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Analysis of the U.S. Environmental Protection Agency's Records of Decision Related to Landfills

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Analysis of the U.S. Environmental Protection Agency's Records of Decision Related to Landfills Analysis of the U.S. EPA Records of Decision Related to Landfills 1 December 2000 Analysis of the U.S. Environmental Protection Agency's Records of Decision Related to Landfills Prepared for the Idaho National Engineering and Environmental Laboratory by McNeil Technologies, Inc. 6564 Loisdale Court Suite 800 Springfield, VA 22150 1 December 2000 Analysis of the U.S. EPA Records of Decision Related to Landfills 1 December 2000 Introduction 1 Methodology 3 Record of Decision(ROD) Identification and Collection Approach 3 ROD Screening Approach 3 Summaries of Selected Records of Decision 5 Idaho National Engineering and Environmental Laboratory, Overview 5 INEEL,Pit 9 7 INEEL,SL -1 and BORAX-1 Burial Grounds 12 Hanford Site, Overview 17 Hanford Site, 100 Area 19 Discussion of Amendment to ROD 97/044 22 Hanford Site, 300 Area 24 Hanford Site, 300 Area Transuranic Burial Grounds 29 Hanford Site, 100 Area 36 Maxey Flats Nuclear Disposal, Operable Unit 1 39 Paducah Gaseous Diffusion Plant, Operable Unit 8 45 Feed Materials Production Center(FERNALD), Overview 52 Feed Materials Production Center, Operable Unit 1 54 Feed Materials Production Center, Operable Unit 2 60 Melton Valley Watershed, Operable Unit 1 65 Moyer Landfill, Operable Unit 1 71 Weldon Spring Site Remedial Action Project, Overview 79 Weldon Spring Site Remedial Action Project, Quarry 80 Weldon Spring Site Remedial Action Project, Quarry 83 Weldon Spring Site Remedial Action Project, Raffinate Pits 86 Preliminary Analysis 89 Waste Comparability 89 Waste Placement Comparability 90 Physical Environment Comparability 90 Remedies 91 Prevailing Factors Behind Remedy Selection 92 Reasons for leaving waste in-place 94 ii Analysis of the U.S. EPA Records of Decision Related to Landfills 1 December 2000 Introduction The Idaho National Engineering and Environmental Laboratory(INEEL) faces a suite of environmental challenges. Many of these challenges bring with them the prospect of decades' worth of activity ranging from site analysis to remediation to long-term stewardship and monitoring. Waste Area Group(WAG) 7 is one such challenge. Covering approximately 174 acres of high, arid to semi-arid steppe ecosystem in southeast Idaho, WAG 7(the designation for the Radioactive Waste Management Complex) was designed to permanently and retrievably store radioactive, transuranic (TRU), and mixed wastes. WAG 7 encompasses the 95.9 acre (38.8 ha) Subsurface Disposal Area (SDA), the 56 acre (23 ha) Transuranic Storage Area (TSA), and a 22 acre (9 ha) Administrative Area. The Subsurface Disposal Area encompasses trenches, soil vaults, an asphalt pad, and an acid pit that are used for the disposal of high-activity wastes. During its operation, TRU and non-TRU wastes were stored, often side-by-side, in these units. These wastes have been sourced from INEEL,the former Rocky Flats Plant, and from commercial AEC licensees. The waste containers (cardboard boxes, wooden crates, and drums, along with rion-packaged bulky wastes) have been alternately neatly stacked and randomly dumped from trucks. Following emplacement of the wastes, they were covered with soil on varying schedules (all wastes were covered at least on a weekly basis). Later disposal activities at the SDA were designed to ensure the retrievability of all solid waste contaminated with long-lived TRU in concentrations of greater than 10 nCi/g (nanocuries per gram). The asphalt pad contained within the SDA currently holds waste that contains transuranic materials, but does not meet the requirements for TRU waste. This containerized waste is currently covered by soil. Ensuring retrieval of TRU waste led to the creation of the Transuranic Storage Area. This above- grade area covers 56 acre (23 ha), consisting of several large asphalt storage pads, the Intermediate Level Transuranic Storage Pad, the Stored Waste Examination Pilot Plant, and other facilities. Waste stored at the TSA is containerized, stacked in subdivided cells, and covered with dirt. The SDA and TSA are active disposal and storage areas. Wastes today are segmented by type, compacted where possible, and placed in pits or in cells on the asphalt pads. Both contact- handled and remote-handled low-level wastes are stored, as are TRU wastes and high level wastes. The entire WAG-7 area is located above the Snake River Plain aquifer, a designated sole-source aquifer under the Safe Drinking Water Act. Within the vicinity of WAG 7, the water table is located at depths of approximately 900 ft (274 m). The site is dry (with an average annual precipitation of 8.7 inches [22.1 cm]), is highly isolated from population centers (INEEL as a whole possesses a 320 acres (130 ha) buffer zone that is currently used for grazing, as well as a Bureau of Land Management(BLM) managed buffer zone), and possesses an extraordinarily thick vadose zone between the surface and the water table. As a component of INEEL's preparations for entering into a Record of Decision(ROD) on remedies at WAG 7, this report details RODs developed at sites with similar wastes and storage 1 Analysis of the U.S. EPA Records of Decision Related to Landfills 1 December 2000 structures. The intent of this review is to provide insight into what remedies have been accepted for similar challenges, and to evaluate the level of comparability between WAG 7 issues and the issues addressed by RODs summarized in this report. This work is not intended as a comprehensive evaluation of the suitability of applying remedies from other sites to WAG 7. Rather, it is a preliminary scoping and identification exercise that can be used by INEEL in the furtherance of WAG 7-related work. The methodology behind this scoping and identification exercise can be found in the following section. The exercise focused its attention specifically on landfills and other units where radioactive wastes, transuranic wastes, and mixed wastes were, or still are, placed. This report is divided into three parts: the methodology section; summaries of the RODs that deal with wastes and waste emplacements most similar to those found at WAG 7; and a short analysis section that begins the process of comparing and contrasting the attributes of the selected RODs against the prevailing conditions at WAG 7. Following the body of the report is a series of appendices that contains: a summary table of all the RODs reviewed; an explanation as to why each was eliminated from the process; and tables outlining the volumes of contaminants of concern from the selected RODs. 2 Analysis of the U.S. EPA Records of Decision Related to Landfills 1 December 2000 Methodology Record of Decision (ROD)Identification and Collection Approach As a primary step in the ROD identification approach, an exhaustive review of on-line EPA resources was conducted. Reviewing resources electronically rather than in hard copy form was selected because it allowed for sifting through a considerable volume of information in a short amount of time. Extensive use was made of EPA's Superfund Hazardous Waste Site Advanced Query Form. This user-defined search tool allowed the selective definition of criteria of interest — in particular, searches were conducted that selectively identified "radioactive" constituents as contaminants of concern. In addition, the database was queried to identify RODs where "radioactive" was listed as a key word or where the term appeared in the text of the ROD abstract. This search tool was used to generate the primary list of RODs of interest. However, the Advanced Query Form web page indicates a "last updated" date of December 1, 1999. To ensure access to the most up-to-date information available, a copy of the current issue of the RODcite CD-ROM was obtained. RODcite, distributed by the National Technical Information Service, is a complete, up-to-date database that includes the text of all RODs, multi-page summaries of the RODs, and a powerful search engine. The interface is designed to allow searches of the database using fields like cost, contaminant, and location in combination with phrases in the ROD text. RODcite contains the complete text of the official ROD documents signed and issued by the EPA Superfund program since 1982. Recognizing that on-line and CD-ROM databases will not necessarily contain the most up-to- date information available (due to production time lags), attempts were made to contact individuals within EPA regional offices. The purpose of this activity was to discern the presence of newly signed RODs or RODs that were essentially complete and awaiting signature. To ensure that the data collection process described above did indeed provide a listing of RODs as comprehensive as one could be reasonably expected to achieve, non-governmental organizations were contacted to 'sanity-check' the preliminary findings. One organization included the Tri-Valley CARES, an environmental citizens "watch-dog" group that works on radioactive issues associated with the government. Also, officials from the EPA Waste Management Emergency and Long Term Hazardous Waste Site Cleanup Division for Regions 2- 5 & 8-10 were contacted in reference to the deselecting process. ROD Screening Approach The screening process applied to the collected RODs was designed to eliminate RODs that address issues with little resemblance to those facing INEEL at WAG 7. The three-step screening process, discussed below, allowed for a quick and accurate screening to reduce the large number of RODs down to the dozen or so RODs that are relevant to the scope of this study. In Step 1, both the EPA's Superfund Hazardous Waste Site Advanced Query Form and the RODcite CD-ROM were searched for RODs that contained the term "radioactive" in either a 3 Analysis of the U.S. EPA Records of Decision Related to Landfills 1 December 2000 keyword field or in the ROD abstract. As originally planned, Step 1 was to have selected RODs based on the term "landfill" or "buried waste." However, an initial run through the databases using this method returned an unacceptably large number of responses — thus, the study team quickly ascertained that the first screen should use the term "radioactive." Using this term rather than "landfill" or "buried waste" quickly narrowed the area of study to less than 100 RODs.
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