Community Guidelines for End Uses of Contaminated Properties

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
Notes:

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,