OSTI FEMP-2 344 WKAT WILL WE DO WITH 104,000,000 CUBIC FEET OF FERNALD WASTE? BY GERALD P. MOTL, FERMCO GERALD J. KRIEGER, FERMCO DAVID M. RAST, U. S. DOE-Fernald Area Office FERMCO* Fernald Environmental Management Project P.O. Box 398704/MS 50 Cincinnati, OH 45239-8704 For Presentation at the U.S. Department of Energy Low-Level Radioactive Waste Management Conference Phoenix, A2 December 13-15, 1994 DISCLAIMER This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsi- bility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Refer- ence herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recom- mendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof. *Fernald Environmental Restoration Management Corporation with the U. S. Department of Energy under Contract No. DE-AC05-920R21972 DISTRIBUTION OE THIS DOCUMENT fS UNUMlTECJ ,. u
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O S T I
FEMP-2 344
WKAT WILL WE DO WITH 104,000,000 CUBIC FEET OF FERNALD WASTE?
BY GERALD P. MOTL, FERMCO
GERALD J. KRIEGER, FERMCO DAVID M. RAST, U. S. DOE-Fernald A r e a Of f i ce
FERMCO* Fernald Environmental Management P r o j e c t
P.O. Box 398704/MS 50 Cinc inna t i , OH 45239-8704
For P resen ta t ion a t t h e U.S. Department of Energy
This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsi- bility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Refer- ence herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recom- mendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.
*Fernald Environmental Res to ra t ion Management Corporation wi th t h e U. S. Department of Energy under Contract No. DE-AC05-920R21972
DISTRIBUTION OE THIS DOCUMENT fS UNUMlTECJ ,. u
DISCLAIMER
Portions of this document may be illegible in electronic image products. Images are produced from the best available original document.
DISCLAIMER
THIS PAPER WAS PREPARED AS AN ACCOUNT OF WORK SPONSORED BY AN AGENCY OF THB UNXED STATES GOVERNMENT. REFERENCE HEREEN TO ANY SPECIFIC COMMERCLAL PRODUCX, PROCESS, OR SPRVICE BY TRADE NAME, TRADEMARK, MANUFACTURER OR OTHERWlSE DOES NOT CONSITWTE OR W L Y lTS ENDORSEMENT, RECOMMENDATION, OR FAVORING BY THE WWED STATES GOVERNMENT OR ANY AGENCY THEREOF. THE VIEWS AND OPINIONS OF AUTHORS EXF'BSED HWEIN DO NOT NECESSARILY STATE OR REFLECl' THOSE OF THE m D STATES GOVERNMENT, OR ANY AGENCY THEREOF OR FERNALD ENVIRONMENTAL RESTORATION MANAGEMEm CORPORATION, ITS AFFILIATES OR lTS PARENT COMPANIES.
WHAT WILL WE DO WITH 104,000,000 CUBIC FEET OF FERNALD WASTE?
The Fern
Gerald P. Motl, FERMCO Gerald J. Krieger, FERMCO
David M. Rast, U.S. DOE-Fernald Area Office Fernald Environmental Restoration Management Corp. (FERMCO)
7400 Willey Road Fernald, Ohio 45030
(513) 738-6363
ABS TRACT
Id Site, a Deu rtment of Enersv (DOE) ur nium metal production facility that ceased pGoduction in 198s; is now being remediated by the DOE under terms of a Consent Agreement with the United States Environmental Protection Agency (USEPA) and a Consent Decree with the State of Ohio. It is estimated that the cleanup will generate 104,000,000 cubic feet of low-level radioactive waste including construction debris, pit sludge, radium residue and a huge volume of uranium contaminated soil.
The waste handling strategy for this huge volume of waste includes minimizing remedial waste generation, recycling material when economically feasible, free-releasing clean material and volume reduction. It is anticipated that large scale radium residue vitrification and sludge drying equipment/facilities will be constructed onsite for waste treatment prior to off-site disposal. Fernald waste dispoeition will include both onsite disposal (if approved under CERCLA) and off-site disposal at both commercial and DOE waste disposal facilities. The waste disposition strategy selected reflects a diverse variety of technical, political, regulatory and economic factors. This presentation will describe the current views at Fernald on "what will we do with 104,000,000 cubic feet of Fernald waste."
INTRODUCTION
The Fernald Environmental Management Project (FEMP), formerly the Feed Materials Production Center (FMPC), is a Department Of Energy (DOE) site which produced high-quality uranium for military defense beginning in 1951. Production at the FEMP was halted in July 1989 and, later that year, the
facility was placed on the National Priorities List (NPL). The DOE is currently conducting a Remedial Investigation/Feasibility Study (RI/FS) and other response actions under the Amended Consent Agreement between the United States Environmental Protection Agency (USEPA) and the DOE.
In December, 1992, Fernald Environmental Restoration Management Corporation (FERMCO) assumed site remediation responsibilities as the DOE'S first Environmental Restoration Management Contractor (ERMC).
The Fernald site includes five CERCLA Operable Units as follows:
Operable Unit 1 - OU1 covers approximately 37 acres and consists of a series of excavated pits containing solid and slurried wastes generated during plant operations. Specifically, OU1 includes waste pits 1 through 6, the Burn pit and the Clearwell.
Operable Unit 2 - OU2 consists of those waste units used for the storage or disposal of solid wastes from site operations. These include the inactive flyash pile, active flyash pile, south field disposal area, north and south lime sludge ponds, and solid waste landfill.
Operable Unit 3 - All plants, buildings and equipment that were involved in producing uranium metal products and in processing thorium for other
DOE programs are included in OU3 remediation. The production area and production-associated facilities are generally steel framed structures
covered with transite and contain a wide variety of process equipment.
Operable Unit 4 - OU4 is defined as the geographic area that includes the two K-65 s i l o s , the metal oxide silo, the empty silo, the decant sump system, the radon treatment system, and soils and perched water that lie above the aquifer. The K-65 silos contain approximately 8,800 metric tons of residues remaining from the processing of pitchblende, a uranium-rich ore.
Operable Unit 5 - The fifth operable unit consists of environmental media that can serve as pathways for transporting contaminants. The environmental media that make up OU5 are soils, flora and fauna, surface water and sediments, and groundwater.
ESTIMATED REMEDIAL WASTE VOLUMES
The Fernald cleanup effort will generate a minimum of 104 million cubic feet of material classified as low-level radioactive waste. Fernald waste volumes are over three times greater than the total cumulative 33,000,000 cubic feet of low-level radioactive waste disposed of at the largest U . S . commercial disposal facility in Barnwell, South Carolina beginning in 1971.
Based on the preferred or current leading remedial alternatives as presented in the respective draft and final Feasibility Studies, the following waste material volumes are expected to be generated by each operable unit. Note that quantities are in place volumes in cubic feet with no allowance for excavation. decontamination, treatment, bulkina or containerization:
By d e f i n i t i o n , cleanup of t h e Fernald S i t e w i l l not be completed u n t i l every cubic foo t of w a s t e material i s "disposit ioned." I n t h e authors ' opinion, t h e d i s p o s i t i o n of t h i s material is t h e s i n g l e most d i f f i c u l t a spec t of s i t e cleanup because of t h e s i g n i f i c a n t p o l i t i c a l , t e c h n i c a l , l e g a l , f i n a n c i a l and emotional impacts of w a s t e d i s p o s i t i o n and land use decis ions. Waste d i s p o s i t i o n decis ions are d e c i s i o n s t h a t t h e s i te owner is f r equen t ly least a b l e t o con t ro l without t h e i n p u t and/or concurrence of m u l t i p l e e x t e r n a l stakeholders.
Prudence d i c t a t e s t h a t a r e s p o n s i b l e owner develop a p o r t f o l i o of w a s t e d i s p o s i t i o n opt ions t h a t "balance" t h e i n t e r e s t s of mu l t ip l e s takeholders . A t
Fernald, c u r r e n t waste d i s p o s i t i o n p lans consider a number of f a c t o r s which w e b e l i e v e t o be t r u e :
1. Nevada w i l l not allow Ohio t o burv a l l Fernald w a s t e m a t e r i a l a t t h e Nevada T e s t Site. History te l ls us t h a t when l a r g e volumes of waste generated i n one area of t h e country are disposed of i n another area of t h e country, s e r ious p o l i t i c a l problems can arise. I n t h e l a t e 1970'8, t h e closure of t w o Eastern U.S. low-level nuc lea r w a s t e d i sposa l f a c i l i t i e s r e su l t ed i n a l a r g e increase i n t h e volumes of U.S.
commercial nuclear waste shipped t o t h e B a r n w e l l s i te i n South Carolina. Governor Ri ley‘s d e c l a r a t i o n t h a t “South Caro l ina w i l l not become t h e dumping ground of t h e na t ion” lead t o u t i l i t y volume a l l o c a t i o n s , imposit ion of a cap on waate b u r i a l volumes and subsequent passage of
t h e Low-Level Waste Pol icy Act (LLWPA) mandating t h e formation of r eg iona l d i sposa l “compacts.” I n t h e la te 1980‘8, s imi l a r problems arose due t o t h e l a r g e volumes of hazardous waste disposed of a t t h e Chemical Waste Management s i t e i n Alabama which u l t ima te ly requi red r e so lu t ion by t h e U . S . Supreme Court.
Current shipments of Fernald backloq waste ( n o t remediation w a s t e ) a l ready account f o r approximately 80% of t h e volume of low-level waste accepted f o r d i s p o s a l a t t h e Nevada T e s t S i te (NTS). I n August, 1994, t h e State of Nevada i n i t i a t e d a lawsui t a g a i n s t DOE t o p r o h i b i t continued b u r i a l of Fernald waste a t NTS u n t i l a NTS Si tewide Environmental Impact Statement ( E I S ) is completed. Whatever t h e r e s u l t of t h e lawsui t , i t ‘s c l e a r t h a t t h e huge volumes of Fernald waste t o be generated i n t h e f u t u r e cannot simply be d isposed of a t NTS without l i m i t .
2 . The people of Ohio do not want DOE t o l eave a l l Fernald waste material o n s i t e i n Ohio. I t’s equa l ly clear t h a t a l l Fernald w a s t e w i l l not remain o n s i t e . Fernald l o c a l s takeholders want, a t a m i n i m u m , t h e m o s t hazardous Fernald remedial waste, inc luding t h e s i l o uranium ree idue and Operable Unit 1 p i t s ludge, removed from t h e site. I n f a c t , s eve ra l l o c a l r e s i d e n t s prefer a r e t u r n t o t h e p r i s t i n e s i te condi t ion e x i s t i n g i n 1951 when p l a n t cons t ruc t ion w a s i n i t i a t e d .
The Fernald C i t i z e n ’ s Task Force, c o n s i s t i n g of l o c a l Fernald s takeholders , have concluded t h a t f i n a l s i t e cleanup should r e s u l t i n a maximum r i s k of exposure t o uranium-contaminated soi ls of 1 i n 10000 (lo4). T h i s f a c t a lone w i l l r e q u i r e t h a t , i n t h e absence of developing other means t o reduce r i s k ( i .e. c o n s t r u c t i o n of an engineered waste management f a c i l i t y capable of s t o r i n g t h e m o s t t o x i c Fernald was tes ) , a l a r g e volume of Fernald waste m a t e r i a l w i l l have t o be removed from t h e site.
3. Removinu a l l Fernald Waste t o o f f - s i t e l o c a t i o n s is not f i n a n c i a l l y f e a s i b l e . Even i f a l l Fernald waste could be disposed of i n Nevada, such an opt ion is not f e a s i b l e because of c o s t s es t imated i n excess of $3B.
4.
I n e a r l y 1994, a t a b l e game c a l l e d "FutureSi te" was developed by t h e Fernald C i t i z e n s Task Force t o eva lua te Fernald land u s e opt ions (commercial, i n d u s t r i a l , r e s i d e n t i a l ) based on acceptable r i s k leve ls . The e x e r c i s e uses s t acks of d i f f e r e n t colored ch ips t o r ep resen t varying concent ra t ions of uranium-contaminated s o i l a t t h e Fernald si te. The "game board" is a m a p of t h e s i te t h a t is marked with a 1000-square-foot g r i d . The o b j e c t of t h e exe rc i se i s t o remove chips from t h e si te game board i n t o e i t h e r o n s i t e o r o f f - s i t e d i sposa l b ins t o achieve the desired s i t e f u t u r e use. I n essence, p l aye r s determine how much s o i l must be cleaned u p t o reach a c e r t a i n land use . F ina l ly , p layers t a l l y t h e c o s t a s soc ia t ed with t h e des i r ed l e v e l of cleanup. The amount of money and number of o f f - s i t e shipments r equ i r ed t o r e t u r n t h e site t o p r i s t i n e condi t ion ( i .e. , remove &J. waste material from t h e site) w a s considered i n f e a s i b l e by v i r t u a l l y a l l game p a r t i c i p a n t s .
Much of Fernald waste mater ia l must remain o n s i t e . Th i s is a coro l la ry of f a c t o r Rc3. Resistance t o leaving material o n s i t e h a s always been based on t h e f a c t t h a t t h e Fernald s i t e i s located over t h e sole-source G r e a t M i a m i Aquifer (which, by t h e way, is already contaminated). Ohio EPA r e g u l a t i o n s e x p l i c i t l y p r o h i b i t t h e s i t i n g of w a s t e d i sposa l f a c i l i t i e s over sole-source aqu i f e r s . Ohio EPA r egu la t ions , however, con ta in a waiver provis ion i f t h e d i s p o s a l f a c i l i t y can be shown t o be p r o t e c t i v e of t h e acqui fe r . Therefore, i n recogni t ion of f inanc ia l , t e c h n i c a l and p o l i t i c a l reali t ies, t h e Ohio EPA has acknowledged t h a t a waiver may be appropr ia te f o r o n s i t e disposal of some of Fernald's contaminated material.
S p e c i f i c a l l y , i n a letter from t h e Ohio EPA t o t h e US EPA Region 5 dated A p r i l 5 th , 1994, Graham Mitchel l , Chief of t h e Off ice of Federal F a c i l i t y Oversight , s t a t e d t h a t :
"Large volumes of contaminated c o n s t r u c t i o n and d e m o l i t i o n debris, s o i l , f l y a s h and bot tom ash and p o s s i b l y some solid waste w i l l have to be d isposed o n s i t e a t Fernald."
5. Commercial d i sposa l r e l i e v e s pressure from DOE d i sposa l ovtions. For w a s t e t h a t can be disposed of v i a shal low land b u r i a l , t h e use of commercial d i sposa l f a c i l i t i e s i n a d d i t i o n t o DOE f a c i l i t i e s not only adds t o t h e p o r t f o l i o of d i s p o s i t i o n op t ions but also removes t h e p r e s s u r e on DOE caused by e l e c t i n g t o bury a l l w a s t e a t a s i n g l e DOE
d i s p o s a l f a c i l i t y . The Envirocare site i n Utah is a v i a b l e opt ion f o r t h e d i s p o s i t i o n of DOE low a c t i v i t y r a d i o a c t i v e waste. I n f a c t , DOE has
already negot ia ted a complex-wide cont rac t w i t h Envirocare for c e r t a i n types of mixed-waste meeting t h e Envirocare si te 's waste acceptance c r i t e r i a .
6. Recyclinp must be an important element of t h e waste d isRos i t ion s t r a t e s v . The P r e s i d e n t i a l Order on r ecyc l ing r e q u i r e s t h a t DOE
"promote c o s t e f f e c t i v e waste reduction and r ecyc l ing of usable ma te r i a l s i n a l l of i t s opera t ions and f a c i l i t i e s " and t h a t DOE
i n t e g r a t e t h e s e programs " t o a s s i s t i n address ing t h e na t ions s o l i d waste d i s p o s i t i o n problems." Notwithstanding t h e order , it makes good environmental and p o l i t i c a l sense t o recyc le . I n f a c t , w e a r e beginning t o see competi t ion be tween DOE s i t e s i n t h e i n i t i a t i o n of recyc l ing e f f o r t s .
Cost comparisons between recyc l ing and d i s p o s a l f r equen t ly show t h a t a cos t premium must be pa id f o r recycling. I n r ecogn i t ion of t h e importance of r ecyc l ing , DOE has concluded t h a t reasonable recyc l ing premiums can be j u s t i f i e d .
7 . Clean m a t e r i a l should not be disposed of a s low-level r ad ioac t ive waste. M o s t DOE s i t e e inc luding Fernald have "con t ro l l ed a reas" t h a t r equ i r e dosimetry f o r en t r ance because of p o t e n t i a l exposure t o r ad ia t ion o r t h e presence of contamination. Should every o b j e c t and a l l mater ia l i n a con t ro l l ed area be au tomat ica l ly considered contaminated and t h u s shipped o f f - s i t e f o r d i sposa l as r ad ioac t ive material? The answer is, of course, "no." W e have enough problems burying m a t e r i a l t h a t r ad ioac t ive . T o avoid burying mater ia l t h a t is c l ean , procedures must be put i n p l a c e t o deal with clean material and, i n f a c t , " f ree- re lease" c lean m a t e r i a l from con t ro l l ed areas.
8. Before w e ask anvone (Ohio, Nevada o r Utah) t o t a k e any Fernald waste, w e must be a b l e t o s t a t e clearly t h a t , "We have: 1) minimized t h e volume o f w a s t e m a t e r i a l senerated; and 2 ) implemented prudent volume reduct ion a c t i v i t i e s v r i o r t o d i s ~ o s a l . " It goes without saying t h a t t h e u s e of best management p r a c t i c e is a necessary p r e r e q u i s i t e f o r DOE before ask ing o t h e r s t o accept t h e r e s p o n s i b i l i t y f o r w a s t e volumes generated by DOE as a legacy of t h e cold w a r .
WHAT DO WE DO WITH ALL T H I S WASTE?
With t h i s background i n mind, Fernald c u r r e n t l y p l a n s t o d i spos i t i on 104 m i l l i o n cubic f e e t of waste as follows. Note t h a t a l l dec i s ions are sub jec t t o approval under t h e CERCLA process.
Pit Sludse (12.8 million cubic feet)
The OU1 pit sludge consists of approximately 12.8 million cubic feet of raffinate, magnesium fluoride slag and miscellaneous process debris that had been buried in pits between 1953 and 1983. This material is a major potential source of contamination of the Great Miami Aquifer and is appropriately included in the list of material that Fernald Stakeholders would like to have removed from the Fernald site.
The preferred alternative for disposition of OU1 pit sludge material is
excavation, drying and shipment by rail to a commercial disposal site in the arid west. Envirocare of Utah is the only disposal site currently known to meet this criteria. Envirocare offers a number o f advantages over the DOE Nevada Test Site (NTS) including; 1) direct rail access; 2 ) ability to bury waste material in bulk rather than containerized form; and 3) location in Tooele County, an area zoned for hazardous waste management operations. The Envirocare facility already contains 75 million cubic feet of DOE uranium mill tailings relocated from the Vitro Company in Salt Lake City. Shipping OU1 pit contents to Envirocare eliminates the need to ship the material to NTS.
Silo Material (378,000 cubic feet)
The contents of the Operable Unit 4 K-65 silos includes residues rich in uranium content and classified as ll(e)2 by-product material. The material contains radium and thorium which contribute to elevated radiation fields in the vicinity of the silos and the emission of radon gas. Like the Operable
Unit 1 pit material, Fernald stakeholders have a strong desire to have this material removed from site. As a result, the preferred remedy for Operable Unit 4 is to vitrify the material in an onsite facility and ship the material off-site to the Nevada Test Site for disposal.
OU2 Other Waste Unit Material (9 .4 million cubic feet)
OU2 includes other waste unit material, specifically solid waste, lime sludge, flyash and contaminated construction debris. This material has activity levels far below the pit materials included in OU1. A s a result, the leading remedial alterative for OU2 is to excavate the material and place it in an onsite disposal cell.
OU2 is especially important to Fernald cleanup plana since it is the first Operable Unit to propose construction of an onsite disposal cell and leaving waste material onsite. If such approval is granted in the OU2 Record of Decision, the facility design will have to be approved by EPAIOEPA and will be
subject to public review and comment. It is anticipated that the cell size would ultimately be expanded to accept larger volumes of OU3 demolition debris
and soils generated from OU's 1, 3 , 4 and 5 provided that these materials meet the cell waste acceptance criteria (WAC).
Concrete/AsDhalt (3.1 million cubic feet)
Demolition of buildings and structures within the OU3 production area will
generate approximately 3 million cubic feet of concrete and asphalt debris. The OU3 interim record of decision permits up to 10% of total OU3 material to be shipped off-site for disposal at the Nevada Test Site prior to the final record of decision. The final Record of Decision is expected to call for the disposition of most oU3 remediation materials, including concrete and asphalt, within the property boundary in an on-site disposal cell.
Metal (61,000 cubic feet)
Operable Unit 3 building demolition will generate 61,000 cubic feet of metal.
As demonstrated on the recent dismantlement of Plant 7, the vast majority of Fernald metal generated before the final OU3 record of decision will be recycled. Recycling is applicable to t w o general classes of material, 1) material that can be reasonably decontaminated and "free-released" to the economy and 2 ) material that cannot be reasonably decontaminated but can be melted and "beneficially reused" within the controlled DOE environment. Plant 7 structural steel will be decontaminated for "free-release" and sold into the commercial scrap metal market. The former Fernald scrap metal pile was melted for "beneficial reuse" and fabricated into shield blocks for use in physics experiments at Los Alamos National Laboratory.
If onsite disposal is approved in the final OU3 record of decision, metal
recycling would be re-examined in light of the economics of the onsite disposal option.
Transite (49,000 cubic feet)
Transite, a building material consisting of cement and asbestos, was used as siding and roofing material on many of the Operable Unit 3 buildings. Since the asbestos material is non-friable, transite will be shipped for burial at the Nevada Test Site at least until the final OU3 record of decision. After the final ROD, it is anticipated that transite meeting the onsite cell waste acceptance criteria will be disposed of in the onsite cell.
__ -
E s u i D m e n t (2.3 mil l ion cubic f e e t )
The approximate 160 bui ldings i n Operable U n i t 3 conta in numerous components of contaminated equipment, es t imated t o have a t o t a l c o l l e c t i v e volume of approximately 2.3 mil l ion cubic f e e t . With t h e except ion of a small amount of equipment t h a t might be excessed and made a v a i l a b l e t o o t h e r U.S. government faci l i t ies , t h i s equipment w i l l either be recycled o r disposed of i n t h e o n s i t e cell i f approved i n t h e Operable U n i t 3 Record of Decision.
Ground Water Treatment Sludae (1.6 m i l l i o n cubic feet)
Operable Unit 5 includes t h e uranium contaminated groundwater under t h e Fernald s i t e p l u s contaminated water expected t o be generated dur ing t h e remediation of o t h e r operable u n i t s . i n an Advanced Waste Water Treatment system p r i o r t o r e l e a s e . Waste Water T r e a t m e n t system i s expected t o ope ra t e fo r 30 years , genera t ing a t o t a l of 1.62 mil l ion cubic f e e t of sludge. It i s expected t h a t t h i s water t rea tment s ludge w i l l e i ther be shipped o f f - s i t e f o r d i sposa l or disposed of i n t h e o n s i t e c e l l .
This water w i l l be t r e a t e d and released The Advanced
Soi ls (74 .4 m i l l i o n cubic feet)
Contaminated so i l cont r ibu ted by f o u r operable u n i t s i s t h e l a r g e s t s i n g l e source of Fernald waste r e p i r i n g d i s p o s i t i o n . This t o t a l Soi l volume inc ludes not on ly t h e s i te su r face s o i l volume of OU5 b u t a l s o contaminated soil impacted by p i t and s i l o excavat ion and bui ld ing removal. I t i s es t imated t h a t t h e Fernald cleanup w i l l genera te approximately 74 m i l l i o n cubic feet of contaminated s o i l exceeding t h e a n t i c i p a t e d cleanup a c t i o n l e v e l of 50 ppm uranium. Total uranium contamination l e v e l s of on - s i t e soi ls range from background (3 .7 ppm) up t o a m a x i m u m of 10,000 ppm.
A t one po in t , it was a n t i c i p a t e d t h a t s o i l washing would be used t o c l ean uranium contaminated s o i l t o des igna ted s i te cleanup l e v e l s . "clean" f r a c t i o n (approximately 80%) would remain o n s i t e while t h e " d i r t y " f r a c t i o n (approximately 20%) p lus secondary w a s t e would be shipped o f f - s i t e f o r d i sposa l . I n support of t h i s i n i t i a l plan, t h e Fernald s i te w a s des igna ted as t h e lead site f o r t h e Uranium I n Soils I n t e g r a t e d Demonstration sponsored by DOE EM-50.
The
The i n i t i a l p lan t o wash Ferna ld Uranium contaminated s o i l w a s modified based upon a recogni t ion of t h e following:
1.
2.
Soil washing would necessitate the construction of substantial capital facilities-something to be avoided, if possible, on a Superfund site.
Soil washing tests at Fernald using an acid based leaching treatment generally yielded results achieving preliminary clean up goals ( 5 0 ppm Total U). However, the leachability of the U remaining in the soil
increased which had the effect of lowering the clean up goal to below 20 ppm. Additionally, higher volumes of secondary waste were generated due to the decomposition of the soil itself. Although clean up goals were partially achieved, the generation of a difficult secondary waste made soil washing in this manner an expensive proposition.
Additional testing performed by the Uranium Soils ID used a Carbonate based extraction process. The treated soil fraction was generally higher and less secondary process wastes were generated. However, results indicated that decontamination levels achieved were only in the 120-150 ppm Total U range, values well above the preliminary clean up goal.
3 . With construction of an onsite cell anticipated, huge volumes of fill material would be required to fill the voids between the components of demolition debris. Since the anticipated waste acceptance criteria (WAC) of the onsite cell is higher than the activity of over 99% of total site soil volume, it turns out that virtually all contaminated
site soils can be placed in the onsite cell as fill material with no need for soil washing.
The current plan therefore, is to dispose of contaminated soil in the onsite cell containing OU2 pit material and OU3 demolition debris.
It should be noted that the volume of contaminated soil requiring disposition in an onsite cell is a function of the ,distribution of soil contamination, the final cleanup action level (estimated to be 5 0 ppm) and the final cell waste acceptance criteria (estimated to be 1080 ppm). Figure 1 illustrates the impact of these factors on the volume of contaminated soil to be placed in an on-site disposal cell.
It is expected that approximately 2 5 % of anticipated remedial waste volume will be removed from the Fernald site with the balance placed in an onsite disposal cell. The disposition of 104 million cubic feet of Fernald
waste is a difficult technical undertaking complicated by many factors
frequently beyond the control of the Department of Energy. It is our belief that the timely disposition of waste material (and therefore the 8uccess of Fernald's remediation) will be successful only if a portfolio of prudent disposition options are made available and then selected based on input from the broadly-defined universe of Fernald stakeholders.
(FIGURE 1 IS I N FREELANCE GRAPHICS FOR WINDOWS - UNDER THE FILE NAME PLANT 7 A )
