to a point, thence;
South 21 degrees 25'58.962" West 55.7450 feet to a point, thence;
South 32 degrees 20*21.707'' West 40.5341 feet to a point, thence;
South 49 degrees 45*04.050" West 29.8371 feet to a point, thence;
South 00 degrees 50*07.788" West 31.8894 feet to a point, thence;
Page 4
205
-------
¦ 206-
South 00 degrees 13*26.221" West 30.4432 feet to a point, thence;
South 31 degrees 41*40.921" West 21.0928 feel to a point, thence;
South 12 degrees 29*04.052" East 20.5991 feet to a point, thence;
South 17 degrees 49*03.108" East 28.6712 feet to a point, thence;
South 06 degrees 10'43.593" East 21.4808 feet to a point, thence;
; South 26 degrees 10*10.682" West 20.8013 feet to a point, thence;
if
South 03 degrees 23*43.878" East 38.0899 feet to a point, thence;
South 11 degrees 24*51.212" West 12.7134 feet to a point, thence;
South 06 degrees 11*38.969" West 40.1212 feet to a.point, thence;
South 52 degrees 57'05.072n West 14.1081 feet to a point, thence;
South 11 degrees 02*23.488" East, 13.9379 feet to a point, thence;
South 33 degrees 04,50.615" West 15.3347 feet to a point, thence;
South 09 degrees 06*46.741" West 21.3282 feet to a point, thence;
South 14 degrees 33*11.765" East 80.4720 feet to a point, thence;
South 04 degrees 53*12.185" West 61.8177 feet to a point, thence;
South 02 degrees 20'44.689" West 57.0248 feet to a point, tbence;
South 05 degrees 41*22.104" East 18.0861 feet to a point, thence;
South 04 degrees 35*14.098" West 59.9922 feet to a point, thence;
South 05 degrees 03*19.826" East 37.4146 feet to a point, thence;
South 22 degrees 31*14.454" West 44.4811 feet lo a point, thence;
South 15 degrees 27*19.237" West 85.8090 feet to a point, thence;
South 14 degrees 01*04.208" West 52.8437 feet to a point, thence;
South 14 degrees 13*53.067" West 87.0815 feet to a 24" Gum, comer to Gary
Johnson, thence with Gary Johnson;
North 65 degrees 23'25" West 383.44 feet to an iron pin, corner to Virginia
Aeeder, thence with Virginia Reeder.
North 65 degrees 23'25" West 137.52 feet to an iron pin, comer to Charles
Blevins, thence with Charles Blevins;
North 65 degrees 2375" West 25.29 feet to an iron pin, comer to Willie Skaggs,
thence with Willie Skaggs;
North 04 degrees 15*30" West 1488.01 feet to an iron pin at a 24" Sweet Gum,
thence;
Page 5
-------
Parcel 38 contains 27.705 Acres and is the same property as conveyed to John
Vise from Charles R.^olton/by deed, dated April 18, 1957. as recorded in Deed
Book 114, Page 352, in the Fleming County Clerk's Office.
This description prepared by Palmer Engineering from a survey performed January
document* 1-ajg.^u
DATEq-^-OM 7TMEcV^r-i
DEED TAX
ssssss?
books^^i-i paof ano
SWECFKajTUCKyj
coutmroFFianG)
"WWBH.FWJZasS(
LOBVTVOfFH
207
-------
^vtsr '
—Commonwealth Owned
iBmer^Zone
Approximate Property Boundary and Areas where Deed Restrictions Exist
Legend
Approximate Property Boundary
Areas where Deed Restrictions Exist
Areas where Deed Restrictions Exist
Commonwealth Owned Property
-------
APPENDIX N - CONTAMINANT TREND GRAPHS
N-l
-------
Attachment
6.A.1
Contaminant Monitoring
of Surface Water
Sampling Locations
subject to
4 mrem/yr Standard
Maxey Flats
Fleming County, Kentucky
Map Legend
u. Surface Water
Sampling Point
Waterway
Basemap Source:
USDA FSA (NAIP 2016)
08 June 2016
Spatial Projection
t
Coordinate System:
Kentucky State Plane North
FIPS Zone: 1601
Units: Feet
Datum: NAD83
1,000
-------
Attachment 6.A.2.1: Location 103E Annual Average Tritium Concentration
25
20
15
10
2.07 max
• H3 Activity
¦Action Level
IRP Completion
IMP Average (2004-2016): 0.49
2000
0.3 min
• -
~T~
2008 2010
Year
2012
—•—
—
2014
2016
2018
-------
Attachment 6.A.2.2: Location 102D Annual Average Tritium Concentration
25
20
i
u
a
15
10
1.19 max
• H3 Activity
¦Action Level
-- IRP Completion
IMP Average (2004-2016): 0.67
0.3 min
i
-+-
2000
2002 2004 2006 2008 2010
Year
2012
2014
2016
2018
-------
Attachment 6.A.2.3: Location 122C Annual Average Tritium Concentration
25
20
15
10
IMP Average (2004-2016): 0.97
¦ H3 Activity
¦Action Level
¦ IRP Completion
0
2000
1.53 max
2002
—1_ 1—
2004 2006
2008 2010
Year
2012
2014
0.61 min
2016
2018
-------
Attachment
6.A.2.4:
Location 106 Annual Average Tritium Concentration
25
20
u
Q.
15
10
6.39 max
¦ H3 Activity
¦Action Level
• IRP Completion
IMP Average (2004-2016): 3.68
2000
2002
2004
2006
2008
2.44 min
t i_ _
"i" " i
2010 2012
2014
--4-~
2016
Year
2018
-------
Attachment 6.A.2.5: Location 122A (background) Annual Average Tritium Concentration
u
a
25
20
15
10
¦ H3 Activity
¦Action Level
IRP Completion
IMP Average (2004-2016): 0.03
-0.06 min
0.07 max
• • *
D 9 » • » 9 • •
2000 2002 ! 2004 2006 2008 2010 2012 2014 2016 2C
Year
-------
Attachment
6.B.1
Contaminant Monitoring
of Surface Water
Sampling Locations
subject to
25 mrem/yr Standard
Maxey Flats
Fleming County, Kentucky
Map Legend
Surface Water
Sampling Point
Waterway
Basemap Source:
USDA FSA (NAIP 2016)
08 June 2016
Spatial Projection
(
Coordinate System:
Kentucky State Plane North
FIPS Zone: 1601
Units: Feet
Datum: NAD83
i 500 1,000
-------
Attachment 6.B.2.1: Location C107 Annual Average Tritium Concentration
120
100
u
a
80
60
¦ H3 Activity
¦Action Level
IRP Completion
40
IMP Average (2004-2016): 11.42
20 ;
o L
2000
16.97 max
2002 2004 2006
2008 2010
Year
2012 2014 2016
- ¦--!
2018
-------
Attachment 6.B.2.2: Location 143 Annual Average Tritium Concentration
120
100
80
60
40
20
• H3 Activity
¦Action Level
IRP Completion
IMP Average (2004-2016): 0.07
4.61 max
-0.11 min
Year
-------
Attachment 6.B.2.3: Location 144 Annual Average Tritium Concentration
120
100
u
a
80
60
40
20
0 —
2000
70.03 max
33.76...
¦ H3 Activity
¦Action Level
IRP Completion
IMP Average (2004-2016): 51.02
1-
2002 2004 2006 2008 2010 2012 2014
-—I-
2016
2018
Year
-------
Attachment
6.C.1
Contaminant Monitoring
of Alluvial Well
Locations
(odd numbered) subject
to 4 mrem/yr Standard
Maxey Flats
Fleming County, Kentucky
Map Legend
<*-
$
Alluvial Well
(Active)
Alluvial Well
(Abandoned 2017)
Waterway
Basemap Source:
USDA FSA (NAIP 2016)
08 June 2016
Spatial Projection
t
Coordinate System:
Kentucky State Plane North
FIPS Zone: 1601
Units: Feet
Datum: NAD83
1,000
-------
Attachment
6.C.2
Contaminant Monitoring
of Alluvial Well
Locations
(even numbered) subject
to 4 mrem/yr Standard
Maxey Fiats
Fleming County, Kentucky
Map Legend
jK Alluvial Well
~ (Active)
Alluvial Well
(Abandoned 2017)
Waterway
Basemap Source:
USDAFSA (NAIP2016)
08 June 2016
Spatial Projection
Coordinate System:
Kentucky State Plane North
FIPS Zone: 1601
Units: Feet
Datum NAD83
-------
Attachment 6.C.3.1: Location AW-1 Annual Average Tritium Concentration
25 ,
u
a.
20
15
10
17.12
2000
¦ H3 Activity
¦Action Level
IRP Completion
IMP Average (2004-2016): 4.11
2005
Year
-------
Attachment 6.C.3.2: Location AW-3 Annual Average Tritium Concentration
25
20
15
u
a.
10
1.34 max
IMP Average (2004-2016): 0.52
0.29 min
2000
2003
2005
¦ h -
2008
• H3 Activity
¦Action Level
¦ IRP Completion
2011
2014
—f —
2016
2019
Year
-------
Attachrr 13: Location AW-4 Annual Average Tritium Concentration
25
20
15
• H3 Activity
¦Action Level
¦ IRP Completion
u
a.
10
IMP Average (2004-2016): 0,20
2000
0,50 max
0.05 min
2b03
2005
2008
2011
2014
2016
2019
Year
-------
Attachment 6.C.3.4: Location AW-5 Annual Average Tritium Concentration
I
25
20
15
£ 10
¦ H3 Activity
¦Action Level
¦¦ IRP Completion
IMP Average (2004-2016): 0.23
• •
0.36 max
•
-0.15 min
2000
2b03
2005
2008
2011
| - .
2014
2016
2019
-5
Year
-------
Attachment 6.C.3.5: Location AW-6 Annual Average Tritium Concentration
25
20
15
10
¦ H3 Activity
•Action Level
-- IRP Completion
IMP Average (2004-2016): 0.17
0
2000
0.58 max
2019
Year
-------
Attachment 6.C.3.6: Location AW-7 Annual Average Tritium Concentration
Year
-------
Attachment 6.C.3.7: Location AW-8 Annual Average Tritium Concentration
25 ,
20
0.00 min
> H3 Activity
•Action Level
¦ IRP Completion
IMP Average (2004-2016): 0.53
1.13 max
2000
2003
2005
--4 • - -
2008 2011
Year
2014
2016
2019
-------
Attachment 6.C.3.8: Location AW-9 Annual Average Tritium Concentration
u
a
25
20
15
10
1.30 max
0
2000
IMP Average (2004-2016): 0.67
•H3 Activity
¦Action Level
IRP Completion
0.21 min
-rrm.. .
2003
2005
2008 2011
Year
2014
2016
2019
-------
Attachment 6.C.3.9: Location AW-10 Annual Average Tritium Concentration
25
20
u
a.
15
10
0.51 max
2000
¦ H3 Activity
•Action Level
• IRP Completion
IMP Average (2004-2016): 0.18
-0.06 min
•-
1
2008
"•l • • •-
2011
2014
2016
2019
Year
-------
Attachment 6.C.3.10: Location AW-12 Annual Average Tritium Concentration
Year
-------
Attachment 6.C.3.11: Location AW-13 Annual Average Tritium Concentration
25
20
15
10
2000
0.78 max
¦ H3 Activity
¦Action Level
- IRP Completion
IMP Average (2004-2016): 0.35
2003 0 04 min 2005
2008
2011
2014
2016
2019
Year
-------
Attachment 6.C.3.12: Location AW-14 Annual Average Tritium Concentration
25
20
15
¦ H3 Activity
¦Action Level
—--IRP Completion
u
a.
10
IMP Average (2004-2016): 0.16
0.73 max
• •
¦» •
2000 2b03 2005 2008
-0.05 min
—: « •
2011 2014
2016 2019
Year
-------
Attachment 6.C.3.13: Location AW-15 Annual Average Tritium Concentration
25
¦ H3 Activity
•Action Level
- IRP Completion
IMP Average (2004-2016): 0.55
0.43 min
0.63 max
2000
2003
2005
2008
2011
— -[¦¦¦
2014
— I—
2016
2019
Year
-------
Attachment 6.C.3.14: Location ALT-1 Annual Average Tritium Concentration
25
20
15
u
CL-
IO
1.57 max
IMP Average (2004-2016): 0.24
0.12 min
;
2000 2003
2005
i
2008
¦ H3 Activity
¦Action Level
-- IRP Completion
2011 2014 2016 2019
Year
-------
Location N2B Annual Average Tritium Concentration
Year
-------
Location UE-2 Annual Average Tritium Concentration
700000
600000
500000
E 400000
u
Q.
300000
200000
100000
638,029 max
2000
- "'4 —
2003
2005
2008 2011
Year
H3 Activity
IRP Completion
111,705 min
2014
2016
2019
-------
Location UF-2 Annual Average Tritium Concentration
350000
300000
250000
E 200000
u
Q.
150000
100000
50000
249,707 max
¦ H3 Activity
¦ IRP Completion
83,818 min
2000
2003
2005
2008
2011
2014
2016
2019
Year
-------
50000
45000
40000
35000
30000
25000
20000
15000
10000
5000
0
Location UF-lOa Annual Average Tritium Concentration
39,157 max
- H3 Activity
¦¦ IRP Completion
3,335 min
00
M
2003
2005
2008
- +-
2011
2014
2016
Year
-------
Location UK-1 Annual Average Tritium Concentration
500000
450000
400000
350000
300000
u I
250000
200000 ;
!
150000 |
100000
50000
0
2000
453,865 max
•— H3 Activity
— IRP Completion
--M —
2003
2005
—, -I
2008 2011
Year
2014
57,729 min
2016
1
2019
------- |