The End Use Working Group's
Community Guidelines and Land Use Recommendations
The EUWG Community Guidelines and Recommendations for the Use of ORR Contaminated Lands were produced after 18 months of intensive study by the End Use Working Group. The EUWG was an open-membership study group which met biweekly with an attendence of 20 to 50. The long-term core membership was about 20 persons. The EUWG's purpose was to aid DOE in preparing CERCLA remediation proposal by expressing the public's opinions on the Community Values and Land Uses very early in the CERCLA process. The support by all levels of DOE management was very encouraging. DOE and it contractors supplied any requested information on the five ORR watersheds and technical topics related to the problem. The result was an informed opinion based on a knowledge of the contamination scenarios that exist on each watershed.
Since these guidelines and recommendations will provide guidance to DOE on the study and determination of ORR remediation alternatives, it is important that DOE receive as wide an expression of public support and/or comment as possible. Stakeholders and other civic organizations are invited to study and endorse the EUWG's outout
The following brief summary has been extracted (6/30/98) from the End Use Working Groups reports:
Final Report of the End Use Working Group
Stakeholders Report on Stewardship
These are available free at:
The Information Resource Center
105 Broadway
Oak Ridge, TN 37830 (near Big Ed's piazza)
Phone - 241 4582 or
On: http://www.oro.doe.gov/em/EUWG.htm/
End Use Working Group Guidelines and Recommendations for the Oak Ridge Reservation Contaminated Lands
Community Guidelines for Determining End Uses of Contaminated Land and Water on the Oak Ridge Reservation
The End Use Working Group believes end use decisions for the Oak Ridge Reservation, and associated remedial activities, must include consideration of the community's values. The public and the Department of Energy (DOE) have a mutual responsibility to deal with each other openly and honestly. To enable stakeholders to comment responsibly on end use and remediation options, DOE must provide accurate and timely information.
DOE's Environmental Management Program should be guided by end use recommendations that are provided by the stakeholder community, are endorsed by the City of Oak Ridge and can accommodate changing circumstances. Once end use recommendations are provided by the community, the federal government should commit to completing all the remediation to meet the recommended end uses and should provide opportunities for meaningful public involvement. The federal government's goal should always be the protection of human health and the environment. In its decision-making, the federal government should use the best available science and technology, while taking into account cultural, social and economic factors, environmental justice, and risks to workers.
The End Use Working Group developed the following guidelines for DOE to use in making future decisions for contaminated land and water. The guidelines for contaminated land are presented in order of priority. Each guideline for contaminated water carries equal weight. DOE should explain how the guidelines are incorporated or cannot be incorporated into each of its decisions.
Guidelines for Contaminated Land
All owners and operators of property must, at a minimum, comply with applicable regulations to provide safe working conditions and to protect human health and the environment.
Guidelines for Contaminated Water
The federal government must assure the unrestricted use of all water exiting the boundaries of the Oak Ridge Reservation.
It should be noted that these Community Guidelines complement, but do not alter, the nine CERCLA (Comprehensive Environmental Response, Compensation and Liability Act) criteria that must be considered by DOE, the U. S. Environmental Protection Agency and the Tennessee Department of Environment and Conservation. These CERCLA criteria are:
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility or volume
Short-term effectiveness
Implementability
Cost
Regulatory acceptance
Community acceptance
The End Use Working Group's Land Use Reconditions for ORR
The following recommendations have been extracted without signatures from the EUWG final report. Each recommendation contains by reference, the following final paragraph:
Implementation of these recommendations by DOE must be consistent with the End Use Working Group Community Guidelines and its recommendations for stewardship. If DOE connot meet these recommendations, exceptions must be discussed in a public forum as a part of the decision making process.
Recommendations for the End Use of Contaminated Lands in the Bethel Valley Area of the Oak Ridge National Laboratory
Oak Ridge National Laboratory (ORNL) is a national and local resource, whose preservation and growth are an important part of the long-term vitality of the Oak Ridge community. ORNL needs to remain attractive to both current and new uses. Therefore, it is essential that Department of Energy (DOE) remediation decisions achieve, at a minimum, a controlled industrial end use for the entire ORNL Bethel Valley area.
A controlled industrial end use should at least provide for surface use of contaminated lands. Currently, there are areas where contamination results in the need for controlled access. Reducing such areas would enhance the overall viability of the laboratory. Remediation should result in lands that are safe for surface use by laboratory employees.
In making its decision, DOE needs to consider the overall utility of ORNL, recognize the variety of uses needed to support an active and vital laboratory environment and use remediation resources wisely. DOE should make the best practical use of existing brownfields while recognizing that not all land needs to be available for every use. If situations occur where DOE cannot meet the surface use criteria due to excessive risks or costs, these exceptions need to be discussed openly in a public forum.
Recommendation to Site A Waste Disposal Facility on the Oak Ridge Reservation
Remediation of the Oak Ridge Reservation (ORR) will generate large volumes of material containing varying degrees of contamination. The End Use Working Group believes that DOE should take a balanced* approach to the disposal of contaminated materials from the ORR. A balanced approach will require construction of an on-site waste disposal facility to manage contaminated materials meeting site-specific waste acceptance criteria. Material not meeting waste acceptance criteria for an ORR waste disposal facility should be disposed of off site.
DOE should consider the following criteria when planning an ORR waste disposal facility:
*A balanced approach is one which recognizes that Oak Ridge’s environmental problems should not be solved by shipping all of its waste elsewhere. DOE must take into account the concerns of stakeholders at potential receiving facilities and along transportation routes. DOE must also take into account the total costs and risks associated with managing wastes on site vs. off site.
End Use Recommendations for the Disposal Areas in Melton Valley
Some of the most highly radioactive waste materials on the Oak Ridge Reservation are buried in Melton Valley disposal areas. Consideration of any near-term land use other than "restricted" for contaminated Melton Valley lands would require removal of more than 3 million cubic yards of material. The resulting disposal requirements and ecological devastation make such an option unacceptable. Thus, the End Use Working Group recommends restricted end use for the disposal areas in Melton Valley. Because contaminated areas in Melton Valley are not contiguous, some areas of Melton Valley are usable for DOE-controlled activities.
For this end use, DOE must, at a minimum, ensure worker safety and control further migration of contamination in Melton Valley to ensure that levels of contaminants released to the Clinch River via White Oak Dam do not exceed standards protective of human health and the environment.
DOE should continue to monitor the major sources of radiological risk in Melton Valley. Such monitoring will indicate when the contaminants have decayed to levels at which additional remediation is feasible. Radionuclides with half lives of several years to decades, such as tritium, strontium, and cesium, are the major sources of risk in parts of the disposal areas. Within 100 to 300 years, such areas may be candidates for land uses other than restricted.
Implementation of these recommendations by DOE must be consistent with the End Use Working Group Community Guidelines and its recommendations on stewardship. If DOE cannot meet these recommendations for Melton Valley, exceptions must be discussed in a public forum as part of the decision-making process.
End Use Recommendations for the Y-12 Plant, Chestnut Ridge, and Upper East Fork Poplar Creek
Using the industrial complex at the Y-12 Plant in a manner that is safe and protective of human health and the environment is important to the long-term vitality of the Oak Ridge community. For the foreseeable future, ongoing missions for the Y-12 Plant and Chestnut Ridge dictate the use for much of this property.
For purposes of end use recommendations, the EUWG has divided the Y-12 Plant into two areas (see map). In the eastern area of the plant, surface soils contain relatively low levels of contamination and this area can be made suitable for uncontrolled industrial development. This area is bounded by residential and commercial property.
In the western area of the plant, surface soils are more heavily contaminated and would require significant excavation for uncontrolled industrial use. In addition, ongoing national security missions are located in the western area of the plant, which requires that it remain under federal government control. This area of the plant is bounded to the west by the Bear Creek Valley waste disposal areas.
The Chestnut Ridge area, adjacent to the Y-12 Plant to the south, is used for a variety of waste management activities and contains closed and active landfills.
Contaminated groundwater plumes flow beneath much of the Y-12 property and off-site into Union Valley to the east. Recognition of the impacts of contamination from the Y-12 Plant and Chestnut Ridge on surface water and groundwater resources is essential to planning overall remediation.
The End Use Working Group makes the following recommendations (numbers do not imply priority):
1. The western area of the Y-12 Plant is expected to remain controlled industrial property. As opportunity arises, national security activities should be concentrated in the western area to allow for the broadest possible use of the rest of the plant.
2. The eastern area of the Y-12 Plant should be made suitable for uncontrolled industrial use.
3. Lake Reality and the RCRA-closed New Hope Pond will require continued federal government control. Use of these sites should be consistent with end uses for the eastern area of the Y-12 Plant (i.e., for parking or other non-intrusive uses).
4. The Chestnut Ridge property should continue to be used and safely maintained for regulated waste disposal for the Oak Ridge Reservation.
5. The Upper East Fork Poplar Creek, its tributaries, and surface waters on Chestnut Ridge must eventually meet State water quality standards. In the interim, water quality must not pose an unacceptable risk to: a) industrial workers at the Y-12 Plant, and b) residential and commercial users surrounding the Lower East Fork Poplar Creek and its tributaries.
6. Contaminated groundwater from the Y-12 Plant and Chestnut Ridge must be controlled by the federal government such that it does not permanently impact the use of currently uncontaminated groundwater.
Short-term control and long-term remediation of contaminated source areas must be assured regardless of who is responsible for the facility. Implementation of these recommendations by the DOE must be consistent with the End Use Working Group Community Guidelines and its recommendations for stewardship. If DOE cannot meet these recommendations for the Upper East Fork Poplar Creek Watershed, exceptions must be discussed in a public forum as part of the decision-making process.
End Use Recommendations for Bear Creek Valley
Bear Creek Valley is divided into three zones (see attached map). Zone III begins with the S-3 Ponds at the western edge of the Y-12 Plant and continues west past the Bear Creek Burial Grounds. It includes approximately 1,000 acres of which 200 acres were used for waste disposal from 1943 to 1993. Most of the contaminated areas are north of Bear Creek Road. In this zone, the nature of the contamination, and the costs, worker risks, and uncertainties associated with its excavation, transport, and disposal lead the End Use Working Group to recommend that Zone III lands be safely maintained under restricted use. Remediation in Zone III must reduce the migration of contamination sufficient to bring contaminants in Zone II to within acceptable levels for unrestricted use and protect Zone I for unrestricted use in perpetuity.
Zone II includes the land west of the Bear Creek Burial Grounds for a distance of approximately one mile. Contaminants in ground and surface water in this zone exceed naturally-occurring levels. Thus, Zone II must be restricted to DOE controlled or recreational end uses until contaminants in ground and surface waters are within acceptable levels.
Zone I is immediately adjacent to and west of Zone II. Land and water in this zone are free from contamination and available for unrestricted use.
Implementation of these recommendations by DOE must be consistent with the End Use Working Group Community Guidelines. If DOE cannot meet these end uses for Bear Creek Valley, exceptions must be discussed in a public forum as part of the decision-making process.
End Use Recommendations for the Former K-25 Site at the East Tennessee Technology Park
Using the former K-25 Site at the East Tennessee Technology Park (ETTP) in a manner that is safe and protective of human health and the environment is important to the long-term vitality of the Oak Ridge community. The End Use Working Group (EUWG) discussed but did not evaluate and is not commenting on the current reindustrialization process or the Toxic Substances Control Act (TSCA) Incinerator. The EUWG recommendations apply to the former K-25 Site following remediation.
The EUWG recognizes that the federal government will maintain ownership of the property and will be responsible for managing all residual contamination and other stewardship actions.
The Remedial Investigation for ETTP has not been completed, and these end use recommendations are based on preliminary information regarding the scope and extent of contamination.
For purposes of end use recommendations, the EUWG has divided the former K-25 Site into three zones (see map). Zone 1 constitutes property along the Clinch River including the former power plant area; this area is the least developed and least contaminated of the former K-25 Site considered by the EUWG. Zone 2 consists of the former gaseous diffusion process and administration areas. Zone 3 consists of the former support area.
The End Use Working Group makes the following recommendations (numbers do not imply priority):
1. Zone 1 should be remediated to allow for uncontrolled industrial end use, with a focus on natural resource conservation.
2. Zone 2 should be remediated to provide for uncontrolled industrial end use.
3. Zone 3 should be remediated to provide for controlled industrial end use. If the existing K-1070 B and K-1070 C/D waste disposal areas in Zone 3 cannot be fully remediated to controlled industrial end use, then these areas should be maintained as restricted access waste disposal properties and should be managed to ensure the safety of surrounding opulations and the environment.
4. The continued storage of UF6 is not compatible with these recommended end uses. This incompatibility should be resolved on a schedule that coincides with the planned remediation of the site.
Implementation of these recommendations by DOE must be consistent with the End Use Working Group Community Guidelines and its recommendations for stewardship. If DOE cannot meet these recommendations for the former K-25 Site, exceptions must be discussed in a public forum as part of the decision-making process.
End Use Recommendation for Sites Not Included in the Existing Administrative Watersheds
During its deliberations, the End Use Working Group (EUWG) was unable to study a number of sites whose remediation is being considered separately from the five existing administrative watersheds. These sites include but are not limited to:
1. White Wing Scrap Yard
2. Molten Salt Reactor Experiment facility
3. High Flux Isotope Reactor
4. Homogenous Reactor Experiment facility
5. Cesium Plots
The EUWG recommends that DOE use the Community Guidelines in making future end use decisions for such sites. Particular attention should be given to selecting an end use that is consistent with end uses of adjacent property.
In particular, because the White Wing Scrap Yard is surrounded by uncontaminated land, it should be remediated to allow for unrestricted use.
Use of the reactor sites in Melton Valley should be consistent with Melton Valley recommendations for government-controlled industrial use. In addition, the Cesium Plots lend themselves to remediation that allows for an unrestricted end use.
The EUWG issued recommendations for an ORR stewardship plan in Stakeholders Report on Stewardship. The criteria for developing the plan were: 1) to provide for long term viability relying heavily on local government, 2) to utilize the existing property rights and land use systems currently in place, 3) to provide for redundancy and 4) to provide for public access.
The following is excerpted from the EUWG Final Report:
"Because some level of contamination will remain on the Oak Ridge Reservation, a stewardship program is needed to protect the public and the environment from the future risks associated with this residual contamination. Developing an effective stewardship program is essential to the application of the EUWG recommendations. The EUWG cannot endorse any remediation program that leaves residual contamination above health-based levels without the assurance that all necessary and appropriate actions for stewardship are in place."
"The Stakeholders Report on Stewardship calls for the Federal government through DOE: