4.3 Recommendation to Site a Waste Disposal Facility on the Oak Ridge Reservation

The issue of an on-site waste disposal facility for the Oak Ridge Reservation remediation wastes was raised early in the EUWG process. Discussion arose during the Bear Creek Valley watershed deliberations, since two of the possible sites are located in Bear Creek Valley. The DOE and the Site Specific Advisory Board considered Bear Creek Valley the most likely area for siting a waste disposal facility. Thus, EUWG members decided that an end use recommendation for Bear Creek Valley could not be made without first addressing the issue of whether an on-site waste disposal facility might be located there.

Furthermore, the EUWG believed a waste disposal decision had to be made before cleanup decisions could be finalized, since waste volumes and costs associated with each remedial action were needed to evaluate alternatives.

As represented by DOE and its contractors, remediation wastes represent about two-thirds of all wastes that will be generated on the Reservation over the next 10 years. DOE has three alternatives for managing this waste:

• manage in place;
• consolidate and dispose in an on-site disposal facility; or
• dispose at off-site facilities.

Each alternative offers advantages and disadvantages. For example, managing waste in place may be the least costly in the short run, but may result in increased risk of groundwater contamination and higher long-term costs. Off-site disposal is favored by citizens who want to remove wastes from the Reservation; however, the EUWG recognized that this increases worker risks due to construction and transportation accidents. Both off-site and on-site disposal can be politically difficult options; other sites in the DOE complex have found a "balanced" waste disposal approach to be the only feasible alternative. A "balanced" approach includes maintenance of large volumes of lower risk waste in an on-site disposal facility, while smaller volumes of higher risk waste are shipped off site.

In planning for the design of a possible disposal facility, DOE used a low-end to high-end waste volume range. The low-end volume was estimated at 200,000 cubic yards of contaminated material, requiring a facility with a 50-60 acre footprint. A high-end volume was estimated to be 1 million cubic yards of material, requiring a disposal facility with a 100-120 acre footprint. If an on-site disposal facility is built, it would consist of an above-ground earthen disposal cell with support facilities, would have a multi-layered 15-foot cap, and a RCRA-compliant bottom liner with a leachate collection system and a geologic buffer.

Initial sites proposed by DOE for an on-site waste disposal facility included West Bear Creek Valley, East Bear Creek Valley, and a site adjacent to the White Wing Scrapyard. West Bear Creek Valley has not been used for waste disposal and is not contaminated. East Bear Creek Valley has been used extensively for waste disposal. Because the White Wing Scrapyard is surrounded by uncontaminated lands, the EUWG did not believe this site was a suitable location for a disposal facility.

Of the proposed sites, the EUWG believes the East Bear Creek Valley site is the most compatible with future land uses, since the area is already used for waste disposal.

The first issue the Group had to address was whether a recommendation for an on-site waste disposal facility and a recommended location for that facility were within the scope of the EUWG. Most members believed the issue was relevant, since the presence of an on-site disposal facility would result in restricted waste disposal end use wherever it was located. The use of an on-site disposal facility also would have significant impacts on cost and risk estimates for end uses of other contaminated areas on the Reservation.

The Group felt that it was very important that DOE ensure that any on-site disposal facility would not adversely affect human health or the environment. This requirement would require protective Waste Acceptance Criteria, and wastes not meeting the criteria would be disposed elsewhere.

• concern over cell size, since volume estimates did not include non-CERCLA wastes or wastes outside DOE’s Environmental Management Program;
• concerns about the possibility of waste shipments from other sites;
• concerns about facility design;
• impacts on the "borrow area" that would provide clay for construction;
• concerns over the long-term requirement for institutional controls;

• concerns that disposal facility construction costs would mean less money for remediation activities (it was pointed out that the disposal facility would be funded as a separate project, and therefore might not impact the remediation budget, and that sites with disposal facilities generally receive more funding, since sites with cleanup facilities are viewed as having a strategy for remediation); and
• concerns about endorsing on-site disposal before waste acceptance criteria have been determined.