Editor's Note: While the Community Guidelines are addressed to DOE they are applicable to the entire process and are thus guidelines for EPA and TDEC as well as DOE. The requlators, as well as DOE, need to openly explain to the public the reasons for their decisions.
The DOE,
EPA & TDEC Community Goal Scorecard
Scorekeeper: Al Brooks
The above goals provide criteria for scoring the DOE choice of proposed alternatives for remedial actions. In fairness to DOE, TDEC and EPA play a major role in the choice of alternative and may be the responsible party for DOE's action.
Update: The EUWG Guidelines and Recommendations are begining to appear in DOE CERCLA documents and DOE is clearly trying to meet them. At the recent EUWG End-of-Task meeting, the attendence and participation by DOE/ORO top management was encouraging.
The following is a running scoreboard for the DOE remedial decisions:
Goal Exceptions are those criteria for which a second satisfactory
alternative exceeded the selected alternative. See the Proposed Plan Documents
for details. Green is Good.
Red
is not. Watersheds
| Operable Unit | Alternative Selected | Cost Difference | EU Goal Exceptions | Notes |
| ORNL Surface Impoundments | 6 - Sludge Removal,
Treatment & Disposal |
37 Million vs. Alternative 3 | 1) Worker Safety
2) Cost |
1 |
| K-25 - Ponds
K 1007 & K901A |
Remediate &
Keep Ponds |
Not Applicable | None, compliant with habitat preservation | 2 |
| K25 K1070 Burial
Grounds |
Excavate & Remove | NA | None anticipated | |
| Bethel Valley RI/FS-D1 | 2 - Composite | 20 million | Deemed compliant | 3, 4 |
| Melton Valley PP-D1 | Mixed methodologies | NA | None | 3,5 |
| Bear Creek Valley ROD
S3 & BYBY |
Interception Trenches & Treat. | NA | None | 3 |
| UEFPC FS-D1 | NA | NA | NA | 3 |
| ETTP RI-D1 | To be submitted | |||
| Waste Disposal Cell Site | East Bear Creek Site | NA | None | 3 |
| MSRE Fuel & Salt Removal | Remove & Store | NA | None | |
| UEFPC - Mercury Sludge & Sump | Remove & Fill | Below Estimate | None |
| Watersheds and major critical projects |
1) Alternative 3, On-Site Consolidation, was rated by the EUWG as satisfactory in all categories but was not selected. TDEC is reportedly responsible for the decision. DOE is attempting to obtain a more favorable cost for Alternative 6. The bid for Alternative 6 came in far beneath the estimated cost so cost is not an issue. The difference in worker safety is somewhat subjective and probably small. Deemed acceptable.
2) After discussions with stakeholders, DOE has adopted plans less destructive of the environment. i.e., the ponds will be cleaned and restored as wetland habitat.
3) For reasons which are not now clear, the regulators have not signed off on these RODs, FSs or RIs. There are some indications that they wish more costly alternatives or are hesitant to commit to actions. The delays may result in lost opportunities. The public deserves an explanation for the delays from the regulators. Hopefully this will be resolved soon. Ratings are interim until regulatory approval.
4) While this is not the lowest cost option compliant with EUWG reccomendations, the added protection against pollution migration (a high priority EUWG guideline) is deemed worth the additional cost.
5) The proposed plan was not the least expensive
but did offer more remediation at a reasonable cost increase,